CLA-2-84:S:N:N1:110 877547

Mr. Donald L. Fischer
Horton, Whiteley & Cooper
1900 Embarcadero, Suite 201
Oakland, California 94606

RE: The tariff classification of an AsanteHub 1012 Controller from Taiwan.

Dear Mr. Fischer:

In your letter dated August 17, 1992, on behalf of Asante Technologies, Inc., you requested a tariff classification ruling. The merchandise under consideration is known as the AsanteHub 1012 Controller. This device is a modular, freely programmable communications processor which controls and monitors the interfacing of computers including the central processing unit to other data processing machines, or to input or output units linked as local area network systems. The AsanteHub 1012 Controller can be incorporated into an aluminum chassis designed to be free standing or mounted into an Asante card cage. Its components include a built-in power supply, a microprocessor which features a 16-bit internal architecture and 8-bit external data bus; two LSI chips specifically dedicated to system wide data collection and monitoring; EPROM, SRAM and flash memory storage; and working in conjunction with the data retrieval chips, 50-light emitting diodes (LED"s) which are dedicated to specific control tasks.

The AsanteHub 1012 Controller satisfies the definition of a control unit through its dedicated function of interconnecting the CPU with other units of the ADP system in order to provide the network's management functions. While the AsanteHub 1012 enables interconnection through its 14 "ports", its management control and monitoring functions are accomplished by its programmable microprocessor, data-retrieval chips and LED panels. Its LED display system is designed to indicate control and monitoring functions through color-coded, flashing signals visible on an external panel. The LED's provide immediate detailed information on the health of the transmission process and the corrective action the AsanteHub 1012 Controller is designed to undertake in the event certain things go wrong. Principal functions of the Asanate Controller include the detection, management and monitoring of network transmission fault conditions; station partitioning; interhub connections where there is more than one star configuration; and all related ADP functions including program execution, memory storage, and interaction with any other central processing units incorporated into the network. The AsanteHub 1012 Controller thus appears to be principally used to control and interconnect with ADP machinery. The applicable subheading for the AsanteHub 1012 Controller will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units for automatic data processing machines and units thereof. The rate of duty will be free.

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

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport