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Miller Professor of Communication at the Annenberg School, says that these phrases and words can activate beliefs about the brand that are not specifically discussed in the ads themselves, ultimately misleading consumers. While other studies have been conducted about the marketing of NAS cigarettes, this study is one of the first with a rigorous experimental design, allowing for evidence that shows a causal connection between NAS advertising and consumer beliefs

Perhaps because of the private action context, the court didnt point out that the other option states have with potentially misleading speech is to mandate disclosure

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[4] As Castro himself recalled the tale in 1994: "I used to see the man smoking a very aromatic, very nice cigar, and I asked him what brand he was smoking