Semantics Matter in the Law: : An Analysis of the FDA Notice Regarding Cannabinoids

Rather than focus this article on the particulars of the FDA request for comments on cannabinoids under docket FDA-2018-N-1072, I am going to use the FDA notice as a vehicle for discussing the use of tricky semantics by the FDA and DEA, which I posit is both intentional and effective in its current war on cannabinoids. This is the sentence on which I’m going to focus:

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