In August 2012, the Australian High Court dismissed a case of four tobacco companies against the first plain packaging legislation worlwide. In June 2013, Philip Morris West Africa sent a letter to the Togolese government stating, that the Australian High Court came to the view, that plain packaging constitutes a substantial privation of property rights. The dismissing of the case by the court is only mentioned in a footnote. The letter was prompted by the intention of the government to follow the Australian example and consider plain packaging. Philip Morris warned: with such a measure Togo would scare off foreign investors and risk the payment of significant sums for compensation. The threatening letter didn’t fail to have an impact. Until today, cigarette packages in Togo only carry text health warnings on smoking, no images – in a country, where about 40% of the population is illiterate.