It's dejavu all over again! I am once again sending a complaint off to PhRMA (see my previous tilt at this windmill: "PhRMA's Response - PRwise, it Stinks!").
I've just sent a letter to PhRMA officially submitting a comment on Takeda's violation of PhRMADTC Advertising Guideline #10: DTC television advertising that identifies a product by name should clearly state the health conditions for which the medicine is approved and the major risks associated with the medicine being advertised.
I also sent a copy to Mark Booth, the president of Takeda Pharmaceutical North America and Matt Kuhn, the Takeda spokesperson cited below. I also faxed the letter and submission form to PhRMA.
For the Record The letters went out today by certified mail. You can see when they were delivered and who signed for them at the USPS.gov site by entering the the following tracking numbers:
Amusing Defense but a Dangerous Precedent I thought Takeda's defense was amusing and sets a precedent I hope other pharma companies don't follow: "We don’t believe that they are reminder ads," said Matt Kuhn, spokesman for Takeda Pharmaceuticals North America. "Rather, they are bookends to the full ad which…opens the commercial break."
I do not believe this argument has merit. In fact, it makes a mockery of the PhRMA guidelines and worsens the industry's reputation as evidenced by several news stories and blog posts devoted to this incident.
Takeda says it adheres to those guidelines but doesn't see its use of the so-called trailer ads as a contradiction.
"If you think about the whole approach to how the brand has been marketed, we think it has been unique," Kuhn said. "And we think this a continuation of that, a somewhat unique approach."
This defense is not endearing the industry to the public and Takeda's defense must be shot down. I just hope I am not the only one speaking out against it.
The Annals of Family Medicine study of DTC advertising (see "TV DTC Educate Little, Increase Sales Less") may or may not be Pharma Marketing Blogworthy (ie, worth my time analyzing here), but a statement from a Pfizer spokesperson meant to counteract the conclusions of the study is blogworthy.
Jack Cox, a spokesman for New York-based Pfizer, the world's largest drug company, said in a phone interview: "It was a bunch of Ph.D.'s sitting around, looking at ads."
As far as comebacks go, this ranks up there with Pee-Wee Herman's famous line: "I know you are, but what am I?"
If this expression of disdain for PhDs is representative of Pfizer's attitude, it may explain its recent problems bringing drugs to market (see "Pfizer's torcetrapib: Who Knew What, When?" for example).
Or maybe Pfizer is not with the mainstream thinking of pharma-friendly organizations like the Coalition of Healthcare Communication, which urges that FDA fund more studies by PhDs and other experts on how to communicate risk in DTC ads.
In case you haven't noticed, sometimes I work in sync with Insider over at PharmaGossip. We seem to be on a hot streak right now.
You can dress Barbie dolls for any occasion -- even for detailing physicians as pharmaceutical reps. The site Denise Designs for Dolls suggests the following outfit for the successful female rep:
May I suggest that the following ensemble is more representative of today's pharma representative?
You heard about the Rozerem reminder ad first on Pharma Marketing Blog (see "Rozerem Reverts to Reminder TV Ads"). Now get a load of Takeda's lame defense:
"We don’t believe that they are reminder ads," said Matt Kuhn, spokesman for Takeda Pharmaceuticals North America. "Rather, they are bookends to the full ad which…opens the commercial break."
We have a saying in New York where I come from: "If you buy that, then I have a bridge to sell you."
As for the reminder ads, Takeda started running them about two weeks ago as part of a DTC campaign that has been on air since last July. Its latest ad was first reported on pharmamarketingblog.com. [my emphasis]
Among its voluntary guidelines on DTC ads for members, the trade group PhRMA calls for a ban on reminder ads. Takeda says it adheres to those guidelines but doesn’t see its use of the so-called trailer ads as a contradiction.
"If you think about the whole approach to how the brand has been marketed, we think it has been unique," Kuhn said. "And we think this a continuation of that, a somewhat unique approach."
Matt, Matt, Matt, Matt, Matt... wake up and smell the roses. You are piling the BS on us so high and so deep, I can't smell anything but you-know-what!
It seems that Takeda, after all, did agree to abide by the PhRMA DTC Guidelines. Matt chooses to redefine what a reminder ad is rather than admit that Takeda is in violation of it's agreement. Looks like I'll have to get PhRMA Intern on the case!
If you have seen the ad in question, how about joining me in reporting it to PhRMA? We'll compare notes on how long, if at all, PhRMA takes to respond. Who knows, we may get another letter from Emily!
