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NY N010850

June 4, 2007



TARIFF NO.: 8471.80.1000

Mr. Myles S. Getlan
Arent Fox LLP
1050 Connecticut Avenue, NW
Washington, D.C. 20036

RE: The tariff classification of an interface board and module from Israel.

Dear Mr. Getlan:

In your letter dated May 3, 2007 you requested a tariff classification ruling on behalf of your client, Excalibur Systems.

Under consideration is the EXC-4000PCI interface board with an attached M4K429RTx module, imported with cables, a CD-ROM containing the software installation and user manuals, and mating connectors. The board and attached module contribute together to support a variety of data processing functions in avionics applications.

The EXC-4000PCI board with the attached M4K429RTx module is a functional unit designed to be physically incorporated into a personal computer (PC) or other automatic data processing (ADP) machine. It connects to the host computer’s central processing unit (CPU) through PCI, ISA, PCMCIA, VME or other bus expansion slots, and enables an ADP machine to connect to an avionic data bus as used in a variety of aircraft, for purposes of data processing and signal conversion.

The EXC-4000PCI/M4K429RTx unit receives signals from the avionics data bus, performs signal conversion from avionics voltage levels to ADP machine voltage levels, then converts the analog signal into a digital signal. The unit performs data processing on the digital signal to convert it into a data form understood by the ADP machine, and stores the data in its on-board memory. In addition, the ADP machine can place digital data in the EXC-4000PCI’s on-board memory, and the board will digitally process the data into a form understood by the avionics data bus. The board converts that data into an analog signal, and uses a special transceiver to convert that to the voltage level necessary for the avionics data bus. This unit permits users to write complex programs that instruct the ADP machine to issue avionics protocol commands onto the avionics data bus. It is also possible to program the ADP machine to receive, interpret and act upon avionics protocol commands received from the avionics data bus.

The EXC-4000PCI board, M4K429RTx module, cables, CD-ROM, and connectors packaged for retail sale constitute a set in accordance with General Rule of Interpretation (GRI) 3(b); the EXC-4000PCI interface board provides the essential character of this set.

The applicable subheading for the EXC-4000PCI interface board with attached M4K429RTx module set 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).

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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