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 l Respondent also mischaracterizes several of the points
 i made in Petitioners _ opening brief. For example, contrary to
 Respondent6s assertions Petitioners did not "urge this Court to
 I order the Administrator '_ to adopt a particular interpretation of
 "accepted medical use in treatmento '_ Respo Br. at 217 see also
 I ido at IS-19. Nor do Petitioners contend that marijuana should
 j be placed in Schedule II "in the interest of promoting research
 based solely on an alleged 'accidental discovery of therapeutic
 l benefits, e_' Respo Bro at 21. Petitioners simply reasoned that
 drugs become accepted for medical use gradually and pointed out
 l that the interpretation adopted by the ALJ in this proceeding is
 i consistent with the nature of this process° See Pet. Br. at 31_
 And Petitioners did not suggest that "the existence of obstacles
 I to research . o °, by itself, render[ed] the decision to place a
 substance in Schedule I arbitrary and capricious. _ Resp. Br. at
 i Respondent concedesu as it mustu that '_FDCA approval
 for interstate marketing is not a necessary prerequisite to
 l placement in Schedules II-V_" Resp. Bro at 17 (citing NORML, 559
 F°2d at 750 no65)); see also Grinspoon vo DEAg 828 Fo2d 881 (Ist
 Ciro 1987). Yet it does not dispute that the Administrator's
 i interpretation of "accepted medical use irk treatment" requires
 compliance with the substantive standards for interstate market-
 l ing approval. See Pet° Br. at 29-30_ Respondent's discourse on
 the virtues of the FDA approval process does not mask the unrea-
 J sonableness of the Administrator's standard°

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