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NY 857260

October 24, 1990

CLA-2-84:S:N:N1:110 857260


TARIFF NO.: 8471.99.1500

Mr. Dennis Heck
Ernst & Young
515 South Flower Street
Los Angeles, CA 90071

RE: The tariff classification of a Software Sentinel Key from either Thailand, Mexico, or Taiwan.

Dear Mr. Heck:

In your letter dated October 15, 1990, on behalf of Rainbow Technologies, you requested a tariff classification ruling.

The merchandise under consideration involves a software protection device that consists of a small printed circuit board that plugs into the parallel printer port of your computer which prevents unauthorized use of the resident software.

This device connects to the parallel printer port of an IBM PC, PS/2 or compatible computer and the 25-pin RS232 serial port. When the software is installed in the computer and this device is connected to the computer's parallel printer port, data streams are transmitted to, and received from, the Sentinel key in a challenge/response sequence. This device runs under DOS, OS/2, Windows, UNIX, and XENIX. This interconnection device is approximately 2 inches long, 1 5/8 inches wide, and 5/8 inches thick. Embedded within each device are 126 bytes of non-volatile memory.

The applicable subheading for the Software Sentinel Key will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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