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NY A87958

October 2, 1996

CLA-2-84:RR:NC:1:110 A87958


TARIFF NO.: 8471.60.7080

Mr. Michael J. Horton
Horton, Whiteley & Cooper
One Kaiser Plaza, Suite 1410
Oakland, California 94612

RE: The tariff classification of a computer touchpad from Japan.

Dear Mr. Horton:

In your letter dated September 25, 1996, on behalf of Alps Electric (USA), Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a "Compaq" notebook computer touchpad which is incorporated into the body of a notebook computer. This touchpad pointing device is the standard pointing device which comes with their notebook computer, model number KGDDCHOO4A. It may be replaced by an optional interchangeable optical trackball which servers the same purpose as the touchpad. Both devices are used to control the placement of the cursor at data or menu selections on the computer screen, or at the place where data is to be input through the keyboard. This touchpad device is utilized by placing a finger at any position on the pad. The touchpad unit slips into the front edge of the notebook computer so that three of the touchpads' six sides disappear within the housing of the notebook computer.

This "Compaq" notebook computer touchpad, meets the definition of a "unit" as noted in Legal Note 5(B) to Section XVI of the HTS, since it is specifically designed for use with an automatic data processing (ADP) machine, and is directly or indirectly connectable to the central processing unit of the ADP system.

The applicable subheading for the "Compaq" notebook computer touchpad, model number KGDDCHOO4A, will be 8471.60.7080, Harmonized Tariff Schedule of the United States (HTS), which provides for input units suitable for physical incorporation into automatic data processing machines or units thereof. The rate of duty will be free.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Art Brodbeck at 212-466-5490.


Roger J. Silvestri

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