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Liver Although the 2004 Surgeon Generals Report concludes that the relationship between smoking and liver cancer is suggestive but not causal, a meta-analysis from the World Health Organization (WHO) International Agency for Research on Cancer found an RR of 1.55 among current smokers and 1.2 among former smokers for development of liver cancer (Lee et al., 2009)

So too with the unprocessed cigarette theory: it was plausible that these plaintiffs, though not reasonable consumers, would believe that the term natural meant that Natural American cigarettes were subjected to fewer engineering processes than other cigarettes