We examined executive deliberations at Philip Morris USA in 2000 to 2002 as the company’s leadership sought to restore legitimacy through a formal corporate social responsibility commitment. Struggling to reconcile responsibility principles with Philip Morris’s history and its products’ deadliness, these executives questioned the purpose and value of Philip Morris itself. Although previous studies have explored Philip Morris’s evolving interest in corporate social responsibility,8–12 none have examined the internal processes by which a tobacco company tries to explicitly address its raison d’être. The evolution of this process at executive levels of the largest US tobacco company suggests that tobacco companies face not only ongoing external public relations concerns, but also internalized legitimacy struggles that may create openings for policy innovation to address the tobacco epidemic more effectively on the supply side.