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OCR Page 1 of 56PRIVILEGED AND CONFIDENTIAL -- Attorney Work Product
Prepared by SMBD & DOM for POTUS & USDOJ in Anticipation of Litigation
promoted and sold tobacco products by concealing and misrepresenting the highly addictive
nature of cigarettes and smokeless tobacco.
399. Defendant U.S. Tobacco Company makes approximately 90 percent of the oral
snuff and chewing tobacco sold in the United States.
400. As alleged above, smokeless tobacco delivers a similar amount of nicotine as
cigarettes and is equally as addictive. Also as noted above, the smokeless tobacco
manufacturers intend to cause nicotine dependence among consumers through a strategy that
involves promoting lower-nicotine brands with the intent of moving users up to higher, more
addictive brands over time.
401. This graduation strategy is supported by the manufacturers' advertising
practices, which indicate the manufacturers intend to have consumers experiment with low-
nicotine brands and graduate to higher-nicotine brands over time.
402. The FDA's 1995 investigation into nicotine and tobacco products found that,
with respect to smokeless products, "tobacco manufacturers control the delivery of nicotine,"
so that products that deliver lower doses of nicotine are provided to "new users" who are then
encouraged by tobacco marketing to "graduate" to products that deliver "higher doses of
nicotine."
Q. The Human Toll of Cigarette Smoking - A Public Health Crises
1. Health Effects of Cigarette Smoking
403. Over 400,000 Americans die each year from tobacco-related illnesses. This
equates to more than one of every five deaths in the United States.
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