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NY 885328

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May 19, 1993

CLA-2-85:S:N:N1:109 885328

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.40.7000

Mr. Michael Koebel
Mentor Engineering Inc.
#503,609 -14th Street NW
Calgary, Alberta T2N 2A1

RE: The tariff classification of a Computer Access Security System from Canada

Dear Mr. Koebel:

In your letter dated April 14, 1993, you requested a tariff classification ruling.

The merchandise is described in the submitted literature as a CASS which is a Computer Access Security System. The system is a security modem which provides both standard telephone modem features as well as security features designed to restrict access to authorized users. It implements security by the use of user callback. After a caller connects to the CASS unit, he will be prompted for a password. The caller is allowed three attempts to enter a correct password. If successful, the CASS unit will disconnect the call and originate a call to a telephone number associated with the user's password.
However, even if an unauthorized user knows the correct password, he must be at the proper location in order to access the computer post. The CASS unit is programmed by a system adninistrator. the system administrator controls the user passwords, callback numbers, status' and security levels. Access to a CASS programming session is controlled by 3 master words and a callback procedure. The CASS unit will perform a callback sequence to the system administrator after 3 passwords have been entered. The system administrator's callback number is fixed and cannot be reprogrammed by any user. THe master passwords can be changed by the system administrator periodically to prevent unauthorized access from the system administrator's terminal. All the important events are recorded in an event log which can be transmitted to a remote site daily, when full or in demand. The event log will show all accesss attempts and can aid in the detection in systematic unauthorized access attempts. Speed translation, command screening , port monitoring, banner disable and diagnostics are a few of the many features that the CASS has to offer its users.
The CASS is used by telephone companies to provide secure access to their telephone switching equipment. It protects against hackers fom gaining access to the switching equipment and setting up free telephone lines, destroying billing information or doing other damage. The system does not appear to be capable of transmitting voice over the wires. It is used for the transmission between two points of symbols representing written messages, images or other data.

The applicable subheading for the Computer Access Security System will be 8517.40.7000, Harmonized Tariff Schedule of the United States (HTS), which provides for "[ Other apparatus for carrier-current line systems: other telegraphic modems] ." The rate of duty will be 4.7 percent ad valorem.

Goods classifiable under subheading 8517.40.7000, HTS, which have originated in the territory of Canada, will be entitled to a free rate of duty under the United States - Canada Free Trade Agreement (FTA) upon compliance with all applicable regulations.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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