In case you haven't seen the previous posts on the topic of Google pharmaceutical "bAdWords," start by looking at "The Girl from Google," which describes the issue when it first arose with Lunesta.
The following are Google Adwords for Celebrex that are currently running on a web site that I frequently visit. (Sorry, I can't say which web site. Terms of Use -- need I say more?)
BTW, these are not reproduced actual size here. The real ads have "Leaderboard" dimensions of 728 x 90 pixels, much larger than the typical 468 x 60 "banner" ad. (You can click on the images to see the full-size versions.)
Once again, like the Lunesta bAdword, these ads appear to violate FDA regulations regarding DTC advertising; namely, that whenever an Rx brand name and its indication are mentioned in the same ad, fair balance or the brief summary of the package insert must also be included. Generally, on the Internet, that means a direct link to the package insert. There is no such link in the above ad.
Google AdWords Not Advanced Enough for Online Pharmaceutical AdvertisingWhat do you think? (Ignore this poll if you've taken it before for the Lunesta ad.)
If Pfizer ran a more technically advanced type of ad, such as a "Rich Media" ad, it could include a mouse rollover, for example, that pops open a window containing fair balance information. Unfortunately, this kind of thing isn't possible using inexpensive (but pervasive) Google Adwords, which can contain only one active link. Another limitation of Google AdWords is the inability -- no matter how large the box -- to include more than about 50 characters in the descriptive text block. This is not enough to do a compliant brand ad (unless it were a "reminder ad").
I expect such shenanigans from Sepracor, the marketer of Lunesta. That company, after all, is a serial violator of their own agreement to follow PhRMA's voluntary Guidelines on broadcast and print DTC advertising (see "Sepracor Sneaks In Lunesta Reminder Ad"). But, I am shocked and disappointed that Pfizer would condone this kind of ad for Celebrex.
It could be that the Celebrex brand team hired the same online ad agency that was responsible for the Lunesta Adword account. The Pfizer people simply may not know what's going on -- not the best defense, but, if true, there's hope that someone in authority at Pfizer will see this post and put an end to this Google campaign. I note that the Lunesta bAdWords disappeared soon after I outed them in this blog. Hopefully, Pfizer will do the same.
Pulling the Celebrex bAdWord may send a message to Google, which must share some of the blame. After all, the "Girl form Google" gave a presentation at a major industry conference and used this type of AdWord as an example of how pharmaceutical companies should advertise with Google.
Google Says: "We're Not in That Business"
My good personal friend, Harry Sweeney, who is also a friend of the pharmaceutical industry and often disagrees with my position on many pharmaceutical issues, agrees with me on this. Here's what he said about Google's promulgation of bAdWords in a recent article he wrote for Pharma Marketing News:
I felt sorry for one presenter from a major search engine company who brightly demonstrated how all of the online services might be supported by pharmaceutical advertising, using a patently violative, illegal, online ad to do it. When she was questioned about the legality and potential risks for advertisers from the audience, her naivete spilled over when she replied "That's for individual companies to figure out. We're not in that business." Or words to that effect. -- see "Pharma's Plodding Approach to eMarketing."Harry was referring to the Google presentation I mentioned above and in my GfG post. Clearly, Google is aiding and abetting as the actors in Law & Order might say.
What Could Pfizer Do?
Here's what I think Pfizer could do:
- find out who's responsible for this ad campaign and put a stop to it;
- lead the way in developing guidelines for online DTC advertising that not only are consistent with FDA laws, regulations and guidelines, but that allows for effective use of the Internet's unique features. One such guideline could be: In all ads that mention a brand name and its approved indication, provide at least a one-click method by which the viewer can access side effect information and/or brief summary; and
- communicate these guidelines to the agencies that handle Pfizer's online ad accounts.
The fair balance is on the landing page.
ReplyDeleteThat may be true, but FDA requires more -- direct access to the brief summary or entire labeling (package insert). These ads require two clicks.
ReplyDeleteI understand this is a matter of interpretation of FDA regulations, but that leaves the door open for all sorts of potential violations.
The consensus by many experts I have spoken with is that these ads are violative. Can 85% of the people who read this blog and take the poll be wrong?
There is some fire here, not just smoke.
The industry needs to establish a brighter line with regard to online advertising -- the FDA sure isn't.
At a recent conference I suggested that the FDA had its head in the sand with regard to the Internet. An attendee in the audience suggested another hole in which the FDA has its head inserted.
My point is this: there are industry voluntray guidelines for broadcast and print DTC, why not online DTC? Should we wait for another scandal to break before addressing this?
I was there for the "Girl from Google" presentation. It's a shame that some parts of our industry will continue to let us all down by pushing the envelope. It's this kind of behavior that will continue to drag the industry's reputation down.
ReplyDeleteIt is my opinion that DDMAC has given us guidance on online advertising - namely there are no different rules for online advertising. I choose to interpret that in the frame of reference, if it was a piece of paper, what would you do?. If that exact message were printed on a business card, would even consider allowing your reps to drop it on a physician's desk without fair balance and the PI physically attached?
So come on, if DDMAC won't give us cleared guidance, let's do it ourselves.
And shame on Google for ignoring the issue altogether for the sake of the easy money.
Neil James
SVP, Business Develeopment, Xoomedia,Inc.
www.zoomedia.com
neilj@zoomedia.com
Comparing the claim made in Lunesta's ad to the benign text in Celebrex's is not a fair comparison John. Let's review the language of the ad and focus on the “claims” made or not made rather than fair balance which the FDA acknowledges, may not always fit in the online space.
ReplyDeleteThe main similarity between the Celebrex and Lunesta AdWords has to do with the fact that both mention the brand name AND the indication. Whether or not the description of the indication goes too far on the benefit side or not is really irrelevant, in my opinion.
ReplyDelete