I. INTRODUCTION In 2003, the alcohol beverage industry spent more than $1.6 billion on advertising in measured media outlets, including $394 million on ads placed in magazines. Industry critics allege that these activities intentionally target adolescent audiences and thereby contribute importantly to social problems associated with underage alcohol consumption (Center on Alcohol Marketing and Youth [CAMY] 2005b; Center for Science in the Public Interest 2002). The favored regulatory approach has been to advocate a placement standard based on the youth audience expressed as a proportion of the total audience. For example, the CAMY (2002, 2005a) claims that advertisements in media outlets that reach audiences with more than 15% underage youth result in "overexposure" to alcohol ads. Two reports by the Federal Trade Commission (FTC 1999, 2003) advocate a placement threshold of 25% as a best practice response by alcohol companies, and a report by the National Research Council's Institute of Medicine (NRC 2004, p. 138) argues that the industry should move toward a 15% threshold for television and 25% for other media. Other organizations, such as the American Medical Association (2004), support a total statutory ban of alcohol advertising except for ads placed inside of retail and wholesale outlets. Following the FTC's 1999 report, the major companies in the alcohol industry collectively altered their self-regulatory advertising codes and media buying guidelines: Beer Institute's Advertising and Marketing Code; Wine Institute's Code of Advertising Standards; and the Distilled Spirits Council of the United States (DISCUS), Code of Responsible Practices for Beverage Alcohol Advertising and Marketing. The Wine Institute amended its code in 2000 to adopt a 70% adult placement standard. In October 2003, the beer and spirits codes were amended to require that adults constitute at least 70% of the audience for TV, radio, and magazine advertisements, which represents an increase from the previous 50% adult standard (FTC 2003). Furthermore, the revised beer and spirits codes require that industry members conduct postplacement audits, including a third-party review system for controversial beer and spirits advertisements (DISCUS 2005). Do alcohol advertisements target underage youth? The evidence on the affirmative side is based largely on a series of descriptive reports commissioned by an advocacy group, the CAMY (2002, 2005a). CAMY's studies measure the youth audience as a percent of the total audience for different alcohol brands and media outlets, which are aggregated to obtain measures of advertising exposure per capita for youth and adults. For magazines, CAMY's measures of gross rating points (GRPs) account for an advertisement's frequency and reach (audience composition), but fail to account for audience size. Because underage youth constitute about 15% of the total population, CAMY characterizes any audience containing more than 15% adolescents as youth-oriented. This designation is used regardless of other aspects of placement decisions, such as the number of adults in the audience or the number of adult readers per copy (FTC 2003, p. 32). Further, CAMY's studies are descriptive and based on the simplistic notion that targeting occurs whenever the 15% threshold is exceeded. Magazines such as Popular Mechanics and Sports Illustrated with 17% and 25% youth readership, respectively, are characterized as youth-oriented despite other features of the audience and magazine (CAMY 2002a). In addition to audience size, advertising content and costs are ignored by GRP-based measures. Analytical evidence on youth exposure to alcohol advertisements in magazines is provided by two recent regression studies. Garfield et al. (2003) examined the occurrence (counts) of annual alcohol advertising placements for 35 major magazines that tracked youth readerships during 1997-2001. Ad counts that are 0 were apparently excluded. …