Read the following excerpt from a US court opinion:
```
try to read into this brief footnote more than is warranted. In light of the complexity and confusion in the law on this issue, it is hard to believe that this somewhat Delphic footnote will bear the weight which Defendants place on it. 71 . It is noteworthy that cases involving the FTC’s determinations of materiality are consistent with the Court's finding here, even though such cases are brought pursuant to the FTC Act rather than the RICO statute. As a general rule, deceptive advertising or claims permit an inference "that the deception will constitute a material factor in a purchaser’s decision to buy.” FTC v. Colgate-Palmolive Co., 380 U.S. 374, 391-92, 85 S.Ct. 1035, 13 L.Ed.2d 904 (1965); see also FTC v. Brown & Williamson Tobacco Corp., 778 F.2d 35, 40-43 (D.C.Cir.1985) ; FTC v. Wilcox, 926 F.Supp. 1091, 1098
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that there must be a causal connection between an insureds advertising and an alleged injury to trigger coverage for an advertising injury
B. holding that deceptive advertising touting defendants low tar cigarettes created an inherent tendency to deceive consumers and was material
C. holding that a plaintiff in a lanham act trademark violation action must demonstrate that the defendants violation tended to deceive consumers
D. holding that federal law did not preempt commonlaw fraud claim against cigarette manufacturer based on advertising of light cigarettes
E. holding under new york law the issue of whether plaintiffs and class members would have purchased the product had they known an allegedly deceptive advertising claim was false can be established with common proof
Reply with [A, B, C, D, E] only.