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nicotine in amounts so small that it would be undetectable 

 in the tobacco in the finished cigarette considering the much 

 larger amount of nicotine from the tobacco. This is 

 confirmed by my calculations demonstrating that the 

 nicotine contribution from SDA-4 denatured alcohol is 

 0.0006 to 0.0008 milligrams of nicotine per Marlboro 

 Regular cigarette. 0.0011 to 0.0015 milligrams of nicotine 

 per Merit Regular cigarette and 0.0012 to 0.0023 milligrams 

 of nicotine per Merit Menthol cigarette. The level of total 

 nicotine in these cigarettes ranges from approximately 16 

 milligrams to approximately 13 milligrams. So the amount 

 contributed by the SDA-4 could not be measured against 

 this naturally occurring background. 



3. The commercial tobacco llavoring commonly referred to as 

 "tobacco extract" was used by Philip Morris in 1993 in its 

 Merit Menthol cigarette. This extract contains naturally 

 occurring nicotine in small amounts. No other flavor used 

 by Philip Morris contains nicotine and this flavor was used 

 only in Merit Menthol. The nicotine contribution from 

 tobacco extract to the finished cigarette in which it was used 

 is so small that it does not measurably change the level of 

 nicotine in the cigarette. For example, the maximum 

 possible contribution of nicotine from tobacco extract in 

 Merit Menthol is about 0.0029 milligrams of nicotine per 

 cigarette by my calculations. When this is combined with 

 the nicotine contributed by SDA-4. it would result in a 



