Friday, March 31, 2006

DTC without the Risk

The Coalition for Healthcare Communication (CHC) -- comprised of major advertising, marketing and PR organizations, including the American Association of Advertising Agencies, the Association of National Advertisers, and the Public Relations Society of America -- filed a Citizen Petition with the Food and Drug Administration today asking the FDA to formulate new rules governing consumer advertising of prescription drugs (see "Coalition for Healthcare Communication Seeks New Prescription Drug Advertising Rules").

The proposal calls for the
elimination of specific risk information in print and broadcast DTC (direct to consumer) advertising. You know, things like erections lasting 4 hours or longer and sleep binge eating; great material for comedians but a royal pain in the ass for advertisers.

It is very difficult, if not impossible, to communicate risk in the current DTC format -- mostly 60-second TV ads (see "
Can Drug Ads Communicate Risk?"). The problem has led many influential stakeholders -- including Senator Frist (see "Deconstructing Frist on DTC") -- to call for a ban or moratorium on DTC. In fact, PhRMA -- the drug industry's trade association in the US -- suggests "companies should spend an appropriate amount of time to educate health professionals about a new medicine or a new therapeutic indication before commencing the first DTC advertising campaign" (see "PhRMA Finalizes DTC Principles"). Not a call for a moratorium exactly, but a tacit recognition of the problem.

Instead of eliminating DTC or grappling with how to communicate risk, the CHC simply wishes to do away completely with the necessity to communicate risk in DTC -- including print and Internet DTC! And they call themselves communicators!

CHC's argument goes something like this:

  1. Consumers are too dumb to weigh all the risks vs. benefits [CHC doesn't use that derogatory term. Their petition uses the more PC phrase "consumers with different educational and economic backgrounds"]
  2. Only prescribers -- "learned intermediaries" -- can do this
  3. DTC ads are effective at getting consumers to visit their doctors and ask about treatment and not effective as an educational tool
  4. DTC ads, therefore, should not mention specific risks, just say that there are risks and direct consumers to discuss these risks with their physicians.

Here's what the CHC envisions the risk statement in a DTC ad to look like:

"Like all drugs, [drug name] has both benefits and risks. [Drug name] is only available by prescription, and your doctor can explain how [drug name] is likely to affect you. Be sure to tell your doctor about all of your medical conditions, and about any other medications you are taking, because this information could affect whether you should take [drug name]. Remember, only your doctor can decide if [drug name] is best for you."

The onus is plainly on the physician. This is the "learned intermediary" doctrine, which has seen better days (ie, starting in 1951 when Congress required FDA to identify drugs requiring a prescription to be filled by a doctor rather than bought over the counter). "Under this rubric," says CHC, "courts recognized that drug manufacturers owe duties of specific side effect disclosure to practitioners, rather than patients, and that practitioners must take responsibility for understanding those risks, relating them to the clinical situation of the patient, and counseling the patient appropriately."

There is one problem -- OK, maybe a few problems -- with the learned intermediary doctrine: how learned is the intermediary? The "duty" of the manufacturer to inform doctors of drug risks has been under scrutiny lately in VIOXX trials and other news that brings into question whether or not drug companies are being completely transparent about risks in communications to physicians (see, for example, "
Merck's Hand in the Cookie Jar").

CHC itself cited a New Jersey Supreme Court view that stated physicians play a "much diminished role as an evaluator and decisionmaker" with respect to prescription drugs and that manufacturers using DTC must take responsibility for comprehensive risk disclosure to patients. The CHC's petition effectively retorts: "Not in my backyard (ie, DTC advertising) you don't!"

Another small criticism of the learned intermediary doctrine: it seems a bit quaint in this day when patients have access to the same information as physicians and often surpass them in the knowledge of medications (of course, I am not talking about those "different" patients). Besides, patients are now being asked to make more decisions about their own healthcare -- like how to spend their insurance dollar (heard of "consumer-directed healthcare" anyone?)

