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82 In Rivera, the court held that the plaintiffs' failure-to-warn and fraudulent concealment claims were not preempted by the FCLAA because it determined that Nevada's common law duty that requires manufacturers to advise consumers of their products' dangers "does not specify that those disclosures be made through marketing and advertising." 83 The court in Brown disagreed, stating that it "could not accept that the Congress meant to create a system in which cigarette manufacturers have the duty both to conform their advertising and marketing to strict federal standards and simultaneously undercut these representations through other 'means,' as yet undefined." 84 Thus, it held that the FCLAA preempts any state law claim that would require additional communication between companies and consumers