Bliley RJReynolds
Memorandum Prepared by RJR in-House Legal Counsel, Transmitted to RJR Managerial Employees, and Copied to An RJR Employee for the Purpose of Rendering Legal Advice Concerning A Regulatory Matter.
Fields
- Author
- Roemer, Henry C. (Jack) (RJR VP; CTR Director)RJR in 1958. He served as Vice President & General Counsel of RJR Legal Dept. in 1970, Senior Vice President & General Counsel of their Legal Dept. 1972-1983, and retired in 1986. Board of Directors 1972-1983; as Senior Vice President, General Counsel, and Secretary from 1982 to the present, as RJR Tobacco Secretary & Director 1958-1970; and as Vice President and General Counsel in 1970.
- Recipient
- Galloway, A.H.
- Smith, W.S. Jr
- Wade, C.B. Jr
- Copied
- Dowdell, J.S.
Document Images
l,~emo to Messrs. A. H. Gall~ay
%',~II llam S. 9mlth
Chas. B. %~ade, Jr. ~'
There have been three continents filed with the Federal
Trade C~,~.~.nlsslon concerning the pending consent orders.
Ro~er Moref~e]d of B~r~in,.~ha:n, Alabama wrote that he
is pleased that the cigarette co'a~,penles hnve agreed to
include war~ings in their printed ads, but that he would
prefer a stronBer wam~in.B and one ~n!ch refers to the recent
evidence that cigarette sn:oklng causes prematurely wrinkled
skln~. His proposed ~am~ing would cons~r,~e 37 words.~
Bruce Kilbourne of Denver, Colorado ~ote he
approves
wholeheartedly of "the proposed black-bordered warnings
on
future cigarette, ads", but that he is sorry the Su~'geon
General's warnln,Bs "could not be more explicit .... "
%:illlam ~4. Rogal, an attorney in ;,,~ashlngton, D. C.,
the Cot~nisslon on February 29 that the Inter-Assoclaticm Counc~1,
which he described as a group of associations vltally interested
|
in advertlsin~, desired to file con~;ents but had been unable
to fully ca~.,,plete and approve their sul~tsslon. He asked that

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the ti~e ~Ithin ~ich the orders re~aln on the public record
for cc~-~ents be extended to March 3, 197P. The
declined to hold open the record in respons~ to his request,
buC stated that anythlnB received on or before ~arch 3 would
receive con~ideratlon by the Ccr~ssion. I do not l:now yet
v~hether or not he su~aItted anything.
~ne rer.~sinlng cc~.~nent received ~yas a letter dated
February ~9 fron~ Warren Braren of New York City. You will
recall that he was for~erly associated with the Code Authority
of the Notlon~l As[~oci~t£on of Broadcasters. According to
recollectlc~, l.~r. Braren left l~tB and has subsequently spoken
out publlcly a~alnst cigarette advert£slng. He re, tilled
before a cor~.~ttee of Con.~ress a few years ago contending that
ci:~rette ~dvertis~.n~ was not adequately regul~ted.
The opening sentc~nce of his eleven pnge dlntrlbe against
the pending consent orders indicates the tenor o~ his comments:
"There is no need in these cou-~ent~ to the Con~Iss~on to
doc~r~ent th~ deception that r~ns fan,ant to this day in c~g~rette
adver~ Is In~."
~le concludes that the pending orders are inadequate in

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that by their lack of "prominence and boldness" they fall to
i~npress forcefully upon the public that cigarette ~n-,oklng is
dangerous; they fall to render ineffective the representations
that s[i~oking is a desirable practice; arid they fall to counter
a~d negate "the deceptive , the~es and representations relating
to relieving anz.leties, filters, quality of the smoke and the
like." His sugBegtlons it~clude the proposal that the warning
be in a type size "no less than 1/2 the height and equal
boldnems of the tallest and boldest type used in the advertisement".
In addition he states that cigarette advertisers "no doubt have
been r;arket testing adm containing the hem] th warning".
suggests that their research might reveal that the warning has
little or no In-~pact, and he states that the C~..,~.,ission should
obtain, by subpoena if necessary, all data pertatnlng to advertls~nB
ca~palgns affected by the pendir~g orders. He also
that the public has no access to the records of the negotiations
which the staff of the C~~iss!on had with the cigarette
manufacturers; he charges that if the public had even a
an~unt of access to the negot~.at~ons a stronger order would
have en;erged. He also con~]alns of the "tobacco lobby on the

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House Co~nlttee on Interstate and Foreign Co~nerce"~ but the
details of his co~.,plalnt in th~s regard are not clear to Me
because part of his letter i~ missing from the copy furnished
Re. ~_ shall obtain the missing portion and advise you further
if It is of interest. In the ~,,eant~e, if you wish to see ~t
I can send you th~ porti~ of hi~ ~etter that I h~ve.
I see no point in attemptinE to answer Hr. Braren's
charges.
H. C. R.
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