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0 I ) 0 Matthew L. !rlyers, Esq. 11 own tests show that BARCLAY is perceived as far easier in draw than other ultra-low "tar" brands (Figure 7) -- a fact totally inconsistent with "filter collapse," for, as noted above, when the grooves are blocked, draw resistance is increased. AR~meAl v.«w..v~v+siwL r i t s. s. .. s w 7. .. w• lw lts Figure 7 ) ~

Matthew L. Myers, Esq. 12 I ) I These facts are confirmed by a study performed by Dr. William S. Cain of Yale University. Dr. Cain asked a nonprofessional panel of 25 smokers to rate the taste and draw of BARCLAY, NOW, and a hybrid composed of a NOW tobacco rod and a BARCLAY filter, as compared to their current brands. He then performed a butt study in which the cigarette butts smoked by the panel were analyzed by gas chromatography.* By use of the filter efficiency figures for each cigarette, derived from machine testing, the amount of nicotine actually deliv- ered to the panelists could be calculated. Dr. Cain's findings were dramatic: As Dr. Gio Gori stated at the July 9 meeting, butt studies are accepted in the scientific community as a reliable way to determine whether cigarettes are similar or different in their nicotine delivery. The enclosed articles by Ashton, et al., and by Schulz and Seehofer, are representative of the scientific literature on butt studies. t

-11 Matthew L. Myers, Esq. 13 far less nicotine to the smoker than the NOW filter and rod While BARCLAY delivers virtually the same amount of nicotine as NOW, smokers perceive it to be significantly richer in taste and much easier in draw. Moreover, the hybrid cigarette (BARCLAY filter), which was also perceived to be significantly stronger tasting and easier drawing than NOW, actually delivered indicating that the BARCLAY filter performed better in lowering nicotine than the NOW filter manufactured by R. J. Reynolds. ~~ Bi41 ~ 0.4 r'&.wewrs J!-N~M ~lr •~ o,a r°"""= j N1COTINE i c ~ a 02 p 1 t1Dw i~sr. ! L Qj ~ ~ r ~ ..r ..:N. . '. : ~ i., ,r.q~. _., d,,,1w, a jE-- s>w -~t C ~..,...r 1 ~ ( ~fren9 ~ -- -- -STIMMM ~ ~ N o , M- 63-!! ~ N<H ---1 i r-aoeooe+ .-so.. 1 I 1 U~- 64 N -I a It_~. L I 11 ~ ~+ , d -to r.~-- --•r~~ DRAW i ~ Y I A Figure 8 I W.dc I I DKfieuR N ~i•-N s H ~-- 1d ~ *.60D" 1 ~ D i 1 L--j c.~y

Matthew L. Myers, Esq. 14 As we indicated, in March of this year we told R. J. Reynolds that our butt studies disproved their "collapse" theory, and asked if they had conducted similar tests. When~ they replied that they had not, we suggested that they do so.* If they h•ave, they apparently have not informed the FTC staff or us of their results. BARCLAY's "Tar" and CO Delivery Is Comparable to Other 1 mg Cigarettes Additional proof that BARCLAY delivers increased ( taste, but not increased "t ar" or nicotine in.normal human smoking is found in the results of independent tests con- ducted by Dr. Gio Gori of the Franklin Research Institute.** Dr. Gori measured the amount of cotinine, the metabolite of nicotine, in the blood of smokers who were acclimated to-ultra-low "tar" cigarettes, after they had smoked BARCLAY, CAMBRIDGE and CARLTON. He found that the * We also aske R.J. Reynolds whether they had performed jV any cotinine studies. Their answer was no. Q N ** B&W has made contributions to the Franklin Research N Institute in the past, and is currently participating CA with other cigarette companies in connection with devel- ~ oping research projects to be performed there. ~ ~ ~

