Cigarette Smoking Causes Disease

¶510. Cigarette smoking and exposure to secondhand smoke (also known as environmental tobacco smoke or "ETS") kills nearly 440,000 Americans every year. The annual number of deaths due to cigarette smoking is substantially greater than the combined annual number of deaths due to illegal drug use, alcohol consumption, automobile accidents, fires, homicides, suicides, and AIDS. Approximately one out of every five deaths that occur in the United States is caused by cigarette smoking. TLT0960104-0112 at 0104 (US 87047) (Centers for Disease Control and Prevention, Smoking-Attributable Mortality and Years of Potential Life Lost -- United States, 1994, MMWR, 46(20) (1997)); VXA1000001-0604 (US 77217) (Thun M., Myers D., Day-Lally C., Namboodiri M., Calle E., Flanders W.D., Adams S., Heath Jr. C., Age and the Exposure-Response Relationships Between Cigarette Smoking and Premature Death in Cancer Prevention Study II, Chapter 5, Smoking and Tobacco Control Monograph 8: Changes in Cigarette-Related Disease Risks and Their Implications for Prevention and Control, National Institutes for Health – National Cancer Institute, p. 383-476 (1997)); TLT0930001-0949 (US 88621) (2004 Surgeon General Report).

250

¶511. Cigarette smoke contains carbon monoxide, nitrogen oxides, cyanide, benzopyrenes, radioactive polonium, arsenic, aldehydes, nitrosamines, numerous toxins, and other human carcinogens. Samet WD, 22:15-23:10. Carcinogens and toxins are absorbed into the bloodstream when cigarette smoke is inhaled. Samet WD, 23:11-24:3.

¶512. Cigarette smoking causes lung cancer. VXA1601844-2232 at 1986 (US 64057) (1964 Surgeon General Report). Lung cancer kills 160,000 Americans each year, and 90% of all lung cancer cases are caused by cigarette smoking. The five-year survival rate for lung cancer is only 14%. Samet WD, 71:18-22, 80:1-3; Carmona WD, 1:18-21.

¶513. The risk of developing lung cancer increases with an increase in smoking. Individuals smoking ten to twenty cigarettes per day have a ten-fold increased risk and individuals smoking forty or more cigarettes per day -- two packs and over -- have more than a twenty-fold increased risk of developing lung cancer. This rate of risk is referred to as "relative risk." Samet WD, 64:17-67:19; (no bates) (US 17141).

251

¶514. Cigarette smoking, including exposure to secondhand smoke, causes cardiovascular disease, including myocardial infarction (commonly known as "heart attack"), coronary heart disease ("CHD") and atherosclerosis. CHD refers to diseases which affect the blood vessels of the heart. CHD can cause a deprivation of oxygen to the heart, and thus, cause heart attacks. Atherosclerosis refers to the development of plaque on the arteries, which contributes to the blocking of blood flow to the heart. Samet WD, 107:18-118:21; (no bates) (US 17165); (no bates) (US 17158); (no bates) (US 17134); (no bates) (US 17159); (no bates) (US 17160); (no bates) (US 17204).

¶515. Cigarette smoking causes chronic obstructive pulmonary disease ("COPD"). Samet WD, 81:4-90:21.

¶516. COPD, previously referred to as "emphysema" or "chronic bronchitis," was found to be causally related to smoking in 1964. Id. at 81:10-83:14; VXA1601844-2232 at 1986 (US 64057) (1964 Surgeon General Report).

¶517. Cigarette smoking causes bladder cancer. Samet WD, 90:22-91:4; 97:5-98:17; (no bates) (US 17103).

¶518. Cigarette smoking causes cerebrovascular disease. Samet WD, 118:21-120:18, 121:15-122:14.

¶519. Cigarette smoking causes esophageal cancer. Id. at 90:22-91:4, 94:5-95:13. Cigarette smoking causes kidney cancer. Id. at 90:22-91:4, 98:18-101:4.

¶520. Cigarette smoking causes laryngeal cancer. Id. at 91:5-92:21.

¶521. Cigarette smoking causes oral cancer. Id. at 92:22-94:4.

252

¶522. Cigarette smoking causes pancreatic cancer. Id. at 90:22-91:4, 95:14-97:4.

¶523. Cigarette smoking causes peptic ulcer disease. Id. at 125:10-127:3.

¶524. Cigarette smoking causes aortic aneurysm. Id. at 122:15-125:9.

¶525. Cigarette smoking causes cataracts. Id. at 127:4-128:8.

¶526. Cigarette smoking causes low bone density in post-menopausal women. Id. at 128:9- 129:22.

¶527. Cigarette smoking causes reduced fertility. Id. at 130:12-131:23.

¶528. Cigarette smoking causes adverse reproductive outcomes, including pre-mature rupture of the membranes, placenta previa, placental abruption, pre-term delivery and shortened gestation, fetal growth restriction and low birth weight. Id. at 130:20-132:9.

¶529. Cigarette smoking causes acute myeloid leukemia. Id. at 101:5-102:23.

¶530. Cigarette smoking causes stomach cancer. Id. at 103:1-104:9.

¶531. Cigarette smoking causes uterine and cervical cancer. Id. at 104:10-105:15.

¶532. Cigarette smoking causes liver cancer. Id. at 105:16-106:9.

¶533. Cigarette smoking causes diminished health status. Id. at 132:15-135:20.