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Philip Morris traditionally has strongly opposed regulation of cigarettes by the U.S. Food and Drug Administration (FDA) until 1997, after which time PM completely reversed itself and started actively aggressively seeking FDA regulation, but on its own terms. PM called the effort its ''Regulatory Strategy Project''. PM's Core Principles of regulation (what it would accept and what it would not) were laid out in 1999 and included preventing FDA from requiring unpalatable modifications to cigarettes, preventing FDA from banning cigarettes, keeping FDA from regulating marketing and sales by using the 1998 Master Settlement Agreement as a shield, attempting to include an element of state preemption in the regulations <ref>Philip Morris [http://legacy.library.ucsf.edu/tid/nst52c00 Sound Bites] Attorney work product. December 22, 1999. Bates No. 2075733351</ref> and appearing to regulators and the public to want to "Focus on dialogue rather than present specific proposals."<ref>Philip Morris [http://legacy.library.ucsf.edu/tid/yko84a00 Talking Points Our Position on Federal Regulation of Cigarettes] Report. April 11, 2000. Bates No. 2081523047/3048</ref> Despite wanting to appear as though it was not presenting specific proposals, [[Mark Berlind]] of PM commissioned the industry law firm of [[Arnold & Porter]] to draft PM's favored proposed FDA legislation.<ref>Jack Holleran, Philip Morris Management Corporation [http://legacy.library.ucsf.edu/tid/iwp65c00 FDA Legislation] Memorandum. August 2, 2000. Bates No. 2081522996</ref> The Arnold and Porter draft contained all of PM's core principles <ref>[http://legacy.library.ucsf.edu/tid/rst52c00 A bill to provide for the regulation of cigarettes and smokeless tobacco products by the Food and Drug Administration under a separate chapter of the Food, Drug, and Cosmetic Act] Draft legislation. 27 pp. January 31, 2000</ref>

<tdo>search_term="Regulatory Strategy Project"</tdo>