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April 27, 1999

CLA-2-84:RR:NC:1:110 E80895


TARIFF NO.: 8469.11.0000

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

RE: The tariff classification of a "ComQuest Pro" from China.

Dear Mr. Arndt:

In your letter dated March 30, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves a model number A0920 "ComQuest Pro" which is a learning device targeted for children ages six and up. It is approximately 10 1/4 inches in length by 9 1/2 inches in width, and it has a height of approximately 2 3/4 inches. This device incorporates a LCD display, a QWERTY keyboard, includes a mouse and mousepad; and is compatible with a "Team Concepts Power Printer Plus".

The "ComQuest Pro" has an electronic data bank, which features various activities for strengthening children's learning skills. Among the multi level activities are language and word activities, strategy games and homework helper. This device has a built-in mini word processor with spell checker, thesaurus, and a printer port to connect this device to a "Team Concepts Power Printer Plus". Documents and graphics may also be uploaded to a personal computer.

The "ComQuest Pro" 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 Pro" appears to be its work processing capacity. NY Ruling Letters C86650 and NY B87626 was the subject of a similar device.

The applicable subheading for the model number A0920 "ComQuest" Pro 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 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 212-637-7019.


Robert B. Swierupski

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