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Known as the "Cigarette Rule," the FTC's old test allows courts and juries to find unfairness using amorphous concepts such as "immorality" or by gazing into "penumbras" of rules and regulations

Many e-cigarette brands are now tapping into themes of stress relief and mental well-being as well, including the popular disposable e-cigarette brand Puff Bar, which during the pandemic marketed its product as a way to stay sane, advertising it as the perfect escape from back-to-back zoom calls, parental texts, and WFH stress. ACTION NEEDED The associations between youth vaping nicotine and mental health concerns add to the urgency to regulate and reduce youth access to e-cigarette products

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