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"But they cannot accurately say that their growers are 'GAP certified' through GAPC because there is no true certification system in place," said Denton

PMUSA maintained that the "plaintiffs' claims conflict with the FTC's 40-year history of regulation and control over the development, testing and marketing of low-tar cigarettes, as well as the reporting of tar and nicotine measurements pursuant to the FTC Method and the use of descriptors substantiated by those measurements." 61 Of its many implied preemption arguments, PMUSA argued that "State-law actions like this one would create a different standard of deceptiveness that would plainly conflict" with the Congress' goals of uniform standards for cigarette advertising

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