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The other 167 letters, the “non-inspection-based warning letters,” were issued pursuant to either a website, labeling, and/or promotional communications review (143 letters), a records request for remote evaluation of a facility under section 704(a)(4) of the FDCA (704(a)(4) request) (22 letters), 2 or a failure to register and list a product (electronic drug registration and listing system violations, eDRLS) (two letters)