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Cigarette smoking is the leading cause of preventable death in the United States, the CDC said, killing about 443,000 people per year as of 2004

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in a particular year, was greater than the [MSA] payments, as determined pursuant to section IX(i) of that agreement including, after final determination of all adjustments, that such manufacturer would have been required to make based on such units sold had it been a participating manufacturer, the excess shall be released from escrow and revert to such tobacco product manufacturer