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Figure 1 documents the difference between the counting that the more stringent interpretation of the statute provides (Roman numerals) and that the FDA is using in practice (Arabic numerals) in an example complaint.24 In this example, per the most stringent reading of statute, the FDA could have issued an NTSO on 7 October 2017, but did not issue it until 18 October 2018, after two additional inspections that resulted in four additional violations

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The objective of the day was to urge tobacco users worldwide to abstain from using tobacco products for 24 hours, an action they hoped would provide assistance for those trying to quit

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