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NY N009878

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 1660 SM Optical Multi-Service Node 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”).

This ruling concerns the classification of an Alcatel 1660 SM Optical Multi-Service Node.

The Alcatel 1660 SM Optical Multi-Service Node 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 Alcatel 1660 SM Optical Multi-Service Node is of an Alcatel generic design and includes features that allow configuration of the Alcatel 1660 SM Optical Multi-Service Node to suit a given system.

The 1660 SM telecommunications equipment is an STM – 1/4/16/64 Multi-Service Node for transmission and cross-connection of a wide range of traditional PDH and SDH telecommunication data signals as well as packet based data flows. It can operate as a Multi-terminal or Add/Drop Multiplexer and can also be configured as a small Cross-Connect with a matrix size of up to 384 x 384 STM-1 equivalent at the High Order VC level and 256 x 256 STM-1 equivalent at the Low Order VC level.

The applicable subheading for the Alcatel 1660 SM Optical Multi-Service Node 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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