knob a lot it's primarily focused on the functionality ok so what we've done is part of the time trying to key in on the primary issues in this case we say this case is about explanatory notes of it it's real to you that's the place you'll find the word going up doesn't appear in any other explained torino or language of the tariff is a door knob a door knob or is it your merchandise you need a cimi in order locker unlock the door no and i don't you don't need to keep them around and you look at these two to unlock it from the outside you need to keep to operate the locking mechanism from the outside who  distinction your answer key distinction here that is important the functionality that's relevant here relates to the terror of language in the tariff language is key operated lock there are if you reject the contention that it has to throw the bolt then yes that's correct and that's what the lower court interpret it they created additional ambiguity in the tariff rather than clarifying the specific language that exist between each real  three o two is that what you're saying or do you have some other argument against why the merchandise does not fit under eighty three oh well there's several actually there's many arguments why when from the real one as i mentioned you've got to distinguish between the in yes we're we're predicating this question and i think all three of our questions are predicated on the notion that perhaps we don't agree with you that your product does not have a key operated lock if we cut so conclude question is is there any argument that this should not be treated as a composite well i think to get to eighty three zero one you've got to consider it as a composite it's got the heat cylinder but look at these other products they latch what i'm saying is it's a door now and there's no dispute the door knobs are classified need three o two you can ask defense counsel hill of knowledge that passage version or passion function privacy function there's if you lost the key the do not still work many people have a door knob on their door where they've lost the key throw away the door knob no it still functions still lack is the door on what your concept of a key operated lock is right so that unfortunately is beyond the scope of this case we don't have any electronic clocks personally i don't understand how an electronic lock works if that were before the court then the same analysis that we're talking about here where the electronic has to throw the ball would be an interpretation because we recognize that there's other adjectives in the parent that tickle that follows or that perceives the term walk ok combination electronic so presuming that it's an electronic lock the electronics would have to throw the ball propel withdraw the ball just like he does if it was a combination it would be the same think think about a gym locker padlocked when you kristen numbers you get to a point where it catches and you turn the combination dial and it actually retracts about let me make sure that we're on the same page with respect to one question of terminology in the accused that subject product the tongue that either comes out and goes through the strike plate or all retreats is considered a bolt correct yes th explanatory note d'sevyn where it talks about knobs for doors including those for locks or latches well my understanding is that it's expansive to what's covered by eighty three o two  interprets what goes in that heading includes the or not i need to be a little more specific with my question i think that what i'm looking for from you is an answer as to what the expression for locks are latches  does that mean that it can be used with a lock or that it contains a lock in the form in which it still well we would consider we interpret to be the latter we acknowledge that the language is not artfully drafted and leaves us with a bit of interpretation but we have some guidance the guidance being that there's no question that an entirety of a door knob goes needs real too so let's just look at it this way let's say it's just parts for your hono assumption here latches are also included we've got some samples here that show what's in these products they're mounted here so you can see the operation because we respectfully assert that the op an operation is critical but if you look at what you've got an interior knob you've got an x you're not a three zero two d seven provides for those of them and i think we all would agree ok now whether it includes the entirety door knob there's an argument and they they disagree we say it does reference that the lower court identifies in some instances we referenced the term law with respect to these goods but it's not the only time we reference any word in fact when you look at it on the web site itself some is throw her think we're o the headings and the terms of those headings and they also looked at the heading eighty three o two heading eighty three a one is padlocks and lots q the combination or electronic or electrically operated base metal and what we have is exactly that it's a heat injury luck the court went into the definition and that's the common meaning of what the terms in the heading are and the court found that  lot using a definition that was offered by home depot in their brief a device for securing a door the lady drawer or the like in the position when closed consisting of a bolt were system of boats propelled and withdraw drawn operators and operate means to perform a function or to produce an appropriate effect so the key is having you know that the key has the effect of unlocking that knob which when you turn  and retract and thereby retract both electrical ok so when you're outside big and these are these are exterior doors if you look at the exterior door equipment if you look at  home depot's website materials they say that these are locks residential locks exterior door locks answer your grade three which in so you agree three goes to performance and security  i come to as i've looked at these products i think about these products and what i see is some kind of integrated composite good door knob with a lock or it's a lock that also has a door knob it have both things going on here and we have two sides trying to basically