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NY N021357

January 30, 2008



TARIFF NO.: 8517.62.0050

Mr. John M. Peterson
Neville Peterson LLP
Counsellors at Law
17 State Street, 19th Floor
New York, NY 10004

RE: The tariff classification of ZP 100 ZonePlayer 100 from an unspecified country

Dear Mr. Peterson:

In your letter dated December 24, 2007 you requested a tariff classification ruling, on behalf of your client Sonos, Inc.

The merchandise subject to this ruling is a ZP 100 ZonePlayer 100. The ZP 100 Zone Player 100 is a single unit whose internal components consist of an internal power converter, wireless Internet router (Ethernet) card, and an audio preamplifier. This wireless, multi-room music system distributes, plays, and amplifies digital music and Internet radio so that it can be played throughout a home or other type of building. The term Internet radio applies to streaming digital files which are transmitted along a wired or wireless Internet network; it is not actual satellite radio transmission or radio broadcasting. The digital files are played from storage on a personal computer or network storage facilities.

As many as thirty-two (32) ZonePlayers may be deployed across a mesh wireless Internet network, which can all be operated and manipulated with the use of a single handheld controller. A system user can play the same digital sound files in different rooms or play different digital sound files in different rooms from storage on a personal computer or network storage facilities. To play music in thirty-two (32) zones, a total of thirty-two (32) ZonePlayers would be needed.

The Sonos system works with a high speed Internet connection and router. The initial ZP 100 ZonePlayer 100 is connected to a personal computer (PC) and to a broadband router. Only one ZP 100 ZonePlayer 100 is required in a network to make such a connection. Thereafter, additional ZP units, such as the ZP 100 or ZP 80 models can be connected wirelessly to the network for a transmission and reception network of up to thirty-two (32) units.

A PC is used to hold the basic software for the Sonos network and to transmit the same to the wired broadband router. The system operator, using the handheld controller, will determine which digital files they wish to play on a particular device located in a particular room or location. The Sonos network software will determine the most efficient path in the network to direct the files to another ZP unit. The Sonos System is not capable of broadcasting to a wide range or users. It is a point-to-point device. Outsiders cannot listen in to the digital sound files or Internet radio file streams because the proprietary Sonos software is designed to prevent intrusion by persons outside the Sonos network.

The applicable subheading for the ZP 100 ZonePlayer 100 will be 8517.62.0050, 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): 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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