CLA-2 RR:CR:GC 960560 DWS
Port Director of Customs
1 East Bay Street
Savannah, GA 31401
RE: Protest 1703-97-100078; Telephone Directory Printing Press
Components
Dear Port Director:
The following is our decision regarding Protest 1703-97-100078 concerning your action in classifying and assessing duty
on telephone directory printing press components under the
Harmonized Tariff Schedule of the United States (HTSUS).
FACTS:
The merchandise consists of telephone directory printing
press components contained within four entries. It is claimed
that together, the four entries contain a disassembled reel-fed
offset printing press for the production of telephone directory
pages. The primary components of the press are two mechanized
reel stands, two printing towers, and a double-width folder.
Each reel stand feeds a continuous paper web through one of the
printing towers, where four separate units use an offset printing
process to print both sides of the paper web using four different
colors. After emerging from the printing towers, the two printed
paper webs enter the double-width folder, which folds the paper
webs into two 64 page signatures (groups of pages) to be bound
into telephone directories. Each printing tower consists of four
separate printing units, supported and positioned one above the
other and integrated into a single structure by iron and steel
structural components. The entire printing press measures 76
feet in length, 29 feet in height, 14 feet in width, and weighs
approximately 850,000 pounds.
Because of the size of the printing press, it was
disassembled and packed in four separate shipments shipped on
four different vessels from Germany to Savannah, Georgia. Entry
500-0611664-9 consists mainly of four of the eight printing units
and miscellaneous components. Entry 500-0611830-6 consists
mainly of the other four
printing units and the control desks. Entry 500-0611454-5
consists mainly of the two paper reel stands and miscellaneous
components. Entry 500-0611459-4 consists mainly of the double-width folder and the structural components of the printing press.
The merchandise was entered under subheading 8443.11.50,
HTSUS, as other reel-fed, offset printing machinery. The entries
were liquidated on December 27, 1996, in the HTSUS provisions
describing the goods contained within the entries. Specifically,
for the classification portion of this protest, it is our
understanding that your office classified components in entries
500-0611454-5, 500-0611664-9, 5000611459-4, and 500-0611830-6,
including the girders, frames, and other structural components of
the printing press structure, under subheading 7308.90.95, HTSUS,
as other structures. Drive motors and motors for circumferential
register and chain drives contained in entry 500-0611830-6 were
liquidated under subheading 8501.40.60, HTSUS, as other AC
motors, single-phase. For entry 500-0611454-5, in a Customs Form
29 (Notice of Action) dated December 10, 1996, claimed that the
components contained therein are commingled, stating that
sufficient information on the components was not furnished by the
protestant, Stevens Graphics, Inc. (Stevens). The protest was
timely filed on March 26, 1997.
In the amended protest, Stevens states that it imported an
offset printing press from Koenig & Bauer-Albert, A.G./Motter
("KBA") in Germany, and that most of it was imported in four
shipments. It is claimed that per KBA's arrangements, other
third party suppliers delivered portions of the printing press to
Stevens in Atlanta, Georgia, and were not included as part of the
four shipments at issue. Stevens claims that the articles in KBA
invoice 96/037 were not actually contained in the entries, at
issue, but that Stevens erroneously included the value of the
goods in the entry summaries. The articles claimed to be not
dutiable because they were not imported or because they were
imported duty paid are as follows:
Certain Allen-Bradley electrical control cabinets in the
amount of $1,020,000, manufactured by Allen-Bradley in
Wisconsin and shipped directly from Wisconsin to Atlanta;
16 Ryco water control cubicles manufactured by Ryco in
Illinois and shipped directly from Illinois to Atlanta;
Cut-off controls, web-break detectors, web guide systems,
and color-to-color register devices manufactured by Web
Printing Controls, in Illinois, also shipped directly from
Illinois to Atlanta;
Ink levelers and ink agitators manufactured by Master Flo
Technology ("Master Flo") in Canada, shipped directly from
Canada to Atlanta and duty paid by Master Flo; and
Roll handling system from MEG, S.A. a French company, which
MEG purchased from HOVAIR Systems, in Seattle, Washington,
who manufactured the roll handling system and shipped it
directly from Seattle to Atlanta
Stevens also claims that 16 Allen-Bradley electrical control
cabinets were exported from Wisconsin to KBA in Germany, where
KBA assembled them into the printing units for the printing
press, and should be eligible for duty-free treatment under
subheading 9802.00.80, HTSUS. Stevens states that it originally
believed that 16 "control cubicles" in KBA invoices 96/032 and
96/036 were 16 Ryco water control cubicles. Steven now amends
its protests since the Ryco water control cubicles were actually
in KBA invoice 96/037, and the 16 "control cubicles" in KBA
invoices 96/032 and 96/036 were actually the electrical control
cabinets manufactured by Allen-Bradley in Wisconsin.
