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D R A F T Mr. George F. Martz Chief Investigator Office of the Attorney General Bureau of Consumer Protection 25 S. Third Street Harrisburg, Pennsylvania 17101 Re: Case No. A-74 136 Dear Mr. Martz: Your letter of January 16, 1974 with regard to LUCKY TEN Filter Cigarettes labelling and advertising has been referred to me for reply. As you may be aware, the Federal Trade Conusission periodically tests the "tar" and nicotine content of cigarette brands. The results of such tests show slight variations from test to test and this shows up when the results are published. Cigarette advertisements generally carry the Federal Trade Commission test results last published before the closing date of the advertisement. in order to avoid conflicts with published FTC test results, LUCKY TEN Cigarette Labels, which are ordered in large quantities, contain the statement: "Periodic lab tests have shown the smoke of LUCKY TEN Cigarettes tested to average no more than 10 mgs. 'tar', 0.8 mgs. nicotine". The label thus simply states an outside limit and is not in conflict with any given FTC test result which appears in an

advertisement. I trust the foregoing will resolve this matter. Very truly yours, L. P. Runyon, Jr.