JUUL Labs

This page was last edited on at

JUUL Labs Inc. is a San Francisco-based e-cigarette company whose product JUUL has been the focus of considerable media attention and critical commentary, mainly around its popularity among young consumers.123

Background

JUUL Devices

JUUL is a flat e-cigarette (also known as electronic nicotine delivery systems, or ENDS) which is designed to look like a USB key and is rechargeable in a USB port (Image 1). It has two components: the battery system, and a prefilled, single use nicotine liquid cartridge that serves as the mouthpiece and is called a ‘JUUL pod’.

The JUUL device was first launched in the US in 2015. With an exceptionally high nicotine content of 59mg/ml (the limit in the UK is 20mg/ml), JUUL cartridges containing e-liquid were initially available in various fruity flavours, including ‘mango nectar’, ‘royal crème’, ‘apple orchard’, and ‘alpine berry’.4 Due to a US ban on fruit and sweet flavoured e-liquids, JUUL cartridges have been available only in tobacco and menthol flavours since September 2019.5

Image 1. Juul e-cigarette (taken from juul.co.uk, April 2019) and JUUL2 e-cigarette (taken from juul.co.uk, October 2021)

In September 2021, JUUL launched the JUUL2 device, with a similar design and ‘pod’ system. JUUL2 pods contain less than 20mg/ml of nicotine, making them suitable for the European market where higher concentrations of nicotine are banned. Despite using liquids with lower nicotine concentration, however, JUUL2 devices deliver significantly more nicotine than the original JUUL e-cigarette. According to the company’s own research, after 10 minutes of using both devices, participants using the JUUL2 devices aerosolized more e-liquid and showed more plasma nicotine concentrations in the 90 minutes after use, compared to those using the original JUUL device.67

At the time of writing, JUUL2 has not been submitted for market authorisation by the United States Food and Drug Administration (FDA).8 JUUL2 cartridges are only available in tobacco and menthol flavours.9

Ploom, Pax Labs, and JUUL Labs

The e-cigarette company was founded in 2007 by entrepreneurs Adam Bowen and James Monsees and was previously known as PAX Labs Inc. (2015-2017) and Ploom Inc. (2007-2015).1011 On 13 June 2017 the company became known as JUUL Labs Inc.12

In contrast to claims that JUUL Labs was an independent company spun off from PAX Labs,1314 official documents filed with the Secretary of States for California and Delaware show that the company changed name only.1516

Staff: Past & Present

A list of the company’s leadership team can be accessed from JUUL Labs’ website. A significant number of staff previously worked for industry regulators (see the section below ‘Revolving Doors’).

Prior to September 2019, none of the senior executives appointed had worked for tobacco companies in the past. This included Kevin Burns who was the company’s Chief Executive Officer (CEO) from December 2017 to September 2019.17

This changed with the appointment of K.C. Crosthwaite, Altria’s Chief Growth Officer, who succeeded Burns as JUUL Lab’s CEO in September 2019.1819 A few weeks later, the company announced that it had also appointed Joe Murillo as its Chief Regulatory Officer.20 Murillo was previously Altria’s Head of Regulatory Affairs.20 JUUL’s Chief Legal Officer, Tyler Mace, worked for Philip Morris International (PMI) before joining JUUL in October 2019.21

Memberships

  • UK Vaping Industry Association (UKVIA) (from March 2019).22
  • Independent European Vape Alliance (IEVA).23. As of December 2021, JUUL Labs is no longer listed as member on the IEVA website.24
  • The American Chamber of Commerce to the European Union.2325
  • Kangaroo Group.23
  • Asociatia Industriei De Vaping (AIV), the Romanian vaping industry association23
  • Up until August 2019, JUUL was also a member of the US-based Vapor Technology Association (VTA). JUUL reportedly left because of “policy differences” and the VTA filing a lawsuit against the FDA. This lawsuit sought to prevent the FDA from enforcing the May 2020 deadline for e-cigarette manufacturers to submit a premarket tobacco product application (PMTA) if they wanted to keep their e-cigarettes on the US market.26

Consultancies, think tanks, front groups and other third parties

JUUL is known to have worked with the following:

  • United States (US) law firm Foley Hoag27 (which led Uruguay’s legal defence in the lawsuit Philip Morris vs the Government of Uruguay), S-3 Group, Empire Consulting and Sims Strategies.28 Chaka Burgess, of Empire Consulting Group, has in the past worked as a consultant with APCO Worldwide (which has a long history of working with the tobacco industry).29
  • UK-based PR firm, Freuds30 (which has been responsible for Public Health England’s Stoptober campaign since 2012),31 and Hanover Communications.323334
  • Pinney Associates and the Centre for Substance Use Research (CSUR), both of which co-authored papers in a JUUL-sponsored issue of the American Journal of Health Behaviour.3536 For more information, see the section below.
  • UK think tank Demos received funding from JUUL in 2019.37 This appeared to be to run an event at the UK Labour Party Conference in September that year, titled “New approaches to tackling health inequalities”.38 Labour MP Helen Goodman was listed as a speaker along with Max Chambers, Director, Government and Public Affairs for JUUL, as well as a representative of a UK charity working on digital exclusion.38 In 2022, Demos received further funding from JUUL for a “new research project” and in March published a report on the future regulation of e-cigarettes in the UK.3940 The MP Adam Afriyie referred to Demos’ work in a parliamentary debate, but did not mention the involvement of JUUL.41. See also Swedish Match and the APPG for Vaping (e-cigarettes).

Relationship with the Tobacco Industry

35% Altria-Owned

In December 2018 tobacco giant Altria acquired a 35% non-voting stake in JUUL Labs.42 JUUL Lab’s press statement alluded to the controversy and scepticism that the acquisition was expected to cause, but stated that it believed that Altria’s investment would help the company to accelerate its “success switching adult smokers”.43

  • Read JUUL Lab’s statement about the acquisition here.

Despite claiming that “JUUL will remain fully independent”, in April 2019 Altria requested, , Federal Trade Commission (FTC) approval to convert its non-voting shares to “voting securities”.44 This was approved by the FTC in November 2020, giving Altria significant control in JUUL, including the right to appoint two representatives to JUUL Lab’s Board of Directors.45

However, Altria also declared it would not exercise these rights until the outcome of a FTC antitrust investigation into the acquisition, launched by the FTC in April 2020, was clear.45 JUUL is alleged to have forced Altria to withdraw its own e-cigarettes from the market when negotiating the deal.46 The FTC case, which aims to terminate the agreement, states that:

“Altria Group, Inc. and JUUL Labs, Inc. entered a series of agreements, including Altria’s acquisition of a 35% stake in JUUL, that eliminated competition in violation of federal antitrust laws. According to the complaint, this series of agreements involved Altria ceasing to compete in the U.S. market for closed-system electronic cigarettes (“the relevant market”) in return for a substantial ownership interest in JUUL, by far the dominant player in that market.”47

