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NY K80379

November 13, 2003
CLA-2-84:RR:NC:1:110 K80379


TARIFF NO.: 8471.70.5065

Mr. Kevin W. Leonard
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 245 Park Avenue, 33rd Floor
New York, NY 10167-3397

RE: The tariff classification of information storage systems from Ireland.

Dear Mr. Leonard:

In your letter dated October 30, 2003, on behalf of your client EMC Corporation you requested a tariff classification ruling.

The merchandise under consideration is the Symmetrix Direct Matrix (DMX) and CLARiiON (CX) information storage systems. Both systems are data storage units. The Symmetrix DMX system is a high-end networked information storage system housed within a single frame measuring approximately 75½ inches high by 54¼ inches wide and is 37¼ inches deep. This system supports all popular hardware and operating system platforms, storage area networks (SANs), and high-availability cluster environments. The DMX system is imported complete with magnetic disk drives, power supply and software. In some instances, the DMX system may contain a display with keyboard and CPU (Central Processing Unit) incorporated into the cabinet as a non-essential diagnostic device used to monitor the system’s performance.

The CLARiiON (CX) system is a networked storage system configured as a stackable rack system. The bottom rack consists of a self-contained unit with magnetic disk drive, printed circuit board assembly (PCBA) and power supply. At the time of import, one or more additional racks containing magnetic disk drives with PCBAs are stacked onto the bottom rack. Additional racks may be added as needed. As with the DMX, this system may include a display with keyboard and CPU incorporated into the rack system as a non-essential diagnostic device used to monitor the system’s performance.

The applicable subheading for the Symmetrix Direct Matrix (DMX) and CLARiiON (CX) storage systems will be 8471.70.5065, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofStorage units: Magnetic disk drive units: Other: Other: Hard magnetic disk drive units.” The general 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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