Redirect URLs in Adwords: Who Knew What When?

In previous posts, I discussed the use of "redirect" URLs in Google adwords for pharmaceutical product websites (see The Next FDA Concern May be the Use of "Redirect" URLs).

This practice is USUALLY forbidden by Google policies: "Your display URL must accurately reflect the URL of the website you're advertising," says this policy. "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."

It appears that Google has granted pharmaceutical companies an exception to this policy AND has been doing so for a number of years:

"We just heard back from Google this morning," said Jeff Hill of MedThink Communications. "Their 'policy board' ruled that they will make an exception just for pharmaceutical companies and allow non-branded URLs in paid search ads to be redirected to branded websites."

"For years it has been standard practice for Google to make this exception for our pharmaceutical clients," said Eileen O'Brien of Compass Healthcare Communications.

This raises more questions than it answers:

If Google was making this exception for years, how come so few experts knew about this? Many members of the ePharma Pioneer Club that I've been talking to, at least, had not heard of this and like Jeff had to call Google to confirm it.

Was Google making exceptions on a case-by-case basis up 'til now, but now is making the exception the rule for ALL pharma?

If some pharma companies were already taking advantage of the exception, why didn't the 14 companies cited last week by the FDA do it? It's hard to imagine that not a single one of these companies would NOT have known about the exception to the rule that O'Brien claims was going on for years.

If the 14 companies KNEW that Google would give them an EXCEPTION, then what was their motive in using the brand name in the adwords if they could have used a redirect URL instead? Did they knowingly use the "one-click" rule -- which everyone knew was not a rule at all -- as an excuse to get an extra bonus by linking the brand name to the benefit WITHOUT including the risks?

Did the FDA know that pharmaceutical companies had the option of using redirect URLs in their ads? If so, the FDA may have said to itself, "These guys could have easily used a redirect URL but they decided to use the brandname URL instead. Let's show them that we are not dummies and quash this practice right now!"

Many questions...not the least of which is the use of redirect URLs at best a bad user experience and at worst false advertising? That's a question raised by Robert Kadar of GoodHealthAdvertising.com



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St. Google Slays the FDA Dragon?

There once was a dragon -- called FDA -- much feared by the citizens of the tiny pharma e-marketing community.

The dragon usually made its nest in TV or print land, but it soon devoured all the denizens of those places and decided to build its nest in Internet land where many pharma e-marketing citizens were wont to do business.

Soon the dragon lashed out and prevented the good pharma e-marketing citizens from doing business as usual in the search engine district of their village. The citizens tried to placate the dragon with user fees, to no avail.

All feared that the dragon, if allowed to get his way, would ruin all business, everywhere in Internet land.

Then there appears Saint Google on his travels. The citizens beseech St. Google to help them rid their land of the dragon.

"I cannot allow this beast to ruin business in the search engine district or anywhere else that I hold sway in Internet land!," he cried.

St. Google then faced the dragon, and protecting himself with the sign of the "one-click rule," slays it -- or at least thwarts its plans to prevent the pharma e-marketers from doing business in the search engine district -- by declaring "redirect" URLs OK in pharma marketing adwords!

From then on, all the pharma e-marketing citizens felt safe and were able to place their adwords all over Internet land!

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This story is based on the rumor swirling in Twitterville that Google has created an official exception for paid search for Pharma and URL redirects. See The Next FDA Concern May be the Use of "Redirect" URLs and follow me and see the reaction to this on Twitter...

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FOLLOW UP

It appears that Google has granted pharma this exception AND has been doing so for a number of years:

"We just heard back from Google this morning," said Jeff Hill of MedThink Communications. "Their 'policy board' ruled that they will make an exception just for pharmaceutical companies and allow non-branded URLs in paid search ads to be redirected to branded websites."

"For years it has been standard practice for Google to make this exception for our pharmaceutical clients," said Eileen O'Brien of Compass Healthcare Communications.

This raises more questions than it answers:

Was Google making exceptions on a case-by-case basis up 'til now, but now is making the exception the rule for ALL pharma?

If some pharma companies were already taking advantage of the exception, why didn't the 14 companies cited last week by the FDA do it? It's hard to imagine that not a single one of these companies would NOT have known about the exception to the rule than O'Brien claims was going on for years?

If the 14 companies KNEW that Google would give them an EXCEPTION, then what was their motive in using the brand name in the adwords if they could have used a redirect URL instead? Did they knowingly use the "one-click" rule -- which everyone knew was not a rule at all -- as an excuse to get an extra bonus by linking the brand name to the benefit WITHOUT including the risks?

Did the FDA know that pharmaceutical companies had the option of using redirect URLs in their ads? If so, the FDA may have said to itself, "These guys could have easily used a redirect URL but they decided to use the brandname URL instead. Let's show them that we are not dummies and quash this practice right now!"

