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NY N006077

February 12, 2007



TARIFF NO.: 8471.90.0000

Mr. Sanford Schupper
Wingspan Investment Partners I, LLC
900 East Hamilton Avenue, Suite 100
Campbell, CA 95008

RE: The tariff classification of the “iLoad” optical reader from Hong Kong.

Dear Mr. Schupper:

In your letter dated January 29, 2007, you requested a tariff classification ruling.

The merchandise under consideration is the iLoad optical reader. The iLoad copies music from compact discs (CDs), as well as album and track data, onto an Apple iPod without using a computer or requiring an Internet connection. The iLoad measures 8” long by 7.25” wide by 3.35” high, and contains a 1 Gigahertz (GHz) processor, 256 megabytes (MB) random access memory (RAM), and 256 MB Disk-On-Module flash memory. The rear panel of the iLoad provides various ports and connectors including 2 high-speed USB ports, an S-Video connector, RCA-style jacks, a 2.5-millimeter (mm) output connector, a 5.5-mm DC barrel connector with 2.5-mm pin, as well as ports for a mouse, keyboard, monitor, and Ethernet connection. The iLoad features a CD receiver slot, an LCD display screen, and a control board comprised of an “On-Off” button, a “Go” button, “Left” and “Right” buttons, and “Up” and “Down” buttons.

To operate the iLoad, the user slides a CD into the CD receiver slot of the iLoad, which is connected to an iPod by a USB cable. The iLoad optically reads the music files embedded in the CD, and converts them into the format required by the iPod. Using the control board buttons, the user may opt to copy either the entire album or individual songs from the CD to the iPod. The iLoad also uses its pre-installed internal Music Database to upload corresponding track data such as album name, artist name, and song title to the iPod. A computer is not required in order for the iLoad to function. Headphones or speakers may be connected to the 2.5-mm output jack to enable the user to listen to the CD. Although the iLoad allows the user to listen to the CD currently residing in its receiver slot, its ability to perform sound reproducing as classified under Subheading 8519 is incidental to its overall function as an optical reader. Moreover, as imported, there is no audio output device included or attached to the iLoad; the user must provide such equipment after importation.

The principal function of the iLoad is that of a reader as defined in the Explanatory Notes (ENs) for Subheading 8471: “Magnetic or optical readers read characters, generally in a special form, and convert them into electric signals (impulses) which can be directly used by machines for transcribing or processing coded information.“

The applicable subheading for the iLoad will be 8471.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “ADP machines; magnetic or optical readers: Other.” The general 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).

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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