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Santa Fe Tobacco had previously entered into a Consent Order with the FTC regarding its advertising practices, requiring the display of the disclaimer: No additives in our tobacco does NOT mean a safer cigarette [i]n the same style and type size as that required for health warnings for tobacco cigarettes. A later Assurance of Voluntary Compliance added, for organic products, Organic tobacco does NOT mean a safer cigarette. Nobody contends that Natural American cigarettes are in any way safer than other cigarettes

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