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Brief advice can simply consist of asking smokers questions such as Have you thought about quitting? or Would you like help to stop smoking? When 80 patients are given solely brief advice on smoking, 1 premature death is prevented 17

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109 The United States argued that "a decision by the Ministerial Conference that does not conform with the specific decision-making procedures established by Article IX:2 of the WTO Agreement cannot constitute a 'subsequent agreement between the parties' within the meaning of Article 31(3)(a) of the Vienna Convention." 110 Distinguishing legally binding subsequent interpretations adopted under Article IX:2 of the WTO Agreement from subsequent agreements under Article 31(3)(a) of the Vienna Convention, the Appellate Body rejected the U.S