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In surprisingly harsh language, the appellate court states that [t]he FDA has not provided a shred of evidence much less the substantial evidence required by the APA [Administrative Procedures Act] showing that the graphic warnings will directly advance its interest in reducing the number of Americans who smoke (RJ Reynolds Tobacco Company v

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Heated devices more closely resemble the process of smoking cigarettes than any other alternative, so they stand as a solid choice for habitual smokers in need of a change

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