613 



and has knowledge of its dependence producing properties," Dr. 

 Connolly points to a single document which was made available by 

 U.S. Tobacco to plaintiff's counsel prior to the Marsee trial. 

 That document is entitled "Pharmacokinetics of Nicotine and its 

 Major Metabolites in Naive and Habituated Snuff Takers." Dr. 

 Connolly further asserts that "there is only one reason that this 

 type of research would be conducted and that is to understand how 

 the drug nicotine delivered from oral snuff effects the structure 

 and function of the human user as compared to cigarette smokers 

 and in turn assist [U.S. Tobacco] in creating and maintaining 

 dependence on their products among consumers." 



Dr. Connolly misstates the facts both as to who conducted 

 the research, and the purpose for which it was conducted. Both 

 Dr. Connolly's assertion that this research was conducted by U.S. 

 Tobacco and his assertion that its purpose was to "assist [U.S. 

 Tobacco] in creating and maintaining dependence on their products 

 among consumers", are false. 



The research in question was not conducted by U.S. Tobacco, 

 and was neither intended nor used by U.S. Tobacco to develop or 

 manufacture smokeless tobacco products. The research was 

 conducted 15 years ago by a group of independent researchers in 

 the Department of Pharmacology at Pennsylvania State University 

 College of Medicine. For a number of years, the Pennsylvania 



12 



