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3 For this reason, the FCTC states that warning labels "should be 50% or more of the principal display areas but shall be no less than 30% of the principal display areas" and "may be in the form of or use pictures or pictograms." Research suggests that warning labels with prominent graphic elements are more effective than text-only messages in engaging smokers, promoting quitting, and impeding "wear-out" that results from habituation to messages

District Judge Sheryl H