In 1990, British lawyer Andrew Foyle wrote a memorandum to British American Tobacco [3] regarding the company's "document retention policy." U.S. government lawyers contend the Foyle memo provides information on tobacco companies' actions "to destroy, suppress or otherwise shield from discovery ... internal research documents concerning smoking and health." The U.S. is seeking release of the memo for use in its $280 billion lawsuit against big tobacco [4]; BAT is claiming attorney-client privilege. A federal district court has ordered BAT to release the memo at least three times, but the company's challenges will delay the memo's potential release until after the U.S. lawsuit.