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As early as January 11, 1991, in its plan entitled California: A Multifaceted Plan to Address the Negative Environment, the Tobacco Institute's State Activities Division set as one of its long-term strategies Adopt a reasonable statewide smoking law, with preemption.6 Preemption is the In the early 1990s there were three major battles over preemption in California: in 1991 with Senate Bill 376 and in 1993 with Assembly Bills 13 and 996