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NY R05148

November 22, 2006

CLA-2-84:RR:E:NC:1:120 R05148


TARIFF NO.: 8471.80.1000

Mr. Brian Johnson
Keytronic Corporation
4424 North Sullivan Road
Spokane, Washington 99216

RE: The tariff classification of InMotion 3000 Series MultiService Controller, InReach 200 Wireless Access Point, and Wireless Client Bridge from Mexico.

Dear Mr. Johnson:

In your letter dated October 30, 2006 you requested a tariff classification ruling.

The InMotion 3000 Series MultiService Controllers are Colubris Intelligent MultiService System’s server platform for delivering wireless local area network (WLAN) services. It controls wireless network devices through an Access Point distributed throughout a wireless zone, building or campus. The wireless communication device integrates a full-featured MultiService Access Point and MultiService Controller with embedded firmware into a single turnkey unit that connects to another network device, such as the LAN switching product in the network center, to enable access to the Internet.

The InReach 200 Wireless Access Point is a bridge that provides connectivity from the LAN to wireless devices such as a desktop or laptop. The Access Point is connected to an Ethernet switching infrastructure known as a local area network to access the Internet.

The Wireless Client Bridge is similar to the Access Point; however, the function is reversed. The bridge plugs into a network device, such as a laptop or desktop, with an Ethernet to wireless converter. It enables the laptop to communicate with the Access Points to reach the Internet.

The InMotion MultiService 3000 Controller, InReach 200 Wireless Access Point, and Wireless Client Bridge meet the definition of a "unit" of an automated data processing (ADP) system as defined in Legal Note 5(B) to Chapter 84 of the Harmonized Tariff Schedule of the United States (HTSUS). They are connectable to the central processing unit either directly or through one or more other units, and are specifically designed as part of such a system. From the information you provided, the principal function is the interconnection of the mainframe to other input and output units. It would thus fall under the definition of a control or adapter unit under HTSUS number 8471.80.1000.

The applicable subheading for the InMotion MultiService 3000 Controller, InReach 200 Wireless Access Point, and Wireless Client Bridge will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Automatic data processing machines and units thereof Other units of automatic data processing machines: Control or adapter units. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

Pursuant to title 19 United States Code, Section 3005 The Harmonized Tariff Schedule of the United States is expected to be amended effective 1/1/07. The amendments are expected to affect the classification of your merchandise. Pursuant to Section 3005 c, the report recommending those changes has been sent to the President for proclamation of the changes. Upon the expiration of sixty legislative days, in the absence of Congressional action, the recommended changes will become law. Accordingly based on that recommendation, it is anticipated that your merchandise will be classified in 8517.62.00 under the 2007 Harmonized Tariff Schedule. Under the circumstances, this classification under the 2007 tariff is advisory only.

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 Denise Faingar at 646-733-3010.


Robert B. Swierupski

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