POLLICHINO, STEVEN Good afternoon, everybody, and welcome to this webinar.
POLLICHINO, STEVEN My name is Steve Pollicino.
POLLICHINO, STEVEN I am and I asked 209.
POLLICHINO, STEVEN Today we'll be talking about heading 8517.
POLLICHINO, STEVEN We had reached out to our.
POLLICHINO, STEVEN Failed import specialists and the seed to see
what topics they want to cover wanted to covered.
POLLICHINO, STEVEN And a request was made that we cover heading 8517 again
because I did it last year.
POLLICHINO, STEVEN Umm, but it's still our hottest.
My hottest heading gets the most action, gets the most ruling requests.
I think it's the heading that our field import specialist deal the most with.
POLLICHINO, STEVEN So that explains to me what this system does,
what this device does within the environment in which it is installed.
POLLICHINO, STEVEN Then I would ask, can that system that network
that environment operate if you remove this system
and this case the answer is yes.
All this was doing was adding a layer of protection,
but the transmission reception function did not rely on this device.
POLLICHINO, STEVEN So while it looked
like a reception transmission apparatus, now while it did in fact receive
and transmit, it was doing a function other than that.
POLLICHINO, STEVEN Umm.
POLLICHINO, STEVEN Which held us, which allowed us
to classify it outside of 8517.
So we really not have to know.
POLLICHINO, STEVEN What item is what system it works within?
POLLICHINO, STEVEN What components are within it?
POLLICHINO, STEVEN To to arrive at a classification
so we don't classify by name.
POLLICHINO, STEVEN Because so many things are called the same thing,
and each version of that may be different, you can add
or remove one functionality to a machine, and classification may change.
POLLICHINO, STEVEN Great.
POLLICHINO, STEVEN Once again, because I told you this last year,
February 2007 was a big year for us in the electronics line because of
a lot of merchandise moved around.
POLLICHINO, STEVEN So back in I gold days, Chapter 84
and I'm heading 8471, which deals with computers 80P machines used
to cover networking equipment.
POLLICHINO, STEVEN Umm hubs.
POLLICHINO, STEVEN Maybe routers I don't remember,
but you should cover a lot of stuff.
POLLICHINO, STEVEN Then 2007, they wrapped up and put into 8517.
POLLICHINO, STEVEN The same with 8525.
That's the heading for Umm, Radio, broadcast and TV reception type stuff.
POLLICHINO, STEVEN That also used to do telecommunication.
POLLICHINO, STEVEN Products.
POLLICHINO, STEVEN In 2007, they took all of that and they put it into 8517.
POLLICHINO, STEVEN So the problem is you can go
into cross cross is our rulings database and you can get to you online.
POLLICHINO, STEVEN By when I'm out on a train
and I'm doing research, I just go to Google
and I put down CBP decisions ruling module and it takes me
to see p.gov right into with across databases.
POLLICHINO, STEVEN If you are an external customer.
POLLICHINO, STEVEN So it crosses a database of customs rulings,
both the rulings we do here at the national Commodity Specialist division
and those rulings that are headquarters partners do.
POLLICHINO, STEVEN So if you go in and you look up a transmission device
or a hub for instance.
POLLICHINO, STEVEN Might have a whole on your desk
where you can connect many USB devices to your computer.
Your computer may have one hub, one USB port, but this allows you now
to have five USB ports, and you can plug all your toys into it
into your computer.
So in the old days that might have been in 8471 or 8473, I'm not sure.
Now it's an 8517, but if you go into cross
and you look at rulings before 2007.
POLLICHINO, STEVEN Chances are you're gonna see that the items classified
in 8471 or 8473, you may look at certain transmission delays
and see that the classified in 8525, whereas now they're done in 8517.
POLLICHINO, STEVEN Problem with cross is when something like that happens
when a tariff change happens.
POLLICHINO, STEVEN Nobody goes into cross or is not possible till.
POLLICHINO, STEVEN Going to cross and flag those older rulings as revoked.
POLLICHINO, STEVEN Umm, so we call those rulings revoked
by operation of law.
POLLICHINO, STEVEN They're not slagged.
POLLICHINO, STEVEN When you search and cross by commodity,
commodity product name, you could put down transmitter.
POLLICHINO, STEVEN And it'll bring you up a bunch of transmitter rulings.
POLLICHINO, STEVEN But I do first is sort them the newest first.
POLLICHINO, STEVEN Because I know anything before 2007,
I'm not really all that interested in.
Yes, if it's an issue, I'll look at those rulings and the reasoning.
POLLICHINO, STEVEN But there's enough rulings after 2007.
POLLICHINO, STEVEN To keep me occupied.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN So then you find a ruling.
You have a ruling number, either either an number or an each number.
If it's a headquarters ruling.
POLLICHINO, STEVEN What you do then is you take that ruling number
that you're interested in and put that back into cross and search it.
POLLICHINO, STEVEN So now.
POLLICHINO, STEVEN A bunch of rulings will come up.
POLLICHINO, STEVEN That referenced that number, that reference,
that ruling number you found when you searched by commodity name.
POLLICHINO, STEVEN And you read those rulings.
POLLICHINO, STEVEN Especially, especially especially
at a headquarters rule names, because within there you might find something
that says and all such rulings that classify this product such and such,
and this tariff number are now revoked.
POLLICHINO, STEVEN So it's possible my point here is it's possible
to have a ruling in cross.
POLLICHINO, STEVEN That is revoked, usually by a headquarters rolling only
by a headquarters rolling.
POLLICHINO, STEVEN And yet, because of the limitations of cross,
the only way to know that is to do a search
by the ruling number you found and then read all the other rulings
that brings up.
POLLICHINO, STEVEN Especially especially why can't I say that way,
especially the headquarters ones,
because they're the only ones who can revoke or rolling?
POLLICHINO, STEVEN And that happened to me a while ago.
We found a great ruling uh fellow, and I asked myself back
when I did motors, it described exactly what we needed.
POLLICHINO, STEVEN But then I took it.
I put in the number and searched again and started reading
and I found the headquarters ruling.
POLLICHINO, STEVEN Which addressed the same issue, arrived
at a different classification and then said these rulings
and cited a bunch of rulings are now revoked by operation of law
by the facts of this issue.
POLLICHINO, STEVEN But yet your original ruling
was not flagged and cross.
POLLICHINO, STEVEN So be careful.
It's the point there.
POLLICHINO, STEVEN Price is a great system,
but it does have its limitations.
POLLICHINO, STEVEN So this year, too, in 2022, we've had a bunch
of changes, especially in the electronics line.
POLLICHINO, STEVEN So of course, today we'll be talking about the changes
that took place in 8517.
POLLICHINO, STEVEN And changes took place so again.
POLLICHINO, STEVEN When you find a ruling.
POLLICHINO, STEVEN You have to check it in real time.
Go to the current tariff and see if all those things hold still hold true.
POLLICHINO, STEVEN So the way I look at it,
heading 8517 is broken out into 3.
POLLICHINO, STEVEN Categories.
POLLICHINO, STEVEN The first one deals with telephone sets.
POLLICHINO, STEVEN Which is simple.
We all know what a telephone set is, or at least we know what a telephone is.
And.
POLLICHINO, STEVEN We're halfway there now.
The hardest part of classifying within the electronics line
is somebody gives us something and we don't know what this is.
POLLICHINO, STEVEN The printed Circuit Board assembly
that's inside some machine that something.
POLLICHINO, STEVEN That the request that doesn't even know what it does.
POLLICHINO, STEVEN Telephone to simple you know what a telephone is.
POLLICHINO, STEVEN The second category is my favorite
because it's cause most of my pain in the last couple of years.
Other apparatus for transmission or reception of voice images, other data.
POLLICHINO, STEVEN Including apparatus in a while.
So when when network that's in there because that stuff came from?
POLLICHINO, STEVEN The.
POLLICHINO, STEVEN 8471 type headings.
POLLICHINO, STEVEN Computer stuff that operates in a when I land,
I'm letting you know that now those computer devices,
computer networking devices are now classified and 8517.
POLLICHINO, STEVEN This subheading talks about items that transmit
and receive.
POLLICHINO, STEVEN And that should be it.
