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In rejecting Philip Morris's implied preemption argument, the Court stated, "[i]n short, neither the handful of industry guidances and consent orders on which [Philip Morris] relies nor the FTC's inaction with regard to 'light' descriptors even arguably justifies the preemption of state deceptive practices rules like the MUTPA." 67 While holding that lawsuits accusing cigarette-makers of fraudulent conduct under state law could proceed, the Court noted that the respondents "still must prove that the petitioners' use of 'light' and 'lowered tar' descriptors in fact violated the state deceptive practices statutes." 68 The public health community strongly supports the elimination of the FCLAA preemption language so that states could impose their own restrictions on tobacco labeling and advertising

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As Al Capone in The Untouchables , De Niro employs a cigar in one particularly memorable scene, when Kevin Costners Eliot Ness invades the lobby of the hotel where Capone lives, inflamed by the murder of one of his men

This creates a complex environment where the rules for vaping can change significantly from one county or city to the next