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While the FDA has denied permission to market some e-cigarette products and has recently stepped up enforcement efforts, including warning letters, fines, injunctions to manufacturers and retailers, and joint operations with other federal officials to seize imports of unauthorized e-cigarette products, enforcement has been slow and many of the most popular e-cigarettes among youth remain on the market

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Internal company documents show these campaigns to be a public relations effort to deflect the severe criticism against the industry for such successful promotions as those using the Joe Camel character, which may have hooked millions of teenagers into smoking. The court also discussed the landmark Kessler judgment of 1999, which followed a legal case brought against the tobacco companies in the US

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