Table 4

Trial quotes related to confounding

Witness	Date	Trial	Quote
Appleton	7 October 1997	Broin v. Philip Morris	“[Koo and Kabat] also concluded that these dietary differences may very well account for the small association that seems to exist in some of these studies of non-smoking spouses with smoking spouses. They even draw the conclusion that this seems to be at variance with the EPA report.”
			“Smokers tend to have diets that tend to increase their risk of lung cancer. And this examined the issue of whether or not non-smokers who live with a smoker also share those same lifestyle and dietary habits.”
Bradley	6 October 1997	Broin v Philip Morris	“For example, if these three items here have been shown to be related both to an increased incidence of lung cancer and to someone smoking in the home; that is, a diet composed of high fat foods, lifestyle factors such as lack of exercise, and also a low fruit and vegetable diet. So those three factors are all related with an increase in lung cancer, and are also associated with people that smoke.”
Appleton	13 March 1998	Dunn v. RJ Reynolds	“Dietary fat is, in fact, associated with lung cancer. There are epidemiological studies that link dietary fact to lung cancer and also red meat is linked to colon cancer.”
Levy	9 March 1998	Dunn v. RJ Reynolds	“In reference to controlling for confounders, “Some of them did for some confounders, some of them did for other confounders, some of them did no control for confounders. As far as I remember, none of them controlled completely for—well, it’s hard to control—none of them controlled for all of the confounders.”
			“[L]ung cancer in women; such as diet, radon, previous history of lung disease, that type of—the type of lifestyle and previous disease exposure.
			“[B]ased on the presence of bias and confounding on the weakness of the association that makes them especially fragile with respect to this…they give very little or no evidence of a causal relationship between environmental tobacco smoke and lung cancer.”