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smoking and health." 61 The fact that the regulations governed location rather than content of advertising did not remove them from the preemption language, which covers "all 'requirements' and 'prohibitions' imposed under state law." 62 The Lorillard decision clarified that while the FCLAA preempts the ability of states to regulate the advertising and promotion of cigarettes, states retain the authority to regulate other aspects of tobacco use and sales

The dangerous effects of smoking on the body are often underlined in an effort to get people to quit, and yet what can be more influential in the path to quitting are the positive results of each day off the habit