In February 2022, an initial decision by an FTC Judge dismissed the charges.48

In relation to its investment in JUUL Labs, Altria has also confirmed that:

  • JUUL e-cigarettes will be sold alongside Marlboro and other Altria cigarette brands;
  • JUUL pack inserts will be added to Altria cigarette products;
  • the distribution of JUUL will widen as it will be supported by Altria’s logistics services; and
  • Altria will support JUUL Labs in its engagement with the FDA and other authorities.42

Criticism of Altria Connection

In April 2019 eleven US senators signed a letter addressed to JUUL Lab’s CEO Burns, expressing their indignation that JUUL Labs had teamed up with Altria.49 In the letter, the senators accused Altria of “a long and sordid history of spending billions to entice children to smoke through targeted campaigns that intentionally life about the science and health effects from cigarettes”. They added:

“The corporate marriage between two companies that have been the most prolific at marketing highly addictive nicotine products to children is alarming from a public health standpoint and demonstrates, yet again, that JUUL is more interested in padding its profit margins than protecting our nation’s children”.49

The tobacco investment in JUUL Labs was widely condemned by public health experts and advocates.50

The New York Times reported that Washington-based public relations company Precision Strategies had ended its contract with JUUL Labs following Altria’s investment, although the PR firm declined to comment.51

27% Owned by Japan Tobacco International (2010 – 2015)

Altria was not the first tobacco company to own shares in the e-cigarette company.

In 2010, when JUUL Labs was still known as Ploom Inc, the company signed an agreement with Japan Tobacco International (JTI) which resulted in JTI owning a minority stake and obtaining exclusive rights to commercialise Ploom’s hybrid heated tobacco products outside the US.52 In February 2015 Ploom Inc and JTI ended their partnership; JTI acquired the intellectual property related to the Ploom products, and Ploom bought back JTI’s minority stake and rebranded to PAX Labs.5354

Sales Strategy: From US to Global

Challenging US Operating Environment

The JUUL e- cigarette, with a nicotine content of 59mg/ml, was first launched nationally in the US in 2015, and experienced an explosive growth from September 2017.55 Nielsen data show that JUUL grew from holding 32% of the US e-cigarette market in late 2017 to 70% by July 2018.56

However, in April 2018 the FDA launched an investigation into JUUL Labs’ marketing practices. This culminated in JUUL Lab’s offices in San Francisco being raided by the FDA in September 2018, and the seizure of documents related to Juul’s sales and marketing activities.57

The FDA investigation was followed by multiple other similar investigations by state and federal authorities.585960 This included investigations by the US Senate (April 2019) and the US House of Representatives’ Subcommittee on Economic and Consumer Policy (June 2019).61

In June 2021, North Carolina became the first of eleven US States to reach a settlement with JUUL over accusations of marketing its products to youth. JUUL agreed to pay $US 40 million to settle the case, stating it would not sell its flavoured cartridges unless authorised by the FDA.62 In November 2021, a $US 14.5 million settlement was reached with the State of Arizona .63 As of November 2021, the FDA is yet to grant  JUUL’s pre-market authorisation.

In addition, numerous lawsuits have been filed by customers who claimed they had become addicted to JUUL, and in some cases, experienced severe health problems.6465

Market  share and valuation history

The US market was the driver of JUUL’s initial explosive growth: by July 2018, JUUL held 70% of the US e-cigarette market and was valued at $US16 billion.566667 Atria’s acquisition and $US 12.8 billion investment in the company boosted JUUL’s valuation to 38 billion USD by December 2018.66

However, the challenging US operating environment quickly brought JUUL’s rapid growth to a halt. By the end of 2019, the company’s valuation had gone down to $US 24 billion, amid regulatory challenges, proposed bans on e-cigarette flavours, litigation relating to its marketing practices, and health scares.66 At this time, the company began to scale back its operations, halting the in-store sale of flavoured cartridges (excluding menthol and tobacco), laying off staff and restructuring its leadership.6869

International expansion – followed by rapid scaling back

The increasing challenges of US regulation made international expansion an attractive option for JUUL Labs. Between 2018 and 2019, JUUL aggressively expanded its operations internationally, to Europe, the Middle East, Africa, South America and Asia, and spent millions of dollars on lobbying.70

However, perhaps due to over-reaching, the company soon began scaling back its overseas efforts in early 2020.71 72 By late 2020, JUUL’s market valuation had gone down drastically to around $US 4.5 billion, with investor Altria citing the company “downsizing international expansion” as a reason for the devaluation.73

A search of the D&B Hoovers database found that, by July 2019, JUUL Labs had set up at least 19 international subsidiaries and holding companies in Europe, Canada, Israel, South Korea, and Switzerland.74 The table below details where and when JUUL Labs launched its e-cigarette (where known), and when it exited the market.

Country  
United States On sale since June 2015, but awaiting a FDA decision on whether they can remain on the market.67
Israel On sale from March 2018 to August 2018.
United Kingdom On sale since July 2018.
Canada On sale since August 2018. JUUL Canada stopped selling flavoured cartridges in early 2020.75
Russia On sale since late 2018.
Ireland On sale from May 2019 until Late 202076
South Korea On sale from May 2019 until May 2020 77
Philippines On sale since June 2019.
Ukraine On sale since June 2019.
Indonesia On sale from July 2019 until February 2020.78
China (online only) Stopped selling in September 2019.79
Germany Stopped selling end of 2020 8081
Austria Stopped selling in July 2020.8081
Belgium Stopped selling in July 2020.81
Portugal Stopped selling in July 2020.81
France On sale, but intends to withdraw.81
Spain Stopped selling in July 2020.81
Italy On sale, but intends to withdraw.82
Poland On sale.
Switzerland On sale.
New Zealand On sale since 201883

Israel

In March 2018, Israel was the first international country that JUUL Labs expanded to, offering the same high nicotine strength ‘pods’ as those available on the US market (59mg of nicotine each).848586 Concerned that the product posed a danger to health, Prime Minister and Minister of Health Benjamin Netanyahu issued a special bill in August 2018 that banned the sale and marketing of e-cigarettes with a nicotine content of 20mg, similar to EU restrictions on e-cigarette nicotine strength.87 In December 2018 the Israeli Parliament passed a further law which extended existing tobacco regulations to e-cigarettes.86

Law firm Eitan Haezrachy & Co, on behalf of JUUL Labs, filed two petitions with the Supreme Court of Israel against the Prime Minister’s special decree and the full law, which included opinions from Professors Moti Ravid and Yehuda Adler (HaYeshua Medical Center) that “Juul-like devices” did not have the same risks as cigarettes regarding cancerous substances.87 JUUL Labs Israel CEO Assaf Snir commented to the The Jerusalem Post that “JUUL will be sold in Israel- whether sooner or later”.8788

As of October 2021, however, JUUL was not for sale in Israel.89FINAL JUUL Letter 4.8.19

Europe

Image 2. JUUL campaign billboard in UK (source: conveniencestore.co.uk90)

