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NY N007406

March 19, 2007



TARIFF NO.: 8517.62.0050

Mr. Michael E. Roll
Partner, Pisani & Roll
1875 Century Park East
Suite 600
Los Angeles, CA 90067

RE: The tariff classification of an “Alcatel Submerged R4 Repeater” from an unspecified country

Dear Mr. Pisani:

In your letter dated February 22, 2007, you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (ASN).

This ruling concerns the classification of the “Alcatel Submerged R4 Repeater”.

The descriptive literature submitted states that the “Alcatel Submerged R4 Repeater” is a hybrid of optical (transmission), electronic, and mechanical systems that form part of a submarine telecommunication system for use in transmission of aggregate data. The “R4 Repeater” is of an ASN generic design and includes features that allow the configuration of the “R4 Repeater” to suit a given system.

The “R4 Repeater” provides amplification of digital transmission signals in the c-band amplification window of the submarine telecommunication system at around 1550 nm. The repeater can be equipped for use with cables having from one to eight fiber pairs. The mechanical arrangement is compatible with all types of Alcatel submarine cables used in repeatered systems. The different cable types are terminated in the cable extremity boxes of the repeaters. The repeater’s powering circuitry is compatible with reversible power feed current.

Each fiber is a data transmission path and is associated with a single erbium-doped fiber amplifier. Each fiber pair has two amplifiers, one for each direction of transmission. These two amplifiers (called an amplifier pair) are mounted on one amplifier module and are connected to 980 nm pump units, control circuit, supervisory circuit and a power supply circuit. Reliable operation is ensured by equipping pump units in pairs, with their output energy combined and then divided via a coupler to pump the amplifiers in both directions. The control circuits operate to regulate the amplifier outputs, so that any decline in the output of one pump unit can be compensated by an increase of output from the other.

The applicable subheading for the “Alcatel Submerged R4 Repeater” will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other”. 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).

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 Hackett at 646-733-3015.


Robert B. Swierupski

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