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The plurality stated that preemption under 5(b) could not be limited to positive enactments of law, and it extended the subsection's preemptive reach to include common law claims, emphasizing that the Court had long recognized "the phrase 'State law' to include common law as well as statutes and regulations." In accordance with this broader reading of "State law" in the 1969 Act to include common law claims, the plurality noted that "[state] regulation can be as effectively exerted through an award of damages as through some form of preventive relief

This is due to caffeine and probably chlorogenic acid, which is found in high concentrations in coffee

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Other components of the toolkit include fact sheets, success stories, and several helpful tools such as a sample logic model, a sample smoke-free ordinance and sample intervention maps