Brown & Williamson had claimed to the Secretary of Health and Human Services that it had “a strict policy against promoting cigarettes to persons under twenty-one years of age”—then produced documents outlining a detailed marketing plan aimed at “the young smoker,” for whom tobacco “is not yet an integral part of life,” recommending cigarettes be depicted “as one of the few initiations into the adult world, as part of the illicit pleasure category” including “ ‘pot,’ wine, beer, sex, etc.,” and crafting language that would offer “a means of repressing their
