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NY N008248

April 2, 2007



TARIFF NO.: 8517.62.0050

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

RE: The tariff classification of an Alcatel Single Wavelength Transponder from an unspecified country

Dear Mr. Roll:

In your letter dated March 12, 2007 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of an Alcatel Single Wavelength Transponder.

The descriptive literature submitted states that the Alcatel Single Wavelength Transponder is a hybrid of optical, electronic, and mechanical systems that forms part of a submarine telecommunication system for use in transmission of aggregate data. The Alcatel Single Wavelength Transponder is of an Alcatel generic design and includes features that allow the configuration of the unit to suit a given system.

The Alcatel Single Wavelength Transponder is intended to be used on long haul unrepeatered submarine cable systems linking networks carrying telecommunications data. For transmission over the submerged cable section, the transponder includes a Forward-Error Correction (“FEC”) code. This has the benefit that transmission errors, which arise in the submerged system, can be detected and corrected at the receiving terminal.

There are three principal functions of the Alcatel Single Wavelength Transponder. They are: to manage and achieve efficient data transmission integrity through the submarine telecommunications optical fiber cable; to transmit one optical signal through the submarine cable, optical fiber; to receive this signal, decode it through an Forward-Error Correction (“FEC”) algorithm and pass it to other land-based telecommunication systems.

The applicable subheading for the Alcatel Single Wavelength Transponder 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 pare 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 M. Hackett at 646-733-3015.


Robert B. Swierupski

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