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NY N009308

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 Alcatel Submarine Line Terminating Equipment (1620) 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”).

The ruling concerns the classification of an Alcatel Submarine Line Terminating Equipment (1620).

The Alcatel Submarine Networks Submarine Line Terminating Equipment (1620) 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 Submarine Line Terminating Equipment 1620 is of an ASN generic design and includes features that allow the configuration of it to suit a given system.

The Alcatel Submarine Networks Submarine Line Terminating Equipment (1620) is designed for telecommunication systems utilizing equipment typically operating at N x 10 Gbit/s and designed to provide up to 84 channels on the International Telecommunication Union (“ITU”) 50 GHz grid, up to 105 channels on the 40 Ghz grid or 126 channels on the 33 GHz grid.

The Submarine Line Terminating Equipment (1620) 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 applicable subheading for the Alcatel Submarine Line Terminating Equipment (1620) 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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