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Regardless of the actual reductions in performance, the average size of smoke particles means that choosing a high performance (i.e., MERV-13 or higher) particle filter is a theoretically effective step, as some studies have shown even a MERV-11 filter to have almost half the CADR of a MERV-13 filter when initially tested with smoke particles [9]

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Given the conservative tilt of the 5 th Circuit, its likely that the court will find some flaw in these revised images and send the FDA back for another rule-making process