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NY N009313

April 26, 2007



TARIFF NO.: 8517.62.0050

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

Dear Mr. Roll:

RE: The tariff classification of an Alcatel 1696 Optinex Metro Span 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 Alcatel 1696 Optinex Metro Span telecommunications equipment is a hybrid of optical (transmission), electronic and mechanical systems that forms part of a telecommunication system for use in transmission of aggregate data. The 1696 is of an Alcatel generic design and includes feature that allow the configuration of the 1696 to suit a given system.

The Alcatel 1696 Optinex Metro Span telecommunication equipment functions utilizing specifically the Optical (Transmission) Amplifier Cards by optimizing the amplification performance of aggregate data transmission. It performs this function irrespective of the number of communication channels being operated or the variances in signal integrity experienced over the communication link, and in this way achieves a constant amplification performance based upon the telecommunication system configuration.

The Alcatel 1696 Optinex Metro Span supports variable rate transmission (optical) interfaces, capable of accepting a broad range of data rates, from 100 Mb/s up to 10Gb/s. The system transports a wide variety of SDH and data signals, such as: STM-1
Fiber Channel, and
Digital Video.

The applicable subheading for the 1696 Optinex Metro Span 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 M. Hackett at 646-733-3015.


Robert B. Swierupski

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