FDA in Focus
Serving a broad range of businesses, we come up against many unusual or difficult situations that clients face with their on-line marketing initiatives, and in particular, search engine marketing (SEM). Recently, our pharmaceutical clients were affected by an unexpected FDA Warning Letter barrage that went to 14 pharmaceutical companies targeting 48 of their brands’ use of Pay Per Click (PPC) campaigns on the major search engines.
Essentially, the FDA took a 20th Century approach to a 21st Century medium – the Internet, and in particular, search engines. The FDA stated that pharmaceutical manufacturers were not providing sufficient information in their search marketing text ads. The FDA’s April Warning Letters didn’t take into consideration how the average Web user searches for information or the limitations of pay-for-click advertising. In my judgment, the FDA was lost in cyberspace on this issue.
To address this very important subject, Stu Friedel, an attorney and partner in the Advertising, Marketing and Promotion group of Davis & Gilbert LLP, and I co-authored an article for DTC Perspectives magazine regarding the FDA’s action.
I invite everyone to read the article and draw your own conclusion and even some insight in how to handle problems with Washington regulators.
Please click here to read the “FDA and Search Engines” article PDF now.
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