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The court didnt rely on the plaintiffs submitted studies, though one concluded that [n]early 1 million US adult smokers prefer Natural American cigarettes and they are 22 times more likely than other smokers to believe that their brand is less harmful than other cigarette brands, leading the study authors to conclude that Natural American smokers may choose that brand because of the descriptors organic, natural, and additive free on product packaging and advertising. As surely as a Ph.D

from 2006 to 2016, it stood at 70%, and in 2019, it increased to 75% 3

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That argument does not hold any water, Painter said