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As it had done in Cipollone and Reilly , the Court emphasized that a preemption analysis begins "with the assumption that the historic police power of the State [are] not to be superseded by the Federal Act unless that was the clear and manifest purpose of Congress." 88 Therefore, "when the text of a pre-emption clause is susceptible of more than one plausible reading, courts ordinarily 'accept the reading that disfavors pre-emption.'" 89 The Court also discussed the purposes of the FCLAA, noting that "neither [purpose] would be served by limiting the States' authority to prohibit deceptive statements in cigarette advertising." 90 It stated that, although the FCLAA's purposes do not demand the preemption of state fraud rules, the Court would have to decide whether the text of 5(b) requires that result

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