Logitech, Inc. v. United States
The CIT held that Logitech Inc.’s videoconferencing cameras where properly classifiable under HTSUS heading 8517 and thereby eligible for duty-free treatment. The CIT held that CBP incorrectly classified the merchandise as “television cameras” under HTSUS subheading 8525.80.3010, with a duty rate of 2.1 percent ad valorem.
The CIT denied both parties cross-motions for summary judgment and determined that since Heading 8517 is a principal use provision, the Court must undertake an analysis of the principal use factors provided in United States v. Carborundum. Pursuant to the Carborundum factors, the Court determined that the subject merchandise’s physical characteristics, use, economic practicality and expectations of the ultimate purchaser support a classification under Heading 8517. The CIT ultimately found that subject merchandise were primarily used for two-way communication, rather than for one-way broadcasting and therefore are classifiable under HTSUS subheadings 8517.62.00 and 8517.69.00.