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NY N009295

April 26, 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 Submarine Line Termination Equipment Alcatel Link Extender Loading Channel Subrack (Unrepeatered) from an unspecified country

Dear Mr. Roll:

In your letter dated April 4, 2007 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of ASN’s Submarine Line Terminating Equipment.

The descriptive literature submitted states that the ASN’s Submarine Line Terminating Equipment is a hybrid of optical, electronic, and mechanical systems that forms part of a submarine telecommunication system for use in transmission of aggregate data (speech & data). The Alcatel Link Extender Loading Channel Subrack (Unrepeatered) is of an ASN generic design and includes features that allow the configuration of the unit to suit a given system.

The Submarine Line Terminating Equipment manages the integrity, quality, receipt, and transmission of telecommunication aggregate data between the submerged equipment and the land-based telecommunication system. Modular construction is employed so that an installation provided with less than the maximum number of channels can be upgraded later by adding more channels with minimum disturbance to those already in service. The principle functions of the Submarine Line Terminating Equipment are to manage and achieve efficient data transmission integrity through the submarine telecommunications optical fiber cables, transmit by taking a number of input channels at different wavelengths and aggregate (optical multiplexing) them into one optical signal for transmission through the submarine cable (optical fiber), to receive this signal and divide (demultiplex) it into a format through which it can be passed to the land-based telecommunication systems, supervision of submerged equipment, and interface to the Submarine Management system.

The applicable subheading for the ASN’s Submarine Line Terminating Equipment 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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