According to the CHC, "the patient is the decision-maker only with respect to whether a practitioner should be approached." How atavistic can you get?

The CHC cites a couple of dangers of including specific risk information in DTC:

  1. "Patients may conclude innocently, but wrongly, that an FDA-endorsed brief summary tells them all they need to know about the risks of taking a particular drug, and
  2. "they may purchase the drug without a prescription or meaningful diagnosis from 'bargain' web sites, or other non-US sources, thus endangering their health."
Point (1) goes under the "patients are dumb" heading. Funny thing -- a couple of paragraphs up in the CHC's petition, they say that OTC drugs (over the counter drugs; do not require a prescription) may be used safely by patients without medical guidance. Keep in mind that OTC drugs used to be Rx drugs. The side effects don't magically disappear when a drug is switched to OTC, but suddenly, consumers are smart enough to weigh the risks against the benefits of the drug without a physician to help them!

Point (2) is the
Internet and Canadian Pharmacy Bogeyman scare tactic, which is often used by the drug industry (see, for example, "PhRMA's Terrorist Plot"). I won't say any more about that.

Obviously, I could go on all day about this. I prefer, however, to open this up to your comments: Take the Online Survey Now! Your responses are confidential and you may remain anonymous. You can view the de-identified results as soon as you complete the survey. Thanks!

Wednesday, March 29, 2006

Drug Development: Science vs. Marketing

According to an article in the March 27, 2006 edition of the Wall Street Journal ("Bureaucracy Buster? Glaxo Lets Scientists Choose Its New Drugs"), large pharmaceutical companies like GSK are experimenting with new ways to organize their research teams:
Mr. Garnier [Jean-Pierre Garnier, CEO] and Tachi Yamada, Glaxo's head of research and development, decided to try a different approach to the problem [of drug development]: giving scientists a vested interest in a single drug's success. To do this, they split middle-stage researchers into seven separate pods of up to 400 people, each concentrating on a specific disease grouping, such as cancer, psychiatry and respiratory and inflammatory diseases.
Some experts contend this will bring back the golden era of big pharma before it became so bloated by mergers and acquisitions:
"Taking [decision-making] out of corporate hands and putting it in scientists' hands allowed them to go back to the way it was in the '60s and '70s, when it was mostly a science-driven process and CEOs were scientists," says Kenneth Kaitin, director of the Center for the Study of Drug Development at Tufts University in Boston. [as quoted in WSJ]
However, I find it difficult to believe that corporate (ie, marketing and sales) influence will be much diminished by this type of re-organization. In fact, this type of therapeutic, pod structure is very similar to the type of organization suited to sales and marketing. In sales, for example, reps selling drugs in a specific therapeutic category often act in pod-like concert to detail physicians. Marketing is also organized within therapeutic silos.

Consequently, this new type of research organization lends itself very nicely to influence by sales and marketing -- not that there's anything wrong with that. However, it does not guarantee that big drug companies will relive their golden era as anticipated by Mr. Kaitin. Innovative products are not always the best-selling products.

The idea is to make pharmaceutical companies operate more like biotech companies, which are truly science-driven and more tolerant of researcher freedom. Biotech companies enjoy this "freedom" not only because they are run by scientist CEOs, but also because they don't have big marketing and sales departments with vested interests (such as commissions based on sales) that are not necessarily aligned with the interests of science and medicine. Despite the WSJ article title, I don't see scientists really having the last say on what drugs reach the market or even what drugs reach the final stages of development.

Big Pharma wants to be like biotech (more research) and
Biotech wants to be like big pharma (more marketing)!

It's interesting that as big pharma is trying to be more innovative research-wise and be more like biotech, biotech companies are being urged to be more marketing-savvy like big pharma and do DTC advertising, for example (see "
From oligos to Oprah—the consumer and biotech"). See below for more on that subject!

