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FDA (2018), US Food and Drug Administration, Premarket Tobacco Product Applications and Recordkeeping Requirements. US Food and Drug Administration, Regulation and Enforcement of Non-Tobacco Nicotine (NTN) Products, November 6, 2023, Juul Labs, Juul Labs Statement on FDA Marketing Authorizations, press release, July 17, 2025,

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The as-efficient-competitor test asks whether the challenged conduct would exclude a rival that matches the defendants efficiency, or only less efficient firms

Initially I was thinking I had less sprays but then realize even 3 sprays are more than enough