You may recall that the FDA sent a letter to Duchesnay Inc. because an Instagram post by Kim Kardashian promoting the company’s morning sickness drug Diclegis violated the law (read “Kim Kardashian’s Diclegis Instagram Post Raises Issues“).

Some time afterward, Alex Peterson, SVP, Health Practice Director at Makovsky — the agency that hired Kim to do the Diclegis Instagram social media campaign – claimed that Makovsky, through social monitoring, knew that Kardashian was struggling with nausea during her first pregnancy. She’d been talking about morning sickness for weeks (read this account).

No doubt Makovsky also knew that Kardashian promoted nutraceuticals years earlier in 2010. As reported by STAT, in a video ad for QuickTrim (see end of this post), “Khloe Kardashian rolls languorously in a tangle of white sheets and asks, ‘Do you feel sexy? Do you have the body you’ve always dreamed of?’ The shot switches to her sister Kim, shimmying out of a pool and commanding viewers to ‘Create the body you deserve'” (read “Celebrity selfies, lax regulations drive booming supplement industry“).

Makovsky claimed they reached out to tell Kim about Diclegis and found out that she was already taking the drug — her doctor had just prescribed it.

But could Kim have been talking about her morning sickness as a prelude to working with Makovsky so that the above account by Peterson would sound perfectly plausible?

If so, it may not have been the first time that a celebrity has “auditioned” for an Rx drug sponsorship deal. Phil Mickelson stunned the golf world back in 2010 when he announced that he suffered from Psoriatic Arthritis and was being treated with Enbrel. This was months before he signed the contract to be an official Enbrel spokesperson. Consequently, in news articles, he was able to say “I have no aches and pains. My back feels great. I feel stronger and more flexible than I’ve ever been,” which is something he would never be able to say as an official Enbrel spokesperson. For more on that, read “Is Phil Mickelson Shilling for Enbrel?

Here are some questions I have for Makovsky, which declined to be interviewed on my Pharma Marketing Talk podcast.

  1. I’ve heard that Kim gets paid $200K per Instagram tweet (see here). Is that about the fee charged by her to do the Instagram post promoting Diclegis? 
  2.  This article said “But, they [Makovsky] knew a letter from the FDA was a possibility – so, the contract with Kardashian included the creation of a corrective post, if needed.” Did she throw in the “corrective message” post for free? 
  3. I knew for sure that the post was violative because it did not mention any side effects — see “OMG. Kim Kardashian Shills for Pharma! No Worry – No Side Effects!” Why did you chance going ahead with the post and getting an FDA letter? Did you feel that the publicity generated from that would more than compensate? I’ve heard that some pharma product managers frame these letters as badges of ritual regulatory passage. 
  4. When exactly did you file the necessary Form 2253 paperwork with the FDA? Prior to the post or simultaneously?
    I’m intrigued by synergies between social media, celebrities, and free media coverage. 
  5. The article above said:” The celebrity post earned 752 million social media impressions, 800+ online print articles and TV/radio segments, $12+ million advertising value, a 388% growth in trafifc to the site…” Is that correct? So you got $12+ million in advertising value how much actual dollars spent (including agency fees)? Do the impressions include the “corrective” post? Do you have nay data to prove that the audience which saw the original post most likely also saw the corrective message? Was the audience who read about this in the media and on TV greater than the social media audience? In terms of viewers, how would you rate this campaign compared to a typical DTC TV ad, which won’t be possible for this drug for (what?) 18 months? 
  6. It was said that “a lot of late-night hours were spent scanning comments for adverse events.” How many were found? I mean, no one is using this product yet – so why the effort? 
  7. Kim has said: “I know a lot of my brands might get frustrated that I don’t promote maybe as much as they would like, but I only do it if it’s authentic.” The article above said “Through social monitoring, they also knew that Kardashian was struggling with nausea during her first pregnancy. She’d been talking about morning sickness for weeks. The team at Makovsky reached out to tell her about Diclegis and found out that she was already taking the drug, her doctor had just prescribed it.” Really? Can you show me the posts where she was talking about morning sickness without mentioning a product?
Meanwhile, enjoy this QuickTrim video featuring Khloe and KIM (note: this Youtube video has been viewed only about 150,000 times, much less that the nearly 1 billion social media impressions resulting from Kim’s Instagram!):