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Congressional Research Service 3 In a unanimous decision, the Second Circuit reversed the district court on the PACT Act interpretation, holding that King Mountains reservation-to-reservation cigarette sales were in interstate commerce. The court based this conclusion on the plain meaning and statutory context, noting that the PACT Act defines State as each of the several States of the United States

It was the first country that adopted this strategy and prompted many to follow suit

The menthol ban in California and Massachusetts is found to be a major contributing factor to casual smuggling for these states

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