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NY N021358

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 80 ZonePlayer 80 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 80 ZonePlayer 80. The ZP 80 Zone Player 80 is a single unit whose internal components consist of an internal power converter and wireless Internet router (Ethernet) card. This wireless device enables the user to play digital music and Internet radio on various types of audio equipment throughout a home or other type of building. The term Internet radio applies to streaming digital files that 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. The ZP 80 ZonePlayer 80 is a wireless router in a Sonos network. It does not need to be connected to a personal computer in order to function.

The Sonos system works with a high speed Internet connection and router. Initially, a ZP 100 ZonePlayer 100, the subject of New York Ruling N021357, 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 80, the subject of this ruling, is connected wirelessly to the network for a transmission and reception network of up to thirty-two (32) units.

The ZP 80 ZonePlayer 80 can interact with the ZP 100 ZonePlayer 100 by wirelessly receiving digital files transmitted from that unit. If there are multiple ZP Zone Players in a system, each one will interact wirelessly with the closes Zone Player within the wireless network, so that data can be transmitted wireless with the least chance of interference. The system operator, using a handheld controller, which is imported with the ZP 100 ZonePlayer 100 ruled on in New York Ruling N021357, 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 the ZP 80 ZonePlayer 80, which will convert the signals to analog form and play the music or sound file. The digital files may be routed through a number of intermediate Zone Players until it reaches the Zone Player nearest to the audio device on which the files will be played, i.e. stereo, home theatre, etc. 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 80 ZonePlayer 80 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 M. Hackett at 646-733-3015.


Robert B. Swierupski

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