POLLICHINO, STEVEN That's where we should start.
If you read the ends on 8517 and the exemplars they give,
what the examples they give.
POLLICHINO, STEVEN They all commodities that they take a signal.
POLLICHINO, STEVEN Boost it converted and transmitted.
That's all they do.
They don't do anything else.
POLLICHINO, STEVEN Somewhere along the line.
POLLICHINO, STEVEN We've gone off.
POLLICHINO, STEVEN Track a little bit.
POLLICHINO, STEVEN Somehow somebody figured out that if you have.
POLLICHINO, STEVEN I wouldn't be surprised if you had a computer
that is so sophisticated that it can land a shuttle on Mars
and then it could measure air quality.
POLLICHINO, STEVEN And it could run the oxygen sensors
and oxygen generators, and then it could run the synthesizers
to make the astronauts food.
And it can measure the astronauts.
And then somebody said, well, you know.
POLLICHINO, STEVEN That's officated computers wireless.
They'd be like, OK, 8517 it goes there.
POLLICHINO, STEVEN That's what I'm seeing unbelievably, be ridiculous.
POLLICHINO, STEVEN Uh scenarios?
POLLICHINO, STEVEN Where I think other acts, aspects of the commodity
or very confusing and complicated and the best we could do sometimes is point
that in and go ohh look it's wireless.
Let's put it in 8517.
POLLICHINO, STEVEN That's not gonna happen anymore.
POLLICHINO, STEVEN 8517 has felt good set, transmit and receive.
POLLICHINO, STEVEN It's a consideration
when you have a complex machine
and that's one of the functions you have to consider it with.
The other functions of that machine, yes.
POLLICHINO, STEVEN In the vast majority of the cases I could think
of ability to transmit and receive wirelessly in a device
that has other functions.
POLLICHINO, STEVEN That had those same other functions way before things
went wireless.
It's still gonna be classified as that other.
POLLICHINO, STEVEN As the in the other headings.
POLLICHINO, STEVEN Umm, the wireless capability is going to be looked at
as a support function or a secondary function.
POLLICHINO, STEVEN So if you have sensors that are measuring.
POLLICHINO, STEVEN Temperature.
POLLICHINO, STEVEN Safety issues.
All this other stuff you have to realize in the past they were wired.
Those sensors were wired to a computer who ran analysis
and did whatever it had to do.
POLLICHINO, STEVEN So now they just took away the wire.
They took away the wire and they made those sensors wireless.
POLLICHINO, STEVEN Of God's sakes, that doesn't make
the whole thing now 8517, the wireless capability
is a secondary support function to the main function of Y.
You need this device and that's the sensor to measure and detect.
POLLICHINO, STEVEN So a lot of things I look at if I removed,
if I have a device like I'll use the sensor again.
UM.
POLLICHINO, STEVEN And I removed.
POLLICHINO, STEVEN The Bluetooth sort of wireless capability.
POLLICHINO, STEVEN I could still have that sensor hardwired
to the computer and theory and it would do the exact function
that is needed sensing.
POLLICHINO, STEVEN Measuring.
POLLICHINO, STEVEN As opposed to if I had this sensor
and I removed it sensing ability and just left the transmitter.
POLLICHINO, STEVEN I have nothing.
POLLICHINO, STEVEN My computer sitting there waiting for information.
Nothing can take the place of that measuring sensor portion.
POLLICHINO, STEVEN So that's how we look at it now.
POLLICHINO, STEVEN That in many cases the transmitting ability is secondary
to the real function of the device.
POLLICHINO, STEVEN The tariff headings
are tariff pavilions are meant to.
POLLICHINO, STEVEN Capture future.
POLLICHINO, STEVEN Generations of products, so as products change
and improve and advance as long as they still hold.
POLLICHINO, STEVEN The original functionality to measure to sense.
POLLICHINO, STEVEN Then adding a Bluetooth
or wireless capability does not change that, it just makes things easier.
POLLICHINO, STEVEN And more modernized.
And if you look up Bluetooth, it's just called Bluetooth
is called a wire replacement technology.
POLLICHINO, STEVEN So if in the past I did not classify this article
as a piece of wire, I'm not gonna classify it as a transmitter
when it does other things.
POLLICHINO, STEVEN Is that 100% always true?
No.
You have to consider everything have to consider all the functions
of the device.
POLLICHINO, STEVEN So here is a beautiful.
POLLICHINO, STEVEN Beautiful.
POLLICHINO, STEVEN Screen prints of 8517 tariff page.
So this is the first three categories.
POLLICHINO, STEVEN Now so the first category is telephones.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN Where's my little pointer it is.
POLLICHINO, STEVEN I do not like this pointer.
POLLICHINO, STEVEN So the the heading reached telephone sets,
including smartphones.
That's no, that was added this year before.
We didn't have a specific.
POLLICHINO, STEVEN Place to put smartphones.
POLLICHINO, STEVEN Which is great.
So what happens is a new technology comes out, a new product comes out.
POLLICHINO, STEVEN Umm, these tariff numbers are used to track and count.
POLLICHINO, STEVEN Trade stats Department of Commerce, US TR.
Outside trade groups they won't know what's coming in.
What's going out so the best way to do that is
to have a specific subheading, a specific tariff number.
POLLICHINO, STEVEN Sorry for a specific product.
POLLICHINO, STEVEN So now smartphones really aren't a new thing.
They've been out a long time.
POLLICHINO, STEVEN But I can't tell you how long it takes.
POLLICHINO, STEVEN To change your tariff and to add something like this.
POLLICHINO, STEVEN And it's a tremendous amount of work
or headquarters attorneys do a fabulous job.
POLLICHINO, STEVEN They have to deal.
POLLICHINO, STEVEN With all the personalities, issues and political.
POLLICHINO, STEVEN Underlyings of every other country.
POLLICHINO, STEVEN That is part of the harmonized tariff schedule,
so they cut our Brussels they talk about.
POLLICHINO, STEVEN Can we add a subheading for smartphones
and that opens up a can of worms and they do a fabulous job dealing
with all of that and it takes a long, long, long time
to get something changed.
POLLICHINO, STEVEN And to give you an example,
since we're talking so nice here.
POLLICHINO, STEVEN Back in the day, LED bulbs.
POLLICHINO, STEVEN Used domain 85 eighty 543
the basket provision dammit theorem.
In the 9405 all the light bulbs provision was back and forth
and it made no sense because we had a place for bulbs.
POLLICHINO, STEVEN Light bulbs, but I guess at the time there was no other
or didn't just didn't fit the criteria semiconductor LED labels.
POLLICHINO, STEVEN So I brought it up.
I had a meeting, we had a seminar, one of my headquarters attorney friends
was there, and I expressed my.
POLLICHINO, STEVEN Curiosity of why it's so hard.
We have a place for the light bulbs.
POLLICHINO, STEVEN Bright LED light bulbs and we're done.
POLLICHINO, STEVEN We said you don't understand.
We're dealing with so many countries and who knows the real reason
a certain country wants something done a certain way.
Everybody's looking out for themselves, right?
POLLICHINO, STEVEN So what happened was.
POLLICHINO, STEVEN They will all set LED light bulbs,
then one country raised their hands and said we wanted
to say Elliot did light bulbs and assemblies.
POLLICHINO, STEVEN Now that set us back years.
POLLICHINO, STEVEN What is an an assembly?
What?
What point is that an assembly, a light bulb or what?
Point is a not an assembly, but it's parts of a light bulb?
POLLICHINO, STEVEN Ridiculous, but everybody has a voice.
Everybody has an opinion.
POLLICHINO, STEVEN And I have to hand it to the headquarters.
People who go down or attorneys I I could never do that.
I would lose my mind.
But they do a great job.
But it does take a long time.
POLLICHINO, STEVEN So here we go.
Somebody must have wanted to track smartphones.
So now it's trackable.
It's traceable.
We can get trade stats on it.
So that's a change in 2022.
POLLICHINO, STEVEN So you may find rulings across right now
that put smartphones someplace else, because I forget the exact designation
of the tariff numbers, but now it's there.
So what happens is all these numbers have changed
because now we added a 517, thirteen.
It used to be something else.
So even though 8517 fourteen here is here, that number
might have been different in a past.
