As CASAA members know, the February 15, 2007 grandfather date, if implemented in the final deeming regulation, would have the practical effect of removing 99.99% of the products currently on the market since all deemed products not on the market as of that date would be forced to file Premarket Tobacco Applications (PMTA), a process so convoluted, time-consuming, and expensive that the FDA itself estimates that only 25 PMTAs will be filed.