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NY I89737

January 22, 2003

CLA-2-84:RR:NC:1:110 I89737


TARIFF NO.: 8471.60.7080

Mr. Brett Ian Harris
McKenna Long & Aldridge LLP
1900 K Street, NW
Washington, DC 20006

RE: The tariff classification of a fingerprint recognition module from France.

Dear Mr. Harris:

In your letter dated January 9, 2003, on behalf of your client Sagem Morpho, Inc., you requested a tariff classification ruling.

The merchandise under consideration is the Morphomodule Fingerprint Recognition Module. The Morphomodule Fingerprint Recognition Module consists of a capacitive fingerprint sensor measuring approximately 1”x ¾” and a microprocessor mounted to a populated printed circuit board (PCB) that measures approximately 2”x1¼”. A multi conductor electronics ribbon connects the sensor and the PCB. A sample of the module was submitted with your ruling request. A capacitive fingerprint sensor is similar in operation to touch-sensitive screens, as both measure changes in capacitance over a two-dimensional electrical field. Touching a touch-sensitive screen yields a single point in a broad X-Y plane. The Morphomodule sensor uses active capacitive pixel-sensing technology. The data collection surface of the Morphomodule sensor allows for concurrent return of multiple contact points, each one reported as a position within an X-Y plane. No other variables contribute to the creation of the image. Moreover, other than determining whether a given pixel is on or off, the variation in capacitance does not affect the final image. The multiple contact points are represented to the Morpho Biometric (MOBI) board as a two-dimensional array of pixels that are processed as a digital image rather than a single point of contact. Each sensor cell (pixel) contains an active capacitive feedback circuit whose effective feedback capacitance is modulated by the presence of live skin close to the surface of the sensor. Differences in the capacitance values across the array correspond to the ridges, valleys and pores that characterize a unique fingerprint. The fingerprint image is sent from the sensor to a chip with embedded software designed to convert the image to an 8-bit digital value, store the unique value, and compare stored values for matches with new ones obtained from the sensor. The Morphomodule Fingerprint Recognition Module is imported without software. The software and module is packaged together at the Sagem Morpho U.S.A. facility prior to retail distribution.

The Morphomodule Fingerprint Recognition Module may be integrated into all types of equipment requiring strong user identification (i.e. Biometric module for POS, safes, locks, kiosks, remote controls, computer and peripherals, etc.). There is no evidence of sole or principal use with ADP machines or systems. However, the device is an X-Y coordinate input device under Ch. 84, Note 5 (D) of the Harmonized Tariff Schedule of the United States. It has a legitimate use when installed into a notebook computer or similar ADP machine. When used with ADP machines it is connectable to the central processing unit (Ch. 84, Note 5 (B) (b) HTS) and is able to accept and deliver data in a form which can be used by the system (Ch. 84, Note 5 (B) (c) HTS).

The applicable subheading for the Morphomodule Fingerprint Recognition Module will be 8471.60.7080, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofInput or output units, whether or not containing storage units in the same housing: Other: Other: Units suitable for physical incorporation into automatic data processing machines or units thereof: Other.” 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 Eileen S. Kaplan at 646-733-3016.


Robert B. Swierupski

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