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By the time Protocol negotiations began in 2008, the TTCs had already begun to rebrand themselves as part of the solution, rather than perpetrators of the ITT.29 30 In 2007, BAT started to frame the concept of a Protocol as a potential opportunity, stating publicly that it strongly supports the need for [it] and look forward to partnering with governments in the development, negotiation and implementation of an effective () protocol.31 In response, the Framework Convention Alliance (a civil society alliance which aims to strengthen the FCTC and support its implementation) wrote: As it has recently become clear to BAT that it is unlikely to succeed in preventing the development of a protocol on illicit trade, [BAT] now wants to maximize its chances of influencing the content of the protocol.32 Attempts to influence the protocol Initially, despite FCTC Rules of Procedures, Article 5.3, and its guidelines to guard against industry interference, multiple TTC representatives attended the third Protocol negotiation (INB3) (June to July 2009table 1).33 34 The NGO observer, Corporate Accountability (CAthen called Corporate Accountability International), found that 23 of 28 people willing to identify themselves to CA in the public gallery overlooking the main floor of the convention hall were from the TI, including 12 from BAT.33 This was part of a larger number of Activities to Manage RisksWHO Protocol, described in a BAT internal strategy document shortly before INB3 (Figure 1).35 Delegates then decided to exclude the general public (with the exception of NGOs) mid-way through INB3.33 This did little to dissuade TTCs from interfering, however

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