So by adding a new commodity that might have pumped all the numbers down
into different numbers.
So be careful when you're looking across when there's a change.
POLLICHINO, STEVEN So here we are.
We got telephone sets.
POLLICHINO, STEVEN UM.
POLLICHINO, STEVEN So I guess the question was,
can we look at the other subheadings in 8571 and can you tell us
what gets classified there?
POLLICHINO, STEVEN So let's start at the beginning.
POLLICHINO, STEVEN We classify by comparing same levels.
POLLICHINO, STEVEN Of the text in a tariff.
POLLICHINO, STEVEN Meaning this is the heading level.
POLLICHINO, STEVEN Telephone set, smartphones and other things,
and by network I would compare that to.
POLLICHINO, STEVEN Off the top of my head, hitting 8471.
POLLICHINO, STEVEN And heading 8525.
POLLICHINO, STEVEN Because some stuff may work in a network
and some stuff I have that I'm trying to classify,
it might be a transmit transmitting, transmitting device.
POLLICHINO, STEVEN For radio or TV broadcasting, that's 8525.
POLLICHINO, STEVEN So that's where I started.
Look at those three headings.
POLLICHINO, STEVEN I don't come down to video phones.
POLLICHINO, STEVEN And compare video phones which is indented
what like 2 * 2 are heading in 8525, we keep it.
POLLICHINO, STEVEN Well, at the same level.
POLLICHINO, STEVEN So once I get past the heading,
I could pay those three headings and I realize I'm here.
POLLICHINO, STEVEN Then the first intent.
POLLICHINO, STEVEN I see if I qualify for that.
POLLICHINO, STEVEN And if I don't?
If it's not a telephone.
POLLICHINO, STEVEN Then I don't go in here
and start looking at these other ones.
POLLICHINO, STEVEN If it's not a telephone set, wireless or otherwise,
then I would skip down.
You can't see it in this slide, unfortunately.
Two other apparatus for transmitting in a wireless wireless network,
but that would be the heading.
I don't go in and start rooting around in here.
POLLICHINO, STEVEN If I don't qualify at this point
at the first indent point, then I go down to the next one and I
and the latest slide, I'll show you.
POLLICHINO, STEVEN OK, so once we get in, we we're we're happy
that we have a phone, we have some kind of phone
and the subheadings telling me smartphones.
POLLICHINO, STEVEN Cellular phones.
POLLICHINO, STEVEN Or Umm.
POLLICHINO, STEVEN Or other wireless phones.
POLLICHINO, STEVEN So the first subheading,
once we realized we have a wireless type phone.
POLLICHINO, STEVEN Is 8517 eleven?
POLLICHINO, STEVEN And I'm sure at some point this was new technology
and somebody needed to get this number in a tariff to track.
POLLICHINO, STEVEN This is very specific.
This is a.
POLLICHINO, STEVEN Your house phone.
If you have a landline house phone anymore
where the base plugs into the wall.
So it's a wireless connection to your telephone provider.
But from the base to your receiver is wireless,
so this is a little wireless receiver.
Walk around your house and it's beaming its signal too much from this base unit
which is hard wired.
POLLICHINO, STEVEN Into your wall socket there.
POLLICHINO, STEVEN So that's a very specific type of phone.
POLLICHINO, STEVEN So that may fall into the new subheading smartphones.
POLLICHINO, STEVEN And I have some wonderful illustrations to you
of what we would all agree as a smartphone.
POLLICHINO, STEVEN Now we say smart phone a lot, but do we know
what that actually means?
POLLICHINO, STEVEN Evidently, I'm saying a flip phone
is not a smartphone here.
POLLICHINO, STEVEN Now why is that?
POLLICHINO, STEVEN Thankfully, chapter 85.
POLLICHINO, STEVEN Note 5.
POLLICHINO, STEVEN Gives your definition
of the new smartphone terminology.
POLLICHINO, STEVEN I just to point out, Charter 85 has notes no 12345
whatever because this chip note 5 is new.
All the notes in Chapter 85 have now changed.
POLLICHINO, STEVEN So usually.
POLLICHINO, STEVEN I would say in a headquarters ruling where they go
into a little bit more depth in my opinion
and they start citing chapter notes.
POLLICHINO, STEVEN You may say that they're gonna say chapter note.
Uh, three pertains to this, that the other thing well currently now.
POLLICHINO, STEVEN Chapter Note 3 may not be the same anymore or let's say 6
because as they after five Chapter Note 6 is not the same anymore
because they added something and that bumped all the other nodes at a whack.
POLLICHINO, STEVEN So again, go across, pull up the rulings
and double check you know what notes they're talking about
because you're looking at it and then it makes sense.
POLLICHINO, STEVEN So smartphone, what they're saying is for the purposes
of 8517, the term smartphone means a cell phone.
POLLICHINO, STEVEN That's equipped with a mobile operating system,
so it has a program on it like your computer has a program,
windows or whatever's operating behind Windows.
Really.
POLLICHINO, STEVEN This one has a mobile version of that.
POLLICHINO, STEVEN And is designed to perform.
They say it's designed to perform functions of an ATP machine.
POLLICHINO, STEVEN Such as downloading
and running multiple applications
at the same time, including third party applications.
POLLICHINO, STEVEN So this is a a stripped down version
of a computer is what they're saying.
POLLICHINO, STEVEN Whether
or not this phone has other integrated features,
such as a camera or a GPS system.
POLLICHINO, STEVEN I think that's a pretty decent description
of what a smartphone is.
POLLICHINO, STEVEN Cell phone.
POLLICHINO, STEVEN That has a little bit of a computer in it
and you could run a bunch of apps.
POLLICHINO, STEVEN You flip phone could not do that.
POLLICHINO, STEVEN OK, settles that are first to subheadings
within telephones.
POLLICHINO, STEVEN The night we get to some other specific things
and this is a radio telephone design for installation in a car.
POLLICHINO, STEVEN For the public cellular radio system,
so this is a cell phone.
POLLICHINO, STEVEN That gets mounted within a car.
It's made to be mounted in a car.
POLLICHINO, STEVEN Back with cell phones.
And again, this is probably coding technology.
At some time.
I don't even know if they make this or do this anymore.
Maybe taxi cabs or fleet cars.
POLLICHINO, STEVEN But back in the old days,
your cell phone was a pretty large device that you had
in a shoulder harness, and you carried around the battery portion
and you head as your mongus hand portion.
It was a big thing.
POLLICHINO, STEVEN And it's made for being installed in a car
because the transceiver units mounted in your trunk is running off
the cars battery, it doesn't have its own battery.
It run uses in a tenant at some on top of the car to handset is made
to be mounted in the car wherever it amounted.
POLLICHINO, STEVEN So there's no question.
POLLICHINO, STEVEN As to what this means, it's not your normal cell phone
that you put in a cup holder clip thing and you use it in your car.
This is a specific commodity made for installation in a car.
POLLICHINO, STEVEN OK.
And then 8517, fourteen.
POLLICHINO, STEVEN Which is sorted and other provision is talking
about other radio telephones for the cell networks as talk about cell phones.
But we know because up above before this we talked about smartphones.
POLLICHINO, STEVEN This can't be a smartphone because that's covered
in a previous subheading.
POLLICHINO, STEVEN So the this is where cell phones
that are not smartphones, where they would be classified.
POLLICHINO, STEVEN OK, so you're coming in here.
You got telephones.
This is where I want to be.
I have a telephone.
Is it a house phone with a wireless?
Now it's at a smartphone.
No, it's not a smartphone.
POLLICHINO, STEVEN OK.
So it's an other telephone for cell networks or other wireless networks.
OK, yeah, it's wireless.
POLLICHINO, STEVEN It doesn't get mounted and a car.
So now we've come down.
POLLICHINO, STEVEN Umm is it a flip style phone?
Yes, it stays here.
Is.
Is it not a flip style cell phone?
Meaning number one, it's not a cell phone.
POLLICHINO, STEVEN Because this heading towards the subheading talks
about other wireless networks.
POLLICHINO, STEVEN OK, so if it's not, I mean, flip phones would go here
if it's not a flip phone using.
I'm sorry if it's not a phone using a cell network, it comes down
to this other other.
