Philip Morris (PM) is a sophisticated company that runs at least ten years ahead of public health authorities in devising strategies to shape its destiny and preserve its future markets. PM knew that sooner or later push would come to shove and public pressure would make the U.S. government try to regulate its products and corporate behavior, especially after the U.S. Department of Justice found PM guilty of 50 years of conspiracy to defraud the public about the dangers of its products. True to form, in 1999 PM started an internal project called the Regulatory Strategy Project to enact Food and Drug Administration (FDA) regulations on the company's own terms. During the project, in 2000, PM generated a "Privileged and Confidential" document listing what the company would require in what it sees as "sensible" FDA regulations.