Stevens states that the Allen-Bradley electrical control
cabinets were first sold to an Allen-Bradley affiliate in Germany
for $245,000, who sold them to KBA for $245,000, and that the
value of the electrical controls upon importation was the same as
their value when originally exported to Germany. Stevens states
that KBA assembled the electrical control cabinets onto the
printing units by mechanically attaching them to the printings
units using nuts, bolts, and hinges, and by electrically wiring
the electrical control cabinets into the printing units. It is
stated that the KBA assembly process amounted to nothing more
than attaching the Allen-Bradley electrical control cabinets to
the sides of the printing units and connecting the required
wiring.
Stevens states that it has been unable to obtain the exact
date or port from Allen-Bradley when the electrical control
cabinets were exported from the U.S., but it is believed to be
sometime between December 8, 1995, and March 21, 1996. Stevens
states that it then imported the electrical control
cabinet/printing unit assemblies in entries 500-0611664-9 and
500-0611830-6. A declaration from Heinz Schmid on behalf of the
assembler, KBA, and an endorsement from Stevens, the importer,
are included.
ISSUE:
Whether the components contained in the four separate
entries together constitute an incomplete and unassembled reel-fed, offset printing press, imparting the essential character of
a complete printing press.
Whether the paper reel stands and double-width folding
machine are classifiable under subheading 7308.90.95, HTSUS, as
other structures of iron or steel, or under subheading
8443.60.00, HTSUS, as machines for uses ancillary to printing.
Whether certain components contained in entries 500-0611664-9 and 500-0611830-6 impart the essential character of complete
reel-fed, offset printing presses classifiable under subheading
8443.11.50, HTSUS, as other reel-fed, offset printing machinery.
Whether the remaining components contained in the four
entries are classifiable under subheading 7308.90.95, as other
structures of iron or steel, or under subheading 8443.90.50,
HTSUS, as parts of printing machinery.
Whether the electrical control cabinets qualify for the
partial duty exemption under HTSUS subheading 9802.00.80, when
imported into the U.S.
Whether enough evidence is submitted to substantiate that
the articles on KBA invoice 96/037 are not subject to duty.
LAW AND ANALYSIS:
CLASSIFICATION
Classification of merchandise under the HTSUS is in
accordance with the General Rules of Interpretation (GRI's). GRI
1 provides that classification is determined according to the
terms of the headings and any relative section or chapter notes.
The 1996 HTSUS provisions under consideration are as
follows:
7308 Structures (excluding prefabricated buildings of heading
9406) and parts of
structures (for example, bridges and bridge sections, lock
gates, towers, lattice
masts, roofs, roofing frameworks, doors and windows and
their frames and
thresholds for doors, shutters, balustrades, pillars and
columns) of iron or steel;
plates, rods, angles, shapes, sections, tubes and the like,
prepared for use in
structures, of iron or steel:
7308.90 Other:
Other:
7308.90.95 Other.
* * * * * * * * *
8443 Printing machinery, including ink-jet printing machines,
other than those of
heading 8471; machines for uses ancillary to printing; parts
thereof:
Offset printing machinery:
8443.11 Reel-fed:
8443.11.50 Other.
8443.60.00 Machines for uses ancillary to printing.
8443.90 Parts:
8443.90.50 Other.
* * * * * * * * *
We will first consider whether, in accordance with GRI 2(a),
the components contained in the four separate entries together
constitute an incomplete and unassembled reel-fed, offset
printing press, imparting the essential character of a complete
printing press (we use the term incomplete as counsel states that
some components of the printing press are sourced in the U.S.).
GRI 2(a) states that:
[a]ny reference in a heading to an article shall be taken to include a
reference to that article incomplete or unfinished, provided that, as
entered, the incomplete or unfinished article has the essential
character of the complete or finished article. It shall also include a
reference to that article complete or finished (or falling to be
classified as complete or finished by virtue of this rule), entered
unassembled or disassembled.
