The right to advertise cigarettes online has been the subject of recent Congressional legislation, specifically, the Public Health Cigarette Smoking Act of 1969, 15 including, inter alia compulsory health warnings and last, but not least, prohibition of advertising by means of the electronic media.

Notwithstanding this unique and draconian legislation enacted by Congress, the Federal Trade Commission Staff ("Staff") in its May 1981 "Staff Report on the Cigarette Advertising Investigation" ("Staff Report") proposed various affirmative disclosure remedies in addition to that provided by present 2 lawnd by a number of 1972 Consent Orders and Consent Judgments .