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NY N009871

May 11, 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 1678 Metro Core Connect from an unspecified country

Dear Mr. Roll:

In your letter dated April 17, 2007 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

The ruling concerns the classification of an Alcatel 1678 Metro Core Connect.

The Alcatel 1678 Metro Core Connect is a hybrid of optical, electronic and mechanical systems that forms part of a telecommunications system for use in the transmission of aggregate data. The Metro Core Connect is of an Alcatel generic design and includes features that allow configuration of the Metro Core Connect to suit a given system.

The Alcatel 1678 Metro Core Connect is telecommunications equipment tat provides an optical platform that combines broadband, wideband, optical transport network, multi-protocol label-switching and packet based functionality into a single element. The Metro Core Connect aggregates and consolidates multi-protocol traffic streams from the metro towards the core. The Metro Core Connect can be used in a variety of network applications and consists of the following subsystems: Two Cross-Connect, Synchronization, Equipment Control, Traffic Port, Protection, Auxiliary and Overhead, and Power subsystem.

The applicable subheading for the Alcatel 1678 Metro Core Connect 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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