POLLICHINO, STEVEN Ah.
POLLICHINO, STEVEN So he'll be here.
POLLICHINO, STEVEN So this is for cell phones that aren't smartphones,
and we know that because smartphones were classed above prior to this
and we go down in order.
POLLICHINO, STEVEN This other.
POLLICHINO, STEVEN Just other.
POLLICHINO, STEVEN Has to be for recovered all the cell phones
we could cover right?
And we got the smartphone up above.
We got the ones mounted in the car and we got the flip phones type.
There are no but the cell phones.
So this other has to be for other wireless networks.
POLLICHINO, STEVEN So we don't get a lot of those.
So what would go in this other heading?
POLLICHINO, STEVEN Otherwise it well, it would be something
that does not operate in a cell network because all of those are covered above.
POLLICHINO, STEVEN So what are we talking about then?
I have a little picture of a satellite here.
POLLICHINO, STEVEN So what would go in that other?
POLLICHINO, STEVEN Would be a satellite phone.
POLLICHINO, STEVEN OK, satellite phones are type of model mobile phone
that connects to other phones or the satellite network by radio waves.
But it beams directly to a satellite.
It does not go through a cell network.
POLLICHINO, STEVEN They use these in like remote areas, or if you're
in a jungle somewhere, a lot of safety type phones, your hiking
and some remote area, you're not gonna get satellite service
because you need cell towers.
POLLICHINO, STEVEN So which case uses satellite phone?
Because it's wireless, so it fits the criteria and it's outside
of the cell network, so it has to fall into this other.
POLLICHINO, STEVEN Another one I found was a Wi-Fi phone.
POLLICHINO, STEVEN And I believe this was used on a college campus.
POLLICHINO, STEVEN So the college campus had its own little network
going around.
They probably had, UM, hot spots and base stations
and transmitters around the campus.
POLLICHINO, STEVEN And maybe to security personnel or the teachers,
the faculty at a specific type of phone.
POLLICHINO, STEVEN That did not operate on cell network.
POLLICHINO, STEVEN It was wireless, so it has to fall into this other
what it did, it was a communicated to the Wi-Fi,
so talked straight just like a router phone talked right to the router.
POLLICHINO, STEVEN And the last one I could find.
POLLICHINO, STEVEN The last example of a wireless telephone
that's not a cell phone.
POLLICHINO, STEVEN Umm, I don't know if you have a watched the TV show,
mash or World War Two movies.
I don't know if the modern.
POLLICHINO, STEVEN Modern Army military uses this.
POLLICHINO, STEVEN But it doesn't.
All old style radiofrequency field telephone.
POLLICHINO, STEVEN That the telephone operator in a company of.
POLLICHINO, STEVEN Military people would have.
POLLICHINO, STEVEN And pretty much what they did, they would crank this up
and it would have just a one way transmission to a pay station
where the commander was in safely and attent.
POLLICHINO, STEVEN A safe distance from the front.
POLLICHINO, STEVEN And they could get calls.
POLLICHINO, STEVEN There was no like dial.
You didn't dial, you know, PY 64796 but.
POLLICHINO, STEVEN It was a one way you got one person.
It was on one frequency.
It just went from this.
This set to commander in the in the camp, in the tent.
POLLICHINO, STEVEN Alright, so that's.
POLLICHINO, STEVEN That's what I would put under this other.
POLLICHINO, STEVEN And why is because other things prior or covered?
POLLICHINO, STEVEN OK, so my phones wireless phones cell phones.
I should say I'm sorry.
POLLICHINO, STEVEN And then other.
POLLICHINO, STEVEN So after that is this other.
POLLICHINO, STEVEN Now you can say it's.
It's one tab to the left, so.
POLLICHINO, STEVEN This gets compared to this level.
POLLICHINO, STEVEN This level and this level, so I should coming down
if you had a telephone that was in the cellar, then cellular network
or other network, you would come in here and you have to stay here.
POLLICHINO, STEVEN So from got to go down to this other you have
to have a product that is not in a cell network.
POLLICHINO, STEVEN And it's not wireless
because it would be covered here.
POLLICHINO, STEVEN So it's not a line phone with a cordless handsets,
not a smart phone, because that's the type of cell phone.
It's a specific smart phone.
It's not a cell network, and it's not wireless and never coming down
to this other.
And we go inside.
POLLICHINO, STEVEN And with this other covers.
POLLICHINO, STEVEN Hey, the other subheading, 8517 eighteen would provide
for a wired telephones.
POLLICHINO, STEVEN A hardwire telephonically used
to have in all our houses.
POLLICHINO, STEVEN And a similar thing.
So the first breakout is for video phones.
POLLICHINO, STEVEN Umm.
POLLICHINO, STEVEN In an apartment building or secure location,
they would have a video phone which consists of a telephone set you dial in
who you're trying to reach.
It has what they call a television camera, has a video camera
and a television receiver so you can communicate
to whoever is inside the building.
POLLICHINO, STEVEN It's wired.
POLLICHINO, STEVEN Multi line phones is next.
That's our desk phone, I guess for most of us, I assume, right.
You have a couple different extensions on your phone.
It's hardwired and.
POLLICHINO, STEVEN You can't have a wireless handset
or else it would be up above.
POLLICHINO, STEVEN And then this other.
POLLICHINO, STEVEN This other so weren't other meaning we're
in non wireless things videophones multiline phones and this other.
POLLICHINO, STEVEN Well, multi aligned corded phones here very.
This would have to be.
POLLICHINO, STEVEN Single line phones like the old fashioned house phones
where you had one line and plugged into the wall.
It's wired.
POLLICHINO, STEVEN And it doesn't have a wireless handset
because if it did, it would be above.
POLLICHINO, STEVEN Right.
So if it had a wireless headset handset, it would be up here
and we would have stopped here.
POLLICHINO, STEVEN OK.
So that's that other.
POLLICHINO, STEVEN I hope this is making sense.
POLLICHINO, STEVEN OK.
So the second and third breakout.
POLLICHINO, STEVEN Categories of 8517.
POLLICHINO, STEVEN Yeah, with my favorite we have the other apparatus.
POLLICHINO, STEVEN Other apparatus for transmission or reception
of voice images.
POLLICHINO, STEVEN Other data.
POLLICHINO, STEVEN For communication are wide or wireless network.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN Other appraiser transmission are exception voice image
of the other data, including those in a wired or what?
OK, so the first one they have is the base station.
POLLICHINO, STEVEN So now we have something that's not a telephone.
You can't dialate it doesn't do anything except they're telling me it transmits
and receives.
POLLICHINO, STEVEN I don't know how because I'm looking at it.
It's a little box, there's a couple of blokes, but it's a transceiver,
which is a combination receiver, transmitter or it's one of the other.
POLLICHINO, STEVEN An example of that is a base station.
POLLICHINO, STEVEN So it well, OK, if it's that, then we stay here
and we intent one and we see what we have to do is see
what's there is the author here.
Wow.
I'm sorry.
So base stations.
POLLICHINO, STEVEN Which as per the ends and our recent decisions
on such commodities.
POLLICHINO, STEVEN The base stations.
POLLICHINO, STEVEN That I talked about in the EN.
POLLICHINO, STEVEN Convince us that that was meant to go there
or Bay stations used in a cell network.
POLLICHINO, STEVEN Are you again, we don't classify by name.
A lot of things in various networks are called base stations.
You can have a base station in a computer network.
You could have something to call a base stations in a radio broadcast
or TV network.
POLLICHINO, STEVEN So if UH-85 seventeen, 61 ohh those base stations
is our position here CBP that they're for cellular networks only?
POLLICHINO, STEVEN And what they do is they receive a signal.
POLLICHINO, STEVEN And they retransmit it to cover.
POLLICHINO, STEVEN More area.
POLLICHINO, STEVEN Transmissions of any type only can go so far.
So let's say it's 1000 feet.
POLLICHINO, STEVEN You transmit 1000 feet, then at the end of that 1000 foot.
POLLICHINO, STEVEN Perimeter did be another base station
that receives that signal.
That's probably getting a little bit weak.
Boosts it and retransmits it transmits it.
So now you get another 1000 feet.
POLLICHINO, STEVEN So you know it's not so bad these days.