: N \ Matthew L. Myers, Esq. 15 amount of nicotine delivered to human smokers by all three brands matched the published deliveries of nicotine as determined by the FTC method. rp"Z= 11ESlARCE IIRE'P2191E. 1961 >ticceiaa Optak•/ci4 SAICZM cuNBImct cxuur= 1 sg. tar 1 eq. tar 1"4. tar llamma eoliaiae (ppas) 212 100 97 pabiish.,d nieotSa. lri.id P.r 1 m9r tas ciqaratte .2 .1 .1 Ratio ef actual tar d.liv.ry to aokas 1.06 1.0 .97 Figure 9 Dr. Gori had also tested the exhaled breath of acclimated smokers after they had smoked BARCLAY, CARLTON and CAMBRIDGE -- all 1 mg. cigarettes by the FTC method. Se found no difference among these three brands in the amount of CO delivered in normal human smoking. Tlt71W= iQlL11RC3 nfSTSSOTE. 1911 3,Vi9Afa VIILQES CO upCawCiq.PPnt ~ACS.i12 Gi01mQ GIILTOM 1 ~Q 1 aQ 1 ~` 2.66 3.11 2.90 Figure 10 And, because CO delivery is also a direct marker of "tar" delivery, he concluded that there is no difference in

Matthew L. Myers, Esq. 16 ( the amount of "tar" delivered to smokers by these three brands. As Dr. Gori stated to the FTC staff, he has concluded, on the basis of these findings, that the introduction of BARCLAY to the ultra-low tar market may be a major step toward meeting the demand of a significant segment of the American smoking public that prefers a lower "tar" product without sacrificing taste. The Filtrona Holder Does Not Provide Reliable "Tar" and Nico- tine Measurements for BARCLAY The Filtrona holder would not, as R. J. Reynolds asserts, achieve more accurate "tar" and nicotine measurements for BARCLAY cirgarettes than the current FTC method. On the .contrary, the Filtrona holder produces far less reliable measurements for BARCLAY, because it crushes the BARCLAY filter in a way that human smokers do not. The publication of "tar" and nicotine deliveries as measured by the Commission's cigarette testing laboratory is the result of voluntary agreement between the Commission and the members of the cirgarette manufacturing industry. The cigarette testing methodology currently in use was developed by the industry in collaboration with the FTC. R. J. Reynolds now asks the Commission to modify that methodology by adopting 0 ~ a test procedure designed to cause competitive harm to one CA cigarette brand manufactured by one member of the industry. ~ ~

Matthew L. Myers, Esq. 17 ( All ultra-low "tar" cigarettes are designed so that dilution is an integral part of the filtration process. All have holes somewhere on the filter. Some have porous filter wrap, and some use porous cigarette paper. Any one smoker can and may reduce the dilution by the way he or she holds the cigarette with hand or lips. One could readily devise a holder that could defeat any one or more of the dilution mechanisms. The real question is which holder most accurately produces results which are consistent with tar deliveries to the average human smoker. The Commission should not change its methodolgy unless compelling evidence proves conclusively that the current methodology is defective and that the proposed new method is superior. As we have shown, R. J. Reynolds' submission falls far short of that standard. R. J. Reynolds would have the Commission inject itself, in a partisan role, into the midst of a competitive contest that is rightly left to the marketplace to decide. Interbrand competition among cigarettes is intense, especi- ally at present -- when the ultra-low "tar" segment of the cigarette market is at the threshold of major growth. The early success of BARCLAY with consumers is based in large N ~ part upon the innovative design of its filter. Innovation, N N an important ingredient of competition, is abhorred by CA ~ ~ ~ CA

Matthew L. Myers, Esq. 18 entrenched market leaders. It is ironic that it is the FTC that is asked to discourage innovation in a competitive market, especially when that innovation promises to advance the process of reducing the amount of "tar" and nicotine being delivered to the American smoking public. For the reasons discussed above, B&W submits that R.J. Reynolds' proposal is utterly without merit, and should be rejected by the Commission. The additional information requested by the FTC staff, along with the curricula vitae of Drs. Kamm, Cain and Gori, are enclosed. This submission is for the confidential use of the FTC staff, but may, in the discretion of the staff, be shared with other tobacco companies or a consultant chosen by the Commission. We are grateful for the opportunity you gave us to tell our side of the story. Sincerely, Martin London