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[20] Although there are many causes of oral ulceration, recurrent oral ulceration has relatively few causes, most commonly aphthous stomatitis, but rarely Behet's disease, erythema multiforme, ulceration associated with gastrointestinal disease, [12] [20] and recurrent intra-oral herpes simplex infection

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The risk of future judgments of this sort would argue for making [M&A deals with] companies that are not subject to such a risk. The jury award would also make the acquisition of another tobacco manufacturer less attractive, he notes

"Tobacco company hit with historic verdict"