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NY 880989

December 14, 1992

CLA-2-84:S:N:N1:110 880989


TARIFF NO.: 8471.99.1500

Mr. Robert T. Givens
Givens and Kelly
950 Echo Lane, Suite 360
Houston, Texas 77024-2788

RE: The tariff classification of a model CTL 3705 Controller- Adapter Unit from Grand Cayman, British West Indies.

Dear Mr. Givens:

In your letter dated December 4, 1992, on behalf of Comtex Communications, LLC., you requested a tariff classification ruling.

The merchandise under consideration involves a model CTL 3705 controller-adapter unit which is used to maximize the use of ADP computers and input-output devices within an ADP system. It does so by relieving the central processing unit (CPU) of front- end, communications processing. Communications processing is that processing involved in the interconnection of the CPU with peripheral input and output units. By offloading the responsibility of communications processing or control, the CPU is left free to focus on data processing, which can then be performed more efficiently.

The model CTL 3705 controller is a microprocessor based front-end communications controller. A single controller manages the interconnection of the CPU with up to 12 ASCII Asynchronous devices. Attached devices may include display stations, printers, terminals, or other peripheral devices. The controller is designed to be installed between the CPU and peripheral units. It attaches to an IBM mainframe computer via the bisynchronous Teleprocessing Line adapter. The controller attaches to peripheral devices via ports which are located on its back.

Noting Legal Note 5(B) to Chapter 84 of the HTS, this controller would meet the definition of a "unit" of an automatic data processing machine. The principal function of this controller appears to be for the interconnection of the central processing unit to input-output devices within an ADP system thereby serving "control" and "adaption" functions.

The applicable subheading for the model CTL 3705 Controller- Adapter Unit 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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