Social Media Wiki

Maybe the Pizza Was Terrible: A Marketing Rant

I receive a bunch of journals in the mail (which I don’t recall ever signing up for) and countless feeds of blogs and more journals everyday. I’m pretty bad at keeping up with all of them. However, every once and a while, I clear out the “Read Later” bin and usually find a few interesting nuggets. One of the mysterious journals that shows up every month is OMMA (The Magazine of Online Media, Marketing, and Advertising). This time around I was catching up on the November issue (read the whole thing online here). Of all the articles in this issue, one stuck with me and the more I thought about it, the more it bothered me. It was entitled “Full Circle” and told the story of how pizza chain Papa John’s used “crowdsourcing” to pick its next “specialty” pizza (read the article here).

I know…remarkably unique concept, right? Here’s what the conversation might have looked like when this idea came to life. Stop me if you’ve heard this one before:

Marketer 1: “Why don’t we have some sort of contest where people tell us what the next pizza should be?”

Marketer 2: “Yes, and they should submit the ideas on Facebook because social media is all the rage.”

Marketer 1: “Of course…what else can we do though?”

Marketer 3: “Well, we should have people vote on which is their favorite.”

Marketer 1: “Yes, why didn’t I think of that? Has anyone done that before?”

Marketer 3: “I’ve never heard of such a thing.”

Marketer 2: “Indeed…have the public pick the next version of our product. It’ll be huge. A marketing first…Ad Age will love this…”

Okay, so maybe it didn’t go quite like this, but you get the idea. To their credit, Papa John’s didn’t pick the winner based on the number of votes for each pizza, they determined the winner based on actual sales. 12,000 submissions were made and the company narrowed  that down to 3 finalists (with the help of “celebrity” judges of course). The winner gets $10,000 and a lifetime supply of pizza (sort of). Here’s the big hook in the article:

“In a lucky break for the pizza chain, three distinctly different people emerged as finalists. Two of the contenders had youth, sizzle and sex appeal on their side. The third had good intentions and people sense. Guess which one won.”

Gee…I wonder.

Pause for a moment and consider the finalists and their entries. Read this paragraph carefully, as it’s the most important to determining the winner in my opinion:

“Blair Dial, 29, a blonde marketing pro from the Chicago area, pushed her pizza, ‘The Big Bonanza,’ heavy on bacon and barbecue sauce. Another, 22-year-old volunteer firefighter Kendra Chapman with flaming red hair, hailed from Georgia. Her pizza, ‘Workin’ Fire’ boasted spicy meat and peppers. Then there was Barbara Hyman, 51, a tanned brunette holistic healer from Los Angeles, who immediately pledged to donate $1,000 to the National Wildlife Federation if she won. Her chicken-and-ham pizza was called ‘Cheesy Chicken Cordon Bleu.’”

I know, you’re probably thinking the “blonde marketing pro” took this contest hands down. Ah ha! A twist. She didn’t. I’m sure you’re totally shocked.

The three finalists were given $1,000 for promotion (and you think your budgets are small) and had a month to drum up some noise before the pizza’s hit the real Papa John’s menu. Implied in this, of course, is that the contestants would use social media to promote their pizzas. It wasn’t a requirement, but it’s what all the kids are doing these days. In fact, Papa John’s had this to say after the contest: “We were surprised and excited by the ways the finalists used social media to execute three classic positioning approaches,” says Jim Ensign, Papa John’s vice president of digital marketing.

And so it began, each pizza had a dedicated Facebook page and Papa John’s tracked the number of “Likes” for each. The results of the social media efforts went like this according to the OMMA article:

“Based on social media indicators, the barbecue pizza should have won by a landslide. Dial posted on her pizza’s Facebook page one to three times a day, with games, contests and jokes. By Aug. 12, her site had more than 1,000 ‘likes,’ while her rivals had only about 500 each. On the company site, 1,351 people voted for her pizza by the end of August.

After that came Chapman, the firefighter, who anchored her page with a striking photo of herself. She posted about every other day and at month’s end 1,005 users voted for her pizza on the Papa John site.

Hyman, in contrast, seemed to use Facebook only as a back-up communication tool; in August she posted only three times. But she included her charity’s name in her Facebook title, calling it ‘Papa John’s Cheesy Chicken Cordon Bleu for Gulf Coast Animals.’ Her pizza got 928 votes on the Papa page.”

Now, the Papa John’s people were smart enough to not leave the future of their menu to the whims of the Internet unlike many others have done in the past (I’m looking at you Kraft for your “iSnack 2.0″ debacle). The winner of the contest wasn’t judged by the number of Likes or votes, but rather by which pizza sold the most.