JUUL’s main European market is the UK, which the company considers an attractive market because “it has the world’s ‘most supportive government’ when it comes to encouraging smokers to vape”.84

The company followed a similar sales strategy in the UK as it had in the US:91 first make the product available online and in e-cigarette retail stores, next start supplying the supermarket sector, then break into the convenience store market and petrol station stores.9293 The gradual roll-out was supported with a 12-week national marketing campaign, which consisted of billboards showing testimonials of smokers that had switched to JUUL (see Image 2), and “local brand ambassador activity”.90

To comply with nicotine strength restrictions set out by the EU Tobacco Products Directive (TPD), JUUL Labs was forced to reduce its e-cigarette nicotine strength from 59mg/ml to 20mg/ml (the maximum strength allowed under the TPD). The company has said that the reduced nicotine strength will make it “less effective as an alternative to cigarettes for heavy smokers”.88 This claim is not supported by European evidence which shows that e-cigarettes with a strength of 20mg/ml and lower were shown “…to be effective for the majority of smokers in their cessation efforts”94 and that most British e-cigarette users “use less nicotine than the limit set in the new EU regulations”.95

Asia & Pacific

The company courted the Indian market from late 2018, when it created an India country team ahead of its plans to create an Indian subsidiary.96 In December 2018 former Uber Head of Policy North India & Federal Affairs, Rachit Ranjan, was recruited to be JUUL Labs’ Senior Public Policy Strategist, and in January 2019 former Mastercard executive Rohan Mishra joined as Head of Government Relations.96 Juul also partnered with Indian Journal of Clinical Practice Group (IJCP), to help JUUL Labs “better understand the India market”.97 The editor in chief, Dr. K.K. Agarwal, was previously a member of the ethics committee of the Medical Council of India and national president of the Indian Medical Association.97

JUUL was unofficially available online, in tobacco retailers and some convenience stores in India.98 In August 2019 the Indian Health Ministry announced a ban on the production and import of e-cigarettes, saying that it was necessary to prevent “an ‘epidemic’ among children and young adults”.99 Under the proposed legislation, those that breach the law would face severe penalties ranging from a fine to gaol terms.

Juul was launched in New Zealand in 2018.83 Despite Australia banning the sale of e-cigarettes, the Australian Financial Review revealed that JUUL Labs had applied to secure several trademarks in Australia, including the company’s logo, JUUL ‘pods’, the word ‘juuling’, and the phrase ‘make the switch’.100 A JUUL Labs spokesperson denied that this move was related to a potential imminent launch in Australia: “The trademark applications associated with the company and brands of JUUL Labs are part of the normal business process to secure our brand identity and intellectual property rights”.100

From May 2019 JUUL was available in South Korea, Philippines, Indonesia and briefly China (online sales were halted one day after launch). Its launch in the Philippines was supported by a JUUL Lab’s organised stakeholder event at 20 June 2019. In Indonesia, JUUL Labs “sounded out government officials in Indonesia” months ahead of its launch, discussing e-cigarette tax with officials of the Ministry of Finance.101

As with the middle east, JUUL Labs indicated that it intended to further expand in the  region. Speaking to the Nikkei Asian Review, Ken Bishop, the company’s Asia Pacific Vice President International Growth, said that “we essentially want to be available wherever tobacco is sold”.102 It is not clear whether it still has ambitions to do so.

Africa and Eastern Mediterranean

JUUL Labs’ EMEA (Europe Middle East and Africa) President Grant Winterton had said, in 2019 that the company was hoping to launch its product in Africa in 2020 or 2021, adding that “There is no one who is not on our radar if you look forward next 4-5 years”.88 However, given overall trends in market expansion for JUUL, the company is likely to remain out of the African market. In 2019, JUUL indicated that it planned to launch in Middle Eastern countries in 2020.10388It is not clear whether that is still the case.

Controversial Marketing and Sales Strategies

JUUL Labs has repeatedly made headlines for targeting its product at young people. Matt Meyers, president of health advocacy group Campaign for Tobacco-Free Kids, said:

“The Juul playbook is identical to what the tobacco industry has done for decades. They claim to care about public health, then they engaged in media marketing whose primary appeal was to kids”.29

Image 3. Invitation to JUUL launch parties (source: R. Jackler, C. Chau, B.D. Getachew et al, 2019104

Early Marketing Practices: “Patently Youth-Oriented”

In 2017, reports emerged that JUUL was popular with young students in the US.105106107 Researchers from Stanford University published a study in January 2019 that examined JUUL’s marketing campaign from its launch in 2015 to autumn 2018, looking at the company’s ads, emails and social media content. The authors concluded that JUUL’s campaign, in its first six months, was “patently youth-oriented” and appeared to mirror well-known tobacco industry tactics.104 This included launch events targeted at young people (see Image 3) and free sampling at youth events such as rock concerts. Thereafter the campaign turned more “muted”, but was widely distributed on social media channels like Instagram, which is known to be popular amongst youth. The social media campaign was “amplified by hashtag extensions” (which effectively mixes JUUL advertisements with postings from a wider variety of Instagram users) and “catalysed by compensated influencers and affiliates”.104 The use of influencers by companies is a type of paid promotion, where a popular person with a large social media following gets paid to promote a product, in this case JUUL.

Voluntary Marketing and Social Media Code

Image 4. JUUL Lab’s Marketing & Social Media Code (source: Juul.com, accessed July 2019)

JUUL Labs has adopted a voluntary “Marketing and Social Media Code” (see Image 4). This strategy echoes tobacco companies’ past efforts to pre-empt formal regulation of its marketing activities.108
The first copy of JUUL Lab’s code dates back to July 2018. The code has evolved over time, with a few notable changes between July 2018109 and July 2019 (bold emphasis added by Tobacco Tactics editorial team):110

  • 2018: JUUL is a nicotine product intended for adults of legal purchase age
  • 2019: JUUL is a nicotine product intended for adult smokers of legal purchase age
  • 2018: JUUL is a switching product. JUUL products have not been approved by the Food and Drug Administration to diagnose, treat, cure, or prevent any disease.
  • 2019: JUUL is a switching product. JUUL products are not intended to be used as cessation products, including for the cure or treatment of nicotine addiction (e.g. smoking cessation), relapse prevention, or relief of nicotine withdrawal symptoms.
  • 2018: Product sampling complies with all federal and state regulations.
  • 2019: Paid product sampling complies with all federal and state regulations
  • 2018: We use social media responsibly to ensure content is targeted to adult smokers, while limiting engagement by youth. In the U.S. we do not use social media to advertise or promote JUUL products, and messaging is limited to non-promotional communications
  • 2019: We do not share social media content that promotes excess use or inappropriate us of our product. We only share user generated social media content that does not feature underaged users.

The July 2019 version included a new principle: We always include nicotine warning messaging with all social media posts.

