Importance of Search
• 87% of U.S. adults use the internet• 72% of internet users looked online for
health information• 77% of online health seekers began at a
search engine
http://www.pewinternet.org/fact-sheets/health-fact-sheet/
Google Dominates Search
64%Yahoo!
13%
Bing
21%
Other
3%
http://www.comscore.com/Insights/Market-Rankings/comScore-Releases-August-
2015-U.S.-Desktop-Search-Engine-Rankings
FDA Enforcement
FDA Enforcement
Post-2009 Compliant Promotion
1. Disease Awareness Promotion
2. Reminder Ads
3. Redirecting Ads
Google 2009 Black Box Option
Reminder-like Ads
Apply to drugs with black box warningsFour requirements1.Brand name (if applicable)2.Generic name and/or active ingredients3.“Please see…” statement4.Provision of PI or Brief Summary immediately accompanying the advertisement
For more on reminder-like ads, see http://regulatoryrx.blogspot.com/2014/10/reminder-like-promotions.htmland http://regulatoryrx.blogspot.com/2015/06/google-search-engine-marketing-changing.html
Google 2015 Updates
• Black box ad format discontinuedEffective date: July 20, 2015
• Redirecting ads vanity URL changesEffective date: January 2016
Black Box Ad Options
Standard ad units
Existing mobile ads
Black Box Ad Options
Standard ad units
Existing mobile ads
Using sitelinks to create second destination link
NOT using sitelinks to create second destination link
Redirecting/Vanity URL Changes
• Option 1: Company
• Option 2: Company.com
• Option 3a: Prescription treatment
• Option 3b: Prescription device
Redirecting/Vanity URL Changes
• Option 1: Company
• Option 2: Company.com
• Option 3a: Prescription treatment
• Option 3b: Prescription device
Destination page will still be under control, but the display URL must be one of Google’s specific options.
Key Takeaways
• Platforms will changeCompany-specific policies matter
• 30-day notice is a luxury• Mobile is the new standard• One link must suffice for promotion &
regulatory requirements
Speaker BioDale Cooke is the owner of PhillyCooke Consulting, which provides advice and training to companies about using 21st century technologies to communicate about FDA-regulated products while remaining compliant with FDA regulations written in the 1960s. Dale has worked with more than 30 pharmaceutical and medical device clients around the world. His insights have been featured in the Wall Street Journal’s Health blog, The Pink Sheet, MedAdNews, PharmExec, and others. He also serves on the faculty of the University of California San Francisco’s American Course in Drug Development and Regulatory Sciences program. Dale is the author of Effective Review and Approval of Digital Promotional Tactics, which is part of FDLI’s primer series.
Contact Info:PhillyCooke.com@PhillyCooke on [email protected]