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[26] [27] In light of that, the model escrow statute requires an NPM selling cigarettes in [*1122] a given state to do one of two things: 1) join the MSA, agreeing to "become a participating manufacturer (as that term is defined in section II(jj) of the [MSA]) and generally perform its financial obligations under the [MSA]," or 2) make similar annual payments into a state "liability reserve" escrow account, the funds of which can only be used to pay a judgment or settlement on a claim against the NPM

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