Date: Fri, May 18, 2001 4:06 PM

Subject: Cigarette and Smokeless Tobacco Reports

May 17, 2001

Office of the Secretary
Federal Trade Commission
Room 159
600 Pennsylvania Avenue, NW
Washington, DC 20580

Dear Mr. Secretary:

It is extremely important to my Organization that the FTC continues to issue its periodic reports on how much the cigarette companies and smokeless tobacco companies spend each year to market and promote their products. I am the Director of a 150 member non-profit organization that works to protect children from tobacco products. I am also a member of the Government Relations Committee of the VA Unit of the American Cancer Society. In addition, for the past 5 years I have spoken as a health advocate at the annual shareholders meeting of the RJR Tobacco Company. In the years 1997 through 2000, I spoke at the annual shareholders meetings of the Philip Morris Tobacco Company.

The American tobacco companies do not provide the information that is included in the FTC Reports. When the tobacco companies signed the multi-state agreement, the health care community assumed that marketing efforts by the tobacco companies would be reduced. Thanks to the FTC reports, we know that exactly the opposite occurred. In 1999 the tobacco industry spent more that $8.4 billion dollars (22.5 million dollars per day) nationwide on marketing cigarettes. This is hundreds of times greater than the amounts spent by the federal government and by the states in 1999 for tobacco prevention. To permit health professionals to protect their patients from cigarette marketing by American tobacco companies, please continue to provide this information.

I would also make the following suggestions that might make your reports more useful:

1. Include a state-by-state breakdown of the reported marketing expenditures.

2. Include company-specific or even brand-specific marketing expenditure data.

3. Provide subtotals for marketing expenditures for regular versus "reduced-risk" tobacco products. (In spite of their denials, it is clear that American tobacco companies intend for the public to believe that low-tar cigarettes are safer. As recently as last night, a smoker told me, "Doctor, I haven't quit smoking but I have switched to a low-tar cigarette". Marketing by tobacco companies had led him to believe that he had decreased his risk.

4. Include a breakdown of the different types of expenditures the companies make within the existing promotional-allowance and retail-value-added expenditure categories (which account for the vast majority of all promotional spending by the companies).

It would be a tremendous blow to public health were you to decide to discontinue your reports on tobacco industry expenditures to market cigarettes. Please continue them.

With best regards,

David O. Lewis, MD