In the wake of DDMAC's "Curious Case of the 14 Letters" (see, for example, "The 14 Letters. Who at the FDA Knew What and When?"), many so-called "expert" consultants are coming out of the woodwork and offering advice on how to comply with FDA's newly "received precedence" concerning sponsored (ie, paid) search engine advertising (eg, adwords on Google).Be careful whose advice you accept. It could be worthless!
Take, for example, this piece of advice from Ropes & Gray partner Alan Bennett published in the "The Pink Sheet" DAILY April 7, 2009 (see the reprint here).
"The citations will likely result in substantial rewriting of the search-result messages," said the Pink Sheet. "One solution for firms would be to insert a 'fanciful' name in place of a product name in a search engine link that leads to a company-sponsored product Web site, offered Ropes & Gray partner Alan Bennett."
Is this a good piece of advice?
Without any other information to go on besides the PUBLIC policies of search engines like Google, you might think this advice goes against Google's policy on the use of "redirect" URLs in adwords, which states that display URLs in sponsored ads "must be accurate." Even more specific: "Your display URL must accurately reflect the URL of the website you're advertising. It should match the domain of your landing page so that users will know which site they'll be taken to when they click on your ad."
If you want your ads to bring searchers to www.brandname.com, then the link URL in the sponsored ad must be "www.brandname.com" and NOT some "fanciful" name like www.bestdrugever.com or www.depressionhurts.com (which takes you to www.cymbalta.com)
It appears, however, that Google has carved out an exception to its link URL JUST for pharmaceutical companies (see "Redirect URLs in Adwords: Who Knew What When?")
Some experts -- maybe Mr. Bennett included -- knew about this for years, whereas many others DID NOT. This is just one example of how CAREFUL pharma marketers should be when taking the advice of "experts."
Although OK with Google (and maybe, just maybe) the FDA, should pharmaceutical companies be using redirect URLs in paid search ads?
As Robert Kadar of GoodHealthAdvertising.com says in a comment to this post, "your example does seem to violate Google rules but they obviously have made an exception for Pharma as a large percentage of pharma brands are masking the url's of their brand sites with generic names like depressionhurts.com. I believe that at the minimum this is a bad user experience and at worst is false advertising."
In response, enkil76 said "Is this like the one-click rule? At this point, I would say they haven't been enforcing a rule. What says tomorrow they won't?"
GOOD QUESTION!
See followup post: "St. Google Slays the FDA Dragon?"
Follow me and see the reaction to this on Twitter...
*heh* "wonderdrug.com" As if any...
ReplyDeleteOh, yeah, Bayer's had that for years. I've wondered how they've gotten by with that one.
John:
ReplyDeleteAs I have said before you can use multiple URL's within a website page for this and even use a site within a site to ensure compliance. A site with page URL's for disease condition such as www.depressionanswers.com can be used and it has been my experience that Google will allow this as the only other option is no adwords which would mean loss of business for Google
Rich,
ReplyDeleteThanks for your comment. If it's a real URL it can be used. But for brand drug ads you may not be able to used a name like that and lead people to a brand.com site.
Here's an example. www.depressionhurts.com is actually an alias for www.cymbalta.com
If Lilly were to create an adword that talked about a new drug for depression and used that URL, it would be OK with the FDA, but it would violate Google's rules, IMHO.
This seems to put drug marketers between a rock (FDA) and a hard place (Google)!
John,
ReplyDeleteYour example does seem to violate Google rules but they obviously have made an exception for Pharma as a large percentage of pharma brands are masking the url's of their brand sites with generic names like depressionhurts.com. I believe that at the minimum this is a bad user experience and at worst is false advertising.
Robert Kadar
www.GoodHealthAdvertising.com
Pharmaceutical Advertising Network
"obviously have made an exception for Pharma"
ReplyDeleteIs this like the one-click rule? At this point, I would say they haven't been enforcing a rule. What says tomorrow they won't?
Pharma needs to go back to the only way they know how to interact with consumers---bribe them. These websites are money pits that offer no value for consumers or Pharma. I am not sure why they feel the need to drive any traffic to them. They should just post a simply site with all the warnings and details about how the drug can kill you and leave it at that. There is no upside for anything else and certainly no justification to spend millions in online advertising.
ReplyDeleteIn the end, Pharma always get what it deserves...