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The lawsuit notes that, in a 2015 marketing memo, Juul framed its vaporized campaign as an attempt to appeal to a cool crowd. E-cigarettes were shown as integral parts of a cool, cutting-edge tech lifestyle that advances image. Accompanying the vaporized pitch were pictures of 10 models, described as New York trendsetters who embody the Juul brand and speak to millennial consumers. But Massachusetts claims the models who appeared in the photographs seemed inappropriately or unsuitably young. Furthermore, the lawsuit states that Juuls employees and its board of directors acknowledged concern that models photographed for the Vaporized Campaign appeared to be too young. Interestingly, Juul had earlier hired Canadian marketing firm Cult Collective

Kupelian et al