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NY N010517

May 18, 2007



TARIFF NO.: 8517.62.0050 8517.70.0000

Mr. Craig J. Pinkerton
Director, PricewaterhouseCoopers
350 South Grand Avenue, 46th Floor
Los Angeles, CA 90071

RE: The tariff classification of a SATCOM System (MCS-7000) and an Intermediate Gain Antenna (CMA-2200) from France

Dear Mr. Pinkerton:

In your letter dated April 27, 2007 you requested a tariff classification ruling, on behalf of your client, International Lease Finance Corporation.

The merchandise subject to this ruling is a SATCOM System (MCS-7000) and an Intermediate Gain Antenna (CMA-2200).

The satellite communication system “SATCOM” (MCS-7000 series) produced by Honeywell International Inc. and Thales is designed for use in commercial aircraft. It is designed for the simultaneous reception and transmission of both passenger and operational flight communications. It is the first SATCOM system in the industry to allow communications over seven separate channels.

The basic components of the MSC-7000 are a satellite data unit (SDU) and a high power amplifier (HPA). The SDU provides overall system control and monitoring, data modulation and demodulation, data synchronization decoding, voice coding, decoding for the cockpit voice, and data services. The SDU features six multiple control units (MDU) capacity, which enables multiple terminals to participate in multipoint communications.

The HPA, which is dedicated solely for use with the MC-7000, has a four MCU capacity. It is a linear power amplifier that provides the power gain necessary to generate the required output power for broadcast from the MC-7000 to the satellite.

Unlike ground based radio frequency communications, SATCOM technology provides direct, digital voice linkage and Air Traffic Control (ATC), even in the most remote parts of the world, with atmospheric distortion. This system streams “toll quality” digital voice connections to the cockpit or passenger cabin. In addition, SATCOM technology enables the automatic transmission of digital aircraft data including reporting time, position, altitude, and other miscellaneous aircraft information.

The Intermediate Gain antenna (CMA-2200) is an antenna that is top-mounted to an aircraft for the purpose of satellite communications. It is an electronically steerable, phased array antenna providing hemispherical coverage. These features provide seamless aircraft communication coverage of more than 95% of the specified Inmarsat satellite hemisphere.

The CMA-2200 receives signals in the range of 1.525 GHz to 1.559 GHz and transmits in the range of 1.6265 GHz to 1.6605 GHz. The antenna supports Inmarsat AERO-I satellite services, which are proprietary IP-based shared-carrier services for Aeronautical Settings enabling voice and fax/data communications at up to 2400 bps.

This antenna is used with SATCOM systems, such as the Honeywell-Thales MCS-7000. It is sold and used in conjunction with a diplexer/low noise amplifier unit that combines multiple transmissions into a single output and amplifies weak signals.

The applicable subheading for the SATCOM System (MCS-7000) 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.

The applicable subheading for the Intermediate Gain Antenna (CMA-2200) will be 8517.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Parts.” 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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