Related Posts and Articles

  • Counterpoint: biotech needs more than DTC as usual -- There is no doubt that in the coming years, biotech companies will need marketing expertise to complement their R&D prowess to be successful in the marketplace. Many experts believe that biotech should follow in the footsteps of traditional pharmaceutical companies and adopt direct-to-consumer (DTC) advertising to promote their products to meet this challenge. What is good for pharma, however, is not necessarily good for biotech -- particularly with respect to DTC TV ads.
  • Pharma's Jekyll & Hyde -- Sir McKillop, former CEO of AstraZeneca, was spotted recently in a pub nursing a pint of bitter and conversing about the bad rep of the pharma industry. He characterized a successful big pharma company as an embodiment of the Goldilock story -- "large enough for marketing clout but not so big that drug discovery and development can't be managed effectively." It's not Goldilocks and The Three Bears that comes to mind when I think of Big Pharma. Robert Louis Stevenson's story of Dr. Jekyll and Mr. Hyde is more appropriate.
  • Vagelos Speaks. Will Pharma Listen? -- Roy Vagelos, Former Chairman and CEO of Merck, gave a keynote presentation at the Pharmaceutical Marketing Congress in Philadelphia this past Tuesday. His presentation was entitled "Medicine, Science, and Merck: The Changing Pharmaceutical Industry." Vagelos began his career as a physician and medical researcher. At Merck, he was also head of research before being "promoted" to CEO. Dr. Vagelos made many interesting points about science, credibility, pricing, and the future of the pharmaceutical industry.

Friday, March 24, 2006

Free Dinner for Brand Managers!

If you are a pharmaceutical brand manager, I would like to offer you a FREE dinner at a fine restaurant in New Brunswick, NJ on Monday, April 3, 2006.

As you many readers of this blog know, I run
Pharma Marketing Network, which is hosting the 3rd Annual Networking Dinner Reception for members of the pharmaceutical marketing community. This is an outstanding networking event that already has about 120 people registered.

In fact, the reason I have been neglecting this blog is because I've been so busy organizing this event! But, it's worth it.

Here's the deal:

What's the catch?

Well, you'll have to co-exist with about 120 sales and marketing people from the vendor/service side of the business. But it's a friendly, non-threatening atmosphere and definitely worth it, especially if you are attending the 4th Annual Pharmaceutical Marketing Summit being held the following 2 days down the block at the Hyatt.

Plus, we have an interesting agenda:

  • 6:00 PM to 7:00 PM: Sign in. Freely mingle to meet and network with colleagues. Wine and beer and other beverages served (included). Cash bar.

  • 7:00 PM to 8:30 PM: Buffet service and sit down to dinner

  • 7:30 PM to 8:30 PM: Presentations

    1. Welcome by John Mack, Publisher of Pharma Marketing News.

    2. The Do's & Don'ts of Integrating Promotional Products into the Marketing MixCustom Promotions, Inc.). The presentation will address the value of promotional products in an overall marketing strategy including considerations in the planning process, compliance issues, and domestic versus overseas manufacturing.

      presented by Joe Blewitt, Chief Operating Officer; Jerry Mauder, Sr. Marketing Executive (
    3. The Future of Brand Marketing: Will You be in the Mix? A short presentation by Dr. Andree Bates, Managing Director, Campbell Belman Europe Ltd. Using predictive modeling techniques and her many years of experience, Dr. Bates will look at the evolution of the pharma marketing mix viz-a-viz Advertising versus Med Ed versus PR versus Events versus Internet versus Reps.

  • 8:30 PM to 9:15 PM: Dessert and Table Discussions:

    1. Brand Management hosted by David Patterson, Thomson Scientific
    2. CME hosted by Barbara Wolk, MCRI
    3. Market Research hosted by Richard Shapiro, The Center For Client Retention
    4. Physician Marketing ROI hosted by Andree Bates, Campbell Belman Europe Ltd.
    5. Physician Meetings hosted by Stephen M. Carnevale, Premier Technologies
    6. Physician Marketing Challenges by Jerry Mauder, Custom Promotions

  • 9:15 PM to 9:30 PM: Closing Comments and Good Byes
After writing a blog and newsletter article as well as hosting a survey about free gifts to physicians by pharmaceutical companies (see "Free Gifts to Physicians: What's the Big Deal?"), I find it interesting to offer a free dinner to pharmaceutical brand managers! Fortunately, I am not constrained by PhRMA or the OIG!

