I was goofing around on Facebook last night when I noticed what looked suspiciously like a branded pharmaceutical advertisement:
It was indeed an ad for Axert, a Janssen migraine treatment, and one click took me to the home page for Axert.com. It's possible I'd "liked" a migraine page on Facebook in the past and that's why it was targeted to me. (I "like" a lot of pharma/health-related pages on Facebook; my friends must think I'm a hypochondriac.)
I've noticed ads on Facebook that recruit for clinical trials, unbranded ads promoting pharma-sponsored Facebook pages, and other unbranded mentions, but this is the first branded Facebook ad that I could recall. Have you seen any others?
A colleague asked about the risk of this ad ending up on a page that mentioned the indication (migraine), and if that was a problem because the ad didn't include fair balance. In my mind, that equates to many display ad purchases available today for WebMD and other condition-related sites. I've never seen FDA give a warning letter for that. However, I do know companies have shied away from branded ads in social spaces because they see places like Facebook as "the Wild West" ... where anything could happen. The branded ad could appear next to a user-generated overstated claim, a comparative claim, or any number of other "violations" that patients unknowingly state about the drugs they use.
FDA pays attention to what is and is not within the control of the pharma company when they engage in promotional activity. Janssen has clearly decided that this is a safe thing to do, and they're putting money behind it. Whether Facebook ads work at all is a different question. And whether consumers will welcome pharma advertising in their stream alongside kittens and kids is yet to be determined.
The question was also raised in discussions here at Intouch... if the ad doesn't have the indication/condition, why would anyone even click on it? Of course, I clicked out of curiosity. But we can't count on those outside the industry to do the same. Janssen must be hoping for some level of awareness to already be in place.
Janssen is not a client, so I can't speak to any decisions made behind the scenes. But I applaud their branded move into the social space. It's crazy to me that it took this long for someone to try it. This industry always needs more trailblazers willing to take a chance!