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As three other appellate courts recognize, because of the unique nature of the concealment conspiracy by the Engle defendants (tobacco companies), the progeny plaintiffs are not required to prove that they relied upon any specific misleading statements to establish their fraud-based claims, the estates brief said

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Dittmann S, Kiessling T, Knickmeier K, Schnberg J, Brennecke D, Hinzmann M, Knoblauch D, Thiel M (2024) Temporal variability of litter pollution of rivers in Germany a long-term assessment by schoolchildren as citizen scientists