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15 The 2018 National Academies of Sciences, Engineering, and Medicine report on the public health consequences of e-cigarettes concluded that there is limited evidence to demonstrate ENDS effectiveness when used in conjunction with tobacco cessation efforts, citing study limitations based on evidence drawn exclusively from laboratory testing of ENDS ingredients

Given the conservative tilt of the 5 th Circuit, its likely that the court will find some flaw in these revised images and send the FDA back for another rule-making process