If you would like to submit a comment to the PhRMA Office of Accountability about a particular DTC advertisement, please follow these steps:
1. The Office can only accept comments made in writing (click to view form) and mailed to the PhRMA Office of Accountability, 950 F Street, NW, Washington, DC 20004 or faxed to 202-775-0258. [Get with the times, PhRMA! How about an online form? Afraid of getting too many comments?]
2. The comment should provide information sufficient to identify the company and/or DTC advertisement at issue.
3. The comment should relate in some way to an aspect of DTC advertising covered by the Principles.
4. Please be sure to include a return address so the Office of Accountability can acknowledge receipt of your comment. [Don't hold your breath!]
If your comment relates to an aspect of a signatory company’s advertising that is covered by the Principles, the Office of Accountability will forward your comment to the relevant company for consideration. [Which the company will promptly ignore.] Download the form and fill it out.
P&G's OTC Prilosec marketers are doing something you'll never see an Rx product marketer do: sponsor a Bunco tournament. Bunco, for those of you who do not know, is a dice game that "likely began in the U.S. during the Gold Rush, when swindlers came to San Francisco with the fast-paced game, then played with dice or cards, to con laborers out of their money. Bunco parlors eventually formed, leading to the use of the word "bunco" as a synonym for financial scams" (see "An Old Dice Game Catches On Again, Pushed by P&G").
Here are some synonyms from Thesaurus.com for bunco as in "bunco artist": bilker, cheater, clip artist, con man, crook, deceiver, fleecer, flimflammer, fraud, hoser, hustler, mountebank, scam artist, scammer, shark, sharpie, smoothie, swindler. I've already explored the link between marketers and bullshit artists (see "Is Pharmaceutical Marketing BS?"). Now I can add bunco artist to the list. That label is a bit more sinister than BS artist. BS, after all, is not against the law, whereas bunco schemes are (hence, the police "bunco squads" of yore).
These days, bunco is played mostly by middle-aged suburban women who like Nascar, camping in RVs, traveling by Greyhound, and listening to country music. They also like tailgate parties at NFL games -- so look for Prilosec ads during the Superbowl game. I know this because P&G has done it's research, according to the WSJ article cited above:
"It's a natural fit for Prilosec OTC, whose ads have long focused on a certain core consumer: the middle-aged woman who loves to socialize.
[Sorry, I couldn't find a more representative image of a "bunco babe" to show you. You'll just have to settle for this "babe." I note that marketers often focus their ads on a younger demographic.]
"That's where her passion -- and her heartburn -- lie," says Mauricio Troncoso, Prilosec OTC's marketing director. P&G figures that 70% of frequent-heartburn sufferers are women.
"P&G studies this consumer so closely that it has a name for her: Joanne. And in order to observe her in her natural habitat, P&G urges everyone who works with the brand to participate in activities Joanne enjoys.
"Studying Joanne has led Prilosec OTC marketers to attend Nascar races, camp in RVs, travel by Greyhound, listen to country music and tailgate at NFL games."
Now that's a passion for the consumer of your product you'd NEVER see a brand Rx marketer have. Imagine, if you will, Pfizer marketers living in the shoes of a middle-aged man suffering from erectile dysfunction! Won't happen. First of all, Pfizer thinks these men are devilish scamps that accompany their women into lingerie shops.
I can think of a couple of other reasons why you wouldn't see this sort of marketing from Rx folks.
P&G is sponsoring bunco tournaments around the nation, including a "Bunco World Tour" with a tournament in Kansas City, Mo., "attended by 135 players. P&G had a pharmacist on hand to answer questions about heartburn and pass out samples of Prilosec OTC."
I don't suppose you can hand out free samples of Rx products like you can with OTC products like Prilosec (they used a pharmacist just for show, I imagine).
P&G is branding everything in its tour with the Prilosec logo and benefit statements as exemplified in its "Bunco Central Scoresheet," the bottom portion of which is shown below:
What's missing is any information about side effects. Inclusion of this information, of course, would be necessary if Prilosec were still an Rx product regulated by the FDA. But it's not and FDA cannot insist that the side effect information be clearly visible on the scorecard, which would defeat the whole idea, wouldn't it? And you can't put this stuff on the back of the card either as Daiichi has learned with its Evoxac calendars (see "Nice try, Daiichi!").
Too bad Rx marketers can not be as clever and gimmicky as the P&G Prilosec OTC drug marketers. But then they'd be bunco artists rather than just bullshit artists.
It's deja vu all over again! I am once again sending a complaint off to PhRMA (see my previous tilt at this windmill: "PhRMA's Response - PRwise, it Stinks!").
It seems that Takeda, after all, did agree to abide by the PhRMA DTC Guidelines. Matt chooses to redefine what a reminder ad is rather than admit that Takeda is in violation of it's agreement. Looks like I'll have to get 