In August 2019, the FTC had reportedly begun an investigation into JUUL Lab’s use of social media influencers and other marketing tactics that might appeal to children.58

Pitched Inappropriately As Smoking Cessation Aid

Despite little independent evidence that JUUL is an effective smoking cessation aid, and in violation of JUUL Labs’ own marketing code which states that JUUL is not intended to be used as a smoking cessation product (see above), JUUL Labs reportedly pitched its product as a tool to quit smoking to US employers and insurers who want to help their staff quit smoking.111 According to CNBC News, JUUL Labs hired former Cardinal Health executive Douglas Roberts to head up a team of 17 staff to strike deals with “health plans, providers, self-insured employers and the public sector”.111 To date (September 2019) no announcements of such deals have been made.

In July 2019, retail magazine The Grocer reported that JUUL Labs had teamed up with a UK convenience store chain to offer smokers “a drop -in service to help them quit”.112 Rather than having a consultation with a trained health professional, smokers visiting the store are assisted by a JUUL Labs employee who “offers information and support on making the switch from smoking to vaping, and informs smokers about the range of alternative products available to them”.112 Customers are offered discounted JUUL products, in a bid “to help transition smokers away from tobacco”. According to the company, the initiative prompted “a four-fold increase in vape sales”.112 This initiative comes after years of UK Government spending cuts to stop smoking support services, with at least one other e-cigarette retailer launching new support services in its stores to fill the gap.113

Tracking its Users

In 2019 JUUL Labs launched a ‘pilot programme’ on the UK market for a JUUL product called C1. Using Bluetooth technology, the e-cigarette can be paired with an android phone via an app, and users can track their usage and lock and locate their JUUL C1 device.114 A similar technology was re-launched alongside the JUUL2 devicein 2021, available only in the UK. 6

JUUL Labs is not the first company to exploit Bluetooth technology to collect e-cigarette usage data. In 2019,  British American Tobacco (BAT) launched the Vype iSwitch Maxx which incorporates similar technology,115 as does IQOS from Philip Morris International (PMI).116

JUUL Labs has argued that the Bluetooth technology is used to help consumers ‘tailor their vaping experience’ and told the BBC News in August 2019 that it “would not sell or share the information without users’ explicit permission”.114 But concerns have been raised that the data collected could be used for entirely different purposes, in particular maintain nicotine addiction. A study by Lempert and Glantz showed PMI for example, using the same technology to remind consumers when to re-order IQOS tobacco sticks, or notify them that they haven’t used their IQOS device yet.117

Illegal Sale of High Strength JUUL

In July 2019 Dutch newspaper De Volkskrant reported on the illegal sale of JUUL e-cigarettes of the 59 mg/ml nicotine strength variety in Amsterdam.118 At the time, JUUL Labs had not officially launched its product on the Dutch market. Retailers selling the product told the newspaper they had either imported it directly from the States or from China (‘it’s probably a reproduction’), with one claiming that the product sells so well that it now represents a quarter of their revenue. JUUL Labs told the newspaper it was aware of the illegal sales in the Netherland but denied involvement.118 The National Institute for Public Health and the Environment (RVIM), the research arm of the Dutch Ministry of Health, said it was concerned about the illegal supply and sales of JUUL in the Netherlands, and would start an investigation.

Influencing E-Cigarette Regulations

Increased Spending on Lobbying

JUUL Labs lobbying budget is substantial and has significantly increased over time.29 In the US alone, the company spent US$1,640,000 on lobbying in 2018,119 including $870,000 to consultancies, such as Sims Strategies, W Strategies, KDCR Partners, S-3 Group, Insight Public Affairs, Empire Consulting Group, and Covington & Burling.119 In the first half of 2019, the company had already spent more than US$1,900,000 on lobbying.120121.

In its early efforts to expand to global markets, the company reportedly spent “millions of dollars lobbying politicians in an  attempt to pre-empt or roll back relevant regulations on products”.70 In Europe, JUUL Labs’ UK subsidiary, JUUL Labs Ltd, has been registered with the European Lobbying Register since August 2018.23 Records submitted in July 2019 state that the company had two members of staff accredited to access the European Parliament, Peter Beckett (Managing Director of Beckett Associates) and Eva Chitul, and that its 2018 EU lobbying budget was between EUR€100,000 and EUR€200,000.122

Political Donations

In the US, JUUL Labs has donated money to members of Congress through its Employees Political Action Committee (PAC), which launched in March 2018.123 In the first half of 2019 the PAC donated nearly $100,000; $74,000 to Democrats and $22,500 to Republicans.124

Funding Allies to Oppose Bans

In addition to lobbying federal decision makers, JUUL Labs has lobbied at state level. According to Forbes, the company spent US$3 million in a July 2019 campaign against the proposed e-cigarette ban in the company’s home city San Francisco.125 Others reported that JUUL Labs spent closer to US$19 million to oppose the ban.126 The funds appear to have supported the establishment of the Coalition for Reasonable Vaping Regulation, a lobbying organisation which was set up in May 2019 to fight San Francisco’s proposed ban.125 In late September, shortly after K.C Crosthwaite was appointed as JUUL Labs’ CEO, the company announced that it would seize “active support” of the campaign to overturn the ban, as part of efforts “to responsibly lead the industry”.127

Image 5. JUUL Lab’s “Switch Network” (source: theswitchnetwork.com, accessed October 2019)

JUUL Labs (by proxy of consultancy Locust Street) has recruited consumers to join the so-called “The Switch Network”.128 The Switch Network is a website where JUUL consumers are invited to share their story about switching from cigarettes, invite friends, and importantly, “advocate for responsible policies” (see Image 5).129 To “protect” their “vapor access”, visitors of the site are urged to sign a petition, email, call or meet with elected officials, attend a public rally, or testify at a state or local hearing”.129 According to CNBC News, Locust Street has been calling and emailing JUUL consumers to get them to sign up to the website.128

Setting up a seemingly grassroot movement to support regulatory change is a well-used tobacco industry tactic. For more information see: Astroturfing.

Revolving Doors

Since July 2018, JUUL Labs has appointed or contracted key staff to strengthen its lobbying and legal team, many of whom have previously worked closely with US politicians and decision makers, or as political appointees:

  • Rebeccah Propp – appointed in June 2019 as the company’s Communications Director.130 Previously, she served as Vice President Mike Pence‘s Director Media Affairs.
  • Johnny DeStefano – contracted as an external consultant in May 2019.130 DeStefano previously oversaw staff recruitment for the Trump administration in 2017.
  • Martha Coakley – joined in April 2019. Coakley most recently worked as a lobbyist for Foley Hoag where she worked on the JUUL account.27 From 2007 to 2015 she was the State Attorney General of Massachusetts. Coakley’s appointment at JUUL Labs followed the announcement in July 2018 that her successor, Attorney General Maura Healey, had launched an investigation into JUUL Labs and online sellers of JUUL, over concerns about the marketing and sale to minors.131
  • Gerald (Jerry) F. Masoudi – appointed Chief Legal Officer in July 2018. From 2004 to 2009 Masoudi worked for the FDA, where he “supervised agency litigation and advised the FDA’s senior leadership on regulatory and enforcement matters”.132 Masoudi’s appointment came in the wake of a series of regulatory FDA interventions to curb teenage use of Juul and other e-cigarettes, with FDA Commissioner Gottlieb later stating that “youth use of JUUL represents a significant proportion of the overall use of e-cigarette products by children”.133 Also see: E-Cigarettes: Altria

The Revolving Door is often used by the tobacco industry as a tactic to exercise influence on its regulatory environment. Recruiting staff with useful connections and a network that they can use to manage those events, can be beneficial for companies and give them undue access and influence. However this is a clear conflict of interest.

