To be sure, ANR could simply have suggested that any poll commissioned by a company should be questioned because there is a potential bias. There was no need to claim that Mistic is actually a tobacco company and that Big Tobacco's history of fraud therefore applies to Mistic. Moreover, there was no need to claim that all electronic cigarette companies are tobacco companies. ANR could simply have stated that some electronic cigarette companies are owned by tobacco companies.

1. Between 2003 and 2008, one of the authors performed consultation services for R.J. Reynolds and Lorillard and conducted research at his medical school which was funded by R.J. Reynolds, Brown & Williamson, and Liggett. The total annual amount of his consulting payments from Big Tobacco was as high as $40,000. While the amount of grant funding received from tobacco companies is not clear, one of the anti-smoking groups has documented that the level of funding in 2005 was $400,000 and in 2004 was $1 million.

In one of the first studies to examine the trajectory of electronic cigarette use over time, Lechner and colleagues have shown that extended duration of electronic cigarette use is associated with

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