First, let's look at a mockup of the ad format we are talking about:
|Google's Black Box Ad Format. Click on image for an enlarged view.|
Recall that Google presented this format to the FDA at the November, 2009 public hearings (see here) and at least one pharma company -- Bayer -- actually ran an ad using this format (see here).
This format is only "OK" for reminder ads, which do not mention product benefits. Hence, in this case, a version of the "one-click rule" is sanctioned (the PI is just one click away).
There are few things I don't like about this format.