RIGHT TO BE SMOKE-FREE COALITION, et al. v. FDA: MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFF TRADE ASSOCIATIONS’ MOTION FOR SUMMARY JUDGMENT, July 25, 2016

the Deeming Rule’s short-comings are several fold. First, FDA has applied a statutory February 15, 2007 grandfather date to vaping products that was intended for traditional tobacco products, like cigarettes. FDA was required under the statute to set a n

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