In the June 1954 "Public Relations Report and Recommendations for Tobacco

¶Industry Research Committee," Hill & Knowlton described the success of its public relations efforts for TIRC:

Committee headquarters is steadily gaining recognition as a source of authoritative information on the subject of tobacco and health. The result is that news and magazine writers, columnists and commentators are turning to the Committee and its public relations counsel for more and more information.

¶TLT0901558-1563 at 1559 (US 88394); 514806129-6131 (US 20860).

Timothy Hartnett became the full-time chairman of TIRC on July 1, 1954, the day after his retirement as President of B&W, and continued to advance the Defendants' "open question" position in that role. In the press release generated by Hill & Knowlton announcing his appointment, Hartnett repeated the two commitments that TIRC had made in its Statement of Purpose and in its bylaws, i.e., (1) to carry on "comprehensive and objective scientific and statistical research to establish the facts," and (2) "report them to the public." After stating that the "tobacco industry is determined to find the answers to the public's questions about smoking and health," Hartnett continued:

It is an obligation of the Tobacco Industry Research Committee at this time to remind the public of [some] essential points: (1) There is no conclusive scientific proof of a link between smoking and cancer; (2) Medical research points to many possible causes of cancer; . . . (5) The millions of people who derive pleasure and satisfaction from smoking can be reassured that every scientific means will be used to get all the facts as soon as possible.

¶Brandt WD, 56:12-23; TLT0901831-1832 (US 88398).

Wilson Hoyt, who was initially a Hill & Knowlton employee with no scientific background whatsoever, held positions as TIRC/CTR Executive Secretary, Executive Director,

¶Executive Vice President, and President in his three decades with TIRC/CTR. Brandt WD, 58:2359:2. In his 1955 administrative reports as TIRC Executive Secretary and Hill & Knowlton executive, Hoyt affirmed the intertwined functions of public relations and research in TIRC's program. In his April 1955 report, he wrote:

Essentially, the major purposes of the TIRC are Research and Public Relations. Our job is to maintain a balance between the two, and to continue to build soundly so that at all times Research and Public Relations complement each other. In that way we intend to assume the mantle of leadership and, ultimately, to create a condition where the public will look to the TIRC for answers rather than to others.

¶CTR-TIRC-MIN000033-0052 (US 33006); Brandt WD, 83:9-23. In his January 1955 report, he wrote, "Within this framework we have furthered and coordinated the two major purposes for which the Committee was organized namely, the public relations phase and the research program." CTR-

¶TIRC-MIN000001-0252 at 0018-0032 (JD 093292); CTRMN003816-3835 at 3826 (US 21147).

Despite Defendants' assertion that TIRC/CTR was solely an organization that funded independent research for the purpose of finding answers to smoking and health question, it served to a great extent as an effective public relations tool and information conduit. In a July 1963 memorandum, Addison Yeaman, General Counsel for B&W, wrote:

The TIRC cannot, in my opinion, provide the vehicle for such research. It was conceived as a public relations gesture and (however undefiled the Scientific Advisory Board and its grants may be) it has functioned as a public relations operation.

¶689033412-3416 (US 22034); Brandt WD, 116:17-117:22; VXA2510190-0194 (US 63599); 2046754905-4909 (US 20477); Duffin PD, Cipollone v. Liggett, 1/23/86, 118:14-17.

Alexander Spears, Lorillard's Director of Research, in 1974 echoed the sentiments of Addison Yeaman when he explained:

Historically, the joint industry funded smoking and health research programs have not been selected against specific scientific goals, but rather for various purposes such as public relations, political relations, position for litigation, etc. Thus, it seems obvious that reviews of such programs for scientific relevance and merit in the smoking and health field are not likely to produce high ratings. In general, these programs have provided some buffer to the public and political attack of the industry, as well as background for litigious strategy.

¶01421596-1600 (US 20049); 83910516-0520 (US 55955); Brandt WD, 123:14-124:1.

In a 1975 speech to CTR members, Addison Yeaman gave his observations on the Council, noting, "It is my sober judgement that CTR, as it now operates is the greatest public relations asset you have in the problem of tobacco and health." 11303014-3020 at 3017 (US 86005) (emphasis in original). See Section III(D)(2), infra for more discussion of public relations activities.