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NY M80366




March 7, 2006

CLA-2-85RR:NC:MM:109 M80366

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.50.9000

Ms. April L. Dyar
WW Trade Compliance Specialist
Scientific-Atlanta, Incorporated
5030 Sugarloaf Parkway
Lawrenceville, GA 30044

RE: The tariff classification of a family of TAP products from China

Dear Ms. Dyar:

In your letter dated January 31, 2006, you requested a tariff classification ruling.

The merchandise subject to this ruling is identified in your letter as a family of TAP products. They consist of a 1 GHz TAP (2,4, or 8-way), a Surge-Gap TAP (2,4, or 8-way), and an Addressable Stretch TAP (single tier/dual tier). These TAP items are devices that are part of the transmission path within the hybrid fiber coax (HDC) network for the routing of integrated services of voice, video, and data. The signals traveling within the HDC network is either analog or digital via either fiber or coax. There are no optical elements in these TAP products.

Your letter states that “TAP” is not an acronym for any telecommunication industry specific terminology. The name “TAP” is derived from the “functionality” of these products. And, although these devices perform the function of both coupling and splitting a single transmission path signal, their primary function is to “TAP” off of the main input signal from a coaxial input stream and split the one signal into multiple (equal level) coaxial outputs for transmission. These devices take the single output transmission signal of voice, video, and/or data and distributes it via two, four, or eight (2, 4, 8-way) connection ports allowing for multiple transmission distribution points off of the initial single input signal.

The 1 GHz TAP (2,4, or 8-way) has been designed to provide the higher current, power passing capability required for telephony and other interactive multimedia services within HDC networks. Its modular design allows changing of the its board and cover without removal of its housing from the cable connection.

The Surge-Gap TAP (2,4, or 8-way) offers IEEE compliant 6kV surge protection surpassing the industry standard of 1kV of protection, and offers improved protection against voltage transient in lightning strike areas and locations within unreliable power networks. It provides improved reliability of cable service and expands the entertainment and information that cable providers can deliver to their subscribers keeping cable service intact by enabling cable technicians to pull the TAP’s faceplate and perform maintenance without interrupting service to subscribers located downstream.

The single tier Addressable Stretch TAP allows broadband network operators to significantly reduce recurring operational expenses associated with customer disconnects and reconnects. Instead of rolling trucks to accomplish those tasks, the single tier Addressable Stretch TAP performs them on command from a centrally located system controller, which is integrated into the customer billing system. Its faceplate resides in a field proven 9-inch coated housing. The faceplate is backwards compatible with Scientific Atlanta’s previously released 9-inch Multimedia Stretch TAP and Addressable Multimedia Stretch TAP housings. The housing contains the connection beam AC/RF bypass switch to keep downstream customers active whenever the TAP faceplate is removed. The TAP has a Local Craft Serial Interface (LCSI) port that can be connected to a laptop computer using a custom cable that connects to a 9 pin serial interface. The LSCI allows local monitoring of TAP port status.

The dual tier Addressable Stretch TAP allows broadband network operators to reduce certain recurring operational expenses associated with customer disconnects, reconnects, and basic service tier changes. Instead of rolling trucks to accomplish those tasks, the dual tier Addressable Stretch TAP performs them on command from a centrally located system controller, which is integrated into the customer billing system. Maximum benefit is achieved when used in high churn areas such as multiple dwelling units (MDUs) seasonal market locations, and areas that have high levels of signal theft. The dual tier Addressable Stretch TAP faceplate resides in a field 9–inch coated housing. The faceplate is backwards compatible with Scientific Atlanta’s previously released 9-inch Multimedia Stretch TAP and Addressable Multimedia Stretch TAP housings. The housing contains the connection beam AC/RF bypass switch to keep downstream customers active whenever the TAP faceplate is removed. The TAP has a Local Craft Serial Interface (LCSI) port that can be connected to a laptop computer using a custom cable that connects a 9 pin serial interface. The LCSI allows local monitoring of TAP port status.

These TAP products will enable your cable operator customer base to expand their video servicing to include data and voice/telephony. Additionally, the family of TAP products will enable your company to gain a new customer base of telecommunications providers who are expanding their service options to provide video within their primarily data/voice markets.

The applicable subheading for the family of TAP products (a 1 GHz TAP (2,4, or 8-way), a Surge-Gap TAP (2,4, or 8-way), and an Addressable Stretch TAP (single tier/dual tier) will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTSUS), 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.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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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