[JasonL]

Each back is a different tobacco, and distribution was regional based upon brand, right?
So the T206 is not actually one large set, but rather a collection of the various Regional sets.

If all that is true and acceptable, then wouldn't it make sense that if you were a collector back in 1911, your available set would be whatever was distributed in your region with the brand of tobacco you can buy?

If so, then when these were issued, there were as many sets being collected as there are backs and distribution areas.

If all of that makes any sense at all, then I would say that the T206 is certainly a collection of sets, analagous to any of the more modern Regionals.