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The Panels interpretation of Article 20 has especially drawn criticism for being a factual assessment and leaving WTO Members with uncertainty as to what other reasons will justify an encumbrance to the use of trademarks.[27] While on this ground alone many trademark rights holders and scholars were hoping that the Panel Report will be reversed, its affirmation will come as a surprise to them

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Products being sent to markets often greatly exceeded what the local population could consume alone

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The growth in the historic period can be attributed to stable consumer demand for tobacco products, expansion of global tobacco trade, growth of established smoking populations, availability of diversified tobacco product formats, development of large-scale tobacco manufacturing