I wonder if any brand managers will take me up on my offer and put themselves in a position similar to physicians at promotional dinner events that pharma brands host? We won't put a target or slap a sign "detail me" on you back, but you will be asked to raise your hand and identify yourself! You owe me that much for the great food!

Sunday, March 19, 2006

Generic Detailing

Last Monday, the Wall Street Journal ran a story entitled: "As Drug Bill Soars, Some Doctors Get An 'Unsales' Pitch" and prefaced it with the tagline "Negative Advertising." Here's the first few sentences of the article, which will give you the gist of it:
Like salespeople for pharmaceutical companies, Kristen Nocco shows up in doctors' offices with slick brochures, well-rehearsed talking points and the budget to buy lunch.

But Ms. Nocco's goal is the opposite of the company people: She wants doctors to consider alternatives to expensive brand-name drugs.

Ms. Nocco, who used to be an Eli Lilly & Co. saleswoman, is part of an "unsales" team funded by the state of Pennsylvania. Its message is honed by Harvard University professors who say they're trying to help doctors make decisions grounded in scientific evidence instead of company marketing. Many of the approaches Ms. Nocco advocates -- such as cheap generic drugs and lifestyle changes -- would cost less, too. Some of her talking points take on top-selling drugs such as AstraZeneca PLC's Nexium for heartburn and Pfizer Inc.'s Celebrex for arthritis pain.

The effort comes as states and employers are reeling from ever-higher bills for prescription drugs. Pennsylvania alone spends about $3 billion a year on drugs for state employees, poor people on Medicaid and elderly people eligible for a generous drug-assistance program.
The WSJ calls this an "unsales pitch" but it has also been called "counter detailing," which more accurately describes the goal: to counteract the influence of branded sales pitches by the pharmaceutical industry.

Perhaps a more appropriate label would be "generic detailing" because that's what it really is. You just can't convey a negative message (eg, "don't listen to drug company sales reps"), you must also convey a positive message:
switch to the generic brand.

PBMs know the score as was pointed out by
Pharma Marketing Online Forum member David Brown: "This is in line with one of our PBM clients. They have a banner in their call center 'brand to generic.'"

Pennsylvania probably scored more points with physicians via the WSJ (and other media) article than by the efforts of its meager "sales force" of which Kristin Nocco is an example. BTW, it appears that PA's tactics may mimic the worst tactics employed by the industry. It's hard to tell from the WSJ black&white cartoon image of Ms. Nocco, but she looks young and attractive -- just the qualities that are valued by the industry (and by male physicians). See "
Sexy Reps Sell Rx" for more on that issue. In other words: sexy reps also sell generic Rx!

Will down and out pharma sales reps flock to states like PA for a new career in generic detailing?

"Great news for reps, but I bet the sales meetings won't be as fun. Ya gotta love the resilience of the American economy. As Pharma lays off reps, the government could hire them. Then they'd qualify for the government retirement health benefits instead of social security, taking more money out of that program, and we could have a competition for which reps the doctors criticize the most." -- Sam Nalbone, Pharma Marketing Online Forum Member.
Yeah, that'll happen.

