Tobacco Documents Online

) :1.:1 i' a~. : :i 1.. N, : : ~ l I l''! 1 ;'f :*Kdi' '7Y:>'t:7:. a. "Y. 1+Wa'9=0 December 17, 1970 0 i ) ) ) . Federal Trade Commission Washington, D.C. 20680 Gentlemen: Mr. Harrington, President of this Corporation, has signed the proposed voluntary program for the disclosure of "tar" and nicotine in consumer-directed advertising in the United States on behalf of Liggett & Myers Incorporated. The program is being submitted to the Commission by Horace R.'Kornegay, President ar.d, Executive Director of The Tobacco institute, Inc., with his letter to the Commission dated December 17, 1970. in Mr. Kornegay's letter to the Commission, he states that Liggett & Myers Incorporated would be writing a separate letter to the Commission explaining the basis upon which it is a signa-- tory to the voluntary program submitted. Mr. Harrington has instructed me to inform the Commission that this Corporation will ad.-aere to the proposed voluntary pro- gram submitted, but believes that the inclusion of any point-of- sale material is a serious mistake. First, point-of-sale material constitutes a relatively insignificant part of cigarette adver- tising. Secondly, once the material is placed with jobbers, re- tailers or others, this Corporation has no control over its use, its final placement, or the longevity of its use. Thirdly, we believe that the inclusion of any point-of-sale material will result in numerous occasions, none of which will be within our control, where outdated point-of-sale material will be in place bearing the Commission's test results which could vary signifi- cantly from then currently advertised test results. In conclusi=, we wish to advise the Commission that we fully subscribe to the disclaimers contained in Mr. Kornegay's letter, and that the submission or carrying out of the proposed voluntary program does not constitute an admission by this Corporation that "tar" and nicotine have any relation to human health. Very truly yours, Vice President and General Counsel