CLA-2-85:RR:NC:N1:109

Mr. James Huynh
Import Manager
Attorney in Fact
GeoLogistics Americas Inc.
19688 Van Ness Blvd
Torrance, CA 90501

RE: The tariff classification of an L-200 PC Expansion (Access Terminal) from Korea

Dear Mr. Huynh:

In your letter dated July 2, 2007, you requested a tariff classification ruling on behalf of your client NComputing, Inc.

The merchandise subject to this ruling is an L-200 PC Expansion (Access Terminal). The L-200 PC Expansion (Access Terminal) is a networking device using WoIP (Windows over Internet protocol) or LoIP (Linux over Internet protocol) networking standards. Users can share the resources of a single host PC system by connecting the PC Expansion terminal(s) to it, providing the benefit of having several networked PCs. Users can connect one or more PC Expansion terminal to one host PC directly using a LAN adapter and Ethernet cable or via the network using a switch/router. The L-200 PC Expansion (Access Terminal) consists of the access terminal, a power supply/cord, LAN Cable, a software installation guide, and a Quick installation guide. The access terminal, itself, has a LAN (local area network) indicator light to indicate when it is connected to a LAN network.

To set-up the L-200 PC Expansion (Access Terminal) the software installation CD is placed into the host PC’s CD drive and the instructions are followed enabling the expansion of the host PC to other terminals (monitor, keyboard, and mouse) via the access terminal. The L-200 PC Expansion (Access Terminal) enables up to a maximum of 30 terminals to share the resources of the host PC when using a server host OS (i.e., Windows server 2003) and a maximum of 10 terminals when using a desktop OS (i.e., Windows XP), thus creating a LAN environment. As sample of this merchandise was submitted for classification purposes and is being returned to you.

The applicable subheading for the L-200 PC Expansion (Access Terminal) will be 8517.62.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Modems, of a kind used with data processing machines of heading 8471.” 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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division