James Gardner, a Boston-area marketer who follows online pharmaceutical advertising at his hobby website -- adverlicio.us/pharma, an archive of online pharma ads -- brought the practice to my attention.
"This awakens in me memories of watching the Super Bowl 4-5 years ago and having Bob Dole uncomfortably intrude on a family moment with a discussion of ED," says James. (Actually, the first DTC ads appeared during the Super Bowl game 2 years ago. It was Cialis -- see "Super Bowl DTC Debut: Was It Good for You?" But you get the point.)
James showed me an unbranded FREE OFFER ad for AmbienCR on the site of Seventeen Magazine, but he was particularly concerned about a branded ad for Levitra that he found on the family -- ie, rated E for Everyone -- section of miniclip.com, "an awesomely fun game site." The screen shot is shown below.
This follows a recent Wall Street Journal article that suggests that TV ads for impotence drugs again are crossing the line (see "New Impotence Ads Draw Fire -- Just Like Old Ones").
"In December alone," reports the WSJ, "an ad for impotence drug Viagra aired at around 9 p.m. during 'Prancer,' a G-rated movie about a young girl who nurses one of Santa's reindeers back to health; another spot for rival medicine Levitra appeared during an afternoon showing of the comedy 'Pee-wee's Big Adventure;' and another for Cialis graced an early-evening presentation of the holiday classic 'Miracle on 34th Street.'Blaming the Medium, Not the Message
"Despite a pledge from the pharmaceutical industry to be more careful with prescription-drug advertising, impotence-drug makers are sliding back to tactics that drew widespread criticism from patients, doctors and regulators. A pediatricians' organization is calling for no impotence ads during hours when children are likely to be watching, and a major AIDS group has expressed concern that ads have become too suggestive again, encouraging people who aren't suffering from erectile dysfunction to use the drugs recreationally."
Pfizer and other advertisers claim that ad placement isn't always under their control, especially on cable channels, where unlike network TV, they cannot purchase time on specific shows.
You would think, however, that it would be much easier on the Web to put ads exactly where you want them.
"Levitra has no business on a family gaming site," says Gardner. "Unless miniclip.com is some kind of exception to the rule, every site offers the ability to buy only certain 'channels' (i.e. not the family one), and the ability to predict visitor demographics."
I admit he's got a point.
NOTE: FDA is concerned about unsafe drugs purchased through the Internet (see "FDA Alerts Consumers to Unsafe, Misrepresented Drugs Purchased Over the Internet"). Maybe they should also worry about drugs being advertised to teenagers on the Internet, especially drugs like ED medications and sleep aids, which have not been tested in children under 18."Advertisers often have an option to alert cable channels in advance when a specific program isn't appropriate for their ads," notes the WSJ. They could do the same thing on Web sites like miniclip.com -- just flag the family section as off limits.
You might defend GSK/Bayer -- the companies responsible for the Levitra ad -- and claim that the agency that does their media buying is responsible. Gardner, however, doesn't buy that defense. He who pays the piper is ultimately responsible.
"Blindly buying media through advertising networks without know exactly where your ads are being placed is not only foolish, it's just plain wrong!" he says.
I second that thought and ask PhRMA again, where are your principles for online DTC advertising?
Dr. Paul Antony, a reserve officer in the U.S. Navy Medical Corps, PhRMA's Chief Medical Officer and Director of its Office of Accountability, may be reading this blog. After all, he did write me to acknowledged my concern over other violations of PhRMA's DTC principles (see "PhRMA Responds to My Rozerem Ad 'Concern'"). If you are reading this Dr. Antony, I invite you to submit a comment in response to my question.