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The court recognized a qualitative difference between the claims of the Attorney General that resulted in the MSA and the claim of Laramie that persuaded a jury

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2 The Salvation Army gave away cigarettes to the soldiers, causing one soldier to remark in a letter complaining about the prices at YMCA canteens: The Red Cross and the Salvation Army are the only ones here that do any good at the front. The violence of the conflict made the hazards of cigarette smoking irrelevant, and relief efforts would undermine the nascent anti-smoking movement in America by drawing away public support, creating a generation of habitual smokers, and equating cigarettes with heroism