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  1. bigdancehawk

    Deeming Regulations have been released!!!!

    Which would be yet another absurd result. But that's how this thing is written. If a vape shop offers 100 liquids and wants to sell samples, then every time they put liquid in an EGO vape pen so it can be sampled they will have manufactured a new tobacco product.
  2. bigdancehawk

    Deeming Regulations have been released!!!!

    We were talking about warnings and you've now moved on to inquiries. Which is fine. I'm going to make Alexander Mundy happy and not reply further.
  3. bigdancehawk

    Deeming Regulations have been released!!!!

    Nicopure's lawyers would make that distinction and I think it's valid in context. The problem you and I and everyone posting here is having is contextual: We're Alice trying to make sense out of Wonderland rules. This stems, in turn, from the FDA's determination to regulate e-cigarettes and...
  4. bigdancehawk

    Deeming Regulations have been released!!!!

    Indefinitely, until there's unconditional surrender.;)
  5. bigdancehawk

    Deeming Regulations have been released!!!!

    It's probably a "throwaway" argument. That can be good strategy. And sometimes you have to take a position your client thinks is important, even though you think it's a loser.
  6. bigdancehawk

    Deeming Regulations have been released!!!!

    The FDA may have taken its opportunity to "weigh in" too literally.
  7. bigdancehawk

    Deeming Regulations have been released!!!!

    Very nice piece of work, in stark contrast to most of the amicus briefs.
  8. bigdancehawk

    Deeming Regulations have been released!!!!

    You missed the footnote.
  9. bigdancehawk

    Deeming Regulations have been released!!!!

    Yes, and irrational. It would be irrational to say that if a perfectly legal product breaks the shop can't repair it because the FDA has arbitrarily decided that's a "modification." It's equally irrational and arbitrary to prohibit a demonstration of how to properly use a legally sold product...
  10. bigdancehawk

    Deeming Regulations have been released!!!!

    Well, yes you can. That's exactly what happened in THIS CASE involving sales to minors. The first time he got caught the owner simply apologized and said he'd instructed his employees. Nothing further was required until the store did it two more times and the FDA hit him with a $500 civil...
  11. bigdancehawk

    Deeming Regulations have been released!!!!

    I get what you're saying and I'm not ruling it out. I'm saying it's unlikely the FDA would try to enforce that interpretation. Incidentally, if you read Nicopure's reply brief, they make a pretty good argument that a tank isn't a tobacco product under the FSPTCA because it doesn't contain...
  12. bigdancehawk

    Deeming Regulations have been released!!!!

    There is enough real stuff to fuel your outrage without making it up.
  13. bigdancehawk

    Deeming Regulations have been released!!!!

    The warning letter, even if it's for the sale of cigarettes to a minor, merely requires a statement as to how the retailer intends to correct the problem to prevent future violations. It doesn't require all those other things. LINK I would respond by simply stating: "We have cautioned all of...
  14. bigdancehawk

    Deeming Regulations have been released!!!!

    I thought we were talking about a store employee filling a customer's tank atomizer with e-juice. But now I'm uncertain what you're referring to.
  15. bigdancehawk

    Deeming Regulations have been released!!!!

    Ha! I will spare you a grim accounting of my penurious past. To repeat, the first enforcement step is a warning letter. No fine. I doubt they would even bother to issue a warning letter for many of the things being discussed in this thread. The situation is bad enough without concocting...
  16. bigdancehawk

    Deeming Regulations have been released!!!!

    They're not going to shut anybody down or seize inventory just because a store fills a tank or something equally trivial. Worse case scenario would be an initial warning letter and then you could decide whether to fight or capitulate. If you don't capitulate, then fines would start out small and...
  17. bigdancehawk

    Hello Guys..............

    Welcome to ECF! Where are you from? How much do you smoke and for how long? Have you any questions?
  18. bigdancehawk

    I don't even go here

    Welcome to ECF! You've come to the right place. Vaper going on 5 years here. With the help of e-cigs I was able to quit a 45 year pack-a-day smoking habit. The process was surprisingly easy and I have no cravings or desires to smoke a cigarette ever again. I don't understand why everything is...
  19. bigdancehawk

    ◙ Li’l PINCH (←thang) ◙ pdib (←maker) ◙ not sayin’ (←just sayin’) ◙ shuh-ZAM! (←hyperbole)

    Ooooh! Where did you find that, BurlSource? What is it? ETA: Ah, I see. It's Koa. It looked like Koa but I immediately dismissed the thought. Knowing Peter's views about Koa and all. I said to myself,"No way is that Koa." Koa is to be shunned and feared and avoided at all costs. I even installed...
  20. bigdancehawk

    FDA FDA response to lawsuits.

    How dare you question the legitimacy of concerns for the well being of the cheeldreen? As in: studies have raised serious concerns about the effects of nicotine on the adolescent brain. Or: recent studies have given rise to concerns among leading experts about youth transitioning from ENDS to...
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