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NY 806015

January 24, 1995

CLA-2-84:S:N:N1:110 806015


TARIFF NO.: 8473.30.5000

Mr. Mark Rave
Clearfreight Inc.
498 S. Airport Blvd.
So. San Francisco, CA 94080

RE: The tariff classification of a data processing security device from China.

Dear Mr. Rave:

In your letter dated January 12, 1995, you requested a tariff classification ruling.

The merchandise under consideration involves an automatic data processing (ADP) security device which is known as a "SecureNet Key device". This device is used to provide secure access of remote users of laptop or tabletop computers. It can also function with any ADP keyboard and screen. The SecureNet Key is a small hand held device, about the size of a small calculator which is used to generate one-time passwords. This device is activated by entering a Personal Identification Number (PIN) and all challenge response entries using the calculator like key pad.

When the remote user attempts to log in, the server generates and challenges the remote user with a random number. This random number challenge is then encoded, using the seed value and the DES algorithm, both by the remote user's SecureNet Key and the server. The resulting value is then used as a one time password which the remote user transmits back to the server as a response. Noting the Explanatory Notes to the Harmonized Tariff Schedule, this device would appear to meet the definition of an "accessory" for automatic data processing machines.

The applicable subheading for the SecureNet Key device will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. 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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