For other (non-JUUL Labs) Revolving Door examples, see Johan Gabrielsson, Michel Petite, Kate Marley.

JUUL Labs and Science

Tobacco companies have a long history of manipulating science, often using industry-funded studies to create doubt about the scientific consensus of the health impacts of tobacco and nicotine products, and to promote their own positions.134 JUUL Labs appears to have adopted similar tactics.135

Promotional Corporate Science Website: JLIScience.com

Like BAT and PMI before it, JUUL Labs has set up an online portal to promote its scientific credentials and studies.136 Through JLI Science, JUUL Labs aims “to better understand the effects and impact vaping products have in the long term, while also discouraging new users, and to share those results with the scientific community”.137 The website contains a ‘research library’ and a section where third party researchers are invited to apply for funding for “studies with scientific and medical merit”.138

The ‘research library’ contained 19 studies in September 2019, with the majority being non-peer reviewed posters published at tobacco industry-accessible conferences like the Society for Research on Nicotine and Tobacco Annual Meeting and the Global Forum on Nicotine, and the Altria-organised Tobacco Science Research Conference.139 Many of the studies in the ‘library’ suggest that e-cigarettes have a positive impact on public health.

Ten of the 19 studies were undertaken by Neil McKeganey’s research consultancy, Centre for Substance Use Research (CSUR). The UK-based CSUR previously has undertaken work for British American Tobacco and its subsidiary Nicoventures, Philip Morris International, and Imperial Tobacco’s subsidiary Fontem Ventures.140 In 2018 CSUR was awarded nearly US$100,000 by the PMI-funded Foundation for a Smoke-Free World, to set up a ‘Centre of Excellence in Behaviour Research Related Smoking Cessation’. See: Foundation for a Smoke-Free World Centres of Excellence.

JUUL Labs also held research contracts with Enthalpy Analytical, Christchurch Clinical Studies Trust, Rose Research Center, Cliantha Research, Celerion Inc, and GfK Custom Research LLC.136

Lack of Scientific Credibility

A 2019 study published in The Lancet, led by first author Tan, evaluated JUUL Labs-funded studies against the eight criteria developed by Cohen and colleagues to evaluate the potential impacts of tobacco industry sponsored research.135141 Tan and colleagues found several weaknesses in the JUUL Labs studies which undermine their scientific credibility, including:135

  • Lack of transparency in the selection process of successful applications, with the selection criteria and expertise of reviewers not fully described;
  • Unclear to what extent the researcher owns the data or has freedom to publish (irrespective of the findings);
  • The research agenda is determined by the company;
  • Lack of information on the governance team providing oversight;
  • There are no stated conflicts of interest policies.

Based on the highlighted weaknesses, the authors urge caution and recommend scrutiny of studies funded by JUUL Labs, warning that the findings might be used for lobbying and PR gains, and promoting the company’s business interests.135

Findings of its Paid-For Research Used to Influence E-cigarette Policy

In response to US President Trump’s plans to ban e-cigarette flavours in September 2019,142 The Times revealed that JUUL Labs had cited evidence from one of its own studies to argue that e-cigarette flavours should not be banned in the UK.143 JUUL Labs had already ceased the sale of most of its e-cigarette flavours in U.S. retail stores in November 2018 due to increased scrutiny by the FDA.144 But the company has opposed any potential move to ban e-cigarette flavours in the UK.

Citing a paid-for study carried out by CSUR, JUUL Labs told The Times that the study found that “the use of non-tobacco flavours, such as mango and mint, increase the likelihood for smokers to move away from tobacco cigarettes by 30%”.143 A similar conclusion was reached by a non-peer reviewed study conducted by JUUL Labs own researchers, which was presented in poster-format at the Global Forum on Nicotine on 14 June 2019, and available at JLIscience.com.145

Attempted to Recruit Tobacco Control Experts

In February 2019, a senior member of the Scientific Affairs team at Juul Labs EMA Region contacted a member of the tobacco control community offering support:146

”As JUUL has an interest in the use of e-cigarettes, we are keen to build more scientific data around this particular use of smoking cessation & ENDS (electronic-nicotine delivery systems) especially within specific populations across different medical disciplines. This is an area that we believe needs more research & and is something that JUUL is committed to supporting. I am very interested in your research within tobacco control and we would be delighted to learn more about your work & possibly support any research ideas that you may have.”146

At the time of publication, Tobacco Tactics was not aware of any similar approaches made elsewhere by the company.

Paid-for issue of the American Journal of Health Behaviour

In June 2021, JUUL sponsored an entire issue of the American Journal of Health Behaviour, spending up to $US57,500 to publish eleven articles in the academic paper.67147 JUUL employees co-authored the articles alongside associates from the US health consultancy Pinney Associates, and from the Centre for Substance Use Research, a Scottish consultancy receiving funds from the PMI-funded Foundation for a Smoke Free World.148149 Some of the paid-for studies, which focus on the role of JUUL’s products in promoting smoking cessation, were submitted by the company as part of its application for market authorization to the American FDA.150 The special issue was widely criticised by academics, NGOs and public health organisations, leading to the resignation of three members of the Journal’s editorial board.151

