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, then the link URL in the sponsored ad must be “” and NOT some “fanciful” name like or (which takes you to

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 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 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?”


See followup post: “St. Google Slays the FDA Dragon?

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