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NY N015401

August 29, 2007



TARIFF NO.: 8517.62.0050

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

RE: The tariff classification of Alcatel 1354 SN Network Manager from an unspecified country

Dear Mr. Roll:

In your letter dated August 1, 2007 you requested a tariff classification ruling, on behalf of your client Alcatel Submarine Networks (“ASN”).

The merchandise subject to this ruling is the Alcatel 1354 SN Network Manager. The Alcatel 1354 SN Network Manager is comprised of one or several Unix workstations that have telecommunication information technology software installed. The computer workstation(s) are configured specifically to manage Alcatel submerged telecommunication equipment and the telecommunication systems in which they operate. In order to host the Network Management system, the Unix workstation(s) must be configured in terms of file systems sizes, swap space, kernel parameters, etc. There is also proprietary firmware installed for a telecommunications function. The 1354 Network Manager runs on a platform which can be scaled to suit the telecommunication network size.

The Alcatel 1354 SN Network Manager is of an Alcatel generic design and includes features that allow for the configuration of the Alcatel 1354 SN to suit a given Alcatel telecommunication system requirement. The Alcatel 1354 SN performs or assists in the telecommunication transmission by providing the following supervision domain functions:

Displays alarms relating to any part of the network, whether it be submerged equipment or termination station equipment, such as the power feed or the line termination equipment Measurement (immediate or periodical) of the sensitive components parameters, such as the optical amplifiers, laser pumps and power supply Logging of all events during the operational lifetime of the network

The Alcatel 1354 SN Network Manager also executes other telecommunication transmission maintenance domain functions, which include:

Detect and locate faults in the network, i.e., in the event of damaged fiber, the location of the damage fiber is determined Dynamic (re)configuration of the network (addition of repeaters, upgrades).

The Alcatel 1354 SN Network Manager supports the functions of the Submarine Network Telecommunication Management Layer, providing end-to-end configuration and monitoring of WDM transmission (optical) paths. The Alcatel 1354 SN supports the G.803 architecture recommendation for transport networks, supporting both a network layer and partition concept. The 1354 SN can configure a number of functions that help to protect end-to-end transmission from hazards, such as:

Performance monitoring counters (start/stop) Fault location (on-demand or automated search of submarine cable faults) Routine maintenance (automated search of faulty line equipment) Alarm thresholds of submerged equipment (repeaters and branching units) Branching unit electrical switch position.

WDM transmission path monitoring is based on the forward error correction (FEC) counters, which are implemented on each STM-64/OC192 tributary to achieve very high data transmission integrity through the submarine cable. The error correction technique consists of processing the traffic signal according to a defined mathematic algorithm to determine the values of additional data bits, which are interleaved into the traffic to send over the submarine line. Processing the received signal at the distant terminal with a complementary algorithm allows transmission errors to be detected and corrected, making the overall system tolerant to a limited number of errors introduced in the aggregate functions and the submarine path.

The applicable subheading for the Alcatel 1354 SN Network Manager 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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