Anyway, here are some other comments on this topic from Forum members:

"On one hand, it's a testimonial to the power of the detailing technique. On the other hand, it's a legitimate tactic for payers who want to control costs. To some extent it's old news as counterdetailng was commonplace among managed care companies in the 90s. It's definitely something that will have to be reckoned with by the industry, as payers fight fire with fire." -- Terry Nugent
I doubt that payers have the heart (or budgetary muscle) to fight fire with "fire." After all, pharma companies have upwards of 100,000 reps out there making, what, 5 calls per day or 100 million calls per year? That's some fire. In six months, PA made 1500 "generic calls" or 3000 per year. If all 50 states did as well, that would only add up to 150,000 calls per year or about 0.15% the amount of calls made by Big Pharma. Talk about your share of voice! PA's voice is a whimper in a shit storm. [However, getting an article in the WSJ, that's big!]

Dr Ulhas Ganu agrees:

"I quote one matter of fact statement about tobacco: The amount of money available for Anti-Tobacco Drive is far less than the one available with the people who promote Tobacco usage. I feel, it more or less applies to the Pharmaceutical Scene vis-a-vis Brand versus Generic." -- Dr Ulhas Ganu
Sam Nalbone sees a silver lining in all this:
"If I go to the doctor for a sleeping disorder, I want a prescription, not a lifestyle lecture. If I don't get a prescription then the service I went there for hasn't been rendered and I won't go back. I'm not there for $100 per hour M.D. life-coach. For doctors that really don't want to see patients, lifestyle lectures in place of prescriptions is are 'just what the doctor ordered!'

"Maybe there is a silver lining - how often has the government tried to use sales and marketing instead of laws and regulations to achieve their agenda? Could this be a creative thought and a tacit nod that pharmaceutical firms aren't so stupid after all?" -- Sam Nalbone
Sam makes a couple of points. First, he criticizes the part of the generic detail that talks about lifestyle therapy in lieu of drugs, generic or otherwise. I can't agree with him there. I could cite personal experience where I lost 25 lbs and for the first time in years and -- despite being on various meds -- I have finally gotten my BP and cholesterol under control! Sam, maybe there are some things about your lifestyle that, if changed, could solve your sleeping problem? Or, you could risk taking Ambien and find yourself "sleep-driving" on the wrong side of the road! That could change your life!

Sam also points out the symbiotic relationship between physicians and the drug industry -- both profit from selling drugs, not lifestyle programs. You can blame patients for this, but DTC advertising is a great influencer of patients as the industry will be the first to admit.

A few other comments from
Pharma Marketing Online Forum members and then I'm out of here:
"Somehow I feel, getting relevant information to prove the generic drug is better than or equal to the brand is really difficult task. To prove something scientifically one needs data and for that one have to rely on clinical trials results. Barring few govt. funded clinical trials like CATIE, most other clinical trials have the primary objective of proving the brand to be better than the generic.

"If the 'unsales' team will try to prove that Naproxen or Tylenol is better than Celebrex, the probably PFE will come up with loads of data showing that when one takes Naproxen or Tylenol one needs to take Nexium with it to avoid GI disturbances (cost is more than Celebrex alone). If to counteract the above logic, "unsales team" wants to prove that generic Omeprazole+naproxen will do the same trick, then probably they will lack the data as AZN has large trials for Naproxen+Nexium and not Omeprazole+Naproxen.

"To complete the loop probably the 'unsales' team needs to be armed with exhaustive data to prove their point." -- Sameer
Harry Sweeney, as usual, puts the topic in a whole new context:
"Students of the persuasive arts know that for considered purchases (of which healthcare, medicines, etc presumably are), the clincher for most people -- no matter how good the non-personal communications may be -- is human contact (and persuasion), at least for the first decision and, for many people, for subsequent ones as well. As people become familiar and comfortable with a purchasing process, depersonalized information such as pricing, availability, etc facilitates choices without further human intervention. That's one reason why internet sales have taken off. But, internet healthcare information and services is a whole other topic." -- Harry Sweeney
Thanks Harry, for a great idea for a future topic!

BTW, PA's bizzaro-world "unsales team" can do something that regular pharma reps cannot do: provide doctors with free CME!

