CLA-2-85:OT:RR:NC:N1:109
Ms. Maria E. Celis
Neville Peterson LLP
Counsellors at Law
17 State Street, 19th Floor
New York, NY 10004
RE: The tariff classification of Sonos ZonePlayer S5 Router from an unspecified country
Dear Ms. Celis:
In your letter dated November 2, 1009 you requested a tariff classification ruling on behalf of your client, Sonos, Inc.
The merchandise subject to this ruling is ZonePlayer S5 Router. It is one of the components of the Sonos digital media network system. The ZonePlayer S5 Router is similar in construction and function to the ZP 100 ZonePlayer ruled on in New York Ruling N021357 and the ZP 80 ZonePlayer ruled on in New York Ruling N021358. With the use of a Sonos ZonePlayer installed in various rooms, a system user can play the same digital sound files in different rooms or play different digital sound files in different rooms. As many as thirty-two (32) ZonePlayers may be deployed across the network, which is a mesh wireless Internet network. All the ZonePlayers may be operated and manipulated with the use of a single handheld controller, which is not imported with the ZonePlayer and not the subject of this ruling. The controller can be purchased separately by the user.
The principal components of the ZonePlayer are a power source and wireless network card. In addition, it incorporates a digital to analog converter, which allows digital files to be converted to analog signals and played through the owner’s existing sound equipment radios, home theatres, and the like. The ZonePlayer S50 also incorporates 5 Class-D amplifiers and five driver speaker system; 2 tweeters, 2 3” mid-range drivers, and a 3.5” woofer.
The Sonos system allows the user to wirelessly stream data, including digital music files and related metadata in multiple rooms. It allows files to be played from storage on a personal computer or network storage facilities, and also play songs from select music services ripping, downloading, or personal computer interaction required. The Sonos system requires a wired Ethernet connection to a router and typically connects to a high speed Internet connection via a personal computer. The initial ZonePlayer S5 in the system is connected to a broadband router and computer software must be installed for the connection to work. Thus, the ZonePlayer is merely a machine for reception, conversion and transmission of voice or other data. After the initial ZonePlayer is hooked up to a router or network, additional ZonePlayers may be installed wirelessly in up to 32 different rooms creating a network.
The user creates the Sonos network by installing the first ZonePlayer in the network into a wired Ethernet connection and activating a desktop configuration program, and a handheld wireless controller (purchased separately). The ZonePlayer and controller contain wireless network cards that establish their own secure wireless mesh network. Any additional installed ZonePlayers will automatically become part of the wireless mesh network. By “wirelessly” it is meant that after the initial ZonePlayer is connected to a router and network, additional ZonePlayers may be installed without a wired connection to the network. The ZonePlayers may be connected by wire to loud speakers, which plug directly into the device.
The devices employ a SonosNet software solution, a secured AES encrypted peer-to-peer wireless mesh network that streams digital music files wirelessly to other ZonePlayers, avoiding sources of wireless interference, which ensure synchronous music playback. In a Sonos network, the same digital music file may be played in multiple rooms or zones without echoes or delays (multi-zone synchronous playback). Alternatively, the system can play different digital sound files simultaneously in different zones (multi-stream playback). The ZonePlayer is a point-to-point device. Outsiders cannot listen in to the audio files of Internet webstreams because the proprietary Sonos software is designed to prevent intrusion by persons outside the Sonos network.
Through the wireless controller, which is imported separately, a user can call up digital music files from a number of sources. The Sonos system also allows a user to source sound files from up to 16 PCs or Mac computers connected to the network. The controller also contains pre-set programming, which allows the user to access streaming audio files from approximately 25,000 radio stations Internet webstreams. The stream audio files are not actual satellite radio transmission or radio broadcasting.
The applicable subheading for the Sonos ZonePlayer S5 Router will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: 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
National Commodity Specialist Division