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Health effects, including coughing and addiction, are shown or mentioned in only a few percent of cases, and are less likely to be mentioned in films targeted at younger viewers

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32 In Lorillard , the Court stated that "[t]he broad sweep of the regulations indicates that the Attorney General did not 'carefully calculate the costs and benefits associated with the burden on speech imposed' by the regulations." 33 The Supreme Court further explained that a "careful calculation of the costs of a speech regulation does not mean that a State must demonstrate that there is no incursion on legitimate speech interests, but a speech regulation cannot unduly impinge on the speaker's ability to propose a commercial transaction and the adult listener's opportunity to obtain information about products." 34 First, the Court noted that "the Attorney General did not seem to consider the impact of the 1,000 foot restriction on commercial speech in major metropolitan areas." 35 Rather, the Attorney General imposed a 1,000 foot restriction that was identical to the FDA's restriction in the 1996 rule

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