The tariff classification of an image transmission device from China

N280876 November 17, 2016 CLA-2-85:OT:RR:NC:N4:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Jimmy Great Ting Great World Customs Service 518 Eccles Ave South San Francisco, CA 94080 RE: The tariff classification of an image transmission device from China Dear Mr. Ting: In your letter dated November 2, 2016, you requested a tariff classification ruling on behalf of your client, Light Blue Optics, Inc. The item concerned is referred to as the Kaptivo. The Kaptivo is a whiteboard collaboration product. It captures images from a whiteboard, as in a classroom environment, and transmits those images to a remote server. Remote users, such as students, can then view the images from the whiteboard on their computer. The Kaptivo system is comprised of the Kaptivo main unit, control pad, power adapter and connector cables. The Kaptivo main unit is the heart and brains of the Kaptivo system. The main unit contains a CMOS image sensor, a processor, sensor board, and Wi-Fi antenna/module. The control pad starts and stops the Kaptivo whiteboard collaboration function and connects to the Kaptivo main unit via a cable. The connector cable is used to connect the control pad to the Kaptivo main unit. The power adapter connects the control pad to a power outlet via a cable. In use, the Kaptivo main unit would be mounted above a whiteboard using a wall mounting plate. The control pad is then connected to the Kaptivo main unit using the supplied cable. The power adapter is then attached to the control pad to provide power for the device. The user then wirelessly connects the Kaptivo to a local Wi-Fi network. Once the system is installed the Kaptivo main unit begins capturing a sequence of images of the work performed on the whiteboard. It does so through the use of the CMOS image sensor. The processor that is inside the main unit, in conjunction with proprietary embedded software, analyzes the image sequence and extracts just the written ink on the whiteboard. Everything else captured by the CMOS is filtered out. This includes reflections, distortions, shadows, background, light level changes, body parts of the person using the white board, etc. What is left is a perfect ink-only, digital image of anything that is written/drawn on the whiteboard. The digitized, processed/extracted image is sent to the Kaptivo cloud server. The Kaptivo cloud server automatically stores key frames in a history so that remote users can go back in time to see how the board contents developed. Users from anywhere in the world can connect to the Kaptivo cloud server via their web browser or Kaptivo companion app. They can see a live view of the board contents (ink) as it develops. Users can also rewind to any point of the whiteboard’s timeline using a history feature. From their browser, users can then save the current contents of the board as an image file (PNG), the whole meeting as a slide deck (PDF), and invite other users to view. There is no capability to save a video or video-like file. The components of the Kaptivo system form a functional unit, the function of the system is to receive and transmit data/images to the Kaptivo network. That information is then accessible to users of that network. The applicable subheading for the Kaptivo will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets…; other apparatus for the transmission or reception of voice, images or other data…: Other apparatus for transmission or reception of voice, images or other data..: Machines for the reception, conversion and transmission or regeneration of voice, images or other data…”. 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 https://hts.usitc.gov/current. 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 Steven Pollichino at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division