dissenting.
Customs’s classification of imported merchandise is presumed to be correct, and the party challenging the classification has the burden of overcoming this presumption. 28 U.S.C. § 2639(a)(1) (1994); Mita Copystar Am. v. United States, 21 F.3d 1079, 1082 (Fed.Cir.1994). To decide whether an importer has overcome this presumption, the court must consider “whether the government’s classification is correct, both independently and in comparison with the importer’s alternative.” Jarvis Clark Co. v. United States, 733 F.2d 873, 878 (Fed.Cir.1984). “Ordinarily it will be difficult to meet this burden of proof without proposing a better classification.” Id.
In concluding that Technicolor met its burden, the Court of International Trade focused on the complexity of the V-0 cassettes and emphasized that “the V-0 cassette is an integral component of the VCR, without which the VCR could not operate in its intended capacity.” However, the fact that V-0 cassettes are complex and are necessary for VCRs to function does not overcome the *489government’s argument that these devices fall within note 1(c) to section XVI, which excludes “[b]obbins, spools, cops, cones, cores, reels or similar supports of any material” from classification under that section. This exclusionary note does not clearly delineate those devices which should and should not be included, but the government interprets it broadly enough to encompass V-0 cassettes, reasoning that the V-0 cassettes essentially perform like functions to the listed items and that their mechanical complexity is not determinative. Thus, notwithstanding the fact that the V-0 may plausibly fit the definition of “parts of VCRs,” the government’s preferred classification is not inferior by comparison and comports with the relevant portions of the classification scheme. Accordingly, I would reverse.