Relevant Links

TobaccoTactics Resources

References

  1. M. Richtel, S. Kaplan, Did Juul Lure Teenagers and Get ‘Customers for Life’, The New York Times, 27 August 2018, accessed September 2021
  2. K. Chaykowski, The Disturbing Focus Of Juul’s Early Marketing Campaigns, Forbes, 16 November 2018, accessed January 2019
  3. Truth Initiative, teens are 16 times more likely to use juul than older age groups, 30 October 2018, accessed November 2021
  4. JUUL Labs, Shop: Juulpods, Juul UK website, 2019, accessed April 2019
  5. S. Kaplan, J. Hoffman, Juul Suspends Selling Most E-Cigarette Flavors in Stores, The New York Times, 13 November 2018, accessed September 2021 (behind paywall)
  6. abJUUL Labs Science, Scientific Assessment of the JUUL2 System, undated, accessed September 2021
  7. N. Goldenson, J. Chen and S. Shiffman, Pharmacokinetic and Subjective Assessment of the JUUL System, Prototype JUUL2 Electronic Nicotine Delivery System in Two Nicotine Concentrations, IQOS and Combustible Cigarette, Queios, 22 September 2021.
  8. Jim  McDonald, 28 September 2021. JUUL2 Smart Vape Now Available Exclusively in the UK, Vaping260 website, accessed September 2021
  9. JUUL Labs, Shop: JUUL2 pods, Juul UK website, 2021, archived October 2021
  10. Ploom Inc., United States Securities and Exchange Commission Form D, Securities and Exchange Commission website, 5 May 2011, accessed March 2019
  11. PAX Labs Inc., United States Securities and Exchange Commission Form D, Securities and Exchange Commission website, 7 April 2015, accessed March 2019
  12. JUUL Labs Inc., United States Securities and Exchange Commission Form D, Securities and Exchange Commission website, 19 December 2017, accessed March 2019
  13. A. Levy, E-cigarette maker Juul is raising $150 million after spinning out of vaping company, CNBC News, 19 December 2017, accessed March 2019
  14. M. Russell, Marijuana startup spun out of Juul reaches new highs, San Francisco Chronicle, 24 February 2019, accessed April 2021
  15. J.W. Bullock, Statement from Jeffrey W. Bullock, Secretary of State of the State of Delaware, 30 June 2017
  16. Secretary of State Amended Statement by Foreign Corporation (ASDC), Document Nr. A0799922, Filed Secretary of State, State of California, 6 July 2017
  17. JUUL Labs Inc., JUUL Labs Inc. Appoints Kevin Burns, Previously President & Chief Operating Officer of Chobani, as its Chief Executive Officer, PR Newswire, 11 December 2017, accessed September 2021
  18. J.Maloney,JUUL CEO Kevin Burns to step down, Wall Street Journal, 25 September 2019, accessed September 2019
  19. Linkedin Profile: K.C. Crosthwaite, undated, accessed October 2019
  20. abT. Rivas, Altria Veterans Are Taking Key Spots at Juul. Barrons.com, 2 October 2019, accessed October 2019
  21. Linkedin Profile: Tyler Mace, undated, accessed October 2021
  22. L. Wells, Juul joins the UK Vaping Industry Association, Talking Retail, 12 March 2019, accessed April 2019
  23. abcdeTransparency Register. Profile of JUUL Labs Ltd, last modified 29 June 2021, accessed October 2021
  24. Independent European Vaping Alliance, Members, IEVA website, 2021, accessed January 2021
  25. American Chamber of Commerce to the European Union, members, 2021, accessed October 2021
  26. A. Gangitano, Juul leaves vaping industry group amid dispute over FDA lawsuit, thehill.com, 21 August 2019, accessed September 2019
  27. abM. Levenson, M. Stout, Former Mass. AG Coakley Joins E-Cigarette Company JUUL, Boston Globe, 2 April 2019, accessed October 2021
  28. S. McMinn, Juul Builds Lobbying Clout in Washington, NPR, 23 January 2019, accessed April 2019
  29. abcO. Zaleski, Juul Said It Would Disrupt Big Tobacco. They May Join Forces Instead, Bloomberg.com, 6 December 2018, accessed September 2019
  30. G. Tucker, Public Health England hires vaping PR firm Freuds, The Sunday Times, 23 December 2018, accessed March 2019
  31. Freuds, Stoptober, undated, accessed April 2019
  32. Public Affairs Board, Register for 1st June 2018-31st August 2018, accessed April 2019
  33. Public Affairs Board, Register for 1st September 2018-30th November 2018, accessed April 2019
  34. Public Affairs Board, Current Register for 1st March 2019 to 31st May 2019 . Hanover Communications, accessed July 2019
  35. CSUR, Our Research on Tobacco Harm Reduction, 2021, accessed July 2021
  36. PinneyAssociates, Tobacco Harm Reduction, 2021, accessed July 2021
  37. Demos, Funding Contracted and Awarded during 2019 Financial Year, 2020, accessed March 2022
  38. abDemos, Mind the Gap: New approaches to tackling health inequality, 24 September 2019, accessed March 2022
  39. Demos, Regulating the Future of Vaping, 14 March 2022, accessed March 2022
  40. P. Mackenzie, Regulating the Future of Vaping, March 2022, accessed March 2022
  41. UK Parliament, Smoke-free England, debate, Hansard, 29 March 2022, accessed March 2022
  42. abAltria Group Inc, Altria Makes $12.8 Billion Minority Investment in JUUL to Accelerate Harm Reduction and Drive Growth, 20 December 2018, accessed January 2019
  43. JUUL Labs, JUUL statement about Altria Minority Investment and Service Agreements, 20 December 2018, accessed April 2019
  44. Altria, Altria Provides Update on FTC Review on JUUL Investment, Press Release, 8 April 2019, accessed April 2019
  45. abBusinessWire, Altria Announces Conversion of Its Non-Voting Shares in JUUL; Does Not Intend to Exercise Governance Rights Pending FTC Litigation Outcome, 12 November 2020, accessed October 2021
  46. J. Maloney, Altria-Juul Deal Goes to Trial, Wall Street Journal, 2 June 2021, accessed October 2021.
  47. Federal Trade Commission, Altria Group/JUUL Labs, In the Matter of. FTC Cases and Proceedings, last updated 3 June 2021, accessed December 2021
  48. Federal Trade Commission, Administrative Law Judge Dismisses FTC Antitrust Complaint against Altria Group and JUUL Labs, Inc., 24 February 2022, accessed March 2022
  49. abUnited States Senate, Letter from 11 Senators to Kevin Burns dated 8 April 2019, Dick Durbin United States Senator Illinois website, accessed April 2019
  50. Campaign for Tobacco Free Kids, Possible Altria-Juul Partnership Would Join Companies with Most Popular Cigarette and E-Cigarette Brands Among Kids, 28 November 2018, accessed July 2019
  51. S. Kaplan, F.D.A. Accuses Juul and Altria of Backing Off Plan to Stop Youth Vaping, The New York Times, 4 January 2019, accessed July 2019
  52. Japan Tobacco International, Innovative partnership for Ploom and Japan Tobacco International JTI to take minority share in Ploom, News Release, 8 December 2011, accessed June 2017
  53. JTI Acquires ‘Ploom’ Intellectual Property Rights from Ploom Inc., BusinessWire, 16 February 2015, accessed March 2019
