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Both IRB boards waived the need for consent to participate and determined that this secondary research study of deidentified survey data does not meet the federal regulation definition of research with human subjects according to 45 CFR 46.102(e) [1]

Obtaining a representative sample of prices for a large number of brands is simply not feasible without sales reporting from tobacco companies

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Following the large increase in excise duty at the end of April 2010, and coinciding with the implementation of plain packaging in late 2012, new brands such as JPS were introduced that were priced well below existing value brands, forming a new supervalue market segment