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smoking and health." 61 The fact that the regulations governed location rather than content of advertising did not remove them from the preemption language, which covers "all 'requirements' and 'prohibitions' imposed under state law." 62 The Lorillard decision clarified that while the FCLAA preempts the ability of states to regulate the advertising and promotion of cigarettes, states retain the authority to regulate other aspects of tobacco use and sales

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Neville B W, Damm D D, Allen C M, Bouquot J E