  54. Japan Tobacco International, JTI acquires “Ploom” Intellectual Property Rights from Ploom, Inc., 16 February 2015, accessed July 2017
  55. Wells Fargo, Altria Group, Inc. MO: vape ‘Em While You Got ‘Em. Equity Research, 25 October 2018
  56. abH. Crossan, Juul hits the UK- but will it repeats its success?, 28 September 2018, Mintel (by subscription)
  57. Center for Tobacco Products, Warning Letter, FDA website, 9 September 2019, accessed September 2019
  58. abJ. Maloney, Juul’s Marketing Practices Under Investigation by FTC (behind paywall), The Wall Street Journal, 29 August 2019, accessed September 2019
  59. Probes of e-cigarette giant Juul underway in Illinois and Washington D.C., CBS News, 30 August 2019, accessed September 2019
  60. A. LaVito, State attorney general accuses Juul of ‘getting kids to start vaping,’ opens probe of ecig market leader, CNBC News, 24 July 2018, accessed September 2019
  61. E. Corbett, House Democrats Launch Investigation Into E-Cigarette Company Juul, Fortune.com, 13 June 2019, accessed July 2019
  62. L. McGinley, Juul agrees to pay North Carolina $40 million to settle vaping accusations. The Washington Post, 28 June 2021, accessed October 2021
  63. The Independent, Juul to pay $14.5 million to settle Arizona vaping lawsuit, 24 November 2021, accessed November 2021
  64. K. Cai, Teen’s two-Pod A Day Juul Addiction Caused Massive Stroke, Lawsuit Says, Forbes, 18 July 2019, accessed September 2019
  65. L. Hautala, Juul, Philip Morris sued for marketing to minors, deceptive advertising, C Net, 19 August 2019, accessed September 2019
  66. abcE. Brodwin, The precarious path of e-cig startup Juul: From Silicon Valley darling to $24 billion behemoth under criminal investigation. Business Insider, 31 October 2019, Accessed December 2021
  67. abcS. Kaplan, Juul Is Fighting to Keep Its E-Cigarettes on the U.S. MarketThe New York Times, 5 July 2020 (behind paywall), accessed November 2021
  68. A. LaVito, Juul names new CFO amid management shake-up, several top executives are out, CNBC, 29 October 2019, accessed October 2021
  69. B. Lovelace Jr, Juul taps CFO to lead embattled e-cigarette maker’s $1 billion restructuring, CNBC, 6 January 2020, accessed October 2021
  70. abM. Davies, J. Kasperkevic, M. Chapman, Juul spreads over the world as home market collapses in scandal. The Bureau of Investigative Journalism, 21 November 2019, accessed October 2021
  71. J. Maloney, Juul Scales Back Overseas Expansion, The Wall Street Journal, 15 January 2020, accessed October 2021
  72. S. M. Lee, Juul Will Stop Selling In Five European Countries, Including France And Spain. Buzzfeed news, 1 May 2020, accessed October 2021
  73. J. Ponciano, Juul’s Valuation Has Tanked 85% In Less Than Two Years–It Could Get Worse. Forbes, 30 October 2020, accessed October 2021
  74. Dun and Bradstreet, D&B Hoovers (behind paywall), Search term ‘Juul Labs’, accessed 2 July 2019
  75. Reuters, Juul Labs to stop selling fruit-flavored pods in Canada, Reuters, 14 January 2020, accessed October 2021
  76. J. Mulligan, Vaping giant Juul to leave Irish market after less than two years, Independent.ie, 23 November 2020, accessed October 2021
  77. E-cigarette maker Juul Labs to exit South Korea after year of health controversies, Reuters, 6 May 2020, accessed October 2021
  78. C. Kirkham, F. Potkin, N. J. Morales, Exclusive: Juul halts Indonesia e-cigarette sales, throwing Asia expansion in doubtReuters, 24 February 2020, accessed December 2021
  79. L. Voytko, Juul Sales Stopped In China Just Days After Launch, Forbes, 17 September 2019, accessed December 2021.
  80. abTobacco Reporter, Juul Labs to Exit Germany,19 October 2020, accessed December 2021.
  81. abcdefS. M. Lee, Juul Will Scale Back In Europe And Leave France, Spain, And Other Countries, Buzzfeed News, 1 May 2020, accessed December 2021.
  82. Tobacco Endgame, Sigarette elettroniche: JUUL potrebbe abbandonare l’Italia (in italian), 7 September 2020, accessed December 2021.
  83. abUniversity of Otago, Vaping with nicotine more common than smoking among NZ teens. Medical Express website, 18 October 2021, accessed October 2021
  84. abM. Geller, Fast-growing e-cigarette maker Juul to launch in the UK, Reuters, 17 July 2018, accessed March 2019
  85. A. LaVito, Juul e-cigarette expands to England and Scotland, eyes Asia, CNBC News, 16 July 2018, accessed March 2019
  86. abM. Gorali, L. Baumer, Juul Withdraws Petition Against Israeli Marketing Ban on Its Full-Nicotine Pods, Calcalist, 2 April 2019, accessed April 2019
  87. abcO. Oppenheim, Juul E-cigarettes Company Files Petition to High Court Objecting Ban, The Jerusalem Post, 23 August 2018, accessed March 2019
  88. abcdC. Humphries, Vaping companies facing European opposition to higher nicotine level, Reuters, 7 May 2019, accessed July 2019
  89. Juul Labs, Juul Israel website, 2021, accessed October 2021.
  90. abConvenience Store, Juul launches first nationwide ad campaign, 28 June 2019, accessed July 2019
  91. L. Cambridge, Juul to expand sales team to break into stores, The Grocer, 21 February 2019, accessed March 2019
  92. O. Gill, Sainsbury’s and Juul strike landmark vaping deal, The Telegraph, 2 November 2018, accessed March 2019
  93. JUUL Enters Wholesale Sector, KamCity.com, 24 May 2019, accessed July 2019
  94. European Commission, E-Cigarettes, undated, accessed July 2019
  95. Action on Smoking and Health, New EU rules on nicotine strength are not a problem for most vapers, Press Release 16 May 2016, accessed July 2019
  96. abS. Srivastav, India’s Health Regulator Calls for Ban on E-Cig Maker Juul’s Entry Into the Country, inc42.com, 16 March 2019, accessed March 2019
  97. abP. Pulla, Medical journals’ published under fire, The Hindu, 7 February 2019, accessed March 2019
  98. N. Kaur, The Juul Comes to School – But Also to the Aid of Adult Smokers in India, The Wire, 3 February 2019, accessed March 2019
  99. A. Kalra, Exclusive: India proposes ban on e-cigarettes, with jail terms for offenders – government documents’, Reuters, 22 August 2019, accessed September 2019
  100. abJ. Frost, Vaping giant JUUL swoops Down Under, Financial Review, 21 June 2019, accessed July 2019
  101. F. Potkin, C. Kirkham, Exclusive: Juul sounds out Indonesia for expansion, other Asian countries in sight, Reuters, 13 November 2018, accessed July 2019
  102. S. Borowiec, Vaping giant targets lucrative Asian market with South Korean launch, Nikkei Asian Review, 14 June 20198, accessed July 2019
  103. E. Clowes, E-cigarette maker Juul weighing Middle East expansion, Gulf News, 21 May 2019, accessed September 2019