Been in the beginning with cell phones.
You could be driving and your call would drop.
POLLICHINO, STEVEN Because you went out of the range
of the last cellular base station or tower and maybe you know,
you're someplace rural and they haven't put up a new cell tower.
POLLICHINO, STEVEN So 8517 sixty one talks about base stations.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN Next we go into when I talking about a base station,
but it is something that transmits and receives.
POLLICHINO, STEVEN Subheading any five 1762 talks about machines
for the reception, conversion and transmission or regeneration of voice,
images or other data.
POLLICHINO, STEVEN Including switching and routing apparatus.
POLLICHINO, STEVEN So what falls here?
POLLICHINO, STEVEN Has to do all three functions it has to receive,
convert and transmit.
POLLICHINO, STEVEN If it does not do all three, we come, we stay
at this level and we come down to this other.
POLLICHINO, STEVEN We don't go in, we don't go to this other cause
that's underneath.
POLLICHINO, STEVEN This subheading meaning I'm saying whatever goes here,
does all three functions.
If it doesn't do all three functions, we stay at this level
and we come down to this other.
POLLICHINO, STEVEN OK.
And like I just said, it has to do all three functions receive,
convert and transmit.
POLLICHINO, STEVEN Said her first thing under this subheading
that does all three talks about modems of a kind used
with data processing machines.
POLLICHINO, STEVEN That's kind of specific.
POLLICHINO, STEVEN So we're talking about on modems, modems receive,
they convert to signal to or from.
POLLICHINO, STEVEN The computer versus whatever network they're trying
to get on.
POLLICHINO, STEVEN But this subheading is specifically for modems
that you can prove to me.
POLLICHINO, STEVEN Work with an ATP machine.
POLLICHINO, STEVEN And I say that
because you could have a modem that's used
in a machine that manufacturers something.
POLLICHINO, STEVEN You could have a modem that you use, uh.
POLLICHINO, STEVEN In an automobile.
POLLICHINO, STEVEN Their modems,
meaning they're their device that gets you.
POLLICHINO, STEVEN Onto the Internet.
POLLICHINO, STEVEN But unless they're used in some way,
they're specifically you shaped made for use with an ADP machine.
They wouldn't go here.
POLLICHINO, STEVEN So this is an old ruling back in the day
when the laptops may or may not have an internal modem,
you could buy little thumb drive type thing.
POLLICHINO, STEVEN Which is a modem.
POLLICHINO, STEVEN And UM.
POLLICHINO, STEVEN It works on a 4G network,
so there's probably a cell SIM card in here.
POLLICHINO, STEVEN But it has the password or it has whatever it needs
to gain access to your Internet provider.
POLLICHINO, STEVEN And disturbing South through your cell network.
POLLICHINO, STEVEN Cillian and network, so this is definitely made
for a computer.
POLLICHINO, STEVEN So somebody's gonna argue you could stick this
into USB slot of a machine.
I don't know.
I don't think so.
POLLICHINO, STEVEN This webinars for advisory purposes only.
So we're gonna assume there's only works with a laptop.
POLLICHINO, STEVEN If it's proven it doesn't work, the ADP machine,
we have to go elsewhere.
POLLICHINO, STEVEN So if it came down here, it does homework
with an ADP machine.
Is it a switch or router now?
We said it's a modem, so then we come down to this other.
POLLICHINO, STEVEN We wouldn't come out here.
POLLICHINO, STEVEN Because we've already staying
at the same levels we've already come within the two indent area.
We're gonna stay there and we would default to this other
if it wasn't the type of motor.
No one was.
The data processing machine.
POLLICHINO, STEVEN So next we have my favorite switching
and routing apparatus.
POLLICHINO, STEVEN This is relatively new, maybe 2-3,
a 100 years now it feels like, but maybe two
or three years ago I don't remember.
POLLICHINO, STEVEN Switching and routing apparatus
was actually giving its given its own subheading.
POLLICHINO, STEVEN Umm.
POLLICHINO, STEVEN A 10 digit level.
POLLICHINO, STEVEN Which caused some confusion at the time a little bit.
Not much, a little confusion.
POLLICHINO, STEVEN Because it says switching and routing apparatus,
it doesn't say switches and routers.
POLLICHINO, STEVEN Switching and routing apparatus.
POLLICHINO, STEVEN The subheading is not limited to the commodities
that we call switches and routers.
Thankfully, because like I said, we don't classify my name.
POLLICHINO, STEVEN What the devices like a classified here have to.
POLLICHINO, STEVEN Perform a switching and routing function.
POLLICHINO, STEVEN Not just be part of the flow part of the network.
POLLICHINO, STEVEN OK, so let's just look at this quick to be classified
as switching routing, the device must perform a switching and routing.
POLLICHINO, STEVEN Function.
POLLICHINO, STEVEN And.
POLLICHINO, STEVEN As we were working through what gets classified here
because this so subheading breakout was sort of sprung on us.
POLLICHINO, STEVEN Sorry.
POLLICHINO, STEVEN My headquarters attorney buddy worked, did
a lot of work trying to figure out and weed
through how we should look at these and how to define them.
POLLICHINO, STEVEN Umm, he worked
with the telecommunications trade groups.
POLLICHINO, STEVEN They had some great input.
POLLICHINO, STEVEN And we have arrived at these definitions that are
to follow.
POLLICHINO, STEVEN But there was a lot of work shipping through this stuff,
so these three headquarters rulings that are on the slide I feel are terrific
and trying to get a better understanding of what a switch and a router is.
POLLICHINO, STEVEN Now, why we?
Why we saying that is because when this first came out,
quite possibly we might might have viewed like a router as well.
Anything if you just telling me it's routing data.
POLLICHINO, STEVEN In the beginning we thought, well,
that's like taking data from point to A and sending it to point B.
POLLICHINO, STEVEN So that could be a base station.
POLLICHINO, STEVEN That could be a range extender.
Could that be hot spot all those things take a reception.
POLLICHINO, STEVEN Receive a reception, receive a signal,
and then send it on its way.
POLLICHINO, STEVEN Well, I'm gonna say me, I was wrong.
POLLICHINO, STEVEN The definition of routing and or switching is not
that it just takes a signal and extends it.
POLLICHINO, STEVEN There has to be some analysis.
I thought process as to hey, where am I sending this signal?
POLLICHINO, STEVEN I'm not just sending it out there,
I have to figure out where this thing look goes in the most efficient way
of getting it there.
POLLICHINO, STEVEN So that's what these headings
and this little slide is saying.
There are a lot of devices that connect other devices together
to take a signal they and then they send it further.
But if it's not making a conscious active decision,
it's probably not a switch or a router.
POLLICHINO, STEVEN So when you router a router is a device
that incorporates intelligent hardware.
POLLICHINO, STEVEN It has something within it called routing tables.
POLLICHINO, STEVEN And it performs optimized path selection for data
and multi point scenarios between computer networks.
POLLICHINO, STEVEN So within a router there's a table of networks,
I'm gonna say.
POLLICHINO, STEVEN And when it receives data, it receives input.
POLLICHINO, STEVEN It checks some address the information you send out
is called a packet.
It's a packet of information, and on there, when you're trying
to send something out through the Internet of someplace.
POLLICHINO, STEVEN It has an address on it.
Well, there's a table of routing table in your router.
POLLICHINO, STEVEN I'm not even gonna pretend I know how it works,
but it compares the address on your packet to which tables
and to the network that's coming from and the network it's going to.
POLLICHINO, STEVEN And figure out figures out the best way
to get that packet delivered.
POLLICHINO, STEVEN Does it descend it?
POLLICHINO, STEVEN It's doing some thinking and it's doing the best.
POLLICHINO, STEVEN Taking the best route to get your information out.
POLLICHINO, STEVEN Bradders work as as a uh dispatcher directing traffic,
the analyzed data being sent across a network and they choose the best route
for the data to travel.
POLLICHINO, STEVEN So rather router is not just forwarding, it's.
POLLICHINO, STEVEN Actively making a decision.
Yeah, there's something called the open system interconnection model.
POLLICHINO, STEVEN And it's a model of layers that tells us
where different types of machines or functionality occurs within a network.
