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Noting that Article 31(3)(a) of the Vienna Convention does not specify a form that a subsequent agreement must take, the Appellate Body stated that Article 5.2 "can be characterized as a 'subsequent agreement' provided that it clearly expresses a common understanding, and an acceptance of that understanding among Members with regard to the meaning of the term 'reasonable interval.'" 117 Because paragraph 5.2 of the Doha Ministerial Decision provides that "reasonable interval" in Article 2.12 of the TBT Agreement "shall be understood to mean" not less than six months, the Appellate Body concluded that paragraph 5.2 was a subsequent agreement on the meaning of "reasonable interval" within Article 31(3)(a) of the Vienna Convention

A review of studies by public health experts convened by WHO on 29 April 2020 found that smokers are more likely to develop severe disease with COVID-19, compared to non-smokers

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These costs reflect direct impacts including emergency response, infrastructure damage, insurance losses, operational disruptions, and increased ratepayer liability