"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 [3], 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 [4]. 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 [5] forum, where industry groups proposed a "Biotechnology state uniformity resolution." Previously, the tobacco industry [6] used a similar approach. A Philip Morris [7] 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."