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In the 2000s, people became more aware of the negative health impacts of tobacco, especially their addictiveness, and contribution to lung cancer

As such, although they are more likely to succeed in stopping smoking than daily smokers, the majority of quit attempts made by non-daily smokers are unsuccessful in the long-term [21, 22]

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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