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Mir M, Rauf I, Goksoy S et al (2022) Electronic cigarettes: Are they smoking cessation aids or health hazards

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Defendants argued that it was implausible for consumers to expect a safer cigarette, because a reasonable consumer would read the disclaimer stating that no additives does NOT mean a safer cigarette. Likewise, they argued that a reasonable consumer knows that menthol cigarettes contain menthol, so would understand that the no-additive term didnt cover menthol

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