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Court of Appeals for the Fifth Circuit has described the premarket review process set out in the TCA as onerous, requiring manufacturers to gather significant amounts of information. [1] As Dobbins points out, under the TCA, whether the APPH standard is met involves an assessment of the risks and benefits to the population as a whole, including users and nonusers of the tobacco product and weighs the likelihood that existing users of tobacco products will stop using such products against the likelihood that those who do not use tobacco products will start using such products. [2] In Nicopure Labs, LLC v