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Distributing a free tenth vial of e-liquid with either the ninth or eleventh purchase would not violate the free sample ban because it would effectively amount to a discount that is part of a sales transaction requiring monetary payment, not a free sample, the FDA guidance states

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This feature provides an excellent opportunity for businesses to maintain contact with their target consumers beyond the initial purchase as the consumer continues using the packaging for their daily cigarette storage

But, as usual, he defies structure and time, remaining cryptic yet accessible as he ponders the fluidity of identity, a theme that haunts much of his work