On March 19, 2013, the Food and Drug Administration (FDA) announced that it would not seek further review of a federal appeals court decision halting implementation of the FDA’s plan to force tobacco manufacturers to surrender 50% of the front and back panels of each cigarette package and the top 20% of all printed advertising for the purpose of displaying nine new graphic warnings containing the government’s anti-smoking advocacy. FDA’s decision not to seek further review leaves in place a powerful precedent which businesses in other industries might deploy in situations where government labeling or warning requirements go beyond disclosure of pure, noncontroversial facts. The U.S. Court of Appeals for the D.C. Circuit ruled late last year that the government’s regulatory attempt to force commercial speakers to convey speech with which they disagree violates the free speech protections of the U.S. Constitution.