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NY L88592





November 21, 2005

CLA-2-85:RR:NC:MM:109 L88592

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.19.8070 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 SpectraLink NetLink e340 wireless telephone and a SpectraLink NetLink i640 wireless telephone from Mexico and IP-DECT solution wireless phone from Germany

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 three items. They are a SpectraLink NetLink e340 wireless telephone, a SpectraLink NetLink i640 wireless telephone, and an IP-DECT solution wireless phone.

The SpectraLink NetLink e340 wireless telephone is a lined multi-line telephone that was designed specifically for busy office environment. This compact wireless handset offers features and accessories that address the needs of a variety of businesses. It communicates using 802.11b and appears to the Mitel ICP as a wired, multi-line display set similar to Mitel’s powerful 5220 IP desktop. It supports calling party, name display, message waiting indication, multiple line appearances and other advanced features that are delivered to the mobile user throughout the workplace. This enhanced multi-line telephone has additional features, such as vibrating, visual, and audio ring signals, headset support, and text message/alert support.

The SpectraLink NetLink i640 wireless telephone is a lined multi-line telephone that was designed specifically for commercial applications. This wireless handset sets the industry standard for durability, functionality, maximum comfort and ease of use making it ideal for healthcare, retail, and industrial environments. It communicates using 802.11b and appears to the Mitel ICP as a wired, multi-line display set similar to Mitel’s powerful 5220 IP desktop. It supports calling party, name display, message waiting indication, multiple line appearances and other advanced features that are delivered to the mobile user throughout the workplace. Push-to-talk functionality is also available for broadcast communication between employees, eliminating the need for two-way radios or walkie-talkies. This enhanced multi-line telephone has additional features, such as vibrating, visual, and audio ring signals, headset support, and text message/alert support.

The IP-DECT solution wireless phone is a lined single line telephone that provides high functionality wireless phones with easy access to telephony and messaging services. It enables businesses to extend the reach of their voice network to improve customer service. IP-DECT delivers high-quality wireless voice with stylish, easy to use, high functionality handsets over a proven, easy to deploy wireless infrastructure that is connected to the LAN. It can deliver fro one to 512 handsets per installation via up to 256 LAN connected radio base stations delivering comprehensive voice radio coverage. This enhanced single line telephone has additional features, such as voice mail access with message waiting display, hands-free, headset working, ringing melodies, and vibrate modes, an SOS key, and a personal and system phone book.

The applicable subheading for the IP-DECT solution wireless phone will be 8517.19.8070, 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; Single line: Other: Other” The rate of duty will be free.

The applicable subheading for the SpectraLink NetLink e340 wireless Telephone and the SpectraLink NetLink i640 wireless telephone 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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