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 nicotine yields of our products are determined by a combination of the tobacco blends and the 



construction of the cigarette, i.e., length, circiunference, filter, tip ventilation, tobacco density, 



etc. The Federal Trade Commission has reported the results of tar and nicotine analysis by 



brand for years. 



We do not set nicotine levels for particular brands of cigarettes. Nicotine levels follow 

 the tar levels. The easy proof that no nicotine manipulation has occurred may be found in the 

 temporal tar and nicotine data from the 1950's to the 1990's. As shown in Chart I, both tar and 

 nicotine on a sales weighted basis have decreased in a parallel fashion and by the same amount, 

 (reference, U.S. Department of Health and Human Services, "Reducing the Health 

 Consequences of Smoking: A Report of the Surgeon General, " at 88; 1988-1990 numbers based 

 on information similar to that used in the 1989 Surgeon General's Report.) Chart II presents 

 the results of a longitudinal analysis for the latest tar and nicotine results on 483 brands to be 

 reported by the Federal Trade Commission. The correlation coefficient of 0.975 is essentially 

 perfect correlation between tar and nicotine and shows that there is no manipulation of nicotine. 



We do not add nicotine to our products, except in two insignificant and incidental cases: 

 (1) through the use of denatured alcohol, which is required to contain small amounts of nicotine 

 under regulation by the Bureau of Alcohol, Tobacco and Firearms; and (2) through the use of 

 a few flavors which incorporate a tobacco extract that contains some nicotine. The combined 

 amount of nicotine from these sources is too small to be measured in the final products. 



