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NY R00089




February 26, 2004

CLA-2-85:RR:NC:MM:109 R00089

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.90.3400

Mr. Chad Charbonneau
Catena Networks Inc.
307 Legget Drive
Kanata, Ont K2K 3C8

RE: The tariff classification of circuit card assemblies for Catena Networks CNX-5 Broadband DSL System from the United States

Dear Mr. Charbonneau:

In your letter dated January 19, 2004, you requested a tariff classification ruling on behalf of Catena Networks, 3131 RDU Center Drive, Morrisville, NC 27560.

This ruling provides for the classification of four different circuit card assemblies, used specifically in Catena Networks’ CNX-5 Broadband DSL System. The CNX-5 provides the data transmission and voice interface between end users and the central office. The circuit card assemblies are parts of telecommunications apparatus and each contains a printed circuit assembly. The name of each circuit card assembly is the Enhanced Channel Unit (ECU), the Enhanced Channel Test Unit (ECTU), the Fiber Enhanced Channel Test Unit (Fiber ECTU), and the DS3 WAN Card.

The Enhanced Channel Unit (ECU) incorporates a printed circuit assembly. It is a CNX-5 subscriber service card, employing integrated POTS and ADSL line interface technology. The ECU replaces the legacy POTS channel unit to provide two standards-compliant ports of POTS and ADSL. When inserted into the SLC-5 chassis, the ECU operates as a regular SLC-5 POTS channel unit, complying with relevant TR-57 voice standards.

The Enhanced Channel Test Unit (ECTU) incorporates a printed circuit assembly. It replaces the legacy Channel Test Unit (CTU) to support DSL services on the SLC-5. The ECTU retains the legacy CTU functionality and adds DSLAM capabilities to the SLC-5. The CNX-5 utilizes existing system resources on the SLC-5 to communicate between ECU cards and the ECTU. This architecture simplifies DSL deployment by eliminating the need for POTS splitters and external cabling. In the event of an AC power failure, the ECTU can disable DSL to preserve power for POTS services. Upon restoration of AC power, the system will automatically re-enable DSL service.

The Fiber Enhanced Channel Test Unit (Fiber ECTU) and the DS3 WAN Card both contain a printed circuit assembly. The Fiber ECTU and DS3 WAN Card are companion cards in the CNX-5 DS3 configuration, which control all ATM switching and traffic management. Together the cards aggregate traffic from multiple CNX-5s and provide a DS3 network interface. One fiber ECTU is inserted into each dual channel bank, and a single DS3 WAN card provides the DS3 network interface for the multiple CNX-5s. The DS3 WAN card acts as the system manager, monitoring the integrity of the interconnections and managing the overall ATM traffic. In addition, the DS3 WAN Card monitors for loss of AC power and can disable DSL service, as required, to preserve lifeline POTS service.

The applicable subheading for the Enhanced Channel Unit (ECU), the Enhanced Channel Test Unit (ECTU), the Fiber Enhanced Channel Test Unit (Fiber ECTU), and the DS3 WAN Card will be 8517.90.3400, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy; parts thereof: Parts: Other parts, incorporating printed circuit assemblies”. The 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 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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