Thursday, November 16, 2006

The "Girl from Google"

"I could strangle that girl from Google," said a friend of mine after a presentation by a Google operations specialist at the recent eyeforpharma eCommunications and Online Marketing conference held in Philadelphia. Of course, this was not a literal terroristic threat, just an expression of frustration by a long-time industry advocate.

What did the "Girl from Google" (GfG) say that upset this person so much? 

The "Girl from Google" (GfG) was up just before my presentation and the title of her talk was "The Importance of Interactivity: How multimedia technologies will change the way you Connect with Consumers & Physicians."

It was actually a nice presentation but it could have benefited from a little legal/regulatory review beforehand. GfG was one of those presenters who have little or no experience working within or for the pharmaceutical industry. Her bio in the conference brochure says only that she has worked with Google for three years (congrats on the stock options!) and graduated with a Masters Degree form the University of Southern California (party on!). I estimate that GfG joined Google straight from school.

I had only one little problem with her presentation.

As an example of how Google Health can help pharmaceutical companies engage consumers online, GfG used as an example a fictitious drug -- let's call it Xenaxa -- indicated for treatment of osteoporosis. The target consumer was a fifty year old woman concerned about osteoporosis. She does a search on Google Health and finds an AdWord for Xenaxa.

Would you believe that GfG's example used an Adword exactly like the Lunesta AdWord I talked about a few days ago on this blog (see "Lunesta, Google, and bAdWords")? Just like that Lunesta AdWord, the AdWord GfG used in her example included both the trade name of the drug (in the URL) and its indication.

As with the Lunesta AdWord, this example also violates FDA regulations, IMHO. Harry Sweeney agreed. I asked the audience what they thought. One person from a pharmaceutical company, perhaps playing the devil's advocate, contended that the ad may pass muster with the FDA because the package insert or brief summary is "one or two clicks away." His argument was that without specific guidance from the FDA, no one knows what is correct in this case.

One Click Away?
The "one click away" defense does not apply here. FDA says it's OK on an Rx product Web site to merely provide a link to the package insert or brief summary. In that case there is no need to provide that information on the same page that mentions the drug name and its indication.

Thus, an AdWord could be said to comply with the "one click rule" only if within the AdWord text there was a
direct link to the package insert (PI) or brief summary. In the example that GfG used, there was only a link to -- the product Web site, not the PI. Presumably, the user would have to find the link to PI once on the Xenaxa Web site. I don't think two clicks would pass muster with the FDA (more on that in future posts to this blog).

It is a shame that the FDA does not have any guidance for the industry as far as Internet advertising is concerned. This means that marketers can use lack of guidance as a defense for sneaking in ads that push the envelope. What are the chances that the FDA would ever notice. These ads are fleeting, here today, gone tomorrow!

However, that should not stop the industry from developing its own Internet DTC advertising guidelines, which it promised to do when PhRMA released DTC guidelines for broadcast DTC.

In this case, however, I think the issue is clear. Any AdWord that mentions a product by name plus the indication, must also include a direct link to the PI within the ad itself.

What do you think?
Consider the Lunesta Adword below:

Does this AdWord Violate FDA's DTC Rules? Results of poll:

She Just Doesn't See
What the "Girl from Google" just doesn't see is what the fuss is all about. "We don't think it's a problem and it's not our roll to enforce the law." This attitude is absolutely stunning. She claims Google is neutral, but as I pointed out before, Google does intervene when it thinks EU laws about DTC advertising are being violated. Why not when US laws are involved?

Update: Much has happened in the legal/regulatory world that has proved me right. Namely, FDA sent 14 warning letters to pharma companies in April, 2009, about Google AdWords similar to the ones mentioned her and promoted by the Girl from Google at this conference.


  1. Anonymous7:27 AM

    GfG: a guileless and naive sales rep. Good to see that other industries have the equivalent of the GfP: Girl from Pharma. There are substantial hazards in her point of view and it would seem that the Google culture is precontemplative regarding the pharma regulatory environment.

  2. Anonymous9:23 AM

    Good point. Good story. But resent your headlining it with an image of violence toward women and your describing her as the Girl from Google, denigrating her professional (although uninformed and naive or worse) status. Do not use images and words that denigrate women professionals in a sexist/violent way. Criticize them for their poor work and sloppy thinking (as you did above) leave the other stuff out.

  3. The heading stays.

    The quote is genuine. It's an expression of frustration, not violence, as if you didn't already know that.

    Maybe you should talk to the Rozerem ad people about the beaver...


    First of all I am happy with the current trends of intensified marketing communication activity through newer and newer means including 'paid blogging' and social network marketing. This makes people put marketing first in the pharma space. And this trend is the way it should be.

    Today in India and Bangladesh micro credit is a big thing in the financial domain. How did this happen? This happened because Mohd Yunus of Grameen Bank put the market first, he identified a target market for micro finance and thus realised profits for his firm and made social contributions. ICICI in India is on the same pathway, which is a wise marketing effort.

