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The approach differs from past litigation by New York and other states, which targeted vaping manufacturers, such as Juul Labs

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The peer-reviewed, two-part regression analysis is too complex to describe here in detail, and the technical discussion has been relegated to "Appendix A: The Econometric Analysis." In general terms, however, the model compares legal, per-capita sales of cigarettes to survey data on the percentage of smokers in each state (the survey data comes from the "Behavioral Risk Factor Surveillance System" administered by the Centers for Disease Control and Prevention)