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NY 889468

August 31, 1993

CLA-2-84:S:N:N1:110 889468


TARIFF NO.: 8471.99.1500; 8524.90.4080

Mr. JC Brownfield
DFM International, Inc.
130 Produce Ave., Suite H
South San Francisco, CA. 94080

RE: The tariff classification of Coactive Connectors and Software from Singapore.

Dear Mr. Brownfield:

In your letter dated August 18, 1993, on behalf of Coactive Computing Corp., you requested a tariff classification ruling.

The merchandise under consideration involves Coactive Connectors for use on Windows, DOS, and Macintosh computers plus accompanying software. The Coactive Connector, (part no. 600- 0001-00), includes a 32-bit Motorola microprocessor, 1-MIPS, supports an address space of up to 1-Mbyte of RAM, and has an ASIC chip with DMA capabilities. The Coactive Connector functions as a networking device to interconnect micro computers. These connectors attach externally to the computer via the parallel (printer) port of a IBM compatible computer or the DIN - 8 LocalTalk connection port of an Apple Macintosh computer. After the Coactive Connector is connected to the computer, telephone wire is strung between and attached to the units which links the network together, and allows the user to network efficiently using its own memory and processing power. With these features, plus the use of software, the user forms a computer network that may be used in a stand-alone fashion or further connect to Ethernet and Token Ring networks, use electronic mail software, and use file and print servers.

The Coactive Connectors may also be imported in kit format. A kit for the DOS version of the Coactive Connector would consist of items such as a Coactive Connector, cables, power supply, DOS disks, and user guide. In this situation the essential character of this kit (set), would be the Coactive Connector noting GRI 3(b).

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

Noting Legal Note 6 to Chapter 85, the software, when imported with the kit, would be separately classifiable under 8524.90.4080, Harmonized Tariff Schedule of the United States (HTS), which provides for other recorded media. The rate of duty will be 9.7 cents per square meter of recording surface.

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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