ALBANY, N.Y. (AP) A tobacco company strategy memo which may or may not exist has become the latest focus of anti-tobacco forces in Albany and their campaign to toughen New York's lobbying laws.

The groups on Wednesday called for the state Lobbying Commission to seek the memo from Philip Morris as part of an investigation the commission is believed to be conducting into the tobacco company's lobbying activities in New York state. The groups said the memo, possibly written in late 1994 by Philip Morris lobbyists in Albany, has not turned up among the reams of documents released by the tobacco industry in the wake of its legal settlement with states including New York over smoking-related health costs. The executive director of the commission, David Grandeau, said Wednesday he doubted the relevance of the memo, if it exists at all. He noted that the commission can only review lobbying activities dating back three years for possible wrongdoing. ''I quite frankly don't see how anything related to this memorandum can affect a lobbying report filed for 1996, 1997 or 1998,'' he said. At issue, according to the anti-tobacco groups, is an internal Philip Morris memo they referred to as a ''SWOT.'' It stands for ''strengths, weaknesses, opportunities and threats,'' and is a strategy document routinely generated by lobbyists, corporate executives and others assessing the current political climate and the chances of positive or negative developments. The groups theorized that in a late-1994 SWOT, Philip Morris may have outlined ''advocacy activities'' the company planned to fund in Albany in 1995, chiefly to block state and local legislation to restrict smoking in restaurants, bars and other public places. The legislative director of the New York Public Interest Research Group, Blair Horner, said spending for some of those activities may not have been properly detailed by Philip Morris to the Lobbying Commission. On the other hand, Horner admitted, ''It may turn out it's a harmless document that doesn't mean anything.'' Common Cause and the League of Women Voters also called for the Lobbying Commission to seek the 1994 memo. In the mid-1990s, tobacco interests were pushing so-called ''pre-emption'' legislation in Albany that would have allowed the state Legislature to override local laws restricting public smoking. The legislation did not pass. In December 1998, the Tobacco Institute trade group acknowledged paying $443,000 to the Empire State Restaurant and Tavern Association in 1995 to fund anti-smoking law activities in Albany. The institute said it failed to report the expenditures on its lobbying reports for that year, and the tavern association also amended its filings with the Lobbying Commission. Scott Wexler, head of the tavern association, said Wednesday his group has acknowledged being allied with the tobacco industry in fighting anti-smoking regulations. But he said the ''pre-emption fight ended two years ago when the Legislature made it clear it did not want to pursue it.'' ''I have no idea of what document they're talking about,'' he said of the three groups' call for disclosure of a SWOT for 1995. A Philip Morris spokesman said Wednesday he is not familiar with the memo. ''I haven't seen this document,'' Brendan McCormick said. ''We have produced millions of documents at various stages of the litigation, but we haven't come across this one.'' The three groups freely admit they have an ulterior motive in pursuing disclosure of Philip Morris activities in Albany. State lobbying laws expire at the end of 1999 and the groups say the spending by Philip Morris and other groups shows the weakness of the statutes and the need for more stringent controls on lobbyist expenditures.

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