OPINION
DAVID PURYEAR, Justice.
After the legislature enacted subchapter V of the Texas Health & Safety Code, entitled, "Fee on Cigarettes and Cigarette Tobacco Products Manufactured by Certain Companies," appellees Texas Small Tobacco Coalition and Global Tobacco, Inc. (Small Tobacco) filed a suit for declaratory and injunctive relief, alleging that the tax imposed by subchapter V is unconstitutional.
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