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Judge Janice Rogers Brown also noted that the FDAs warnings might be misleading, since the image of a man smoking through a tracheotomy hole might be misinterpreted as suggesting that such a procedure is a common consequence of smoking. The picture was intended to serve a a warning about the addictiveness of nicotine

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This estimate relied on the assumption that the relative risk of death based on the number of cigarettes smoked per day is linear, and that this assumption is consistent with the observations from large cohort studies in the literature (25, 26)

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