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If the proposed rule is adopted, the FDA and others may see in subsequent years empirical evidence to support their contention that establishing and maintaining illicit markets in relevant tobacco products will be challenging, and to the extent that they emerge, it is unlikely they will be significant enough to outweigh the benefits of the product standard. We will post below the Freedom of Information Act request we submitted to U.S

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In fact, internal industry documents reveal that from the very beginning, tobacco companies were well aware that smokers compensated for the low-nicotine draw from light cigarettes by changing their smoking behaviors