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The most obvious is full, complete, and unambiguous disclosure by the manufacturer. Judge Leon argued that, unlike in Zauderer , the FDA warning labels required more than disclosure of purely factual and uncontroversial information and therefore should be subjected to strict scrutiny

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And as smoking increases, the damage becomes much more substantial, with a much higher risk of developing smoking-related illnesses. Beyond the lungs, smoking harms the cardiovascular system from the earliest stages, damage that begins at the level of the blood vessels themselves and can end in life-threatening events