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<tr><td><b>Comment Number: </b></td><td>526363-00046</td></tr>

<tr><td><b>Received: </b></td><td>11/16/2006 2:44:37 PM</td></tr>

<tr><td><b>Organization: </b></td><td></td></tr>

<tr><td><b>Commenter: </b></td><td>Lewis Bryson</td></tr>

<tr><td><b>State: </b></td><td>PA</td></tr>

<tr><td><b>Agency: </b></td><td>Federal Trade Commission</td></tr>

<tr><td><b>Rule: </b></td><td>Alcohol Reports</td></tr>

<tr><td>No Attachments</td></tr></Table>

<hr><P><b>Comments:</b></p>I'd like to state my oppostion to these requests for information to beverage alcohol industry. The FTC has done a number of studies on this issue, some comprehensive, some more focused like the recent one on the advertising of flavored malt beverages, and in each case, the findings have clearly shown that the beverage alcohol industry is NOT marketing to underage drinkers. 


This additional request is the result of continued, dinning pleas of anti-alcohol groups like CPSI, PIRE, and CAMY. They ask for these investigations all the time, for obvious reasons. First, they cost the beverage alcohol industry money to complete, which is a benefit in the eyes of anti-alcohol organizations. Second, these organizations know that all they have to do is get one FTC report that finds against the beverage alcohol industry, and they'll have something to use in their reports and fund-raising requests -- without a year of publication, qualifying statements, or any other context -- forever.


Don't give in to this obvious manipulation. The legal drinking age of 21 is an artificially precise dividing line: how do you advertise legally to a person who just turned 21 without appealing to someone who is underage at 20 years, 11 months, and 27 days? It has been shown many times, by many studies, that advertising does not induce someone to buy a product, but persuades someone to change their brand selection. That is what booze ads are all about: You, customer, are already drinking; why not drink our brand?


No one wants to see young teens drinking, not the most hardened, cynical executive. But does that mean that all public media must be restrained to the level of the Disney Channel? No, in fact, according to judgments already on the books, it does not. Booze ads do no harm. Most anti-underage drinking programs do no good. Instead of wasting federal dollars, time, and talent on another witch hunt, why not take a truly fresh look at ways to reduce underage drinking? Just a thought. </body></html>