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The Tenth Circuit concluded in 1989 that courts generally require a minimum market share of between 70% and 80%.[12] The Fifth Circuit observed that monopoly power was rare with a market share of less than 70%.[13] The Ninth Circuit suggested a 65% minimum.[14] The Fourth Circuit indicated that 70% was enough.[15] The Third Circuit found 75% to 80% sufficient in one case,[16] and held in another that 55% would not be enough unless other factors indicated power to restrict entry, supply, or price.[17] In Microsoft , the D.C

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Canadian Virginia provides a milder experience with a subtle sweetness, while American Virginia offers a slightly tangy flavor, adding more character and depth to cigarette blends