    In fact the bane of the pharma field is the hyperfocus on intellectual property, patents, patent life and evergreening of products. Marketing is not taking the front seat. In fact, the obsession on drug patent(s) and TRIPS is causing much hardship in making drugs and health care products available at an economical price. Morever, having patent rights is itself a great source of income for pharma companies, thus many other good molecules and drugs that are beyond the ken of patents are not picked up for commercialization and/or intensive marketing by big pharma companies. In fact, it is not an exaggeration to say that pharma companies are more in the business of intellectual property, patent holdings & evergreening products rather than marketing products. In fact this innovation led business activity is said to be the highest of profitable business models, where in the focus is on innovation and creating intellectual property and gaining value, rather than marketing products based on target audiences. So who cares about health and societal or market needs when the focus of pharma companies is on intellectual property, patents, monopoly markets for products, profits and big bucks(?)

    In fact, google is creating a revolutionary 'flat world' and seamlessly allowing exchange of ideas, information and comments across geographies. Google is doing a great marketing job, they are putting marketing first. And putting marketing first should be the priority for pharma companies too; it should not be patents first for pharma companies. - SUNIL S CHIPLUNKAR

  5. Anonymous10:11 AM

    College Graduate, female, Google stock options - John you're just jealous!

  6. Anonymous10:29 AM

    I think the issue doesn't lie with what the GfG doesn't get, but with what the fact that you don't get social networking and its true dynamics and implications.

    Evident with the fact that all your examples (paid blogging, amazon and ADwords) are irrilevant in explaining what social networking is about. It is about making commerce better, more efficient - redefining economics by using markets, networks, and communities.

    Get the way MySpace works, and the way it has impacted the music industry, and you might get what social networking is actually about. Some marketers have, and in fact spaces are always more populated with marketers.

    Regulations are beyond the point.

  7. Anonymous3:29 PM

    Agencies, marketers and regulatory people are responsible for interpreting FDA guidelines. The practice of having a brand and condition has been routine for years. Only recently has it been debated.

    I don't think it's Google's responsibility to enforce FDA rulings. I told the Google team how my company is interpreting it, but should I be concerned if they use an example that has a more relaxed interpretation? I think not.

    Google has a strong healthcare vertical, btw. I don't know about the one you assaulted but most of them know my category better than the media buyers.

  8. Thanks for your comment.

    You and others have said that Google is not responsible for enforcing FDA rulings.

    That may be, but Google has taken responsibility to enforce other laws, which I mentioned -- such as preventing DTC ads to be served on non-US sites (check out their AdWord Editorial Guidelines if you don't believe me). Also, I believe they have kowtowed to China's censors in many ways as well.

    Therefore, there are precedents for them to follow that they themselves have set up.

    Anyway, the point is mute. As a pharmaceutical company you are ultimately responsible for what your agencies do on your behalf. If you do not monitor them and reign them in, then shame on you!

    When the FDA comes knocking or sends your CEO a letter, what excuse will you have: Google ate my homework? It's just a wrist slap anyway. Nothing to be concerned about.

  9. Anonymous5:15 PM

    Your whole entire "GFG" rant is an angry, misogynistic, and uninformed personal attack. Several people attending the presentation have commented on the fact that you misquote the Google employee (in addition to petty comments about where she got her Masters degree and whether she as stock options). Your blog is a disgrace and you should be ashamed of yourself.

  10. I Know I Am, But What Are You?

    Got a name?

  11. BTW, here are a few unsolicited comments I received personally from people attending the meeting:

    "Enjoyed ... your constructive rabblerousing at the conference a LOT; can’t tell you how often I’ve wished for someone to go beyond the mutual butt kissing and stir up some bees."

    "I've been enjoying your blog of late, and I appreciated your contributions at the e-marketing sessions during the conference."

    "We really learned a lot from you and you instigated some great debate and thinking which I think will ultimately help us all."

  12. Anonymous12:32 AM

    Hi John

    For such a perfectionist and fan of rules, you may want to check your grammar. The point is moot, not mute.

    In any case, I appreciate your willingness to challenge conventional wisdom and stir it up among a sea of very boring people, but have to say that from my perspective, you seem a bit focused on what's "right" for industry insiders, not patients. That's what we should all be focusing on. What if the rules are wrong? Forget what DDMAC says about that Lunesta ad. Do you feel it serves patients?

  13. Thanks for correcting my "mute" vs. "moot" mistake! I wish I could edit my comments, but I can't. Once the Publish button is pushed, that's it! My mistakes live on in infamy. That's the beauty of Web 2.0!

    But, back to the real issue.

    Of course I focus on industry insiders. That's my business objective. I am not in the patient advocacy business.

    But I believe what's "right" for patients should also be "right" for insiders. Or, to put it another way, if insiders behave ethically, it will benefit consumers/patients.

    In this case, whether or not the Lunesta adword is violative of DDMAC rules matters very little to consumers directly. But consumers have a choice in this marketplace. If one company chooses to violate this "rule," what's to stop another from doing it also?

    Then there is the temptation of escalation. If you get away with a small infraction, maybe you can get away with another, more serious one.

    Isn't that the reason Rudy Giuliani went after vagrants cleaning windshields and graffiti "artists" scribbling on walls? It sends a message that there are rules for living in a civilized society.

    I dare you to say that Giuliani was more interested in protecting insiders' (landlords) property than improving the lives of New Yorkers in general.


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