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NY C86090

March 27, 1998

CLA-2-84:RR:NC:1:110 C86090


TARIFF NO.: 8471.60.1095; 8524.91.0030

Mr. Bob Cripe
Mutoh America Inc.
3007 East Chambers St.
Phoenix, Arizona 85040

RE: The tariff classification of a video tablet from Japan.

Dear Mr. Cripe:

In your letter dated March 6, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a device which is known as a video tablet. This device gives a personal computer (PC) user an interactive video display. The video tablet has an liquid crystal display (LCD), that displays a PC user interface screen. The tablet (digitizer portion) is basically an absolute tracking mouse. The video tablet allows the user to point and click on the LCD to an absolute location displayed on the LCD screen. This gives the user an exact inter-active response to the movement and inputs that are needed to work on the PC. The video tablet is therefore both an output (video display) and input (digitizer tablet) device.

The model MVT-12P/MVT-14 video tablets are imported as a complete unit. The two main components of this device are the grid assembly and pen. The grid assembly is a populated printed circuit board that is placed behind the LCD. This is the receiving unit for the signal sent by the pen. It also acts as the main interface between the video (LCD) and the host PC. The pen is a completed device that sends a signal to the grid and that allows the video tablet to track the pen movement and receive input signals.

The software which the importer provides functions as a device driver. This software which is loaded on the host PC allows the video tablet to communicate with the host PC. The software driver is on a standard floppy disk. The software diskette, if imported with the video tablet, is separately classified as per Legal Note 6 of Chapter 85 of the Harmonized Tariff Schedule (HTS).

The MVT-12P/MVT-14 video tablets appear to incorporate the design characteristics which are similar to the input/output units used with automatic data processing (ADP) applications. Noting Legal Note 5(B) and 5(D) to Chapter 84 of the HTS, these video tablets would meet the definition of a "unit" of an ADP system.

The applicable subheading for the model MVT-12P/MVT-14 video tablets will be 8471.60.1095, Harmonized Tariff Schedule of the United States (HTS), which provides for combined input/output units of ADP machines. The rate of duty will be free.

The applicable subheading for the software diskette will be 8524.91.0030, HTS, which provides for prepackaged software for ADP machines, of a kind sold at retail. The rate of duty will be 1.3 cents per square meter of recording surface.

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.


Robert B. Swierupski

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