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He began by critiquing the Court's fidelity to Cipollone as unwise, and declared that the Court should "instead provide the lower courts with a clear test that advances Congress' stated goals." 111 He advocated that, instead of relying in Cipollone , the Court adopt the proximate application test and abandon the plurality's predicate duty test because it is "unworkable

The warning letters notified the companies to remove their products from the market

Garam masala is from North Indian Cuisine and Curry powder is from South Indian Cuisine

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