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Similarly, it is clear that a ban on all but tobacco-flavored e-cigarettes would constitute a tobacco product standard. Bates explains that the court justifies its assertion that the FDA is imposing a de facto standard with reference to the so-called fatal flaw memo. This was an expedited decision-making regime that stipulated that applications for nontobacco-flavored products must be supported with controlled trials or longitudinal studies showing a quitting or switching advantage over a tobacco flavor

The verbal content of physicians opinions in the videos was transcribed verbatim, and the analyzed videos were categorized into four main themes and eight sub-themes

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It is designed to make the group "more agile, cost disciplined and innovative"