Wednesday, March 15, 2006

Buzz 'n Blogs -- Stealth Marketing

I recently attended and survived another pharmaceutical eMarketing conference (CBI's eMarketing for the Pharmaceutical Industry). As usual, I came away feeling like a time traveler returning from a visit to the past. Pharma marketers are the first to admit that they are not trend setters and usually trail other industries by 2 or more years when it comes to the Internet.

Vendors were subtly and not-so-subtly trying to convince the pharma people in the audience that it's high time to do more marketing via the Internet. This process starts with quoting some numbers to show that other industries are way ahead. Conference chairperson, RJ Lewis of eHealthcare, made a "That was then, this is now" argument and showed a convincing chart of Ad spending over the years. After a trough caused by the Internet bubble burst in 2000-2001, spending rose substantially -- 30% in the last year -- and is currently at $12.5 Billion (see chart).

Ad Spending via Internet

Of course, RJ did not get into what portion of this ad spend was attributable to pharma nor did he specify if it trended as in the chart above (ie, he didn't say that pharma Internet ad spending was 30% higher "now" vs. "then" -- I doubt that is is). It's generally agreed, however, that pharma spends less than 5% of its ad budget online -- less than $600 million per year.

Consumer Generated Content

Clearly, pharma trails other industries in its use of the Internet. There are many good reasons for this, which I may explore in a future post to this blog. I will focus here on one of the "hot" topics at this meeting: "Consumer Generated Content."

There are many examples of marketers using consumer generated content. From a recent Wall Street Journal article:

"Drawing consumers into marketing campaigns is a time-honored tactic, whether companies are searching for the new Oscar Mayer kid, Brawny man, or Crayola Crayon colors. But in recent years, the Internet has furthered the conversation between corporations and consumers, tapping into the public's views and talents on a grander scale. Meanwhile, new technologies enable even amateurs to create sophisticated images. Earlier this year, Subaru of America enlisted fledgling filmmakers to produce 30-second films. The company was trying to generate awareness for the launch of its Subaru B9 Tribeca, an SUV." ["Marketers' New Idea: Get the Consumer To Design the Ads," WSJ, 12/14/2006]
Buzz 'n Blogs
I'd like to focus on "buzz 'n blogs" (remember, you saw this term here first!) As RJ put it: "Then: Good content attracts users" and "Now: Empowered users create good content." He cited blogs and Wikipedia (which is a sort of consumer-generated encyclopedia that some people contend comes close to Britannica in terms of accuracy; could a Wikipedia version of the Merck Index be next?).

Clearly, a lot of people online are tapped into blogs as the following chart shows:

Blog Readers

With so many fish in the pond, it's no wonder that some pharma marketers are wondering if and how they should use buzz 'n blogs to their advantage. At the CBI meeting, this topic was discussed by a panel of experts, which strangely included a Google representative.

Although I participated on the search engine marketing panel, I was not asked to join the User Generated Content (UGC) panel whereas Google was and did. The Google representative wondered why she was on the panel and I wondered why I was on the search engine panel. Go figure! BTW, not all the search engine panel members were happy when I whipped out results from the
Pharma Marketing News Search Engine Marketing Survey on paid inclusion -- you can take this survey and see a summary of the results: click here.

Anyway, as usual, I digress.

Paul Ivans, the panel moderator, pointed out that between 20,000 and 70,000 new blogs -- the most talked about type of "user" generated content on the Internet -- are created every day and that the number of posts to blogs and message boards (another form of user generated content) is increasing dramatically (see Chart).

UGC Growth

Buzz 'n Blogs are attractive targets for advertisers not only because of the volume of participants (ie, reach; 41 Million US adults use blogs, message boards, or podcasts) but also because they think they can enlist -- I would say dupe or pay off -- consumers to spread their messages to other consumers. After all, poll after poll shows that consumers trust other consumers. A Neilson Buzzmetrics poll claims that consumers trust consumer opinions posted online more than they trust advertising in newspapers, magazines, TV, or radio. Duh!

What marketers want to do is manipulate that trust to their own ends. There are various means for doing that.

