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Human twin studies and animal research demonstrate that these genes significantly influence smoking behavior, nicotine dependence, and quit success by controlling how nicotine interacts with the brains reward system, particularly in the dopaminergic cells of the ventral tegmental area and nucleus accumbens These genetic factors make certain people more likely to develop tobacco dependence compared to others

any requirement' relating to safety or effectiveness that is different from, or in addition to, federal requirements." 102 The Court found that the Riegel plaintiffs' common law products liability claims "unquestionably sought to enforce 'requirement[s] relating to safety or effectiveness' under the MDA," whereas in Cipollone the plaintiffs' fraud claim was outside the FCLAA's preemptive reach because it did not seek to impose a prohibition based on smoking and health

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