"Close to 100 New England towns have passed resolutions opposing the unregulated use of GMOs (genetically modified organisms); nearly a quarter of these have called for local moratoria on the planting of GMO seeds. In 2004, three California counties, Mendocino, Trinity and Marin, passed ordinances banning the raising of genetically engineered crops and livestock." In response, "fifteen states recently have introduced legislation removing local control of plants and seeds. Eleven of these states have already passed the provisions into law." The move to deny local control over food was launched at a May 2004 American Legislative Exchange Council forum, where industry groups proposed a "Biotechnology state uniformity resolution." Previously, the tobacco industry used a similar approach. A Philip Morris employee explained, "By introducing preemptive statewide legislation, we can shift the battle away from the community level back to the state legislatures where we are on stronger ground."