Advertising on Blogs
First, there is the technique of "latching onto a star" where the advertiser pays a blogger to run ads on the blog. The blogger could be a patient, a physician, or an industry pundit like me. Ivans showed a finding from some study (may have been from Manhattan Research) that consumers are twice as engaged on Yahoo! expert blogs (eg, physician blogs) than other Yahoo! content on the same topics. Therefore, it makes sense, from an online marketer's point of view to advertise on those expert blogs.

Should bloggers accept advertising from companies that they may criticize in their blogs? Will that influence their opinions and change the "voice" of the blogger? It's what I call the advertising principle of uncertainty. Bloggers are popular because of their independence form "the man" - a perceived lack of independence caused by advertising makes the blogger less independent and hence less popular. Pretty soon, advertisers will not be interested in running ads on that site.

Now, I accepts ad to be run on this blog. However, they are ads served up by Google based on the content. I can only say to Google that I do not want ads that link to certain URLs. In other words I do not choose the ads. Secondly, not a lot of money is involved. Therefore, my editorial side feels totally separate from my commercial side. I don't think twice about criticizing a pharma company or a brand drug.

Things might be different if big bucks were involved. But that's why I have a more "balanced" newsletter and an opt-in list of subscribers who want to receive commercial messages. The blog is my church, the other stuff is my state. I hope to keep them tied together, but separate!

Stealth Marketing
Marketers are being enticed to delve into the blogosophere in more nefarious ways than via advertising. It is expressed thusly: "Consumers of UGC are 'hyper-engaged' and therefore advertisers should embrace UGC to engage their targets in new, open dialogue." That is, jump into the conversation and "influence the influencers!"

Heaven forbid that there are conversations about your brand going on out there that you cannot control! It's questionable how "open" a dialogue is when one participant views the other as a "target"! I know this is jargon only meant for other marketing professionals, but it nevertheless suggests that marketers can never be open and honest. It's just not in their nature nor is it even their goal (see "I
s Pharmaceutical Marketing BS?" for more on this).

All this talk about "dialogue," therefore, is a lot of bullshit. What will happen is that marketers will try and create their own blogs and disguise them as consumer blogs or they will pay off expert (eg, MD) bloggers to write approved content disguised as the expert's opinion. That's not engaging in dialogue, that's stealth marketing. I suspect this sort of thing is already going on (see "
Cialis Blog Shut Down").

What clearly is needed is a code of ethics defining what is and what is not acceptable buzz 'n blog marketing. I hope to write more on that in future blogs. Meanwhile, your comments are welcome.

Friday, March 03, 2006

Immutable Laws of DTC Domain Naming

My friend RJ Lewis wrote a column entitled "The importance of a Name" that recently appeared in Product Management Today. His premise is: "Choosing and capitalizing on a memorable domain name for a pharmaceutical product may very well be the most important on-line marketing strategy."
In this new age of educational DTC, marketers must think of newer variations of generic terms to create such domain names as (AstraZeneca Wilmington, DE), (Eli Lilly, Indianapolis), and (Bristol-Myers Squibb, Princeton, NJ). -- RJ
I also just happen to be reading the book "The 22 Immutable Laws of Branding" by Al and Laura Ries. The book also includes "The 11 Immutable Laws of Internet Branding" as a "bonus."

These two expert sources could not be further apart from one another! The Ries' lambast "generic" domain names and claim that "one of the reasons for the dotcom disaster is the almost universal use of common-name Websites." They cite some examples:

  • etc.
The Ries' propose that "the mind treats a generic or common word as the name for a category of things, not as one particular thing or brand." They often ask the reader to imagine conversations like this:

"Where did you learn about depression online?"

"Depression Hurts."

"I know it does, but what's the name of the site?"

"Depression Hurts."

"OK. Let's go home. Everything will be fine!"

