Thursday, May 21, 2009

FDA to Online Marketers: Same Rules Apply

Some of my first blog posts were about warning letters issued for several online initiatives such as Pfizer's Viagra game and the Ty Pennington videos from Shire. There also was a letter issued for an online banner from Novartis, a milestone which John Mack dubbed the "death of the one-click rule." And more recently, DDMAC made it clear they were watching the way pharma advertised via search engines.

Today, DDMAC issued a warning letter to J&J for a webcast.

With DDMAC's new focus on digital initiatives and the influx of corresponding warning (and untitled) letters, it seems DDMAC is sending a message:
  1. It's not just Web sites anymore ... FDA is paying attention to all kinds of online marketing.
  2. The same rules apply online as they do offline. (Yeah, we know .... Boooo!)
Dare I predict a social media-related warning letter by the end of the year? Then again, maybe not ... there aren't enough examples out there that push the envelope to garner a letter. But as fellow bloggers have pointed out, the FDA is definitely paying attention.

While I'm a proponent of social media and understanding how it's shifted control to consumers, I am also a realist, and I realize there are limits.

DDMAC, it seems, is making sure those limits are well-known.

1 comment:

Mark Hollander said...

Wendy, I agree with you that the same rules apply, however frustrating they may be, including the "one click rule" which is not dead at all. The big challenge ahead is not only social media, but Google's "Ad Sense" contextual ads which unless properly locked down, might allow a brand's message to appear in the most unlikely and unwelcome places.