POLLICHINO, STEVEN And the trade association that worked
with our Hikaru's court as attorney brought this to light.
And they're telling us that route is operate
in the third layer of this model.
POLLICHINO, STEVEN The open system interconnection model.
POLLICHINO, STEVEN Does that matter where it operates?
Well, it helps us understand a product better.
If you looked at this table like layer one is the physical aspects,
maybe a wires and just connectors and stuff layer too.
POLLICHINO, STEVEN Would be a simpler.
POLLICHINO, STEVEN Transmission devices lay a three.
We get more complicated.
Lay a four so one and so forth.
POLLICHINO, STEVEN So it doesn't help us classify, but it's nice to know.
POLLICHINO, STEVEN OK, I just lost everything.
POLLICHINO, STEVEN More about a routing table.
POLLICHINO, STEVEN If adding table or routing information base
is a data table stored in a router, it allows a router to direct packages
to the appropriate destination.
Without this table, a router cannot direct traffic.
Now that's currently that's what a router needs.
Who knows, in the future, I hate putting things putting things down like this
because it makes it sound absolute and I'm just going to check this
and it doesn't have that.
It can't be there.
Well, my next question would be does it have something?
POLLICHINO, STEVEN Akin to that, is there some new technology
that takes the place of a routing table?
The question is, is there is this device you considering a router doesn't make?
POLLICHINO, STEVEN Active smart decisions on
how to direct the information the packet of information tomorrow.
Maybe it won't be cold or routing table.
It'll be called something else, so don't get hung up
on the current terminal terminology.
Look at the overall picture.
You have a device that's receiving a data packet, reading an address
and making a conscious decision of how to forward it.
Well, how does it do with that?
I would ask.
Well, doesn't have a routing table, so it can't be that.
How does it do it?
POLLICHINO, STEVEN Well, it has something else.
Well, then it's still going to be a router.
POLLICHINO, STEVEN It's making a conscious decision analyzing.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN It again, it's an Internet page.
POLLICHINO, STEVEN I think that's plenty about routers.
POLLICHINO, STEVEN A switch, also a switch.
POLLICHINO, STEVEN Is a network device
incorporating intelligent hardware?
POLLICHINO, STEVEN It uses that a routing table,
but it uses something called a Mac address table.
POLLICHINO, STEVEN OK, so the key to the full growing concepts is
that routing and switching.
POLLICHINO, STEVEN I define that by allowing devices to connect
to one another, but the ability to perform intelligent path selection.
POLLICHINO, STEVEN I I think we've beaten this to death.
POLLICHINO, STEVEN Hold on while my computer refreshes.
POLLICHINO, STEVEN So when looking at routing switching devices.
POLLICHINO, STEVEN After deciding that what
what gets classified there are not the commodity known as routers and switches.
POLLICHINO, STEVEN But things that perform the routing
and switching function.
POLLICHINO, STEVEN And I've been now we know that we decided
that the routing and switching function.
POLLICHINO, STEVEN Is an intelligent path.
POLLICHINO, STEVEN Selection functionality.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN So here we had a ruling for something called a gateway.
POLLICHINO, STEVEN And the question was, well, the gateway is that a route
or it's not a switch, it can't be classified as a router
and switching apparatus?
POLLICHINO, STEVEN Amy molded around for a while.
POLLICHINO, STEVEN I'll give credit to my headquarters.
Attorneys are doing all the tough work and coming to these decisions.
POLLICHINO, STEVEN Uh, thankfully now because I had an end with the.
POLLICHINO, STEVEN Communication.
POLLICHINO, STEVEN But what it is is it works between.
POLLICHINO, STEVEN So what it does besides routing is it converts.
POLLICHINO, STEVEN Bought decision was is performing a routing function.
POLLICHINO, STEVEN That's a decent rule on to read
if you ever have a question about that.
POLLICHINO, STEVEN So to pointed out was, it's not restricted to routers
and switches.
If you have a device that's performing a routing and switching function,
I don't care what you call it.
We don't classify by name.
I have to know what it's doing.
POLLICHINO, STEVEN So a lot of times I will ask, tell me what's happening
in this device in layman's terms, because you may not believe this,
but I'm not a genius.
POLLICHINO, STEVEN What type of signals going into this box?
POLLICHINO, STEVEN What happens in the box?
POLLICHINO, STEVEN Does that signal gets changed?
Why does it get changed?
How does it get changed?
What's coming at it the the box and where is it going?
POLLICHINO, STEVEN So in this case it would be.
Well, I have a signal from the network A that needs to be converted
because network B where it's destination is,
doesn't understand that language Hussam.
So it gets converted, yeah.
Then what happens?
Well then it checks us routing tables and make OK,
so it's doing a routing function.
POLLICHINO, STEVEN So it's not outside the realm of reasonability.
POLLICHINO, STEVEN That's performing a routing function, so it goes there.
So not only not only routers and switches,
but things that perform routing and switching functions.
POLLICHINO, STEVEN So then, here's another other.
POLLICHINO, STEVEN So how is that thing?
It's like, so if you remember, the subheading was devices that transmit,
receive and convert to all three functions
that we went within those modems.
It was switches and there was other so that would that would be something
that does all three.
POLLICHINO, STEVEN So here's the this is the other, so it's not a modem,
it's not a switch.
POLLICHINO, STEVEN Than other shows up.
POLLICHINO, STEVEN While other has to be has to be in line
with that subheading that it does all three.
POLLICHINO, STEVEN Just not the two above.
It is not a modem, and it's not a switch.
So 8517 sixty two ohh 90 other provides for devices
that do all three functions perception, conversion, transmission,
regeneration of voice images like data.
Except it ain't a modem because we know that's covered above.
POLLICHINO, STEVEN And then Anna Switch or routing apparatus,
because that is also covered above.
So it's anything except that that does all three functions.
POLLICHINO, STEVEN Pence, a Wi-Fi range extender.
POLLICHINO, STEVEN And what that is is a device.
You might have a dead spot in your home or you have like a camp
as a college campus.
POLLICHINO, STEVEN You have your router and your computer system
of 1 ended a campus and you're trying to get that signal to the other end.
You employ a bunch of Wi-Fi range extenders, which received the signal
at the point it's starting to get weak 100 feet, 200 feet,
and rebroadcast the signal for another 100 feet.
At that point, you have another Wi-Fi range extender, and it goes on and on,
and you keep adding more.
It keeps receiving, boosting the signal and sending it out.
POLLICHINO, STEVEN That would go in the other.
POLLICHINO, STEVEN 8517 Sixty two ohh 90.
POLLICHINO, STEVEN Because it's not a modem.
POLLICHINO, STEVEN And it is not a router switch.
It doesn't have and why isn't it a router switch?
Because it doesn't have any intelligence,
it's just receiving a signal.
POLLICHINO, STEVEN Boasting it, which I guess we consider
the conversion part.
POLLICHINO, STEVEN Sometimes it has to convert it
prior to boosting aversive visa.
POLLICHINO, STEVEN Is boosting it and then rebroadcast,
but just going out Willy nilly, it's going out there.
There is no path selection.
It's a dumb thing, so it can't be a router or a switch.
POLLICHINO, STEVEN That would come in other that's would go
in other you ask how can tell you a hub.
POLLICHINO, STEVEN Now this is one of the things
that probably I'm pretty sure, so I'm gonna say it used to be an 8471
prior to 2007.
POLLICHINO, STEVEN Now it's an 8517.
I'm pretty sure it's gonna.
So what is the hub?
POLLICHINO, STEVEN A Hobbit is like a switch.
POLLICHINO, STEVEN Except it's stupid.
A hub makes no decisions, whereas a switch receives the data packet
and goes hmm.
Who was this addressed to?
And let me send it only to them.
POLLICHINO, STEVEN This hub receives a signal,
and let's imagine there are five slots there.
There are five different people plugged into those.
POLLICHINO, STEVEN Ports.
POLLICHINO, STEVEN So the HOB takes in a signal
and broadcasts it out exactly the same.
POLLICHINO, STEVEN Through all those five ports,
so everybody gets the same signal.
There is no thinking, there's no one else.
There's no path selection.
Hopefully the computer, the printer, the fax machine, whatever's hooked up.
