In 1998 a number of tobacco producers entered into a landmark, multi-billion dollar settlement agreements with a number of states that set penalties to be paid by the producers based upon actual future tobacco sales, contingent upon certain criteria. One obligation that fell upon the states was proving diligence in their effort to collect escrow payments from non-party tobacco manufacturers. Celerity assisted certain states with establishing this diligence. Our team standardized the varied sales data, identified duplicate and irrelevant portions of the data set, and summarized the amounts by state. Celerity then compared the states’ internal data to producer-reported data to identify discrepancies between the two sources. In addition, Celerity independently analyzed data and provided reports to refute the tobacco companies’ experts. Celerity established a repeatable, defensible calculation model that can be used for years into the future to assist state AGOs in cost-effectively and accurately calculating annual penalty payments.