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any requirement' relating to safety or effectiveness that is different from, or in addition to, federal requirements." 102 The Court found that the Riegel plaintiffs' common law products liability claims "unquestionably sought to enforce 'requirement[s] relating to safety or effectiveness' under the MDA," whereas in Cipollone the plaintiffs' fraud claim was outside the FCLAA's preemptive reach because it did not seek to impose a prohibition based on smoking and health

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