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NY F89831




August 15, 2000

CLA-2-85:RR:NC:MM:109 F89831

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.30.1500

Ms. Laura Guay
Livingston International, Inc.
100 Walnut Street
Champlain, NY 12919

RE: The tariff classification of SmartLoop 1600 from Canada

Dear Ms. Guay:

In your letter dated July 12, 2000, you requested a tariff classification ruling on behalf of Simpler Network, 555 Dr Frederick Phillips Blvd, Ste 21, St Laurent, PQ

Simpler Networks’ SmartLoop 1600, is a Loop Management System (LMS) that enables network managers to take total control of the copper local loop infrastructure. SmartLoop 1600 extends control to network elements and the physical layer of the network. In other words, the feeder, distribution, and drop cables that make up the so-called “last mile” of the telecommunications network.

SmartLoop 1600 has an innovative matrix switch platform that sits at the demarc point of a collocation cage. It is designed to allow universal access to any service. The SmartLoop 1600 switch is completely protocol-transparent and sits in front of any actual or future access gear that delivers services over the local copper loop.

Simpler Networks’ SmartLoop 1600 software and API allow easy control of any number of SmartLoop 1600 frames from virtually any point or application on the network. Its open management architecture integrates into virtually any OSS and scales from managing a single SmartLoop 1600 frame, to managing thousands in a network-wide deployment. Its huge, any-to-any, non blocking switching capabilities mean that circuits can be cross-connected, disconnected, and moved freely without the need to manually re-arrange circuit connections. Its open management architecture also enables such forward-looking initiatives as automated flow-through provisioning and the dim lights central office.

SmartLoop 1600’s testing & monitoring features empower technicians to completely qualify and test circuits running from the central office to the customer premise. It also allows proactive Automatic Loop Test (ALT) scans and cable patterning of faults. If the loop fails or is subjected to an excessive level of noise, which may compromise the level of service being offered, the system will report the failure and allow for a repair to be executed. Its self-healing feature can even switch the customer to another loop or equipment port while the tests are run, ensuring that the customer remains up and running at all times.

The applicable subheading for the SmartLoop 1600 will be 8517.30.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for “Telephonic or telegraphic switching apparatus: Telephonic switching apparatus: Central office switching apparatus.” The general rate of duty will be free.

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 212-637-7048.

Sincerely,

Robert B. Swierupski
Director,

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