The article goes on to talk in more detail about the tactics that each person used to promote their pizza. “The blonde” and the one with the “flaming red hair” relied on social media almost exclusively, while the “brunette” focused on more offline, traditional approaches (note: why the hair color of each contestant is relevant to the article is never explained).

And, to end your torture, the winner was the “brunette holistic healer.” Her pizza sales accounted for 45% of the total (31% for the redhead, 23% for the blonde).

Papa John’s explained why she won this way: “In hindsight, Ensign says Hyman’s site, pitch and pizza had two powerful hooks. One, the Cordon Bleu name was familiar and easy to remember; two, her cause was framed as a way to help animals harmed in the BP oil spill, which had a timely, emotional pull.”

And also this:

“While Facebook contributed somewhat to the success of the winner, it was an even bigger factor as a way for us [to use the contest to] engage people in our entire menu of specialty pizzas,” says Ensign. “Social media will continue to be a growing part of our marketing strategy.”

Okay…now onto the point of this post and an explanation of the title. This entire case should teach you one lesson. In trying to come up with an explanation for why one person won versus another, there are about five different explanations in the article from “emotional pull” to “in-person interactions” to “cause marketing” and everything else in between. What’s missing, however, is the most logical and simplest explanation (and it has nothing to do with hair color).

I’m a big subscriber to the principle of Occam’s Razor. You’ve probably heard it before, but for review, this principle states that the simplest explanation is most likely the correct one. It’s the concept behind the quote: when you hear hoofbeats, think horses, not zebras.

In my opinion, Papa John’s is looking for zebras here. Why did the “Cheesy Chicken Cordon Bleu” pizza best its rivals? Simple. The other two pizzas sound vile. One featured “spicy meat and peppers” and the other was described as “heavy on bacon and barbecue sauce.” The “Cordon Bleu” pizza, on the other hand, features a dish that every American has had either in a Hot Pocket or as part the main course at a wedding reception. It’s something we’re familiar with and don’t find objectionable, so sure, I’ll try that pizza if I must…certainly over the “bacon and barbecue sauce” pizza.

As you’re devising your next big marketing plan or struggling to figure out the reason why your last big one was a success or failure, look at the obvious explanations first. Don’t try to impress anyone by using terms like “engagement” or with reams of spreadsheets and stacks of binders. Look for the simplest answer. When you devise a new product or program, ask yourself, “Is anyone REALLY going to do this/buy this?” Get unimpressed with your idea for a second and ask yourself that tough question. If you hesitate, the answer is probably no and it’s time to find a new idea.

So, next time you need to explain why a program worked or didn’t, remember this article and think to yourself: “Maybe the pizza was terrible.”

11 Reasons Why You Need to Get a LIKE (Button)

Dose of Digital Mini White Paper

It’s no mystery that I’m a big fan of enabling sharing on your websites and all of your other content. Let’s get that on the table right now. I’ve recently written about why sharing is a great “baby step” into the social media maelstrom. Our company even worked with ShareThis, one of the leading sharing platforms, to develop new functionality for their sharing tools that allows companies in regulated industries to better control what is shared from their sites.

So, today I want to show you why sharing, specifically sharing on Facebook, is so important and I’ll also show you the best ways to utilize the Facebook sharing tools on your site. They are simple to implement, but there some finer points that will make them work even harder for you. We’ll look at the reasons why you should be doing this, the reasons why you shouldn’t (along with my rebuttal), and finally, things you probably didn’t know (about the Like button). Here goes.

The Reasons Why

In summary:

  1. People expect to be able to share
  2. Exposure to potentially 500 million people (for free)
  3. A new way to connect with potential customers

There’s a good reason why I think you need to enable sharing…actually, there are a few reasons. First and foremost, people expect you to make sharing simple for them. And by simple, I mean including sharing buttons on your site. They shouldn’t have to rely on an extension in their browser or worse, copying and pasting your URL. Sharing buttons are very familiar to people now, they expect them to be there, and they know how to use them. ShareThis, for example, has its buttons placed on more than 900,000 sites, which are seen by 400 million people a month. Sharing is common practice, so get with it.

The next big reason is pretty obvious…exposure. It’s no secret that there are 500 million Facebook users out there (plenty more stats here). And, yes, you have the potential to reach every single one of them…for free. Of course, chances are that your content won’t get shared with everyone on Facebook (in fact I’ll guarantee it won’t), but you don’t need everyone. In fact, here’s a different way to look at it. By adding Facebook sharing tools to your site, it has cost you exactly $0. Even if only one person shares one thing, it’s probably still worth the effort. But likely many more than one will share something and a number of people will see what they share. Cost? Still $0.

