"I could strangle that girl from Google," said a friend of mine after a presentation by a Google operations specialist at the recent eyeforpharma eCommunications and Online Marketing conference held in Philadelphia. Of course, this was not a literal terroristic threat, just an expression of frustration by a long-time industry advocate.
What did the "Girl from Google" (GfG) say that upset this person so much? I will get to that in a moment, but now that I have your attention, let me recap a few highlights of this very interesting and dynamic meeting.
One of the highlights of the conference was my live podcast during the lunch break on the second day.
Joining me for my podcast was Mark Bard, President, Manhattan Research, Harry Sweeney, CEO of Dorland Global Health Communications, Svetlana Toun, SVP, International Strategic Alliances, Alansis Media, Steven Krein, CEO of OrganizedWisdom, and Unity Stoakes, CMO at OrganizedWisdom. Fard Johnmar, Founder of Envision Solutions, L.L.C. and fellow blogger over at Healthcare Vox also joined in by phone.
Listen to what these experts have to say about social networking and how pharmaceutical marketers should get involved. Click here to listen to an archive of this podcast. You will need Microsoft Media player. Go to the Pharma Marketing Talk Host Page for other options and to listen to previous podcasts.
Social networking was a common thread throughout the conference and many speakers, including the "Girl from Google", were extolling the virtues of this new phenom and encouraging pharma marketers to get involved or be left in the dustbin of Internet marketing.
Don't get me wrong. I think social networking is a great opportunity for marketers, but it's not something that pharmaceutical marketers should leave up to their agencies to handle without close adult supervision.
What marketers are being encouraged to do is to "insert themselves into the conversation" because conversations about their products are going on all the time. As the saying goes, when you are invited to a party and you don't show up, people talk about you.
I have blogged about several faux pas's committed by agencies in the employ of pharma companies attempting to insert themselves into the conversation (see "Influencing the Dialogue: Marketers Suck at It!" and "Question Everything"). Indeed, I covered this at the conference in my own presentation entitled "Clear Words, Obscure Benefits," which you can download here.
Consumer Opinion Leaders (COLs), product wikis, Computer-Assisted Persuasion (Captology) were some of the concepts that were discussed in some detail. Look for these concepts to be implemented by "innovative" pharma marketers soon.
Consumer Opinion Leaders
Jack Barrette, pharmaceutical category leader at Yahoo!, claims he coined the term Consumer Opinion Leaders (COLs) to describe ordinary people who influence what many other consumers believe and buy. He cited examples from Yahoo! Answers, which is a social network where people ask questions and Yahoo! experts – who can be any qualified person – provide answers.
COLs earn their status by getting good "grades" from the people that requested help. If you have ever ordered a book on Amazon.com, you may have seen reviews of books written by other readers. Amazon allows visitors to vote on how helpful reviews were to them. You can look up all the reviews that a person has written and see how they scored. This gives you an idea of how helpful this person is likely to be in future reviews.
When COLs speak, others listen.
Other pundits have spoken about these kinds of people. For example, Malcom Gladwell -- author of the book "The Tipping Point" -- calls these people "Mavens." "There is something about the personal, disinterested, expert opinion of a Maven that makes us sit up and listen," says Gladwell.
Just how pharmaceutical marketers can take advantage of COLs in the health arena remains to be seen. It could be similar to how they work with celebrities who are paid to appear in commercials or on talk shows. COLs might be paid to do podcasts, for example.
The "Girl from Google"
OK. Now that you've gotten a background in social networking, it's time to get back to Google. The "Girl from Google" (GfG) was up just before my presentation and the title of her talk was "The Importance of Interactivity: How multimedia technologies will change the way you Connect with Consumers & Physicians."
It was actually a nice presentation but it could have benefited from a little legal/regulatory review beforehand. GfG was one of those presenters who have little or no experience working within or for the pharmaceutical industry. Her bio in the conference brochure says only that she has worked with Google for three years (congrats on the stock options!) and graduated with a Masters Degree form the University of Southern California (party on!). I estimate that GfG joined Google straight from school.
I had only one little problem with her presentation.
As an example of how Google Health can help pharmaceutical companies engage consumers online, GfG used as an example a fictitious drug -- let's call it Xenaxa -- indicated for treatment of osteoporosis. The target consumer was a fifty year old woman concerned about osteoporosis. She does a search on Google Health and finds an AdWord for Xenaxa.
Would you believe that GfG's example used an Adword exactly like the Lunesta AdWord I talked about a few days ago on this blog (see "Lunesta, Google, and bAdWords")? Just like that Lunesta AdWord, the AdWord GfG used in her example included both the trade name of the drug (in the URL) and its indication.
As with the Lunesta AdWord, this example also violates FDA regulations, IMHO. Harry Sweeney agreed. I asked the audience what they thought. One person from a pharmaceutical company, perhaps playing the devil's advocate, contended that the ad may pass muster with the FDA because the package insert or brief summary is "one or two clicks away." His argument was that without specific guidance from the FDA, no one knows what is correct in this case.
One Click Away?
The "one click away" defense does not apply here. FDA says it's OK on an Rx product Web site to merely provide a link to the package insert or brief summary. In that case there is no need to provide that information on the same page that mentions the drug name and its indication.
Thus, an AdWord could be said to comply with the "one click rule" only if within the AdWord text there was a direct link to the package insert (PI) or brief summary. In the example that GfG used, there was only a link to www.xenaxa.com -- the product Web site, not the PI. Presumably, the user would have to find the link to PI once on the Xenaxa Web site. I don't think two clicks would pass muster with the FDA (more on that in future posts to this blog).
It is a shame that the FDA does not have any guidance for the industry as far as Internet advertising is concerned. This means that marketers can use lack of guidance as a defense for sneaking in ads that push the envelope. What are the chances that the FDA would ever notice. These ads are fleeting, here today, gone tomorrow!
However, that should not stop the industry from developing its own Internet DTC advertising guidelines, which it promised to do when PhRMA released DTC guidelines for broadcast DTC.
In this case, however, I think the issue is clear. Any AdWord that mentions a product by name plus the indication, must also include a direct link to the PI within the ad itself.
What do you think?
Consider the Lunesta Adword below:
What the "Girl from Google" just doesn't see is what the fuss is all about. "We don't think it's a problem and it's not our roll to enforce the law." This attitude is absolutely stunning. She claims Google is neutral, but as I pointed out before, Google does intervene when it thinks EU laws about DTC advertising are being violated. Why not when US laws are involved?
In contrast to the "Girl from Google", the "Guy from Yahoo!" (aka, Jack Barrette) really knows the pharmaceutical industry! My advice to pharma: Go with number two on this one. Jack can really help you do social network marketing right.