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=o.A .......... COVINGTON & BURLING .... ~o.. o.~v,,N UNION TRUST BUILDING ~¢.~.0~ ,~ WASHINGTON 5, D. C. Mr. George V. Allen ~o~t~;~.~ O~ President, ~e Tobacco Institute, In~e~ • ~,.~.~=~- Suite gO5 o,: ~. 0i~£~ Washington 6, D.C. ~ Georg-~ : Enclosed is a memor~d~ briefly s~Izlng my dlscuss~on with Carl ~ompson yesterday about the fi~ strip. '~ere appear to be two questions: The ~irst is whether the fi~ strip as reco~ended for modificatien would even remotely sub- Ject the l~stitate to challenge. I ~ satisfied that, .as p~oposed to be modified, It would be metic~ously ac~ate. Moreover, C~I ~pson tells me that he can re-pho~ogr~h ~hese ~wo ~es ~d give you a revified fi~ strip for e~ibition at the Board meeting on the 17th. -'..~e second question Is somewhat double-barrelled. C~ it be ~aid that the fi~ strip, even as revised, is susceptibl~ to such use as wo~d adversely ~fect ~y litigat ien ~ain~t a member, comp.an~? ..... ~ .. o~. gi~.w~ Is extremely remote. .. ~,~ere remains the problem of whether ~d to what e~en[', this proposed modification shoed be checked with the m~:,mbers of the ~gal Co~lttee. ~. - 0043328

COVING'TON g, E~URLING Mr. George V. Allen PRIVILEGED AND CONFIDENTIAL October 5, 1961 Produced as required by the Court's March 7,1998 Order in Page 2 State of Minnesota, et ~1. v. Philip Morris, et al. Court File No.: CI-94-85~ advises me that according to the notes of the dis- cussions c_~f that Committee, the members at least a~tlclpatc receiving a copy of the script. (Here a~ain I am stilN~ baffled as to why if the member Companies get something, the responsibility for e~hlbitlng it to the counsel dc.esn't rest with them. But since the question was raised, and indeed the script exhibited to the Legal Com_~.ittee, I suppose that inquiry is foreclosed). It is my recollection that y.ou had concluded that you v.ould prefer to call Ym. Ramm and simply to tell him that in the light of the discussion of the Committee, you had directed a modification in two of the video ~ra~-.es and that you believed it would eliminate all of the potential difficulties. I presume you would add that counsel for the Institute had reviewed the chan~es ac_.d were sati.~ed with them from the Instituters point of view. Sincerely yours, HTA/pks ~ eric. 0043329