Date: Mon, May 7, 2001 11:37 AM

Subject: Cigarette and Smokeless Tobacco Reports

YES! to requiring continued detailed reporting on advertising expenditures by tobacco companies. Especially, if the FTC cannot forbid the advertising of this health assaulting 'product' altogether.

Please don't stop this reporting! How else will the FTC and the public be able to determine whether advertising continues to inappropriately target our 12-14 year olds, the prime age for addicting teens?

Furthermore, the FTC should be requiring the measurement of ad impacts to ensure that those responding are not children and teens. I suggest this be done via an independent audit funded by ALL tobacco companies. Tracking of children smokers should accumulate data by age ranges from 8 to 21, to determine what age groups are smoking which brands...not just those over 18.

Any advertising for 'legal' tobacco products, i.e. products that we all agree should only be obtained and consumed by adults, should have the ad content restricted to simply the merits of the product itself, and be precluded from association with 'lifestyle' or 'image', the elements essential to suggesting it's 'coolness' to teens. I'd prefer to go as far as recommending that we disallow advertising for brand names and images that don't reflect the nature of tobacco itself, but doubt the FTC would be able to enforce that over all the lobbyist din this will create.

In other words, I suggest that an advertisement about a tobacco product should be able to only speak of and portray elements concerning the tobacco products flavor, quality, packaging, price, along with the obligatory and writ large warnings about the numerous health hazards, the numerous chemicals with addictive and potentially lethal characteristics...but no tobacco user should be shown using it and especially, somehow benefiting socially from it. Since this is a product with grave medical implact, this sort of restriction on speech about the product is required. NO NEW CUSTOMERS must be our motto! The misleading element in current tobacco advertising is the social benefit lie, since there are no social benefits from smoking an addictive, health breaking product. It is not glamorous or sexy or cool. It is a health risk to the user and all those in the same room. It is threatening, not invitingly sexy. It emits hot rapidly spreading and nasty chemicals, not coolness.

Product placement advertising should also be banned or at least monitored and controlled, especially since an overly large and nonrepresentative (statistically) number of people are shown smoking in movies and TV shows. This practise should be banned in any shows not rated X, i.e. for any entertainment potentially viewable by under 18 year olds. This should extend to sporting events as well.

Smokers should no longer be told by tobacco companies they have rights to light up anywhere. The legal right to BUY where ever they can, is not the same as the legal right to USE where ever they want. Instead, the tobacco companies should be required to fund ads explaining common courtesy requires asking those around for clearance before lighting up and deferring if anyone around hesitates or fails to consent. This also should suggest that no one smoke where children are present. This would be akin to the alcohol companies providing advise pieces about not drinking and driving.

Being a part of a declining group incurring and inflicting an disproportional share of our nation's health bill is certainly no social virtue. It is time to sunset this product and it's consequences. We've already paid too much for cleaning up the workplace and landscape, rising medical insurance and medicare costs, and other costs such as wasted productivity, reduced vigor, and social conflict.

All tobacco companies should also have to report, in any advertising, whether they are complying with the federal tobacco settlement terms. This should help surface the newer rogue companies which have been arising post settlement. The newer companies should be prohibited from any advertising, until they contribute significantly to the settlement pool, in the same proportion as the original settling companies.

Steve Armstrong