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NY L88589




November 18, 2005

CLA-2-85:RR:NC:MM:109 L88589

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.19.8080

Mr. Stephen W. Marlow
Manager, Regulatory Services
FedEx Trade Networks
Transport & Brokerage, Inc.
205 West Service Road
Champlain, NY 12919

RE: The tariff classification of a 5220 IP Phone (Dual Mode), 5230 IP Phone, 5240 IP Phone from China and a Superconsole 1000 and a Superconsole 2000 from Canada

Dear Mr. Marlow:

In your letter dated October 27, 2005, you requested a tariff classification ruling, on behalf of your client Mitel Networks, Inc.

This ruling pertains to the classification of five items. They are a 5220 IP Phone (Dual Mode), a 5230 IP Phone, a 5240 IP Phone, a Superconsole 1000 and a Superconsole 2000.

The 5220 IP Phone (Dual Mode) is a multi-line IP (Internet Protocol) speakerphone with full duplex handsfree operation. It has user-programmable access to advanced voice communications, IP-based applications and services. The 5220 IP Phone supports a full lineup of IP peripherals, such as programmable key modules (PKMs), conference units and line interface modules, for broadened access to IP applications right at the user’s desktop. This enhanced multi-line telephone has additional features, such as speed dialing, call hold, transfer, and forwarding, and programmable multi-functional keys.

The 5230 IP Phone is a multi-line handsfree IP phone with PDS integration for desktop access and location transparency. It provides for seamless access to PDA applications, such as their contacts database. The 5230 IP Phone enables users to transfer their personal profile and preferences to any 5230 IP Phone on the network by dropping their PDA into the docking cradle. This enhanced multi-line telephone has additional features, such as a built in speakerphone, speed dialing, call hold, transfer, and forwarding, and programmable multi-functional keys.

The 5240 IP Phone is a web-enabled, multi-line support, dual port IP Phone with a large backlit display that delivers one-touch access to web-based applications and services, including HTML and XML browsing. It is targeted towards users who require real-time access to advanced voice and multimedia applications and services. It provides users with advanced telephony functionality, support for infrared PDA integration, as well as one-touch access to fully personalized IP applications and services. This enhanced multi-line telephone has additional features, such as handsfree operation, personal/corporate directories, visual voice mail, nine programmable feature keys, off hook voice announcement capability, and on hook dial.

The Superconsole 1000 is a multi-line, multi-use console for Mitel SX-200® and SX-2000 PBX business telephone systems. It can be used as an attendant console, a sub-attendant position for departments or workgroups, and as a back-up answering position. This enhanced multi-line telephone has additional features, such as two integrated headset/handset jacks, combination of softkeys and fixed function keys including up to nine line keys with descriptive labels, programmable macro keys, eight call hold keys, and access to integrated Mitel hospitality functionality including room status and automatic wake-up call.

The Superconsole 2000 is a multi-line advanced PC-based attendant console and PBX administration application for the Mitel SX-2000 PBX enterprise telephone system. It features a specialized keypad and an intuitive, PC-based user interface for smooth and efficient call handling. This enhanced multi-line telephone has additional features, such as specialized telephony keypad for dialing, call processing and access to PBX features, screen-based call status and call handling prompts, dual handset/headset jacks, one-button access to programmable key functions, single key transfer to voice mail, call answering priority, and on-screen scratch pad window for notes and messaging taking.

The applicable subheading for the 5220 IP Phone (Dual Mode), 5230 IP Phone, and 5240 IP Phone will be 8517.19.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for ““Electrical apparatus for line telephony or line telegraphy including telephone sets with cordless handsetsTelephone sets; videophones: Other: Other: Multiline (including key, call director and consoles).” The rate of duty will be free.

The applicable subheading for the Superconsole 1000 and Superconsole 2000 will be 8517.19.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy including telephone sets with cordless handsetsTelephone sets; videophones: Other: Other: Multiline (including key, call director and consoles).” 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 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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