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55 Although the Court determined that Massachusetts had presented sufficient evidence to satisfy the first three prongs of the Central Hudson test, the outdoor advertising regulations were found to be too broad to meet the fourth requirementthat is, that the regulation not be "more extensive than is necessary." 56 The Court's key finding in the Lorillard case was that Massachusetts had not engaged in a "careful calculation" of the costs of the advertising regulation, nor did the state "seem to consider the impact of the 1,000-foot restriction on commercial speech in major metropolitan areas." 57 Rather, the Attorney General simply imposed a 1,000 foot restriction that was identical to the FDA's restriction in the 1996 rule

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This might have been done by ensuring proper merchandising of their product, running sales events in-store and helping the shop stay on top of ordering product