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NY J89187

October 8, 2003

CLA-2-85:RR:NC:MM:109 J89187


TARIFF NO.: 8517.50.9000

Mr. Craig M. Schau
Menlo Worldwide Trade Services
6940 Engle Road
Suite A
Middleburg Heights, OH 44130

RE: The tariff classification of a Virtual Presence Communications (ViPr) System from United States

Dear Mr. Schau:

In your letter dated September 19, 2003, you requested a tariff classification ruling on behalf of Marconi Communications Inc.

The merchandise is a Virtual Presence Communication (ViPr) System. The literature submitted described the ViPr System as a state-of-the art video and audio communications system. Its advanced features of the ViPr system extend beyond those of traditional Private Branch Exchange (PBX) and video conferencing systems, transforming the video conferencing experience into that of virtual presence.

The ViPr system is as easy to use as a telephone and more effective and responsive than conventional video conferencing, delivering real-time information, basic telephony services, and face-to-face video interaction between two or more geographically dispersed sites. It represents a new category of active desktop appliances while maintaining full interoperability with standard telephone systems and legacy video conferencing equipment. The system integrates voice, video, and data over an architecture that is based on Session Initiation Protocol (SIP) standards. Its advanced architecture leverages the Quality of Service (QoS) features of a modern network to enable geographically dispersed locations to communicate virtually and transparently. It also enables easy and automated collaboration using Microsoft NetMeeting for application sharing. Additionally, ViPr can be configured for simultaneous viewing of live video feeds and prerecorded video feeds.

The ViPr System consists of a ViPr Desktop Unit, ViPr Session Initiation Protocol (SIP) Platform, and a Telephone Gateway. An Audio Mixer is optional.

The ViPr Desktop Unit includes a display monitor, camera, audio speakers and handset telephone, which enables the user to receive an incoming call by picking up the handset or pressing the “Call Accept” button on the screen display. As an alternative to accepting an incoming call, it can be sent directly to voice (or video) mail, or the call can be declined. The touchscreen provides access to standard office telephone functions, including hold transfer, forward conference and caller ID. These functions can be used for both audio-only and video-enabled calls.

The ViPr SIP Platform is designed to be a network appliance. It provides network control call features and central management functions to the Desktop. It centrally stores user’s preferences and address books, enabling the users to access their preferred environment from any ViPr Desktop.

The Telephone Gateway expands the system to encompass the Public Switched Telephone Network (PSTN). A series of Telephone Gateways enables interconnections between the ViPr system and various telephone systems, i.e. ISDN, analog, and proprietary digital phone systems. These gateways allow fixed and mobile telephone users to participate in point-to-point and multipoint ViPr calls. They also enable existing voice mail systems to be integrated in the ViPr environment.

The Audio mixer, which is optional, enables audio-only users, i.e. those using traditional phones, mobile phones, or SIP phones, to participate in multipoint ViPr conferences.

The applicable subheading for the Virtual Presence Communications (ViPr) System 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 646-733-3015.


Robert B. Swierupski

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