SNEED, Circuit Judge:
U-Haul International, Inc. (U-Haul) sued Jartran, Inc. (Jartran) for false comparative advertising under section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), and under the common law. The district court awarded U-Haul $40 million and attorney fees, as well as a permanent injunction against certain Jartran advertisements. U-Haul International, Inc. v. Jartran, Inc.,
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