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[38] The August warning letter to ITG marked the first time the FDA had used its authority under a 2009 tobacco-control law to take action against a company for making "additive-free" ("No Bull" ad campaign) claims on product packaging

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However, by the heavy hand of the tobacco industry, such laws were rendered unconstitutional and were withdrawn by about 1910. Although, smoking among women was no longer banned, the cigarette companies were still not satisfied with the number of women who actually smoked