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Warnings were first displayed on cigarette packs in the 1960s and 1970s, but these typically vague text messages in small print and relegated to the side of the pack likely benefited tobacco companies (allowing a defence against failing to warn of the potential harms) more than consumers.4 5 By the 1980s and 1990s, larger, rotating text warnings on the main display areas of cigarette packs were common and warning content had become causal (eg, Smoking kills) rather than cautionary (eg, Government warning: Smoking may damage your health), and some countries had banned specific misleading descriptors (eg, light and mild).6 In addition, the idea of plain brown packs was mooted as a possible regulatory measure by the New Zealand Department of Healths Toxic Substances Board.7 This century has seen a shift in the balance of power between governments and the tobacco industry for control of the pack

Reynolds remains firm in its belief that its products comply with California state law and should continue to be sold