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Nonlimiting examples which can be used are described, for example, in A

It says less about cigarettes themselves and more about collective burnout, about people craving messiness after years of unattainable perfection, about rejecting the polished performance of wellness culture

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But respondents did not bring such a claim." 125 Thus, it would appear, as the First Circuit pointed out, that "Plaintiffs suing tobacco companies must assert a broad range of causes of action in order to avoid the pitfalls of preemption." 126 This could have the effect, as PMUSA had argued, of "elevating form over substance and allow parties to evade the preemptive scope of a statute simply by relabeling their

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