RJ cites an example of a Philadelphia couple selling generic domain names such as for millions of dollars. He's implying that these names have value for pharmaceutical marketers who should register generic names relevant to their products before a bum with $10 from Hoboken does!

Well, I'm no bum from Hoboken, but I thought I'd give it a shot.

First, I looked at some other generic depression names like (I think this is closer to what depressed people must feel about depression than depression hurts). Unfortunately, that name is already registered by a David Butler from Bowie, MD. Evidently, David registered this domain name way back in 2002 in the hopes that Eli Lilly would buy it. Sucker! Lilly spent about 30 seconds coming up with another name that no-one had yet claimed; hence,

Undeterred, I tried and Bingo! That's available. I bought it. Lilly, you can have it for $295! (I don't expect a lot of money for this one because it violates one of the Ries' immutable laws: it's too long!)

Another pharma-owned DTC generic domain name I like is, which is GSK's site about erectile dysfunction. At first, when I was doing research for this post, I mistyped the URL and ended up on And Lo and Behold! was at the top of's "Sponsored Links for Impotence." This is very disturbing because other sponsored links include "Solid Erections In Minutes" and a Mexican online pharmacy. Thinking the link was a spoof, I clicked it and wouldn't you know? It lead me directly to the genuine GSK site! Obviously, GSK or one of their agents is paying to be on this sleazy site! is registered to Bill Swartwout out of Baltimore, MD. (seems a lot of these questionable sites originate in MD).

Next I tried It turns out that Bill also owns that. So I tried, which is owned by Andy Tran in Orange, CA.

Crap! All the good generic names are taken (even!

So, what's my point? I don't know, except that my research turned up one interesting tidbit and a question: GSK, why are you advertising on the sleazy Website? Are generic domain names that important to your eMarketing Strategy?

Thursday, March 02, 2006

Paid Inclusion: Too Hot for Pharma Marketing?

Next week I will be participating in a search engine marketing panel discussion at CBI's 5th Annual eMarketing for the Pharmaceutical Industry conference in Philadelphia.

Everything I know about search engine marketing I learned from an article by an expert (see "
Searching for Answers on Search Engine Marketing?"; print available), but the options have come a long way since. As the panel description states:
Search engines play a major role in health information research.— a recent survey found 93% of respondents used search engines to research medications, conditions and treatment options. Not surprisingly, search is one of the fastest-growing categories of online advertising.
Pharmaceutical marketers need to have a good search strategy, but one tactic I find questionable is "paid inclusion." Paid Inclusion results are listings that look like natural or algorithmic results, but are actually paid for by marketers.

The issue, as I see it, is that the searcher (eg, patient looking for credible health information on the Net) does not know that the paid inclusion is a fee-based result of the search and not strictly based on the relevancy or popularity of the site. Paying a fee gets you in the game, but does not, in itself, guarantee a high position in the natural search list. However, it is my understanding that marketers can also supply key words as part of the paid inclusion option and improve the results.

The problem is that someday a pharma company using this technique might be exposed in a critical Wall Street Journal or New York Times article.

Way back when the commercial Internet was young, the Web site was criticized for confusing editorial with advertising by charging hospitals to be listed in an editorial page on their site. That is, they did not tell visitors that hospitals paid to be listed there.

That lead to the development of the
eHealth Code of Ethics, which I helped develop. Paid inclusion can also lead to consusing "editorial" (natural, unbiased) and "advertising," which paid inclusion looks like. Therefore, is there a similar need for a Search Engine Code of Ethics? And should paid inclusion be shunned? (Google and MSN discontinuedtheirr paid inclusion option, but Yahoo! has not.)

I hold the pharma industry to a high standard. It's not like other businesses -- it's business is to improve health. Sometimes this means that tactics that may legitimatley be used by other businesses may not be appropriate for the pharmaceutical industry. Is paid inclusion one of these tactics?

I would like to know your thoughts on the subject of paid inclusion as a pharma marketing search engine tactic. Please take the Pharma Search Engine Marketing Survey.
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