Sarah Milov provides a more convincing argument, based on factual evidence from scientific studies, that any use of e- cigarettes provide any healthy or helpful effects for smokers to quit. Mitch Zeller,J.D., does not provide a very convincing argument, lacking any real evidence other than personal opinion that e-cigarettes provide any healthy or helpful benefits to help smokers quit. Quoting the FDA , historian Robert Proctor, and Mitch Zeller himself, Sarah Milov provides tantalizing evidence that more studies should be enacted in order to provide proof of wether e-cigarettes healthy or helpful claims are factual. Without any evidence or reference to studies Mitch Zeller provides an argument that appears opinionated that e-cigarettes