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soon after the 2015 launch,80 After several buyers placed bulk orders of JUULs on the companys
website, PAX Labs reportedly began to suspect that they were being resold to underage users 81 The
company did not confirm these reports.) By late 2015, the company had discontinued the ad campaign.
Marketing a growing brand After JUUL's inaugural ad campaign, official marketing was
mostly confined to the product's website and social media accounts. In the early days of the JUUL
website (late 2015 and early 2016), marketing efforts focused on JUUL's non-tobacco flavors. One
promotion in 2016 associated JUUL with fine dining: "JUUL's medley of satisfying flavors makes it
easy to pair with your favorite foods. We asked three chefs to try JUUL and create recipes inspired by
their favorite pod flavors."82 On social media, PAX Labs used celebrity endorsements and photos from
users to sell the product. A 2016 tweet noted that pop singer Katy Perry was spotted holding a JUUL
at the Golden Globe Awards, 83 Other JUUL sOcial media posts foregrounded sensuality and
individuality, often featuring images of young adults and the tagline "share a#JUULmoment "4 The
company continued to arrange one-offendorsements from social media "influencers" as late as 201785
Over time, JUUL Labs transitioned from emphasizing non-tobacco flavors, with little mention of
smoking, to marketing JUUL as asmoking alternative. By September 2017, JUUL's website contained
the heading JUULis for adult smokers seeking asatisfying alternative to cigarettes. JUUL was
designed with smokers in mind. With its snique satisfaction profile, simple interface, flavor variety,
and lackof lingering smell, JUUL stands out as a genuinely satisfying vapor alternative for smokers. "s6
By mid-2018, when the FDA and at least one state Attorney General launched separate probes into
JUUL Labs' marketing practices, the company's website seemed uniformly focused on older adult
smokers, prominently featuring images and videos of older adults using JUUL,S7 Every page on the
site now contained the banner: "WARNING: This product contains nicotine. Nicotine is an addictive
chemical." The website claimed: "We support reasonable regulation of nicotine products and comply
with all relevant laws and regulations."8JUULLabs published anew "marketing && social media code"
(see Exhibit 7), and launched the website www.juulfacts.com to handle public relations, headlined by
’ the phrase: "If you dontsmokeor vape, don't start."89,90 Monsees andother executives amplified that
message. Underage use of JUUL, Monsees said, was "antithetical to the company's mission."1 Chief
Communications Officer Matt David added: "We have never marketed to anyone underage. Like
many Silicon Valley technology startups, our growth is not the result of marketing but rather asuperior
product disrupting an archaic industry. When adult smokers find an effective alternative to cigarettes,
they tell other adult smokers."92

Free advertising from distributors and users Despite JUUL Labs' modest ad spend to support
its launch, a growing social media following, primarily among young users, promoted the brand. By
February 2018, seven Instagram accounts dedicated to JUUL (inluding the official JUUL account and
S0x fan accounts) attracted 278,172 followers,93 Many were operated by companies that produced or
sold JUUL products and accessories, 94 As of March 2018,35 JUUL-related videos on YouTube had over
100,000 views each.95 Many were submitted by young users, including the YouTube drama, "Dude,
Where's my JUUL?" -a reference tothe 2000 comedy film Dude, Where's MyCar? - which had over a
million views, 6 Some videos showed users applying colorful "skins" to decorate (and potentially
disguise) their JUULs, 7 While such social media exposure enhanced JUUL's visibility, Burns lamented
in 2018: "We have frustrations about how our product is glorified on social media."o

Health Impacts of E-Cigarettes

hgarettes
term were arelatively new product, litle research had been conducted on their long
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social media
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that JUUL Labs had because its young customers are doing it for them."163
But Gottlieb
a step in the right direction. "Voluntary action is no substitute for regulatory
tweeted

steps #FDA will soontaken

take," he wrote. "But we want to recognize actions by Juul today and urge all
manufacturers to
FDAannounced aimmediately
new implement steps to start reversing these trends. " 164
Two days later, the
had threatened. Under
the directive far weaker than the full flavor ban the 18agency
FDA's new rules, retail prohibited
stores that allowed customers under age inside would be
Tom seling non-tobacco flavors unless those nroductswere kept off public display.

New Owners, New

Pressures
ember 2OT8, news broke that Altria had acauired a 35% stake in JUUL Labs for $12.8 billion,
wnich more than doubled JUUL Labs' valuation to $38 billion. 166 Altria representatives clatmed tuiat
the investment, the largest in its history, was part of its "significant action to prepare fora future wnere
adult smokers overwhelmingly choose non-combustible products over cigarettes." The deal gave
hiria one-third of JUUL Labs' board seats (one ofwhich was assumed by Crosthwaite) and gave JUUL
Labs access to Altria's distribution network and retail shelf space (Altria products were sold at 230,000
stores in 2018, compared with JUUL's 90,000), 168, 169 Announcing the deal,partnership
Burns wrote: e
with the
understand the controversy and skepticism that comes with an affiliation and convinced by actions,
largest tobaccocompany in the US. We were skeptical as well. But. we were
not words, that in fact this partnership could help accelerate our success switching adult smokers."10
Altria's investment included $2 billion cash, distributed among JUUL Labs' 1,500 emnployees (an
average of $1.3 mnillion per employee).171
JUUL undermined an
Gottlieb worried that Altria's commitment to offering retail shelf space to
its pod-based e-cigarettes
agreement Altria had made the previous year with the FDA to stop selling
altogether and instead focus on selling cig-a-like e-cigarette devices, which appeared to be less
statement, Gottlieb wrote: "I'mn reaching out to both
attractive to young people. 172 In a January 2019
why they seem to be deviating from the steps
companies to ask them to come in and explain to me will decrease access to kids "173
in a way that
they are taking to restrict their products
Labs started its first major marketing campaign
Amid renewed pressure, in January 2019 JUUL series of TV, radio, and print ads, titled "Make
earlier. The
since the vaporized campaign several years adult smokers on why they had switched to IUUL. The
the Switch." featured testimonials from ads 9.000 inmes 174 In
$30 million on this ad campaign, airing Make the Switch" TV
company spent "quitting" or "cessation" to avoid
JUUL Labs used the term "switching" rather thanwithout FDA
the campaign, therapeutic claim about JUUL, since, approval, e-cigarete
making an unproven their products were inherently safer
therapeutic claims nor imply that
Companies could neither make
than cigarettes.15
2017
reacting to areported 78% increase in vaping among high school students from
In March 2019, Gottlieb moved the date that e-cigarette makers were
released new policy guidance. More troubling for
to 2018, the FDA
their productsfor FDA review up by a year to May 2021.176
required to submit any flavored e-cigarette products that proved particularly popular
Labs, Gottlieb said that subject toimmediate regulation. 177
JUUL
people would be
among3young
New Health Concerns
released this. new guidance, hospitals in the U.S. began reporting mysterious
after Gottlieb regularly used e-cigarettes. Affected individuals arrived at emergency
Not lon8 patients who breathing and pneumonia-like symptoms. 178 X-rays revealed lung
illnesses among
complaining of trouble
rooms 11

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