POLLICHINO, STEVEN To those ports has internally some kind of,
UM computer analysis system that says, yeah, this ain't mine.
I don't want this.
POLLICHINO, STEVEN So there.
POLLICHINO, STEVEN Accepting or denying the input of this,
the incoming signal would be on the device itself,
but this hub is a silly thing that just takes 1 signal
and broadcasts the same exact thing to anybody plugged into it,
so it's not a switch, it's not a router, it falls into other.
POLLICHINO, STEVEN But it does all three things.
POLLICHINO, STEVEN A repeater is the same thing as we just talked about.
It takes a signal, boosts it, and we broadcasts it.
POLLICHINO, STEVEN There's no intelligence to it.
It's not deciding where it goes.
Anybody with a cell phone?
I guess this is a picture of we'll pick up that signal.
It's not just going to Johnny boy.
It's going to ever has a self on an area.
POLLICHINO, STEVEN We are so then where is that?
Do I have it?
POLLICHINO, STEVEN Yeah, I'm new to this teams thing,
so give me a second, yeah.
POLLICHINO, STEVEN OK.
So we were under the subheading, it said.
POLLICHINO, STEVEN Receives, transmits
and converts the subheading did all three.
POLLICHINO, STEVEN If you have a device that does not do all three.
POLLICHINO, STEVEN So what would go into other of 85 seventeen 69?
Ohh.
POLLICHINO, STEVEN Are things that don't do well three functions.
POLLICHINO, STEVEN Umm this is a block up converter
and a low noise block converter.
POLLICHINO, STEVEN Umm, whatever the heck they are,
they don't do all three functions.
POLLICHINO, STEVEN OK, the.
POLLICHINO, STEVEN The buck, as they call it, only transmits.
POLLICHINO, STEVEN It doesn't receive.
POLLICHINO, STEVEN The LPN only receives, it doesn't transmit,
so it cannot go under that subheading.
Though I'm I said those all three, so it defaults to the other subheading.
POLLICHINO, STEVEN Similarly.
POLLICHINO, STEVEN An old school pager.
POLLICHINO, STEVEN It will receive the page.
POLLICHINO, STEVEN You could read it.
POLLICHINO, STEVEN But as far as I know, you cannot respond.
If you could respond, then it wouldn't go here.
It would go into the other.
POLLICHINO, STEVEN Subheading.
POLLICHINO, STEVEN Or we're assuming what I'm saying here is correct
because this is only for advisory opinions.
This pager could not transmit, it just received.
As such it would fall to this other.
POLLICHINO, STEVEN I wish I could see what's the next.
OK, so now we're going to get.
Yeah.
I'm sorry.
Now we're getting into parts.
POLLICHINO, STEVEN So we were under other apparatus.
We did base stations and then we came down to things that have to do all three
where we had modems and switches and routers and it wasn't one of those,
but yet it did all three.
It would fall to this other.
POLLICHINO, STEVEN If we came down, we had a device
that did not do all three.
We would not come in here.
We would stay at this level and come down to this other
because it's the same level and that's with a block and the Lync and the pager
and other things that didn't deal well, three functions would go.
POLLICHINO, STEVEN And we have a new item in pots aerials
and arrow aerial reflectors of all kinds.
POLLICHINO, STEVEN And parts suitable for use therewith.
POLLICHINO, STEVEN So this is a no.
Before we never had antennas aerials within the parts.
POLLICHINO, STEVEN Subheading at 8517.
POLLICHINO, STEVEN But I believe like 8525 or maybe it's 8529, the TV.
POLLICHINO, STEVEN The Tapee UM headings.
POLLICHINO, STEVEN Had a pause provision that provided
for antennas aerials.
POLLICHINO, STEVEN So when it came down to, you know,
you had an antenna that was used for my stuff, it I 517.
POLLICHINO, STEVEN Umm,
I would either go into parts or would go into one
of the actual subheadings, depending on how it functioned.
POLLICHINO, STEVEN OK, so now we're at parts and we come under
and either it's an antenna or it's not.
Let me go back here.
POLLICHINO, STEVEN OK, so when we have something called a part.
POLLICHINO, STEVEN In a real world, real agrees apart.
POLLICHINO, STEVEN It's made for this machine.
It can only be used in this machine.
I don't know what else to do with this thing
except scroll it into this machine. It's a part.
POLLICHINO, STEVEN OK, that's great.
But for tariff purposes, we look at these things that we all agree aparts
and we have to apply section 16, Note 2 or Note 2 to section 16.
POLLICHINO, STEVEN And this is talking about chapters 84 and 85.
POLLICHINO, STEVEN OK.
And what it says.
And I'm gonna paraphrase.
POLLICHINO, STEVEN A parts which are goods included in any of the headings
of chapter 8485 are in all cases to be classified in their respective heading.
What that says is if I have a part.
POLLICHINO, STEVEN But I would say uh, power supply, I have a power supply
for a computer.
It's a printed circuit board that goes in my computer that changes AC current
to DC current of 12 volts.
It's a rectifier or it's an inverter?
POLLICHINO, STEVEN Yeah, it's a part of this computer.
POLLICHINO, STEVEN But based on this note, if I can find a specific heading
in Charters 8485, I classify there way before it classify it
as a part anywhere else.
POLLICHINO, STEVEN Now you're looking at these headings that I have here
and says other than these headings.
POLLICHINO, STEVEN These headings are parts headings.
They're not specific headings.
POLLICHINO, STEVEN Like I know 8503.
POLLICHINO, STEVEN It's the heading that says parts for generators
and electric motors, which is the heading
of that comes before this 8501 eighty 502.
POLLICHINO, STEVEN 8548 is a general parts provision,
parts other parts nobody wants to do.
I call it.
It's a parts electrical parts basket provision.
POLLICHINO, STEVEN Which makes sense because we're trying
to get this item we call a part.
We're trying to get it into the most specific heading.
POLLICHINO, STEVEN So first we want to see if it has its own function.
It can it be classified within its own heading, its own specific heading
instead of power supply.
POLLICHINO, STEVEN Is it a converter of some sort?
Is it a transmitter?
A little Bluetooth thing that goes in a computer?
Yes, it's a computer part, but there's a place for Bluetooth transmitters.
POLLICHINO, STEVEN So first we tried to get it in a specific heading.
POLLICHINO, STEVEN And we're not talking about headings
that are parts headings, because that's just silly.
Those are not specific.
So if we look at all the specific headings, 84 and 85
and we disregard these guys because they're parts headings.
POLLICHINO, STEVEN And then we come down to be.
POLLICHINO, STEVEN If there is no specific heading.
POLLICHINO, STEVEN If the parts used with.
POLLICHINO, STEVEN Our principally or solely used with a particular kind
of machine.
POLLICHINO, STEVEN Then it gets classified.
POLLICHINO, STEVEN As that type of machine with that type of machine.
POLLICHINO, STEVEN So you have a part of computer, uh, so 8517.
You have a part of a transmitter.
It doesn't have its own specific heading.
It's not our power supply is not transmitter in and of itself.
But it says thing that goes in a transmitter, there's no heading so.
POLLICHINO, STEVEN It works with this transmitted unit can only work there,
so it's gonna be done as a part of a transmitter.
Failing that, then it goes into.
POLLICHINO, STEVEN One of the parts headings.
POLLICHINO, STEVEN So the whole point is we can argue for days
that the device you have is a part.
POLLICHINO, STEVEN But we try to stick parts
in their own headings before we make them parts.
POLLICHINO, STEVEN So antennas, this is new.
POLLICHINO, STEVEN An antenna is an electrical device
which converts electric power into radio waves and verse of icy.
POLLICHINO, STEVEN It's usually used with a radio transmitter
or a radio receiver.
POLLICHINO, STEVEN And transmission.
A radio transmitter supplies an oscillating radio frequency current
to the antennas terminals.
POLLICHINO, STEVEN Then the antenna radiates the energy from the current
as the electromagnetic radio waves.
POLLICHINO, STEVEN So an electrical current goes into the transmitter.
Transmitter sends that to the antenna.
POLLICHINO, STEVEN And through magic, because I don't know how it works.
Yeah, tennis changes that into electromagnetic waves
that go through the ether,
and they float around out in space until they hit a receiver antenna
which takes those electromagnetic waves.
