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New York City, which increases to 21 the minimum age to purchase tobacco products beginning in May, modeled its regulation after Needham's

Illicit Tobacco Market: Characteristics, Policy Context, and Lessons from International Experiences (Washington, D.C.: The National Academies Press), 2015, 4

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The Court further expressed concern over the allegations, stating that if these factual aspects are correct, the respondents-authorities must take appropriate steps to ensure that such articles are not readily available in the manner described and must implement all statutory provisions effectively