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    Imperial Tobacco Limited U
    381C SI-Anioire Stree
    Monirdal. Carpacz
    HAC 1~i!
    (514)932-6161
    Jean-Louis MerC;er
    Chatrman 9"
    Chief Executive 01f1ccer
    Novwabar 15, 1991
    BY F&X1 011-44-71-627-5570
    Mr. Donald Trelford
    Editor
    The Observer
    Chelsea Bridge House
    Queenstown Road,
    London
    SWS 4NN
    Dear Mr. Troltord:
    We have road the article which appeared on the front page
    of your November 10 issue suggesting that Imperial Tobacco Ltd.
    in Canada used its advertising to lure people as young as 12
    years old into imaking.
    The headline is wrong and grossly misleading as is much
    of your article. Imperial Tobacco did not and does not advertise
    to non-smokers or to any one below the legal age to buy
    cigarettes. The documents wore not, an you suggested ' "hiddanw.
    The ago groupings, as presented in the article, misreprasent the
    document I a origin and purpose.
    Here are the facts as they war* presented, in
    unchallenged fashion, during a y r I n txial in Montreal which,
    a - 0 Yn a Quebec Superior court
    the article fails to mantion, re:u1ted
    judgment that the Canadian ban of tobacco advertising is
    unjustifiable in a free and democratic society. (The judgment is
    be nq appealed by the Canadian govox, ant to the Quebec Court of
    10 Appeal, not the Quebec governmant to the Supreme Court as you
    say.)
    The judgment nowhere found anything blameworthy in either
    the advertising or the advertising strategies of imperial
    Tobacco.
    ,Tudge Chabot in his ruling hold that the Government had
    not shown that tobacco advertising causes people to smoks and
    ruled that the Tobacco Products Control Act banning such
    advertising is an unconstitutional restriction of fro* speech
    under the Charter of Rights and Freedoms.
    ... 21
    "N.)
    BAT Industries document for Legal Services : Health Canada 20 October 1999

    




    - 2 -
    Your article implies, through its presantation of our
    documents which show "target group 12 to 17", that this is the
    age of the brand marketing target of some of our brands. That
    implication is false. our marketing plan of that year (1980)
    shows that the Player's brand target group was from the minimum
    legal age for the purchase of cigarettes under Canadian federal
    law to ago thirty.
    The documants you presented are not marketing strategies
    but extracts of media planning documents. The difference in
    important, as was explained to the court and as I am sure you
    well understand. The Print Measurement Bureau is an organization
    that supplies standardized information on readership of magazines
    to any ma-rkater wishing to purchasis such information. Imperial
    Tobacco is one of many organizations that does so. The
    readership of different publications was presented in acme six
    ago groups by the Print Measurement Bureau, from the youngest
    (12-17) to the oldest (65-1-). The photo in your article, for
    whatever purpose, eliminated reference to the groups other than
    the youngest.
    rux-thar, this information vas used prima ily to determine
    jr&au&Z3cv of placement of advertisements. Among the most
    important determinants used by Imperial Tobacco in the selection
    of publications were (i) that the publication accepts tobacco
    advertising (obviously) and, if it does, (ii) that Its editorial
    orayoneral contant not be oriented towards audiences younger than
    th r late teens,
    Nearly all of these facts were given to your journalist
    by our counsel. We would be pleased to continue to help your
    staff to more accurately report this issue.
    I thank you for this opportunit of clarifying the fact
    and would be grateful if you could &bIYah this letter to keep
    the facts straight for your readers.
    0 Yours truly,
    J-L Mercier (Signed)
    J-LM 1 Pt
    Original to fol1cw by post
    BAT Industries document for Legal Services: Health Canada 20 October 1999