But now you’re saying something like, “Yes. That’s wonderful, but I really am not trying to reach a bunch of teenage girls. Isn’t that who’s using Facebook?” I thought we moved past this, but apparently not because I still hear it. Again, your cost is $0 to do what I’m recommending, so it almost doesn’t matter how many of your target audience uses Facebook, but let’s play it out. Let’s focus on age for a second. Did you know that there are currently 18,560,740 women between the ages of 50-64 who live in the United States that use Facebook? Cool stat, eh? Pretty precise too. Well, go and see for yourself. Facebook has a handy tool that’s part of their ad creation platform that lets you target your ads and see how many people you’ll reach. You can find it here. So, enough about that. Your audience is on Facebook.

Finally, by using the Facebook Like button, you’re creating a new way to connect with some of the biggest advocates for your brand and content. Did you know that if someone Likes your page besides showing up on that person’s Wall and in their friends’ News Feeds, that you can publish updates to their Facebook News Feed? You probably didn’t…most people don’t. Good news, I’m going to show you how to do this in a minute. This becomes a way to send messages to people who are likely your biggest advocates. If they shared something of yours once, they might just do it again…and again. “Likers” turn out to be some of the most engaged people on Facebook. A recent study done by Facebook showed the following:

“People who click the Facebook Like button are more engaged, active and connected than the average Facebook user. The average “liker” has 2.4x the amount of friends than that of a typical Facebook user. They are also more interested in exploring content they discover on Facebook — they click on 5.3x more links to external sites than the typical Facebook user.”

And, adding the Like button seems to have a big impact on some sites. Facebook cited the following stats:

“Many publishers are reporting increases in traffic since adding social plugins, including ABC News (+190%), Gawker (+200%), TypePad (+200%), Sporting News (+500%), and  NBA.com (#2 referral source). Publishers have also told us that people on their sites are more engaged and stay longer when their real identity and real friends are driving the experience through social plugins. For example, on NHL.com, Facebook visitors are reading 92% more articles, spending 85% more time on-site, viewing 86% more videos, and generating 36% more visits than visitors other sites.”

I bet you’d like these kinds of numbers.

The Reasons Why Not

In summary:

  1. Regulatory concerns and issues
  2. A lack of shareable content
  3. No expertise to implement or manage

Let me start by saying that I don’t accept any of these reasons, so here’s why.

Okay, I’ll be the first to admit, it’s not all roses with this Facebook sharing. If done incorrectly, it can open you to legal and regulatory issues especially in regulated industries like healthcare and pharma. The simple rule to remember is that the content that you are enabling people to share must be compliant with regulatory rules if you also are providing the means for sharing. That is, if you put the sharing buttons on your site, then make sure what gets shared when someone pushes the button follows the rules. What’s legal depends on the industry, but for pharma, that means that you can’t have together the drug name and the indication (what it does) or any claims of how the product works. If you did, you would need to provide all that “mouse type” fair balance information, which you can’t fit into a piece of shared Facebook content.

With the Like button you can easily control this by using what are called Open Graph tags. These tags are added to the coding of your site and are specific to every piece of content that will have a button associated with it. You can set the title, URL, description, image, and many other parameters all to ensure that you’re in compliance with whatever rules you have to follow. You can download my white paper on sharing tools in regulated industries to read more about Open Graph tags and how they work. It’s in the context of ShareThis, but it’s the same idea for the Facebook Like button (Download here: Digital Alert-Bridge Worldwide-Social Sharing in Regulated Industries [PDF]).

Bottom line, since you can control what of your content is shared, you don’t have to worry about regulatory issues. And, no, you are not responsible for the comments people might add to the content that is shared. In summary:

The next issue you might have is worrying whether or not you have any content that is shareable. This is two different issues in my mind. First, you are correct. Some of the content you have isn’t going to be readily shared or Liked by people. For instance, as I’ve said many times, you’re going to have a problem if you’re asking people to have something like this show up on their Facebook Wall.

However, they might want to share a part of the page or maybe they do want to announce that they really like their erectile dysfunction medication. Don’t judge. In other words, let them decide if it’s shareable or not. Put the button there and let people figure it out for themselves. For the record, Viagra.com has been shared as a Wall post or status update on Facebook 779 times, plus 590 comments have been made on those shares  plus 199 Likes on these posts or updates. Grand total: 1,567.  Bet you didn’t know that one, Pfizer. Stay tuned for where I got those numbers.

You likely do have a lot of content that could be shared. Maybe a compelling video or a really good bit of informative text that educates people about a condition. Perhaps a really solid patient success story. If you look through your site and see nothing that is shareable, then you know your first job. Start making more and better content.

The last of the Why Not objections is all about not having the expertise to implement the Like button. Sure, the full implementation instructions look pretty complicated, but for anyone with even cursory programming knowledge, it’s extremely easy. It’s supposed to be. If you already have added a sharing platform like ShareThis to your site, then you have the capability to add the Like button as well. Your web developer (or you) should be able to do it in minutes. Just remember to add the Open Graph tags if you want to control what is shared. If you don’t, the buttons will still work, but Facebook will pick which content is shared from by using your page data. If you want to see what from a page will be shared, just try out this link.