negate the one piece that they want they prefer to ignore and that's where i'm troubled i  and the c i t's analysis was quite brief i might even say conclusory so can you build up for me why my my instant reaction to reading the seven would thoughts about eighty three o two specifically how to understand explanatory no eighty three o two d seven yes your honor and why my instant my instinct that it covers door knobs integrated  knob is not the entire reference to what this article is of this article is more than that and the court went through her camel back to look at whether something has more functionality but i guess the question is looking at this explanatory no and we talked mr rucker about this is whether the explanatory note is can't recognize the fact that knobs can be coming in or important separately and they're not associated with what the parent product is and therefore the parent product could either just be a knob for a passage eighty three o two under this explanatory no will include the door knob that is important separately that could be assembled after importation together with a lock if it was unrecognizable upon import that it belongs with the parent item that knobs for doors including those for locks is to say is to read it as a knobs for doors including those with locks and that the proposition is for which is a little ambiguous lost as to how you want us to understand the words and e n eighty three o two d seven what how do you want us to think about it i understand judge bryson's proposed conception of the meaning of eighty three zero to the seven i don't quite understand yours yet honor the and you give me an example maybe give me an example of an abstract definition there we were we have been discussing the example of a entry coming in that's just a door not that can't be associated with this paranoid and that's what the lower court what does that mean can't be associated with its parent item what is that it's not known to be part of an index reading tree block at the time of importation that it could be seems as though this provision would cover some door knobs that are used with locks and i don't quite understand your suggestion that if at the time of if the door knob is imported separately it's within eighty three o true if it's imported together with a locking mechanism it's within the three zero one or alternatively that even when it includes the locking i understand of course that your position that these are merely just holes and therefore they are under eighty three a lot but we're back to trying to figure out what this final clause and a three zero to the seven and that's why i'm searching for a definition from you or an example from you so i can clarify in my mind what is the government this means it's here for a reason we all have to answer for it you have to answer for it we have to answer we have to have a rational explanation of what this importation that they do not come in and it can't be associated with this parent article that is one understanding of it the fact that it could come in with what would an example of that be if that if the importation is just a door not coming in and it has a hole it could be associated with perhaps a passage a privacy lock which is not a key block it would be looked at and classified likely under eighty three o two because it can't be associated with  if hypothetically the merchandise we have here in puerto broke up the package and just imported the door knob with a big hole in it and then the strike latch assembly and all that but without the actual locking interior locking compartment and you would say ok that's what a three zero to the seven is trying to cover when you break up the entire s components and you import the interior lock locking portion separately from all the other stuff then that is what the authors of this were thinking about is that your position there's no indication that it's going to be put together with a lock or whether it's not going to be i mean and if you block and that would put it in a three zero two you view that when that is looked at that point and that would probably go into eighty three o two but once again these are these are not really we understand that point but we're interested in seeing what this guidance actually tells us that's that's the reason we're focusing on this because this in this whole set of both the tariff and the end this is the most specific information we have before so we're trying to pin down exactly what it means and i'm having trouble figuring out exactly what your position is with respect to that issue and to say it's one that says it's for a lox suggest that the good when it comes in there is a contemplation that it will be your honor when it says under the understanding that unions are our guidance and we don't really have that understanding trust us we're seeing that for lots than it could be hypothetically for  to see it has more functionality than one is an eighty three o two and the court looked at the american n c standards one fifty six one two and looked at what they describe as the entry lock system and the court noted that this locking mechanism has multiple components working together to securely locked the door so as a whole it's described in any three zero one it's complete the complete product mr rocker you have community in your arms well we certainly covered a lot of ground there so let me do my best to try to sum up in the time i have one thing i want to correct defense counsel long is that each real one is not only our nominee a provision that covers all forms let's not forget the word similar in eighty three zero two two types of door knobs undisputedly classified eighty three o two what's similar the key to entry not let's go through the factors real quick what are the similarities in opening closing door and allow a person to go through yes those are all the functions of door knobs in the juice in generic analysis our product has everyone know limiting characteristics exist our products classifiable in iti three zero two to summarize if you will you run both headings covered or faster fastening by door hardware is accomplished by the operation of the bolt that's why bolt is referenced in the e x e that's why key operated references