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Companies like Imperial Tobacco have argued that these measures are enough to negate any marketing efforts, and that plain packaging could lead to more illegal, counterfeit products on the market.

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Commercial Union had also been calling upon its fellow-insurers to file cross complaints against the United States, on the ground that the government had been responsible for asbestos exposure in the shipyards during the Second World War, and to file cross complaints against the tobacco industry on the ground of scientific evidence showing that asbestos workers who smoked cigarettes ran a far greater risk of developing lung cancer than those who did not smoke