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First, the Zauderer Court did use the purely factual and uncontroversial information language once when describing the disclosure mandated in that case, but its reasoning encompassed disclosure requirements in general: it explained that disclosure requirements trench much more narrowly on an advertisers interest than do flat prohibitions on speech. Second, the FDAs warning labels are of purely factual and uncontroversial information. The labels require warnings that smoking cigarettes is harmful, a well-established scientific fact

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