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NY N021949

February 7, 2008



TARIFF NO.: 8517.62.0050

Mr. Christos Linardakis
Braumiller Schulz LLP
120 Oakbrook Ctr., Suite 416
Oak Brook, IL 60523

RE: The tariff classification of Service Concentration Switches (SCS) from China

Dear Mr. Linardakis:

In your letter dated December 30, 2007 you requested a tariff classification ruling, on behalf of your client World Wide Packets, Inc.

The merchandise subject to this ruling is Service Concentration Switches (SCS). They are identified in your letter as Model Numbers LEAC-0327AB, LEAC-0427AB, LESC-0450AB, LESC-0470AB, LESC-0590AB. The SCS series is a family of compact Ethernet switches that deliver advanced carrier-class services to residential and/or business subscribers. These switches can be configured with copper and/or fiber physical Ethernet interfaces that operate at a variety of speeds, including 10/100Mbps, 10/100/1000Mbps, 1000Mbps (1Gbps), and 10Gps. All SCSs operate under LE-OS software operating systems.

The SCS products support Service Provider Carrier Ethernet Access and Aggregation Networks. They deliver or aggregate a wide variety of Ethernet Data/Voice/Video connectivity services including VLANs (Virtual Local Area Networks), Ethernet Private Lines, and Ethernet Private LANs. These services can be delivered on a per-port, per-service types, or per-virtual interface basis, or any combination of the above to both business and residential customers. SCS switches are available up to either 24 10/100/1000Mbps Ethernet ports or 48 1000Mbps Ethernet ports and up to 4 10Gbps Ethernet ports. The SCS products are generally utilized as aggregation devices to concentrate and integrate Ethernet traffic from WWP SDS (Service Delivery Switches).

The applicable subheading for the Service Concentration Switches (SCS), Model Numbers, LEAC-0327AB, LEAC-0427AB, LESC-0450AB, LESC-0470AB, LESC-0590AB, 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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