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Rolfe acquired seeds (it is unclear how or where) and began growing a more desirable species found in Central and South America called Nicotiana Tabacum, which provided a sweeter taste and was preferred in Europe

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In 1971, United was the first airline to create a nonsmoking section, with others following suit

In a dissent that would later cast him as a defender of free speech and the First Amendment, Holmes wrote that the best test of truth of particular ideas is not the approval of government but the power of that speech to get itself accepted in the competition of the market. Just because speech might be problematic or even contrary to government policy, it should not be prohibited by law, according to Holmes

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