Tobacco Documents Online

~COVINOTON ~,, BURLING (- September 30, 1981 MEMORANDUM TO: Committee of Counsel There is enclose~~/i/81, of the response to the FTC~on thg/cigarette advertising investigation.~ ~ mul±d±ng on the cormnents at the recent meeting of the Committee of Counsel, the draft opens with a section titled "Summary and Conclusions," which sets forth in relatively concise fashion the overall comment on the FTC Staff's paper. This is then followed by tab sections dis- cussing in more detail all the major points. In the tab sections we have attempted to incor- porate all of the specific suggestions received. In a few instances we received what can only be termed "conflicting suggestions" -- for example, one conunent recommended shortening a particular point while another comment on the same matter suggested that the point was important and, if anything, should be further emphasized. In the case of some of these still unresolved areas, we believe that the revamping of the draft, particularly the inclusion of an opening summary, may lead to a different viewpoint on some of the comments. Consequently, we hope that we have re- duced substantially the number of open questions, but request you to review the current draft with care. We would welcome any suggestions on the current draft as promptly as is feasible. In this connection, Dave Cynamon is planning to call certain of you who have raised particular points to discuss them further with you. We are directing this draft to the Committee of Counsel and those individuals who have received the earlier draft enclosed with my memorandum of Septen~ber 18, 1981. We assume that company counsel will make such further distribution of the draft within his own organiza- tion as he deems desirable. Enclosure $ ~2~ ~ cc: Janet £.~B~. M~r. Samuel D. Chilcote, Jr. Arnold Henson, Esq. Edwin J. Jacob, Esq. Horace R. Kornegay, Esq.

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