I think CASAA has submitted one of the best comments to FDA (especially from economic and scientific perspectives).
While my comments delineated many of FDA's (and DHHS') intentionally misleading claims about e-cigs since 2009, CASAA's delineated many of FDA's intentionally misleading claims in its proposed Deeming Regulation.
Out of the one's I've read, CASAA's is a stellar example of hitting the right points with the right importance. The part on the black market is incredibly detailed and could be prophetic.
I applaud this: "Part of the explanation for FDA’s apparent lack of understanding about the role e-cigarettes and other tobacco products play in consumers’ lives, as well as what will actually happen if these regulations are implemented, is the lack of consumer involvement. There are many people who could have explained these matters to the CTP, but they were intentionally excluded from the process."
Showing the willful and blatant ignoring of information that would be necessary for the FDA to have any regulation that would be tailored to the products they would be regulating. And also points out how they wouldn't have a clue as to what would happen in the black/shadow market.
Part of my comment after suggesting the use of Azim's 'baseline predicate product' from:
http://www.khlaw.com/webfiles/What_To_Expect.pdf
"You can work with vendors, consumers or vendor groups and consumer groups, such as CASAA, AEMSA, and others, who have had the input from us users, and the self-regulating actions that we have done to make the e-cigarette even safer than when it was first introduced - something that it, if the deeming goes as is planned, will revert to, in the form of cigalikes, and virtually eliminate all the knowledge and experience we have had, moving away from those products to products that are now much safer and more effective at moving people from cigarettes to e-cigarettes and from, in some cases, addiction to nicotine to no nicotine at all."