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NY L88591





November 21, 2005

CLA-2-85:RR:NC:MM:109 L88591

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.50.9000

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 VCON conference bridge 2000, media Xchange manager, and a ViGO™ from Israel

Dear Mr. Marlow:

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

The ruling pertains to the classification of three items. They are a VCON conference bridge 2000, media Xchange manager, and a ViGO™.

The VCON conference bridge 2000 (VCB 2000) is an apparatus that combines traditional multipoint videoconferencing and streaming into a single solution. This allows interactive conferences to be broadcasted to hundreds or thousands of passive participants via bandwidth-efficient multicasting. In addition to common I MCU features, like voice-activated switching and continuous presence, VCB 2000 also supports more advanced features like chair control, cascading and wide-band audio with transcoding. As an embedded gatekeeper and remote management agent, the VCB 2000 is shipped as an integrated solution in a rack-mount engine. Its scalability up to 64 ports per server provides for expandability and investment protection.

The media Xchange manager (MXM) is at the heart of VCON’s integrated conferencing and collaboration solution. The architecture of MXM makes it effectively multiple products layered together in one solution, providing combined value for the network administrator and the end user. The management and administration layer provides the most value for the network administrator, who is responsible for the initial deployment and on-going support of the rich-media conferencing network. The video telephony features and integration with rich media applications provide the most benefit to the end-user community that is looking for user-friendly tools that enhance the effectiveness and efficiency in performing their job.

The ViGO™ is a compact personal videoconferencing appliance for both laptops and PCs offering business-quality audio and video. A small, lightweight unit with a USB interface, ViGO is simple to install and is very portable. Equipped with a hot-pluggable speaker tower and detachable camera, it has a variety of configurations. Its user-friendly interface combined with the smart one-touch ViGO button makes videoconferencing as easy as making a phone call. vPoint, the software used by Vigo, but which not a subject within this ruling, is also capable of running in software only modes when ViGO is not attached to the PC, providing even more flexibility.

The applicable subheading for the VCON conference bridge 2000, the media Xchange manager, and the ViGO™ will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “ Other apparatus for carrier-current line systems or for digital line systems: Other: Telegraphic: Other.” 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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