CLA-2-84:S:N:N1:110 873516

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

RE: The tariff classification of a "Mpression Color Overhead Projection System" from Taiwan.

Dear Mr. Fisher:

In your letter dated April 13, 1992, on behalf of Micronics Computers Inc., you requested a tariff classification ruling. The merchandise under consideration involves a "Mpression Color Overhead Projection System" which is used exclusively in conjunction with an automatic data processing machine. This device projects a high resolution computer text or graphic on a wall or screen by utilizing an overhead projector. The system is specifically designed to enhance the visual component of the automatic data processing function by providing the projected overhead image automatically and simultaneously with the ADP's CRT monitor. The "Mpression" is designed to function with any PC to which a transmitting cable can be attached.

The "Mpression" device consists of the following subassemblies contained within a plastic housing: a color-active matrix transistor film transistor (TFT) LCD 10.4" diagonal 640 x 480 panel; a printed circuit board whose driver/control chip set is specifically designed to receive a separate signal from the computer simultaneous with the computer's signal to its own monitor; a dual fan cooling system; an air deflecting system; and port entry to receive the cable from the computer.

The "Mpression" device converts computer signals to render an image utilizing an LCD rather than a CRT, and present the image on a 10.4-inch (26.41 cm) viewing diagonal. It provides the user with a high resolution projected image that is both graphically perfect and synchronous with the computer program which generates it. Since "Mpression's" PCB and cable attachment are designed to receive, translate and transmit a separate signal directly from the computer, " Mpression" bypasses the computer's CRT monitor to create a better, more efficient data processing display. The driver chips located within the LCD panel are specifically designed to receive the PCB's translated signal from the computer's controller.

The applicable subheading for the "Mpression Color Overhead Projection System" will be 8471.92.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for display units without cathode-ray tube (CRT), having a visual display diagonal not exceeding 30.5 cm. 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