On October 21, Juul Labs published its administrative appeal of the marketing denial order (MDO) issued by the Food and Drug Administration at the end of June 2022. The move, and Juul’s decision to make it public, reflects the company’s apparent offensive pivot from its longstanding defensive strategy. It calls into question the decision made by the FDA’s Center for Tobacco Products (CTP)—which Juul maintains came from an incorrect and incomplete assessment of its data, leading to an insufficient review of its premarket tobacco product applications (PMTAs).