556 



- 10 - 



The manuscript thus did not conclude that nicotine is 

 "addictive. " 



Moreover, by the time the Philip Morris 

 researcher was ready to publish this information (1983) , 

 the "positive reinforcing" nature of nicotine had 

 already been reported in other published literature. 

 Indeed, the 1988 Surgeon General's Report states that 

 such nicotine reinforcement was "shown conclusively" as 

 early as 1981 . based on government -supported research. 



VI. CONSUMERS ARE NOT MISLED BY THE PUBLISHED 



NICOTINE DELIVERIES AS MEASURED BY THE FTC METHOD 



Contrary to the impression given by Commissioner 

 Kessler that the FTC has somehow adopted a test 

 procedure that misleads the public as to the true levels 

 of tar and nicotine they are inhaling, the routine 

 Analytical Smoking Methods derived from the FTC method 

 are nearly identical to those used throughout the world 

 to measure tar and nicotine deliveries and accurately 

 compare brand deliveries. 



All of the tests are conducted on cigarettes 

 obtained from the marketplace. They are, therefore, the 



