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Applying principles of tribal jurisdiction, the Ninth Circuit found that the Yakima Tribal Court did not have colorable jurisdiction over King Mountains tribal action for declaratory relief insofar as it implicates Philip Morris federal trademark infringement claim against King Mountain and its principals, members of the Yakima Tribe

Limitations of Pack Years While pack years are a useful tool, they have some limitations: Does Not Account for Smoking Intensity: Two individuals with the same pack years may have different health risks depending on how intensely they smoked

(2) a focus on specific population groups 23,24

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