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NY 815902

October 20, 1995

CLA-2-84:R:N1:110 815902


TARIFF NO.: 8471.99.1500

Mr. Dennis Heck
Tower Group International, Inc.
2400 Marine Avenue
Redondo Beach, CA 90278-1103

RE: The tariff classification of Netrunner Integration Routers from Malaysia

Dear Mr. Heck:

In your letter dated October 13, 1995, on behalf of Micom Communications Corp., you requested a tariff classification ruling.

The merchandise under consideration involves four models of integration routers which are basically free standing units that allow for multiprotocol transmissions to be sent across wide area network (WAN) lines. The four models include the following: Netrunner 50E data/voice internetwork feeder/router; Netrunner 100E Data/voice Internetwork Node; Netrunner 200E Integration Router, and Netrunner 500ET Integration Router.

These Netrunner units are high performance IP/IPX routers, with hardware data compression and central point of control. Voice digitization and compression is performed by using 20 MIPS digital signal processors (DSP) in order to reduce WAN bandwidth requirements. The Netrunner series is Novell certified and integrates Ethernet LAN traffic with free legacy data traffic and toll-free voice and fax. This is done by compression of all information on one end (data, voice, LAN), overlaying it on the existing network, and decompressing it on the other end. The mainboards of these various models of Netrunner units contains various configurations of the Z80-Zilog microprocessor, and all units contain various ROM's of program memory from .5MB to 765KB EPROM and 32KB of non-volatile RAM. All four models possess I/O capability.

Noting Legal Note 5 (B) to Chapter 84 of the HTS, these various models of routers appear to meet the definition of a "unit" of an ADP system. They control and process information exchange within the framework of a network, and are used to interconnect the CPU to other units or ADP machines, thereby serving "control" and "adaptor" functions.

The applicable subheading for the four models of Netrunner routers will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adaptor units. 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 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 Art Brodbeck at 212-466-5490.


Roger J. Silvestri

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