sample="supplemental" bates="TIMN0457513" isource="ti" decade="1980" class="ue" date="19881119" November 19, 1988 A private citizen has asked this Office whether Minn. Stat. Section 325F.77(4) prohibits the distribution of cigarette "coupons" in Minnesota. Like coupons for other products, cigarette coupons may entitle a consumer to purchase the product at a discount, obtain a free sample of the product, qualify for prizes, etc. The citizen requesting the opinion says she has in her possession cigarette coupons that were included in recent Sunday newspaper supplements, but we have not been advised what the coupons purport to offer or whether they include restrictions. Section 325F.77(4) provides: "No person shall distribute smokeless tobacco products or cigarettes, cigars, pipe tobacco, or other tobacco products suitable for smoking, except that single serving samples of tobacco may be distributed in tobacco stores." Under Section 325F.76 (3), "distribute" means "to give products to the general public at no cost or at nominal cost." The language of Section 325F.77(4) contains no reference to coupons. It refers to the distribution of products. Moreover, we have reviewed transcripts of the committee and floor discussions of H.F. 1283, the bill that became Section 325F.77(4), and we can find no reference to coupons in that legislative history. Accordingly, it is our opinion that Section 325F.77(4) does not prohibit the distribution of cigarette coupons in Minnesota. The value of a cigarette coupon in Minnesota will depend on what the coupon offers. Since retailers, like other persons, are forbidden to "distribute" cigarettes in Minnesota, it would violate Section 325F.77(4) for a retailer in Minnesota to redeem a coupon offering cigarettes at no cost or at nominal cost. On the other hand, it would not violate Section 325F.77(4) for a retailer in Minnesota to redeem a coupon entitling a consumer to purchase cigarette at a discount. Sincerely yours, CONFIDENTIAL: MINNESOTA TOBACCO LITIGATION