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NY C86650

April 20, 1998

CLA-2-84:RR:NC:1:110 C86650


TARIFF NO.: 8469.11.0000

Mr. A. Arndt
Team Concepts North America, Ltd.
331 Eisenhower Lane South
Lombard, Illinois 60148

RE: The tariff classification of a laptop learning device from China.

Dear Mr. Arndt:

In your letter dated April 7, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a model #A0800 "ComQuest Gold" device which is designed to allow children to type memos, reports, build computer skills, and play strategy games. This personal laptop learning device is approximately 11 3/4 inches in length by 9 3/4 inches in width, and has a height of 1 3/8 inches. It consists of a standard QWERTY typewriter keyboard in addition to special function keys. The function keys include various activities such as ""Player", "New Name", "Lunar Tool", and "Sound On/Off". The "ComQuest Gold" incorporates built-in memory for saving and storing documents.

The "ComQuest Gold" device is age graded for kids 9 and above. There are built-in educational games and activities in Math, Strategy, Publishing, and more. Also built-in is a mini- word processor with spell check, and a printer port to connect this device to a paper printer.

The "ComQuest Gold" device is not an ADP computer, and does not meet the requirements of Legal Note 5(A) to Chapter 84 of the Harmonized Tariff Schedules. This composite good does have the ability to perform word processing, storage, data retrieval, and game functions. The principal use of the "ComQuest Gold" appears to be its word processing capacity. NY Ruling Letters B87626 and NY B86269 were the subject of a similar device.

The applicable subheading for the model #A0800 "ComQuest Gold" device will be 8469.11.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for word processing machines. The rate of duty will be 0.3 percent ad valorem.

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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