Will the FDA's letters affect SEM?

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How will the recent FDA warning letters for pharma-sponsored search engine advertising affect your search engine marketing (SEM)/search engine optimization (SEO) strategy going forward?


Josh Pierry, Principle and founder,
 Pierry Interactive

I think these letters highlight how little the FDA understands search marketing; however, they will have a pretty large impact on the way pharma SEM will be done. I can see a lot more micro-sites that will focus on conditions, but be sponsored by a single drug. A good example is Pristiq.com.They have an ad now that says "Depression—Learn about the causes, symptoms and a proven treatment option." It never mentions the drug's name and they use the URL KnowMyDepression.com.This is beneficial because there will be more content, more landing pages and will open drug marketing up to more keywords. From a consumer's perspective, I wonder which is better: knowing you are clicking on a specific drug's ad or clicking on an ad that you think will give objective advice, but is really an advertorial? 



R.J. Lewis, President and CEO, eHealthcare Solutions


Based on discussions with clients, we've seen two immediate trends as a result of the recent FDA warning letters.The short-term trend was somewhat of a knee-jerk reaction where many online campaigns, both SEM and display, were put on immediate hold as the client did an in-depth self-assessment and campaign review of all creative. The longer-term trend we are hearing is that SEM will lose some effectiveness and clout, and budgets will shift more heavily into display, where the rules are more easily followed. Display offers more real estate (larger ad sizes will gain further popularity), scrolling text and multiple forms of rich media...all of which are means to address the inclusion of fair balance and risk information on advertising.



Bruce Grant, SVP, business strategy, Digitas Health

FDA's letters reinforce the strategies we have been recommending all along. FDA has stated repeatedly that it believes the rules applicable to offline advertising apply equally to online—and all of its Internet enforcement actions have been against tactics that would have been violations in any channel. In this light, it seemed clear to us that ads containing both the product name and any representation about the product, but not the risk information, would be no more compliant on the Internet than in print or broadcast. So we have consistently advocated paid-search ads either in "help-seeking" format (mentioning the indication but not the brand) or in "reminder" form (mentioning the brand but not the indication). None of our clients who followed this advice received one of the 14 letters.




Buddy Scalera, VP, interactive content and market research, Qi


These letters had a dramatic effect on many pharma companies doing search engine advertising. Since several companies were really pushing the envelope, the letters dramatically changed the way many agencies structured ads and landing pages. Our clients traditionally opt for a conservative approach to SEM. For most of them, it's not about pushing the envelope. It's about placing an appropriate message in front of people. Obviously we've made the proper adjustments to our clients' campaigns, but we're optimizing keywords and ads daily anyway. It's never a good idea to have a "set it and forget it" campaign strategy. That said, we think more guidelines and restrictions are likely. 



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