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NY R05147

November 24, 2006

CLA-2-84:RR:E:NC:1:120 R05147


TARIFF NO.: 8471.80.1000

Mr. Brian Johnson
Keytronic Corporation
4424 North Sullivan Road
Spokane, Washington 99216

RE: The tariff classification of a MultiService Access Point, MultiService Controller (5000 Series), WLAN Access Point, Wireless LAN Bridge, and Wireless Access Controller (CN3000) from Mexico

Dear Mr. Johnson:

In your letter dated October 30, 2006 you requested a tariff classification ruling.

The Inreach MultiService Access Point (320/330) is a bridge that provides connectivity between the local area network (LAN) to wireless devices, such as a desktop or laptop. It has a Wireless Fidelity (WIFI) built-in radio and is connected to an ethernet switching infrastructure known as a local area network to access the internet.

The MultiService Controller (5000 Series) is a stand-alone server connected indirectly to the internet via ethernet switching devices. The server has a processor, no hard drive, DRAM, and a PC platform running on Linux firmware with hardware blocks to control the firewall. The server is a specialized 1U rack-mount controller designed specifically for large-scale internet access services. The 5000 series controls client devices such as laptops and desktops that are connected via wireless local area network (WLAN) Access Points or directly to an ethernet network, enabling both service providers and enterprises to authenticate users and control session operation. It integrates a firewall and IP router, enabling it to support a range of network architectures built for large campus and hotspot operator applications. The 5000 series delivers multiple network services mapping the traffic to destined portals and servers.

The WLAN Access Point (CN1250) has an embedded virtual private network (VPN) server, designed to deliver secure Wi-Fi access to mobile users within a LAN environment. It has hardware encryption capability and an integrated firewall. It functions as a router and connects to an ethernet switching infrastructure known as a LAN, enabling it to access the internet. It is not capable of directly connecting to the internet.

The Wireless LAN Bridge (CN 300) communicates with all Wi-Fi certified wireless adapters, and plugs into a network device with an ethernet-to-wireless converter. It allows the laptop to communicate with the Access Points to reach the internet.

The Wireless Access Controllers (CN3000) are Colubris Intelligent MultiService System’s server platform for delivering wireless local area network (WLAN) services. It controls wireless network devices through an Access Point distributed throughout a wireless zone, building or campus. The wireless communication device integrates a full-featured MultiService Access Point and service controller with firmware in a single turn-key unit that connects to another network device such as the LAN switching product in the network center, enabling access to the internet.

The InReach MultiService Access Point (320/330), MultiService Controller (5000 Series), WLAN Access Point (CN1250), WLAN Bridge (CN300), and Wireless Access Controller (CN3000) meet the definition of a "unit" of an automated data processing (ADP) system as defined in Legal Note 5(B) to Chapter 84 of the Harmonized Tariff Schedule of the United States (HTSUS). They are connectable to the central processing unit either directly or through one or more other units, and are specifically designed as part of such a system. From the information you provided, the principal function is the interconnection of the mainframe to other input and output units. It would thus fall under the definition of a control or adapter unit under HTSUS number 8471.80.1000.

The applicable subheading for the InReach MultiService Access Point (320/330), MultiService Controller (5000 Series), WLAN Access Point (CN1250), WLAN Bridge (CN300), and Wireless Access Controller (CN3000) will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Automatic data processing machines and units thereof Other units of automatic data processing machines: Control or adapter units, Harmonized Tariff Schedule of the United States The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

Pursuant to title 19 United States Code, Section 3005 The Harmonized Tariff Schedule of the United States is expected to be amended effective 1/1/07. The amendments are expected to affect the classification of your merchandise. Pursuant to Section 3005 c, the report recommending those changes has been sent to the President for proclamation of the changes. Upon the expiration of sixty legislative days, in the absence of Congressional action, the recommended changes will become law. Accordingly based on that recommendation, it is anticipated that your merchandise will be classified in 8517.62.00 under the 2007 Harmonized Tariff Schedule. Under the circumstances, this classification under the 2007 tariff is advisory only.

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 Denise Faingar at 646-733-3010.


Robert B. Swierupski

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