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JUUL was one of the earliest brands to use widespread social media marketing (Jackler, ENDS brands may utilize multiple social media platforms (e.g., Instagram, Twitter) to market products to users and potential users (Artman, The 2009 Family Smoking Prevention and Tobacco Control Act granted the US Food and Drug Administration (FDA) authority to regulate the manufacture, marketing, and distribution of tobacco products to protect public health and reduce minors' use (US Food and Drug Administration and US Department of Health and Human Services, In response to the increase in youth ENDS use, particularly flavored cartridge-based devices, FDA issued final guidance in January 2020 (revised April 2020) for industry describing how FDA intended to prioritize enforcement resources with regard to marketing of certain deemed tobacco products, such as flavored (other than tobacco or menthol) cartridge-based ENDS without premarket authorization