In HQ 954820, dated December 13, 1993, which dealt with
whether two separate shipments of printing press components
together constitute a complete and unassembled printing press, we
stated that:
[i]t is well settled that articles which are not imported together are
precluded from being an
entirety. U.S. v. Baldt Anchor, Chain & Forge Division of Boston Metals
Co., 59 CCPA 122,
C.A.D. 1051, 429 F.2d 1403 (1972). The term "entirety", which was used
in the Tariff Schedules
of the United States (TSUS), is embodied in GRI 2(a) of the HTSUS. *****
The shipment of the
various parts and the shipment of the main printing head do not together
constitute a complete
and unassembled flexographic printing press. The two shipments arrived
at the port of Savannah
on two different dates, and, under Baldt Anchor, they cannot together
constitute a complete
printing press as if the shipments were entered at the same time. The
fact that the main printing
head was intended to be included in the subject shipment is irrelevant
as to the classification of
the subject parts. See HQ 081999, dated December 10, 1990.
With regard to the subject components, they were packed in
four separate shipments, shipped on four different vessels, and
entered on four different days. Therefore, in keeping with the
reasoning in HQ 954820, it is our position that the subject
components together do not constitute an incomplete and
unassembled printing press imparting the essential character of a
complete reel-fed, offset printing press classifiable under
subheading 8443.11.50, HTSUS.
As stated above, for entry 500-0611664-9, your office, in a
Customs Form 29 Notice of Action dated December 10, 1996, claimed
that the components contained therein are commingled, stating
that sufficient information on the components was not furnished
by the protestant, Stevens Graphics, Inc. (Stevens). However,
based upon a
review of the documentation provided by your office, it is
inconclusive whether the components contained in the entry
constitute a commingling of goods. See General Note 17, HTSUS.
Counsel for Stevens states that all the goods contained in
entry 500-0611454-5 are parts of the subject printing press and
therefore should be classifiable under subheading 8443.90.50,
HTSUS. However, apart from reiterating that the components are
integral to the operation of the press and specially designed for
use with the printing press, we find that no convincing evidence
has been provided demonstrating such. Based upon a review of
counsel's attachments and the provided entry documents, it
appears that the components are mostly general purpose in nature,
capable of use with other products. For instance, counsel has
attached a depiction of the completed printing press. The
depiction indicates that a number of the structural elements
(i.e., I-beams, railings, and walkways) are standard structural
elements which do not appear to have been modified for use
specifically with the subject printing press. The articles
appear to be capable of use in various types of structures or as
support elements for various types of machinery. Because it is
our position that requisite information has not been provided
concerning the proper classification of the components contained
in the entry, with the exception of the paper reel stands, it is
our position that the components remain classifiable in heading
7308, HTSUS, as liquidated. See section 174.13, Customs
Regulations (19 CFR 174.13).
Counsel, as an alternative claim, argues that the paper reel
stands are classifiable under subheading 8443.60.00, HTSUS. In
understanding the language of the HTSUS, the Harmonized Commodity
Description and Coding System Explanatory Notes may be utilized.
The Explanatory Notes, although not dispositive or legally
binding, provide a commentary on the scope of each heading of the
HTSUS, and are generally indicative of the proper interpretation
of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128
(August 23, 1989). In part Explanatory Note 84.43 (pp.1339 -
1341) states:
*****
The heading also covers:
(1) - (2) *****
(3) Ancillary machinery (whether or not presented separately) such as
feeders and folding
machines, provided they are specially designed as ancillary
machines to printing
machines.
(I) *****
(II) MACHINES FOR USES ANCILLARY TO PRINTING
This group covers machines (whether or not presented separately) for
uses ancillary to printing
exclusively designed to operate with printing machines and used during
or after the printing
operation for feeding, handling or further working the sheets or rolls
of paper.
As it is our understanding that the paper reel stands are
designed for attachment to the printing press and serve to supply
a continuous paper web to the printing press towers, we agree
with counsel that they meet the description above for machines
for uses ancillary to printing and are classifiable under
subheading 8443.60.00, HTSUS. It is also our position that the
double-width folding machine, contained in entry 500-0611459-4,
is a machine for uses ancillary to printing classifiable under
subheading 8443.60.00, HTSUS. See NY 803750, dated November 23,
1994, which held reel stands and folders to be classifiable under
subheading 8443.60.00, HTSUS.
