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as far as the respective competitive positions of individual tobacco companies were concerned, it was clear that over this phaseout period the plan would favor the sales of those brands that were then in a dominant position in the market and place at a disadvantage the less powerful companies that were trying to dislodge them by putting large advertising sums into their own brands

34 In January 2024, the FDA denied applications from a Chinese company, Shenzhen IVPS Tech, which argued in court that it had spent $30 million preparing its PMTA, conducted extensive testing, and provided 600,000 pages of documentation

3a and 4a, b)

It minimizes the wastage of tobacco and rolling paper, making it a cost-effective tool