WASHINGTON, D.C. - The Food, Drug and Cosmetic Act (FDCA) does not preempt California's regulation of drugs under the state's unfair competition law (UCL), a federal appeals court panel ruled Dec. 30 (Allergan, Inc., et al. v. Athena Cosmetics, Inc., et al., No. 13-1286, Fed. Cir.; 2013 U.S. App. LEXIS 25746).