We will now deal with the classification of the printing
units contained in entries 500-0611830-6 and 500-0611664-9.
Counsel claims that, in accordance with GRI 2(a), the printing
units impart the essential character of a complete printing
press.
In HQ 954820, we also held that printing press components,
imported together without the printing head, do not impart the
essential character of a complete printing press. In the ruling,
we stated that:
[t]he essential character of the printing press is not imparted by the
shipment of various parts,
but by the main printing head. Without the main printing head, it would
be impossible for the
printing press to function as intended. Therefore, the main printing
head plays the primary role
in relation to the use of the printing press.
It is our understanding that each printing unit is
equivalent to the print head in HQ 954820. Therefore, we find
that the printing units and the drive motors and motors for
circumferential register and chain drives contained in entry 500-0611830-6, and the printing units in entry 500-0611664-9, impart
the essential character of complete reel-fed offset printing
presses and are classifiable under subheading 8443.11.50, HTSUS.
As with the components in entry 500-0611454-5, with regard
to the remaining components in entries 500-0611830-6 and 500-0611664-9, because it is our position that requisite information
has not been provided concerning their proper classification, it
is our position that those components remain classifiable in
heading 7308, HTSUS, as liquidated.
With regard to the components under protest contained in
entry 500-0611459-4, it appears that, based upon a review of the
relevant entry documents, they are mostly general purpose in
nature. They are standard structural elements which do not
appear to have been modified for use specifically with the
subject printing press. The articles appear to be capable of use
in various types of structures or as support elements for various
types of machinery. Again, it is our position that those
components remain classifiable in heading 7308, HTSUS, as
liquidated.
SUBHEADING 9802.00.80, HTSUS
Subheading 9802.00.80, HTSUS, provides a partial duty
exemption for:
[a]rticles ... assembled abroad in whole or in part of fabricated
components, the product of the United States, which (a) were
exported in condition ready for assembly without further
fabrication, (b) have not lost their physical identity in such
articles by change in form, shape or otherwise, and (c) have not
been advanced in value or improved in condition abroad except by
being assembled and except by operations incidental to the
assembly process, such as cleaning, lubricating and painting.
All three requirements of subheading 9802.00.80, HTSUS, must be
satisfied before a component may receive a duty allowance. An
article entered under this tariff provision is subject to duty
upon the full cost or value of the imported assembled article,
less the cost or value of the U.S. components assembled therein,
upon compliance with the documentary requirements of section
10.24, Customs Regulations (19 CFR 10.24).
Section 10.14(a), Customs Regulations {19 CFR 10.14(a)},
states in part that:
[t]he components must be in condition ready for assembly without
further fabrication at the time of their exportation from the
United States to qualify for the exemption. Components will not
lose their entitlement to the exemption by being subjected to
operations incidental to the assembly either before, during, or
after their assembly with other components.
Section 10.16(a), Customs Regulations {19 CFR 10.16(a)},
provides that the assembly operation performed abroad may consist
of any method used to join or fit together solid components, such
as welding, soldering, riveting, force fitting, gluing,
lamination, sewing, or the use of fasteners.
Operations incidental to the assembly process are not
considered further fabrication operations, as they are of a minor
nature and cannot always be provided for in advance of the
assembly operations. See 19 CFR 10.16(a). However, any
significant process, operation or treatment whose primary purpose
is the fabrication, completion, physical or chemical improvement
of a component precludes the application of the exemption under
subheading 9802.00.80, HTSUS, to that component. See 19 CFR
10.16(c).
KBA invoices 96/032 dated April 19, 1996, and 96/036 dated
April 26, 1998, each indicate that "8 control cubicles mounted
to printing unit" (of U.S.-origin - later corrected by Stevens)
were shipped from Germany to Stevens in Atlanta for $122,500
each. Allen-Bradley invoice NBC701-1 dated December 8, 1995,
indicates that 16 unit couple panels (right and left sides) were
shipped from Wisconsin to KBA in Germany for a total of $245,000,
and billed to Allen-Bradley in Germany. German Customs Form 0747
dated March 21, 1996, indicates that the exporter, Allen-Bradley
shipped 16 boxes valued at $245,000 to the importer KBA in
Germany. A declaration dated March 25, 1997, is submitted from
Terry Knapper, Supervisor of Transportation, Drives and Motion
Control of Allen-Bradley, stating that in 1996, Allen-Bradley
sold printing press electrical controls to an Allen-Bradley
affiliate in Germany, which in turn sold them to KBA to be, as
indicated by KBA, incorporated into a reel-fed offset twin tower
Commander printing press which KBA sold to Stevens, in Atlanta.
