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NY R01515




March 21, 2005

CLA-2-85:RR:NC:N1:109 R01515

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.50.9000

Mr. Michael E. Roll
Pisani & Roll
1875 Century Park East
Suite 600
Los Angeles, CA 90067

RE: The tariff classification of an “Alcatel Light Manager - ” from an unspecified country

Dear Mr. Roll:

In your letter dated February 21, 2005 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of an “Alcatel Light Manager - .”

The descriptive literature submitted states that the “Alcatel Light Manager - ” is telecommunications equipment, which offers a transmission system providing very high bandwidth capacity through Dense Wavelength Division Multiplexing (DWDM) technology. The system can provide up to 96 x 10 Gbit/s operating channels with a 0 to 100% add/drop capability to the Optical Add/Drop Multiplexers (OADM’s), which enable selective access to the needed channels and non-regenerative pass-through for the others.

The “Alcatel Light Manager - ” manages the integrity, quality, receipt and transmission of telecommunication aggregate data (speech & data) within the telecommunication system and is capable of providing transmission in a terrestrial environment across all the distance classes; Long Haul (LH), Very Long Haul (VLH), and Ultra Long Haul (ULH). The “Alcatel Light Manager - ” is of modular construction so that an installation provided with less than the maximum number of channels can be upgraded later by adding more channels with minimum disturbance to those already in service.

The “Alcatel Light Manager - ” is a hybrid of optical, electronic, and mechanical systems that form part of a submarine telecommunication system for use in transmission of aggregate data (speech & data). The “Alcatel Light Manager - ” is of an ASN generic design and includes features that allow the configuration of the “Alcatel Light Manager - ” to suit a given system.

The applicable subheading for the “Alcatel Light Manager - ” 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 Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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