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After the judge's decision she said the award was a "ridiculously high number." Forrest, in her ruling, said a "very significant award" was necessary because of the danger of smoking, and that the court "is convinced that modest penalties would not make a significant corporate impact on UPS."

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Smoking Categories Studies were categorized based on the basis of the smoking behavior(s) they assessed: smoking onset, smoking status, smoking heaviness, tobacco dependence, and smoking trajectory