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March 25, 1994 Page 7 



calculation of sales weighted average nicotine deliveries, as 

 depicted in Figure 1.' Figure 1 shows a decline in sales 

 weighted nicotine delivery from around 1 . 4 mg per cigarette to 

 about 0.94 mg in the period 1968-1991. However, nearly all the 

 decline occurred between 1972 and 1980. Since 1980, there has 

 been no change . 



Cigarette manufacturers rely on comparisons based on smoking 

 machine tests to help sell their products. Enclosed with this 

 statement is a recent (1993) advertising insert from the American 

 Tobacco Company for its Carlton brand. The leaflet makes 

 explicit comparisons of various versions of Carlton with brands 

 made by competitors. 



The FTC Method Test is a Fraud 



Despite the cigarette companies' reliance on FTC method test 

 results for cigarette brand promotions, the FTC method test does 

 not provide consumers with a reliable index of the amount of 

 smoke they ingest from a particular cigarette. Unlike all other 

 test results familiar to consumers that are included in the 



' The report of sales weighted nicotine delivery prior to 

 1968 relied upon by Mr. Johnston in his 2/28/94 letter to Dr. 

 Kessler is unavailable to me. The source referenced in the 1989 

 Surgeon General's Report (USDHHS, 1989, page 88) was a private 

 communication from Helmut Wakeh^am of Philip Morris to another 

 investigator in 1976. Neither the 1988 Report nor the chart it 

 references include the actual numerical values being plotted. 

 Unless the analytic methods used are shown to be comparable to 

 those employed for the period 1968-1991, and unless the actual 

 values are available for replotting and analysis, the numbers 

 taken off these charts prior to 1968 should not be used in 

 comparisons with the later time period. 



