Friday, September 30, 2016

Kybella Double Chin TV Ad: Are the BEFORE & AFTER Photos REALLY Unretouched as Claimed?

Perhpas you've seen the recent TV ad ("Ancestors") for Allergan's Kybella, a new drug approved for the treatment of double chins (read "Pfizer May Own Your Penis, But Allergan, Maker of Botox & Kybella, Owns Your Face"). The ad claims that double chins may be inherited. You can view it on iSpot.tv here.

To prove the efficacy of Kybella, several screens are devoted to showing BEFORE and AFTER photos as in the following example:


You clearly can see from these "unretouched photos" of an "Actual KYBELLA patient" that the double chin is gone.

But are these photos really "unretouched." It all depends on what you mean by "unretouched." Let me explain.

Monday, September 26, 2016

Pharma Has Funded Hilary to Tune of Nearly $1 Million This Cycle, But Supports Republicans Overall

According to the latest data from the Federal Election Commission released on Monday, September 12, 2016 (here), Hilary Clinton has received more than $990,000 in funds from the healthcare/pharma industry although the industry has donated nearly 50% more money to Republican presidential candidates than to Democratic candidates.


Apparently, Trump doesn't need no stinkin' money from pharma, which only gave him about $95K. Does that mean that Trump will come out swinging harder at pharma during tonight's presidential debate than will Clinton?

Friday, September 16, 2016

Do Drug Ads Need to Scare Consumers to Motivate Them?

I was quoted in an AdAge story (see embedded summary at the end of this post) about the recent spate of scary drug ads seen on TV and in print. The title of the article - "Halloween Already? Big Pharma Marketers Try Terror Tactics to Scare Up Sales" - was bit over the top but, hey, that's how you sell content.

The article quoted me as saying "a trend with companies, especially ones with injectable drugs and vaccines, which also have big price increases, is to scare people into buying their product or getting their vaccine." I have posted about that here on Pharma Marketing Blog ( read "Branded as Well As Unbranded Vaccine Ads Are the Scariest!").

My comments hit a nerve with Bob Ehrlich, Chairman of DTC Perspectives, who wrote in an email to his subscribers: "Drug ads are meant to motivate action. Showing what can happen when not vaccinated is not fear mongering. I have been reviewing DTC ads for over 20 years and there is no new trend to using scare tactics." [Ehrlich doesn't mention me by name. Sigh!]

I can only say that I stand by my opinion based on my paltry 16 years of reviewing DTC advertising via Pharma Marketing News and ~12 years here on this blog.

Mr. Ehrlich had some other things to say in defense of scary drug ads.

Saturday, September 03, 2016

FDA May Have No Choice But to Allow Direct-to-Consumer Off-Label Drug Promotion

In what's been described as a "surprise move" (here) the FDA recently published a notice that it will hold a 2-day public hearing this November to obtain "input on issues" related to off-label product communications about by pharmaceutical and medical device companies. FDA defines off label use of drugs as, "Use for indication, dosage form, dose regimen, population or other use parameter not mentioned in the approved labeling."

FDA's authority to prevent or even regulate off-label promotion by pharmaceutical companies is dwindling. After losing to Amarin in court ("FDA Deal with Amarin: Does It Mean More or Less Off-Label Promotion?"), FDA suffered another setback when it settled a case with Pacira Pharmaceuticals (here).

In both cases, the plaintiffs argued that off-label marketing was protected free speech as long as the information was truthful and not misleading. While the FDA still insists it has the ultimate authority to decide what is and is not truthful, other entities - most notably the Washington Legal Foundation (WLF) - have claimed a stake in the debate.

FDA issued some "draft guidance" in February, 2014, but this did not mollify WLF, which claimed that the guidance document is in "direct violation of a 1998 permanent injunction (WLF v. Friedman) it obtained against the agency to prevent it from trampling on industry's purported First Amendment rights." WLF said it "intends to enforce its injunction and will seek contempt of court citations against FDA officials who violate its terms" (read "WLF to FDA Regarding Distribution of Off-Label Reprints: See You in Court!").

The FDA cannot win the "First Amendment" battle and has hinted in the public hearing notice that it may have to allow pharma companies to engage in off-label communications directly to "patients and consumer audiences" and not just to physicians.

If you stay awake reading the Federal Register Notice (here) and get to the questions for which the FDA is seeking input, you'll find this unusual set of questions:

Friday, September 02, 2016

Are We at the Saturation Point Viz-a-Viz Celebrity Pharma Endorsements?

I read with interest today's email missive from Bob Ehrlich, Chairman of DTC Perspectives. He was talking about the "Dry Eye DTC Battle" between Allergan's Restasis and the new kid on the bloc: Shire's Xiidra (two i's - get it? aka two "eyes").

Ehrlich pointed out that Shire enlisting Jennifer Aniston is a "big get. Getting a movie star to promote the dry eye condition must have cost Shire a lot in talent fees," said Ehrlich.

"Obviously they think she is worth it. Her ad just went on air under the 'myeyelove' title" (read "Jennifer Aniston is Shilling for Shire!").

Ehrlich noted that Aniston is getting "lots of commercial endorsements these days. She is touting skin care brand Aveeno and plugging the comforts of Emirate Airways. I am sure Shire considered whether we at a Jennifer saturation point. My feeling is we can take a couple more campaigns before she gets overused."

My view is that celebs are being overused by pharma marketers these days. Why?

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