In a declaration from Heinz Schmid, Vice President of Sales
of KBA dated July 3, 1997, it is indicated that the 16 control
cubicles in KBA invoices 96/032 and 96/036 were actually
electrical control cabinets manufactured by Allen-Bradley in
Wisconsin and that the printing units were assembled in part from
these electrical control cabinets. He states that after being
manufactured in Wisconsin, they were exported to KBA in Germany
in a condition ready for assembly without further fabrication.
At KBA, the electrical control cabinets were assembled onto the
printing units by mechanically attaching them to the printing
units using nuts, bolts, and hinges and by electrically wiring
them into the printing units. KBA did not further manufacture,
fabricate, or process the electrical control cabinets in any way.
The electrical control cabinets, after being assembled onto the
printing units were sold to Stevens Graphics for $245,000.
Based upon the invoices, bills of lading, and declarations
submitted, it is our opinion that sufficient evidence has been
submitted to prove that the electrical control cabinets were
manufactured in the U.S. by Allen-Bradley, such that they may be
considered products of the U.S., and that they were exported to
KBA in Germany. We also find that the operations of attaching
the electrical control cabinets by mechanically attaching them to
the printing units using nuts, bolts, and hinges and by
electrically wiring them into the printing units are acceptable
assembly operations pursuant to 19 CFR 10.16(a). Accordingly, we
find that the printing units may receive a partial duty exemption
under subheading 9802.00.80, HTSUS, with allowances in duty for
the electrical control cabinets. Therefore, this portion of the
protest should be granted.
ARTICLES NOT SUBJECT TO DUTY
Stevens Graphics also asserts that various articles included
on KBA invoice 96/037, and included erroneously on the entries
at issue, were not actually subject to duty because they were
actually shipped per KBA's instructions by third parties from
other areas in the U.S. to Atlanta; or if imported were duty paid
by third parties before shipment to Atlanta.
KBA invoice 96/037 dated April 26, 1996, states that "we
have sent through the sub supplier in U.S.A. insured up to plant
in Atlanta".
A bill of lading dated April 19, 1996, is submitted
indicating the shipment of electrical controls, instruments,
motors and transformers from Allen-Bradley in Wisconsin to Steven
Graphics in Atlanta. Two Allen-Bradley invoices no. NBC701-B3
dated April 12, 1996, and NBC701-B4 dated March 22, 1996,
indicate that various articles, such as a 3 bay motor control
center, auxiliary control enclosure, press control deck, and
custom item were shipped from Allen-Bradley in Wisconsin to
Steven Graphics in Atlanta. In the declaration from Mr. Schmid
of KBA, he also declares that in 1995, KBA sold one twin-tower
reel-feed offset Commander printing press with two M.E.G. reels,
two printing towers, double width folder, and Allen-Bradley
electrical drive to Stevens. Mr. Schmid also declares that the
electrical controls for the press in KBA invoice 96/037 were
manufactured by Allen-Bradley in Wisconsin and that they were
shipped directly from Wisconsin to Atlanta. He also confirms
that the 16 Ryco water control cubicles, cut-off controls, web-break detectors, web guide systems, color-to-color register
devices, ink levelers and ink agitators, and roll handling system
were either shipped from their place of manufacture in the U.S.
directly to Stevens in Atlanta, or were duty-paid by some third
party. The declaration from Mr. Knapper of Allen-Bradley (see
above) also states that Allen-Bradley manufactured the electrical
controls in Wisconsin and shipped them directly to Stevens
Graphics in Atlanta.
A Ryco Graphic Manufacturing invoice 43775 dated May 10,
1996, indicates the sale of a digital plus dampening system and
two folders from Ryco to KBA, but shipment to Stevens in Atlanta.
