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That's my point: of course they do (well, used to). A key demographic is 18–35. Ads portraying "happy, playful 20-something models" seems legit for that demographic, including using social media as a channel, where that demographic tends to be.

That young models, a sleek device, and social media is also attractive to the 13–17 demographic that Juul is being accused of illegally marketing to is impactful, but not damning in of itself.

So that goes back to my question: is there a way to market to 18–35 and actively not market to 13–18? Let's be clear: "teens" 18–19 and people in their early 20s are adults.

Otherwise, the proposed solution is not to market <35 at all... which seems to be exactly what Juul is doing.[1] So then the argument is that they used to, and that's good enough to cry foul.

All this comes back to "targeting". In my mind, it's very hard to draw a distinction between targeting 18–35 that happens to be attractive to 13–18 (because of course it does), and targeting 13–18. Then, you can argue whether incidental attraction is a "feature or a bug", and whether or not it was part of an insidious strategy all along.

[1] "[In 2018], Juul’s ads began to look more adult and conservative... with the slogan 'Make the switch,' the ads now feature testimonials from [people over 35]."




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