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NY N021950

February 8, 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 a LighteningEdge Operation System (LE-OS) 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., hereafter WWP.

The merchandise subject to this ruling is a LighteningEdge Operation System (LE-OS), a software management system. The LE-OS works primarily with WWP’s Ethernet Service Manager (ESM). The LE-OS software is imbedded into hardware and runs in tandem with ESM.

LE-OS is a carrier-grade, automated service activation, creation and management platform for managing a service provider’s “LightningEdge” access and aggregation telephony network. LE-OS will allow a client to manage and track certain information in their telecommunications network, including performance monitoring, identifying faults, providing carrier scalability & reliability, including supporting clustered servers, replicated databases for server load-balancing, server clustering, and remote management. LE-OS works for both Local Area Network (LAN) and Wide Area Network (WAN) devices, and allows carriers to manage their networks. The LE-OS software and network management platform is available for use by small utilities, municipalities, and independent operating carrier (IOC) networks to the large, geographically dispersed networks of Tier 1 service providers and multiple service operators (MSOs).

The applicable subheading for the LighteningEdge Operation System (LE-OS) 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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