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NY H82810

July 18, 2001

CLA-2-85:RR:NC:MM:109 H82810


TARIFF NO.: 8517.50.9000

Ms. Leslie Pembroke
Manager, Airport Office
Paxton, Shreve & Hays, Inc.
Lindbergh Field
2361 Airlane Drive “D”
San Diego, CA 92101

RE: The tariff classification of an Optimesh Rooftop Node from Taiwan

Dear Ms. Pembroke:

In your letter dated June 15, 2001, you requested a tariff classification ruling on behalf of AirFiber Incorporated of San Diego, California.

The merchandise is described in your letter as the OptiMesh Rooftop Node. The OptiMesh provides telecommunications carriers (CLEC’s ILECS and IXC’s) with a low cost, quickly deployed, reliable method of extending fiber-optic backbones to a large number of customer premises. The mesh network transports voice, data, video and multimedia services using ATM technology.

The OptiMesh network is composed of wireless optical (785-nm laser) links, each capable of 622 Mbps transmission rates. Nodes in the mesh network are typically installed on the rooftops of buildings in an urban industrial environment linked together by line of sight. Each node in the network serves as an access point for one building and a relay point for traffic originating elsewhere in the mesh. Each node is equipped with up to four eye-safe optical transceivers, a drop to the building demarcation point, a control microprocessor, a small 6x6 ATM switch for routing, and software. Each optical transceiver has tracking capability to automatically adjust alignment for building sway and thermal expansion. The physical shortness of each optical link and the alternate routing capability of the mesh network provide the product with carrier-grade availability. Nodes are connected to the carrier’s fiber optic backbone and to the customer’s premises using standard OC3c/STM-1 or OC12c/STM-4 interfaces.

This OptiMesh Rooftop Node has the following features:

High Reliability – Optical links are severely impacted by weather conditions, especially heavy fog. The OptiMesh network accounts for weather conditions in three ways: 1 - The optical power transmitted automatically adjusts for change atmospheric attenuation due to weather.

2 – The maximum link length allowed is short, typically 200 meters, as defined by the specific annual weather patterns in a particular city. Network plans connecting all the buildings in a typical urban environment show average link lengths of 50 to 90 meters and less than 200 meters for the longest link.

3 - The mesh network provides multiple paths and rerouting capability for transmission around temporary, localized link outages. The OptiMesh network is designed for the high availability that carriers and their customers demand.

High Scalability – Additional nodes are easily commissioned into the network from a centralized Element Management System that resides in a carrier’s Network Operating Center (NOC), efficiently accommodating growth in the customer base.

The applicable subheading for the OptiMesh Network Node will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other apparatus for carrier-current line systems or for digital line systems: Other: Telegraphic: Other.” The rate of duty will be free.

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 Linda M. Hackett at 212-637-7048.


Robert B. Swierupski

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