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NY L88593




November 29, 2005

CLA-2-85:RR:NC:MM:109 L88593

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 an SX-200 CX Controller, SX-200 IP Node, SX-200 ISDN BRI/PRI, SX-200 E1 R2 Signaling Solutions, and 3600 Hosted Key System from Canada

Dear Mr. Marlow:

In your letter dated October 28, 2005, you requested a tariff classification ruling, on behalf of your client Mitel Networks, Inc.

The ruling pertains to the classification of five items. They are an SX-200 CX Controller, SX-200 IP Node, SX-200 ISDN BRI/PRI, SX-200 E1 R2 Signaling Solutions, and 3600 Hosted Key System.

The SX-200 CX Controller is an Integrated Communications Platform (ICP), which delivers communication features and applications in a small business package. This all in one solution includes an embedded powered and managed 16 port layer 2 switch, Internet gateway and firewall. It also provides an extensive PBX/Key system feature set. Applications like standard unified messaging, teleworking, feature transparency over IP networking, automatic call distribution (ACD), in addition to other features, enable small businesses to enhance their customer service, employee productivity, and reduce capital expenditures and operating costs.

The SX-200 IP Node is a platform designed to provide next generation Internet Protocol (IP) functionality with minimal effort and maximum investment protection. It provides customers with point-to-multi-point transparent networking. The SX-200 IP Node supports IP devices such as the Mitel Networks 5201, 5215, 5220, and MiNet wireless IP sets. Remote teleworkers using IP sets connected remotely to the SX-200 IP Node will be able to utilize the same features and services as if they were located in main office-completely transparent to the outside caller.

The SX-200 ISDN BRI/PRI supports voice and data communications over ISDN, plus a range of advanced network services and capabilities that enhance user productivity, improve communications management, and enable computer telephony integration (CTI) applications, such as calling party name and number, called line number, voice and data calls, and line side and trunk side connectivity. The SX-200 with BRI/PRI can control and manage any ISDN PRI/BRI compatible devices, like routers, inverse multiplexers, gateways, video equipment, and remote access services, to support essential and advanced data services.

The SX-200 E1 R2 Signaling Solutions enables analog-to-digital migration. It enables the conversion from analog trunks to digital trunks. The migration from analog to digital equipment, when passing voice and data traffic over a Private Branch Exchange (PBX) network to a Public Switched Telephone Network (PSTN), yields a significant reduction in the number of transport lines required in networks that have many analog trunks already in use, resulting in a cost savings.

The 3600 Hosted Key System is a multi-tenant software suite that allows carriers to provide hosted voice and data over Internet Protocol (VoIP) telephony services for small businesses in the form of a virtual key system. It is designed to allow for hosting of thousands of small businesses on a single network. The 3600 Hosted Key System is hosted in the carrier’s network and delivers key system functionality to the small business via broadband access. It provides features such as call park, three way calling, transfer, and hotdesking. The web-based management solution uses web interface that administrators and end-users can access to personalize the company’s telephone system.

The applicable subheading for the SX-200 CX Controller, SX-200 IP Node, SX-200 ISDN BRI/PRI, SX-200 E1 R2 Signaling Solutions, and 3600 Hosted Key System 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 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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