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NY N007901

March 15, 2007



TARIFF NO.: 2940.00.6000

Mr. Shelliam Lee
Threshold Pharmaceuticals, Inc.
1300 Seaport Boulevard, 5th Floor
Redwood City, CA 94063

RE: The tariff classification of Glufosfamide (CAS-132682-98-5), imported in bulk form, from India

Dear Mr. Lee:

In your letter dated March 5, 2007, you requested a tariff classification ruling.

According to a press release from Threshold Pharmaceuticals, Inc., dated September 28, 2006

See: http://investor.thresholdpharm.com/ReleaseDetail.cfm?ReleaseID=212484., the subject product, Glufosfamide, is an investigational drug that was granted orphan drug designation for the treatment of pancreatic cancer. In addition, three Phase 2 clinical trials (two recruiting and one not yet recruiting) were found on the “ClinicalTrials.gov” website to evaluate the safety and efficacy of Glufosfamide in the treatment of ovarian cancer, small cell lung carcinoma, and previously treated advanced soft tissue sarcoma.

The applicable subheading for Glufosfamide, imported in bulk form, will be 2940.00.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Sugars, chemically pure, other than sucrose, lactose, maltose, glucose and fructose; sugar ethers, sugar acetals and sugar esters, and their salts, other than products of heading 2937, 2938 or 2939.” Pursuant to General Note 13, HTSUS, 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 merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by visiting their website at www.fda.gov.

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 Harvey Kuperstein at 646-733-3033.


Robert B. Swierupski

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