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During the course of my investigation I randomly requested data 

 with respect to brands and time periods, and all of the information 

 requested was provided. For example, while I reviewed all of the 

 ingredients used in the manufacture of Philip Morris cigarettes I 

 randomly chose three brands - Marlboro, Merit Regular and Merit 

 Menthol - and was provided with a list of flavors and processing aids for 

 each brand. I also requested this information for randomly selected time 

 periods and was provided with this information for all three brands 

 currently as well as six months and one year ago. Similarly, data 

 regarding nicotine content for all three brands for all three time periods 

 was produced at my instruction. 



I was permitted to ask any question of any Philip Morris employee I 

 chose, and all inquiries were readily answered. Also, all records that 1 

 requested were readily provided. 



The conclusions of my investigation can be summarized as follows: 



1 . There is nothing I observed in the processing of tobacco or 

 the manufacture of cigarettes at Philip Morris that would 

 materially increase the nicotine in their products above what 

 naturally occurs in the tobacco. 



2. The denatured alcohol used as a processing aid by Philip 

 Morris contains nicotine in the form of nicotine sulfate (SDA- 

 4) as approved by the Bureau of Alcohol, Tobacco and 

 Firearms and 27 C.F.R. § 21.38. Denatured alcohol contains 



