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27,28 Opioid manufacturers perfected techniques used by the tobacco industry on marketing their drugsthey sought out physicians through advertisements in medical professional publications and purposefully misled consumers about the addictive tendencies of their products

Funding This work was supported by the US National Cancer Institute Grant Number RO1CA160695

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Cell culture and construction of 3D-gingival epithelial tissues IHGE cells (epi 4, kindly provided by Shinya Murakami, Osaka University) 40 were maintained in Humedia KG-2 (Kurabo)

It is conceivable that the FDAs deeming rule would not have survived scrutiny by the Office of Information and Regulatory Affairs during the rulemaking process had the RIA used cost estimates closer to the outturn