618 



Moreover, there is no set pattern of brand switching among 

 smokeless tobacco consumers. In short, smokeless tobacco 

 consumers remain loyal to a single brand or switch among a 

 variety of brands according to their preference for flavor, cut 

 of tobacco, form and packaging. They do not conform to any so- 

 called "graduation strategy". 



U.S. Tobacco offers smokeless tobacco products suited to the 

 tastes of those consumers who choose to make tobacco a part of 

 their lifestyle. The variety of different U.S. Tobacco products 

 reflects the wide range of consumer preferences in flavor, cut of 

 the tobacco, form and packaging. 



Conclusion 



U.S. Tobacco does not in any way manipulate the nicotine 

 levels in its smokeless tobacco products, nor does it control the 

 nicotine content of its tobacco products before, during or after 

 the manufacturing process. 



Furthermore, U.S. Tobacco does not employ any marketing 

 strategy based upon a theory that consumers can be enticed to 

 begin using low-nicotine "starter" smokeless tobacco products, 

 and subsequently caused to "graduate" to products with higher 

 levels of nicotine. 



17 