Many questions...



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The Next FDA Concern May be the Use of "Redirect" URLs

FDA's recent "untitled" letters notifying 14 pharmaceutical companies that their search engine paid search ads violate FDA regulations (see "The 14 Letters. Who at the FDA Knew What and When?") has opened a can of worms that is rapidly becoming a snake pit for pharmaceutical marketers. FDA's actions and the resultant analysis by bloggers, ad agencies, and consultants has opened several questions about the current search engine marketing practices of pharmaceutical companies.

On example concerns the use of "vanity" or "redirect" URLs in Google adwords (paid ads). According to Wikipedia "URL redirection, also called URL forwarding, domain redirection and domain forwarding, is a technique on the World Wide Web for making a web page available under many URLs."

There are good and legitimate reasons for using redirection, but when used in a paid search ad for an Rx product, redirection is always used to mask the fact that you will be going to a branded Rx site.

As Robert Kadar of GoodHealthAdvertising.com says in a comment to my previous 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 [which takes you to www.cymbalta.com]. I believe that at the minimum this is a bad user experience and at worst is false advertising."

Usually, as I pointed out in yesterday's post, Google does not allow redirect URLs in adwords. Google's public policy states: "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."

It appears, however, that Google has carved out an exception to this policy to allow pharmaceutical marketers to create adwords that mention the drug's benefits WITHOUT having to include the drug name as would be the case if the URL accurately reflected where the consumer would be sent if he or she clicked on the ad.

Consumer might be "fooled" into thinking they were going to an independent site and NOT to a pharmaceutical company site. Would they be harmed? Probably not.

But another commenter to my post, enkil76, pointed out that this practice may be another sort of "one-click rule" destined to cause trouble for pharma: "Is this like the one-click rule? At this point, I would say [FDA] haven't been enforcing a rule. What says tomorrow they won't?"

GOOD QUESTION!

Tomorrow's FDA might not be as friendly to pharma as today's FDA is:



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PhRMA Says FDA Should Initiate a Public Process Rather than Regulate by Warning Letter When it Comes to the Internet

"FDA should initiate a public process, which could take the form of a meeting or draft guidance, rather than regulating by warning letter in an area where there is now a lack of clear standards," said Jeffrey K. Francer, Assistant General Counsel, PhRMA.

His comment was made during a recent 45-minute ePharma Pioneer Club conference call that I hosted. Several other ePharma Pioneer Club members, including Fabio Gratton, Jonathan Richman, Rich Meyer, and Rob Nauman were also on the call and had comments.

The subject of the call was Overcoming Barriers to Pharma's Engagement in Social Networks. I expect a podcast audio archive to be available shortly.

Meanwhile, here are the opening comments I made during the call:

As all of you probably know, the FDA just sent off 14 letters to different pharmaceutical companies about pay-per-click search engine ads that violated FDA regulations regarding fair balance. Although some of us felt in the past that these ads were perfectly kosher because of a so-called “one click rule,” it turns out that this is not the case.

Mark Senak expressed our concerns well when he said in an Advertising Age article:

"The FDA is of the mind that they don't need to issue guidance specific to digital media because their current regulations cover that," said Mark Senak, senior VP at Fleishman Hillard and author of blog Eye on FDA. "Technically that's true. However, the internet presents a lot of situations that are somewhat nuanced and would lead to question in the mind of any reasonable person. Those questions deserve some answer. Formulating policy by issuing mass warning letters is not a valid way to set that policy or express it."

I think most of us agree that there are several other ways in which pharmaceutical companies can get into trouble with the FDA when they use social media. Right now, there is NO guidance from the FDA on how they may look at social media marketing in the future. As recent FDA actions have shown, companies can be in for some bad publicity and risk losing sales if they are caught unawares. It is perfectly reasonable, therefore, for the drug industry to insist that the FDA come up with some guidelines for use of the Internet and social media.

Before the FDA goes off and creates guidelines, however, it is important that it understand the position of all stakeholders on this issue. 84% of respondents to my survey agree that before issuing any draft guidance, FDA should convene a public hearing in which ALL stakeholders – including pharma, agencies, patient advocates, healthcare professionals, web site owners, etc. – can put on record their suggestions and concerns.

Some of us have already approached the FDA on this and have been rebuffed. One goal of this conversation, therefore, could be to approach the FDA as a stronger coalition of concerned stakeholders and demand at least a private meeting.

Although it would be helpful for the FDA to release guidance for the industry on the use of social media, there is also a need to develop “best practices” that go beyond what the law requires. Some pharma companies are currently discussing this and that is perhaps what we can also do starting with this roundtable discussion.

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When it Comes to Pharma Marketing on the Internet, be Careful of the Advice You Get from "Experts"

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?"

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