TDC – Tobacco Documentation Centre

TDC – Tobacco Documentation Centre

434. On December 4, 1991, the Tobacco Documentation Centre ("TDC"), was established as a successor entity to INFOTAB. BATCo joined the TDC at its inception. Its charter stated:

The Association has as its purpose the establishment of a forum for exchange of views and information on international tobacco issues by the coordination of data and information in economic, social, scientific and technical areas. The general objectives are to broaden the knowledge of its members. In large part accomplishment of these objectives will be sought by providing information to various national and other tobacco trade associations and by serving as a resource of expertise and data analysis on these subjects of interest to the industry.

¶301159092-9101 (JD 031017); 301159136-9151 (JD 031018); 700495549-5561 at 5550 (JD 031478); Proctor PD, United States, 6/12/02, 16:8-18, 113:7-11; Tully PD; United States, 6/13/02, 38:9-24.

435. The Founding Members of the TDC and subscription levels for each were as follows: Philip Morris International, Inc., 20%; RJR Tobacco International, Inc., 20%; BATCo, 20%; Gallahers, 10%; Reemtsma, 10%; and Rothmans International, 20%. Subscription levels of membership categories were based on annual production. On the unanimous proposal from Charter members, the following persons were unanimously elected to the Board of Directors for 1992: D.J. Bacon of BATCo, L.E. Birks of Gallahers, Richard J. Marcotullio of RJR International, F.J. Moreno of Philip Morris, C.J. Walther of Reemtsma, and A.A. Woods of Rothmans International. 301159092-9101 (JD 031017); 301159136-9151 (JD 031018).

436. The TDC was formed to act as a central information resource for the tobacco industry worldwide. [Predecessor] INFOTAB had an extensive information collection and database, which was considered valuable and worth maintaining.

¶502601564-1567 at 1565 (US 29570).

437. The IEMC and CECCM scheduled meetings from time to time at TDC's offices. 700494467-4471 (US 89139); 2024210630-0631 (US 22868); 2028363540-3549 (US 86604); 2078742951-2951 (US 27724); 2078742947-2948 (US 27721); 2078742962-2963 (US 45192); 900006204-6204 (US 88482); 2051809368-9369 (US 86603).

438. On April 28, 1992, the International ETS Management Committee ("IEMC"), which was comprised of representatives from Defendants BATCo, Philip Morris, and RJR, prepared comments for distribution by the TDC regarding the draft EPA Risk Assessment on the health hazards of ETS. All national manufacturer associations ("NMA") were to use these comments in responding to inquiries regarding the draft Risk Assessment. The document was also provided to TDC member companies. 515622547-2547 (US 20865).

439. TDC distributed the IEMC ETS position papers, dated May 6, 1992, to the NMAs and lead companies, stating that the documents had been cleared for use by Defendants BATCo, Philip Morris, and RJR. TI13040345-0424 (US 86522).

440. On June 19, 1992, Matt Winokur, Director of Corporate Affairs at Philip Morris International, informed Geoffrey Bible, President of Philip Morris, and other Philip Morris employees, that the EPA talking points prepared by Covington & Burling were

also being used by our international competitors and by National Manufacturers Association via the TDC. This coordinated approach to communications is highly desirable. It enables the entire global industry to espouse a common position immediately, an essential element in quickly responding to local government and media.

¶2021173016-3016 (US 20342).

CORESTA – Center for Cooperation in Scientific Research Relative to

Tobacco/Centre de Coopération pour les Recherches Scientifiques Relatives au Tabac 441. The Center for Cooperation in Scientific Research Relative to Tobacco/Centre de

¶Coopération pour les Recherches Scientifiques Relatives au Tabac ("CORESTA") was created following the resolutions approved by the First International Scientific Tobacco Congress held in Paris, France, on September 10, 1955. It was created "[i]n order to operate a permanent Secretariat for international co-operation in scientific studies relative to tobacco." Its registered offices are located in Paris, and every world-wide major tobacco company and tobacco industry organization is a member. Meetings have been held every two years and, as of 1992, CORESTA had approximately 190 members, including Defendants BATCo, Philip Morris, Lorillard, B&W, Liggett, and RJR. 401349241-9242 (US 47550); 401349243-9248 at 9243 (US 21788); 401349330-9333 (US 47575); Stevens WD, 4:3-5.

442. A March 31, 1992 BATCo document described CORESTA's value to the tobacco industry:

It is perceived as being objective, technical and independent. It is this perception which makes CORESTA unique and very valuable. Unlike other organizations, e.g., CECCM[,] it is not regarded as a lobbying organisation of the tobacco industry.

¶401349243-9248 at 9243 (US 21788) .

443. In June 2001, representatives from Defendants Lorillard, Philip Morris, and RJR, along with other delegates from the industry, convened at CORESTA's ETS Sub Group meeting, where they discussed trends in ETS research. In November 2001, the CORESTA Sidestream Task Force, which included representatives from Defendants BATCo, RJR, and Philip Morris, among others, met to review research conducted on sidestream tar and nicotine. 525302822-2823 (US 86526); 525302728-2729 (US 86527); 525776902-6936 (US 86528); 325260347-0362 at 0348 (US 29146); 524596882-6890 at 6883 (US 66571).