CONTINGENCIES Tobacco-Related Litigation : Overview. Since 1954, Liggett and other United States cigarette manufacturers have been named as defendants in numerous direct, third-party and purported class actions predicated on the theory that cigarette manufacturers should be liable for damages alleged to have been caused by cigarette smoking or by exposure to secondary smoke from cigarettes. The cases have generally fallen into the following categories: (i) smoking and health cases alleging personal injury brought on behalf of individual plaintiffs ( Individual Actions ); (ii) lawsuits by individuals requesting the benefit of the Engle ruling (  Engle progeny cases ); (iii) smoking and health cases primarily alleging personal injury or seeking court-supervised programs for ongoing medical monitoring, as well as cases alleging that use of the terms  lights  and/or  ultra lights  constitutes a deceptive and unfair trade practice, common law fraud or violation of federal law, purporting to be brought on behalf of a class of individual plaintiffs ( Class Actions ); and (iv) health care cost recovery actions brought by various foreign and domestic governmental plaintiffs and non-governmental plaintiffs seeking reimbursement for health care expenditures allegedly caused by cigarette smoking and/or disgorgement of profits ( Health Care Cost Recovery Actions ). With the commencement of new cases, the defense costs and the risks relating to the unpredictability of litigation increase. The future financial impact of the risks and expenses of litigation are not quantifiable. For the three months ended September 30, 2015 and 2014 , Liggett incurred tobacco product liability legal expenses and costs totaling $5,355 and $2,108 . For the nine months ended September 30, 2015 and 2014 , Liggett incurred tobacco product liability legal expenses and costs totaling $11,068 and $7,282 . These costs are included in the operating, selling, administrative and general expenses and litigation settlement and judgment expense line items in t