POLLICHINO, STEVEN And converts them back to a signal.
POLLICHINO, STEVEN Through the receiver unit.
POLLICHINO, STEVEN So a couple of things.
POLLICHINO, STEVEN Having this in 8517 is kind of weird.
POLLICHINO, STEVEN And I'm gonna say again, we don't classify by name.
POLLICHINO, STEVEN Because I've had things that they will calling antennas.
POLLICHINO, STEVEN Even just says aerials.
POLLICHINO, STEVEN But yet this commodity was a high end device
that they called an antenna.
But yet inside of it, it had receivers and transmitters.
POLLICHINO, STEVEN So being that it had a receiver and transmitter in it,
and the thing received the transmitted.
POLLICHINO, STEVEN Umm, he got classified
not in parts because of our note.
POLLICHINO, STEVEN Because you want to find a specific heading.
POLLICHINO, STEVEN Ah, OK.
POLLICHINO, STEVEN Better to have a hold on.
POLLICHINO, STEVEN So.
POLLICHINO, STEVEN So since it had a receive and transmit it within it,
even though they called it an antenna or an aerial.
POLLICHINO, STEVEN The classified it here on 8517 sixty 200 ninety.
POLLICHINO, STEVEN Because it had the ability in and of itself to receive,
convert and transmit.
POLLICHINO, STEVEN It wasn't just an aerial I a metal rod.
POLLICHINO, STEVEN It had the functionality.
POLLICHINO, STEVEN Of doing these functions that,
but that was an intelligent statement, OK.
POLLICHINO, STEVEN So the aerials that fall under the parts vision least
at 8517.
POLLICHINO, STEVEN You have to be careful with
and not just gonna be everything that's called an antenna or aerial.
POLLICHINO, STEVEN And in my view, an aerial is of simple.
POLLICHINO, STEVEN Device it's.
POLLICHINO, STEVEN They reflect their unit or a.
POLLICHINO, STEVEN Some kind of metal device
that receives the electromagnetic waves.
It doesn't have a transmitter.
It doesn't have a receive.
If it does, it's gonna come over here.
It's gonna fall under other.
POLLICHINO, STEVEN So be careful with that.
POLLICHINO, STEVEN Whereas and I think 8425 is 2529
where they talk about aerials and antennas, I don't think it matters.
But 9517, I'm not just dumping everything into pause because we have.
POLLICHINO, STEVEN A place for aerials.
I'm going to come down.
POLLICHINO, STEVEN I had this device of calling an antenna, but hey.
POLLICHINO, STEVEN It does these three functions really well.
Then I'm coming in here.
POLLICHINO, STEVEN Those three functions definitely great.
POLLICHINO, STEVEN So it's coming down to other one never going
to get the parts because we have that parts.
Note that says I'm gonna try to find a more specific place
before I make it apart.
POLLICHINO, STEVEN And when I'm talking about antennas,
aerials, aerials, antennas.
POLLICHINO, STEVEN It's a within a parts provision of 8517,
so an only could be a part of something that gets classified in 8517.
So a television antenna or aerial.
POLLICHINO, STEVEN And since nobody knows what, that's a picture of
and the old days we used to have antennas on our houses,
so we could watch TV.
POLLICHINO, STEVEN It's crazy, right?
So if such a thing still exists?
POLLICHINO, STEVEN That's for television broadcast signals,
so that would go into 85 about a 25 ish.
POLLICHINO, STEVEN And I would not go to 8517 once we get into parts
of 8517, there has to be a part of something.
I would classify an 8517.
POLLICHINO, STEVEN So not all antennas go there, only if they're.
POLLICHINO, STEVEN Going to be viewed as a part of something that goes
in 8517.
POLLICHINO, STEVEN OK.
POLLICHINO, STEVEN So I guess what I'm saying here
is this ruling made this thing an antenna.
This is actually a printed antenna.
POLLICHINO, STEVEN I made this.
This is nice, right?
Little bullseye.
POLLICHINO, STEVEN Get this little polls light is copper tracing
that would be on this.
POLLICHINO, STEVEN Insulated base.
POLLICHINO, STEVEN Is create a use of a uh printing type process?
POLLICHINO, STEVEN Accuracy copper antenna padded
on a laminated substrate aboard.
POLLICHINO, STEVEN It's a surface mount component that's used.
POLLICHINO, STEVEN And it's going to be cited onto a circuit board assembly.
POLLICHINO, STEVEN This component does not incorporate
any other electric elements, don't active elements.
There are no passive elements, there's no modulator or demodulator.
POLLICHINO, STEVEN Is no amplified is no signal generate.
There's no filters, no switching, because if it had any of that,
I'm looking at that other sub heading and I'm looking at parts.
So all this was was.
POLLICHINO, STEVEN That substrate with a copper design on it.
POLLICHINO, STEVEN The copper access and antenna.
POLLICHINO, STEVEN Being that this is a piece of device does no way shape
or form, this is doing anything else.
This could be a part on the 8517, assuming this is going into an article
of 8517, some type of transmitter, receiver, some kind of telephone.
POLLICHINO, STEVEN Another type of part that we've done in 8517.
POLLICHINO, STEVEN Not the aerial one, but the other.
POLLICHINO, STEVEN Had a hinge for a cell, a folding cell phone.
POLLICHINO, STEVEN And the hinge was drilled out and modeled
and specifically made to only go in these type of cell phones.
POLLICHINO, STEVEN It couldn't be used anywhere else.
Wasn't an article of general use.
POLLICHINO, STEVEN So that was pretty much the only other.
POLLICHINO, STEVEN Part I could find that when 8517 other
because it wasn't an aerial by 8517 parts versus aerials
and this other this is an other type of part.
POLLICHINO, STEVEN And that's it.
POLLICHINO, STEVEN So I think that's it.
POLLICHINO, STEVEN I hope some of it made sense.
If not, you could always shoot me an email.
POLLICHINO, STEVEN Steven Steven dot.
POLLICHINO, STEVEN POLLICHINO.
POLLICHINO, STEVEN That's POLLICHINO at cbp.dhs.gov.
I'll do my best to answer you.
You may have to email me twice.
We're very busy here.
POLLICHINO, STEVEN Umm.
POLLICHINO, STEVEN Betted Ultra joking aside,
I hope this helped you out a little bit.
POLLICHINO, STEVEN Umm.
POLLICHINO, STEVEN Just keep in mind, stay
at the level only compare like levels and then when you get to another.
POLLICHINO, STEVEN That can only be what's not included above.
POLLICHINO, STEVEN Don't bounce around
between different levels and others and different headings.
It gets confusing.
POLLICHINO, STEVEN I think that's it.
POLLICHINO, STEVEN Please email any questions UM.
POLLICHINO, STEVEN I've gone over my hour because I Babble a lot.
POLLICHINO, STEVEN I hope my Babble was a little bit entertaining.
POLLICHINO, STEVEN If not, let me know so I could brush up for next year.
POLLICHINO, STEVEN I think that's all like I'm trying to think.
Keep an eye out on cross what you're querying across what you search,
search and cross.
Take it with a grain of salt.
At the time it was probably correct.
Times change, tariff changes.
POLLICHINO, STEVEN A change in a tariff will throw
all the tariff numbers off possibly, and all the notes off the numbers.
So when you're reading, especially if you know and you have a headquarters or
and IS Nashmi specialty, his ruling and it says as per Note 3 this chapter 40
and you go there Note 3 has nothing to do with what you're just talked about.
You know why when that crazy things change?
POLLICHINO, STEVEN Alright, I wanna thank everybody for tuning in.
POLLICHINO, STEVEN I hope somehow this helps.
POLLICHINO, STEVEN You making that stuff up about the antennas atop.
Yeah.
No, believe it or not, used to have antennas on top of our house.
And then in a bad storm, they would blow off and you would have no TV reception.
POLLICHINO, STEVEN And you could have banged
that tube TV device all you want.
You weren't getting nothing.
POLLICHINO, STEVEN That's fine, very good.
POLLICHINO, STEVEN Alright.
Thanks everybody.
I'm gonna go now.
It's been way too long.
I can't believe you stuck with me because I'm listening to my own voice
and he's headphones and I hate it.