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Court of Appeals for the Second Circuit held that plaintiffs' complaints do on their face state a cognizable claim against the defendants under the Americans with Disabilities Act, noting that the determination of whether a particular modification is reasonable involves a fact-specific, case-by-case inquiry that considers, among other factors, the effectiveness of the modification in light of the disability in question and the cost to the organization that would implement it

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Using this framework, a spectrum of four categories of reduced-harm products can be delineated

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