Web Printing Controls invoice 45945 dated May 24, 1996;
invoice 45942a dated May 24, 1995; invoice 47227 dated August 22,
1996; invoice 47229 dated August 22, 1996; and invoice 45944
dated May 24, 1996; indicate the sale of various articles to
Germany, but all shipped May 3, 1996, to Stevens in Atlanta. A
bill of lading dated May 3, 1996, indicates the shipment of
printing press parts from Illinois to Atlanta.
A Master Flo invoice 5757 dated June 4, 1996, indicates the
sale of ink levellers to KBA but shipped from Canada to Stevens.
A bill of lading dated June 4, 1996, indicates the same. A
Customs Form 7501 shows Master Flo as the importer of the ink
levellers entered on June 4, 1996. The same information is
presented for the ink agitators.
A MEG invoice 961438 dated April 29, 1996, indicates the
same circumstances with respect to the sale of a roll handling
system to KBA with the final customer being Stevens, and the
price is quote "CIF Atlanta (from Seattle/USA)." Additionally, a
HOVAIR invoice 951434-2 dated November 15, 1996, indicates the
sale of an 80" Star System to MEG in France, but shipped to
Stevens on May 29, 1996. A bill of lading dated May 29, 1996,
indicates the shipment from HOVAIR to Stevens.
Based upon the invoices, bills of lading, and declarations
presented, it is our opinion that there is sufficient evidence to
conclude that the various articles included on KBA invoice
96/037, and included erroneously on the entries at issue, were
not actually subject to duty because they were actually shipped
per KBA's instructions by third parties from other areas in the
U.S. to Atlanta, or if imported were duty paid by third parties
before shipment to Atlanta. According, this portion of the
protest should be granted.
HOLDING:
CLASSIFICATION
In accordance with GRI 2(a), the components contained in the
four separate entries together do not constitute an incomplete
and unassembled reel-fed, offset printing press, imparting the
essential character of a complete printing press.
The paper reel stands contained in entry 500-0611-454-5 and
the double-width folder contained in entry 500-0611459-4 are
classifiable under subheading 8443.60.00, HTSUS, as machines for
uses ancillary to printing. With regard to these components, as
re-classification of the merchandise as indicated above would
result in the same rate of duty as claimed, you should ALLOW the
protest.
In accordance with GRI 2(a), the printing units and the
drive motors and motors for circumferential register and chain
drives contained in entry 500-0611830-6, and the printing units
contained in entry 500-0611664-9, impart the essential character
of complete reel-fed, offset printing presses and are
classifiable under subheading 8443.11.50, HTSUS. With regard to
these components, the protest should be GRANTED.
The remaining components contained in the entries are
classifiable under subheading 7308.90.95, as other structures of
iron or steel. With regard to these components, the protest
should be DENIED.
SUBHEADING 9802.00.80, HTSUS
On the basis of the information submitted, we find the
sufficient evidence has been submitted to prove that the
electrical control cabinets were manufactured in the U.S. by
Allen-Bradley, and that they were exported to KBA in Germany. We
also find that the operations performed in Germany are acceptable
assembly operations pursuant to 19 CFR 10.16(a). Accordingly, we
find that the printing units may receive a partial duty exemption
under subheading 9802.00.80, HTSUS, with allowances in duty for
the electrical control cabinets.
ARTICLES NOT SUBJECT TO DUTY
On the basis of the information submitted, we find that
there is sufficient evidence to conclude that the various
articles included on KBA invoice 96/037, and included erroneously
on the entries at issue, were not actually subject to duty
because they were actually shipped per KBA's instructions by
third parties from other areas in the U.S. to Atlanta, or if
imported were duty paid by third parties before shipment to
Atlanta.
In accordance with Section 3(A)(11)(b) of Customs Directive
099 3550-065, dated August 4, 1993, Subject: Revised Protest
Directive, this decision should be mailed by your office to the
Protestant no later than 60 days from the date of this letter.
Any reliquidation of these entries in accordance with this
decision must be accomplished prior to mailing of the decision.
Sixty days from the date of the decision the Office of
Regulations and Rulings will take steps to make the decision
available to Customs personnel via the Customs Rulings Module in
ACS and the public via the Diskette Subscription Service, Freedom
of Information Act and other public access channels.
Sincerely,
John Durant, Director
Commercial Rulings Division