  104. abcR. K. Jackler, C. Chau, B.D. Getachew, et al., JUUL Advertising Over its First Three Years on the Market, published 31 January 2019, accessed March 2019
  105. S. Logan, C. Campanile, Schumer pushed for regulations on e-cigs as more kids vape, New York Post, 15 October 2017, accessed September 2019
  106. A. Chen, Teenagers Embrace JUUL, Saying It’s Discreet Enough to Vape In Class, WBUR News, 4 December 2017, accessed September 2019
  107. C. Anders, The dawn of the JUUL, Indiana Daily Student, 8 December 2017, accessed September 2019
  108. Y. Saloojee, R. Hammond, Fatal Deception. The tobacco industry’s ‘new’ global standards for tobacco marketing, Rev Panam Salud Publica, February 2002, accessed July 2019
  109. JUUL Labs, Marketing & Social Media Code, Juul.com, archived 26 July 2018, accessed July 2019
  110. JUUL Labs, Marketing & Social Media Code, Juul.com, archived 2 July 2019, accessed July 2019
  111. abA. LaVito, C. Farr, Juul is pitching its e-cigarette as an anti-smoking tool to employers and insurers, CNBC News, 7 March 2019, accessed July 2019
  112. abcL. Cambridge, Thornton’s Budgens links with Juul offer smoking cessation service, The Grocer, 9 September 2019, accessed September 2019 (behind a paywall)
  113. H. Saker-Clark, UK’s biggest vaping firm attacks Government over smoking support cuts, Yahoo News, 2 September 2019, accessed September 2019
  114. abJuul trials ‘lockable’ C1 e-cigarette for UK vapers, BBC News, 5 August 2019, accessed September 2019
  115. F. Briggs, Vype incorporates Bluetooth technology and app in new vaping product launches, Retail Times, 14 February 2019, accessed September 2019
  116. Philip Morris International, How to connect IQOS via Bluetooth with mobile app IQOS Connect 3.0?, iqosmag.com, 6 August 2018, accessed September 2019
  117. L.K. Lempert, S.A. Glantz, Heated tobacco product regulation under US law and the FCTC, Tobacco Control, 2018:27:s118-s125
  118. abC. Luckerhof, Verboden e-sigaret Juul gewoon te koop in de winkel, De Volkskrant , 2 July 2019, accessed July 2019
  119. abJUUL Labs Summary 2018, Open Secrets.org, 24 January 2019, accessed March 2019
  120. JUUL Labs Inc, Report Q1 2019, Office of the Clerk of the U.S. House of Representatives, accessed September 2019
  121. JUUL Labs Inc, Lobbying Report Q2 2019, Office of the Clerk of the U.S. House of Representatives, accessed September 2019
  122. Transparency Register. Profile of JUUL Labs Ltd, last modified 19 July 2019, accessed September 2019
  123. L. Woellert, S. Owermohle, Juul tries to make friends in Washington as regulators circle, Politico, 12 August 2018, accessed September 2019
  124. Federal Election Commission, JUUL Labs Employees PAC (JLE PAC) 1/1/2019 to 07/31/2019, accessed September 2019
  125. abK. Cai, Juul Shells Out $3 Million As San Francisco Vaping Ban Battle Intensifies Forbes, 6 August 2019, accessed September 2019
  126. Juul withdraws support for ballot measure aimed at overturning anti-vaping law in San Francisco, CBS News, 1 October 2019, accessed October 2019
  127. JUUL Labs, Statement regarding San Francisco Ballot Initiative, 30 September 2019, accessed October 2019
  128. abA. LaVito, Juul hires ‘political dark arts’ firm led by ex-Clinton campaign director in its fight for survival, CNBC News, 1 October 2019, accessed October 2019
  129. abJUUL Labs, Support the Mission to End Cigarettes, 2019, accessed October 2019
  130. abD. Richardson, Juul Labs Brings on Top Trumpworld Talent as Federal Investigators Circle, Observer, 20 June 2019, accessed July 2019
  131. Office of Attorney General Maura Healey, AG Healey Announces Investigation into JUUL, Other Online E-Cigarette Retailers over Marketing and Sale to Minors, Massachusetts State website, 24 July 2018, accessed April 2018
  132. JUUL Labs, JUUL Labs Appoints Former FDA Chief Counsel Gerald F. Masoudi as Chief Legal Officer, PR Newswire, 21 June 2018, accessed March 2019
  133. S. Gottlieb, Letter to Howard A. Willard III, Chairman and Chief Executive Officer Altria Group Inc, dated 6 February 2019, FDA website, accessed March 2019
  134. R.N. Proctor, Golden Holocaust: Origins of the Cigarette Catastrophe and the Case for Abolition. University of California Press, February 2012
  135. abcdA.S.L. Tan, S. Soneji, M.B. Moran, et al., JUUL Lab’s sponsorship and the scientific integrity of vaping research, The Lancet, 3 August 2019,volume 394, issue 10196
  136. abJUUL Labs, JLI Science, 2019, accessed March 2019
  137. JUUL Labs, About Us, 2019, accessed March 2019
  138. JUUL Labs, Investigator Sponsored Research, jliscience.com, 2019, accessed September 2019
  139. JUUL Labs, Research Library, jliscience.com, 2019, accessed September 2019
  140. CSUR, About, CSUR website, archived 15 August 2018, accessed March 2019
  141. J.E. Cohen, M. Zeller, T. Eissenberg et al., Criteria for evaluating tobacco control research funding programs and their application to models that include financial support from the tobacco industry, Tobacco Control, 2009; 18: 228-234
  142. J. Doward, T. Fraser, UK attacked for defence of flavoured e-cigarettes, The Times, 14 September 2019, accessed September 2019
  143. abD. Fortson, Juul defends flavoured vaping with research the company helped pay for, The Times, 15 September 2019, accessed September 2019 (behind paywall)
  144. S. Kaplan, J. Hoffman, Juul Suspends Selling Most E-Cigarette Flavors in Stores, The New York Times, 13 November 2018, accessed September 2019 (behind paywall)
  145. N.I Goldenson, S. Prakash, J.G. Vose, et all, Flavoured JUUL Use and Smoking Abstention Among Adult Smokers, poster presented at 6th Annual Global Forum on Nicotine, 14 June 2019, available from jliscience.com, accessed September 2019
  146. abK. Adams, Email to undisclosed recipient, Subject: Introduction to EU Medical & Scientific Affairs, dated 11 February 2019, 14:37
  147. D. Reuter, Juul spent more than $50,000 to have a medical journal run an entire issue of pro-vaping studies funded by the companyBusiness Insider, 7 July 2021, accessed July 2021
  148. American Journal of Health Behavior, JUUL Special IssueVolume 45, Number 3, May 2021
  149. S. Shiffman, M.A.  Sembower, E.M. Augustson, et al, The Adult JUUL Switching and Smoking Trajectories (ADJUSST) Study: Methods and Analysis of Loss-to-Follow-UpAmerican Journal of Health Behavior, Volume 45, Number 3, May 2021, doi:10.5993/AJHB.45.3.3
  150. W. Jan, Juul hooked an entire generation on nicotine – can it redeem its image? The Guardian, 2 September 2021, accessed November 2021
  151. A. Zilber, Juul paid $51k for an entire science journal where EVERY article presented evidence that vaping ‘helps smokers quit cigarettes’Daily Mail, 20 July 2021, accessed July 2021
Go to Homepage