Just when I thought it was safe to stop raking Pfizer over the coals about torcetrapib, they go and do something stupid! I’m talking about running a Google Adword program that at least 85% respondents to my poll on the topic (see below) consider in violation of FDA regulations.

In case you haven’t seen the previous posts on the topic of Google pharmaceutical “bAdWords,” start by looking at “The Girl from Google,” which describes the issue when it first arose with Lunesta.

The following are Google Adwords for Celebrex that are currently running on a web site that I frequently visit. (Sorry, I can’t say which web site. Terms of Use — need I say more?)

BTW, these are not reproduced actual size here. The real ads have “Leaderboard” dimensions of 728 x 90 pixels, much larger than the typical 468 x 60 “banner” ad. (You can click on the images to see the full-size versions.)

Once again, like the Lunesta bAdword, these ads appear to violate FDA regulations regarding DTC advertising; namely, that whenever an Rx brand name and its indication are mentioned in the same ad, fair balance or the brief summary of the package insert must also be included. Generally, on the Internet, that means a direct link to the package insert. There is no such link in the above ad.

Google AdWords Not Advanced Enough for Online Pharmaceutical Advertising
If Pfizer ran a more technically advanced type of ad, such as a “Rich Media” ad, it could include a mouse rollover, for example, that pops open a window containing fair balance information. Unfortunately, this kind of thing isn’t possible using inexpensive (but pervasive) Google Adwords, which can contain only one active link. Another limitation of Google AdWords is the inability — no matter how large the box — to include more than about 50 characters in the descriptive text block. This is not enough to do a compliant brand ad (unless it were a “reminder ad“).

What do you think? (Ignore this poll if you’ve taken it before for the Lunesta ad.)

Does this AdWord Violate FDA’s DTC Rules?
Yes No Not Sure

I expect such shenanigans from Sepracor, the marketer of Lunesta. That company, after all, is a serial violator of their own agreement to follow PhRMA’s voluntary Guidelines on broadcast and print DTC advertising (see “Sepracor Sneaks In Lunesta Reminder Ad“). But, I am shocked and disappointed that Pfizer would condone this kind of ad for Celebrex.

It could be that the Celebrex brand team hired the same online ad agency that was responsible for the Lunesta Adword account. The Pfizer people simply may not know what’s going on — not the best defense, but, if true, there’s hope that someone in authority at Pfizer will see this post and put an end to this Google campaign. I note that the Lunesta bAdWords disappeared soon after I outed them in this blog. Hopefully, Pfizer will do the same.

Pulling the Celebrex bAdWord may send a message to Google, which must share some of the blame. After all, the “Girl form Google” gave a presentation at a major industry conference and used this type of AdWord as an example of how pharmaceutical companies should advertise with Google.

Google Says: “We’re Not in That Business”
My good personal friend, Harry Sweeney, who is also a friend of the pharmaceutical industry and often disagrees with my position on many pharmaceutical issues, agrees with me on this. Here’s what he said about Google’s promulgation of bAdWords in a recent article he wrote for Pharma Marketing News:

I felt sorry for one presenter from a major search engine company who brightly demonstrated how all of the online services might be supported by pharmaceutical advertising, using a patently violative, illegal, online ad to do it. When she was questioned about the legality and potential risks for advertisers from the audience, her naivete spilled over when she replied “That’s for individual companies to figure out. We’re not in that business.” Or words to that effect. — see “Pharma’s Plodding Approach to eMarketing.”

Harry was referring to the Google presentation I mentioned above and in my GfG post. Clearly, Google is aiding and abetting as the actors in Law & Order might say.

What Could Pfizer Do?
Here’s what I think Pfizer could do:

  • find out who’s responsible for this ad campaign and put a stop to it;
  • lead the way in developing guidelines for online DTC advertising that not only are consistent with FDA laws, regulations and guidelines, but that allows for effective use of the Internet’s unique features. One such guideline could be: In all ads that mention a brand name and its approved indication, provide at least a one-click method by which the viewer can access side effect information and/or brief summary; and
  • communicate these guidelines to the agencies that handle Pfizer’s online ad accounts.

In other words, start the ball rolling on developing industry Guidelines for Online DTC Advertising to complement PhRMA’s DTC Guidelines for broadcast TV and print advertising.