Things You Probably Didn’t Know

There are quite a few things, so here’s a list of what you’ll find in this section. You can skim through to find the explanation for the particular “did you know” that you’re interested in.

Did you know…

  • …what happens when you press “Like”?
  • …what including a comment with a Like means?
  • …that there is an alternative for the word “Like”?
  • …there are three different types of Like buttons and that you can have multiple Like buttons on one page?
  • …every piece of content that is Liked has a Page on Facebook?
  • …that you can publish to the News Feeds of people who like your content?
  • …that the number shown next to the Like button isn’t actually the number of people who have liked that item?
  • …that you can create a Like button for a Facebook Page (like your brand Fan page) that you can use anywhere?

Okay, let’s get down to business. How do you use the Like button and what can it do for you? For starters, there are actually two different Facebook sharing buttons: Like and Share. Like is newer and is supposed to replace the Share button. They basically serve the same function, but have some slight differences that aren’t critical for the purpose of this post. The differences and how to use them could be a post in of itself, but I’m not going to go into that much detail. Let’s focus on the Like button as a great place to start.

What happens when you “Like” and why comments matter

The Like button allows people to “casually” show their affinity to something at different levels. That is, when you press the Like button on a site, you could simply leave it at that. However, you also have the option to add a comment. Try it out for yourself (this is to Like this post, which you can unlike right away and it won’t show up on Facebook if you don’t really Like this). [NOTE: If you don't see the button, you need to view the post in your browser. Click to do this.]

You’ll notice that after you press the Like button, after a second or so, another box pops up that allows you to leave a comment (or Unlike). Like this:

If someone only presses the Like button and doesn’t leave a comment, what shows up in their feed looks like this:

Chances are that this will go unnoticed if it finds its way into my friends’ New Feeds. However, if I leave a comment (look right next to my name), the content becomes much more prominent:

That will get noticed.

Facebook’s rationale for doing it this way is simple. By just clicking Like and doing nothing more, you’re simply indicating that you like/approve/have some interest in/connect with/enjoy/etc. the bit of content. It’s not really important to you, but of interest for sure, so it doesn’t get much prominence on Facebook. However, if you take the time to leave a comment, then that must mean that you are a bit more passionate about the item, so therefore, the prominence on Facebook matches this.

Pick your favorite button

For the record, there are three different versions of the Like button (click any of them to Like this post).

A few things you should notice. First, yes, you can have multiple Like buttons on a single page. And, yes, you can even have them for different pieces of content. For example, click the Like on this one to Like the Pharma and Healthcare Social Media Wiki.

Don’t like “Like”?

For those paying attention, you notice that in the above example “Like” has been replaced by “Recommend.” This is one of your options with the Like button. You can pick whichever verb works for you. Recommend might be more appropriate for some content (like healthcare), but it is less familar to people, which might make them less likely to click on it. The good news is that you can test it. You can add both or use Recommend one week and Like the following and see which did better. Alternatively, you can add a “ref” attribute to the code for the button so that you can track which works best it in your website analytics program (here’s how). For example, I added unique “ref” attributes to the three different versions of the Like button above to see which will perform the best (I’ll let you know).

The secret pages of Facebook

So, as you can see, you have a lot of different options for the Like button. You know what happens when someone does click it, but you might not know what you can do as the content owner. I mentioned earlier that you can publish updates to the News Feeds of anyone who has like a piece of your content. Theoretically, your update could be about anything and not necessarily about the content they liked. I wouldn’t recommend this. Stick with what the content was about. Perhaps share when you update the page or if you have other related content that these people might like. In other words, don’t abuse it. Here’s how it works:

Every piece of content that has even a single Like also has a page on Facebook. That’s right. There are hundreds of millions of pages out there that correspond to a single piece of content. For example, every blog post on this site has its own page on Facebook. These are created automatically when someone clicks your Like button for the first time. You can add some administrator information to the Open Graph tags for each piece of content with a Like button, so that you can be the admin of these pages in the same way that you admin any other page you create on Facebook.

Bet you didn’t know that. After you have the button installed, the admin needs to Like the page and then you’ll see something new next to the button.

If you click that Admin Page link, then you’ll be taken to the page that was created for the piece of content [click to enlarge].

You’ll notice the message on top:

“This is the administration interface for your webpage at http://www.doseofdigital.com/healthcare-pharma-social-media-wiki/. You can see Insights and publish to the users that have liked your webpage. Only the administrators of the webpage can view this interface, other users are sent to the webpage.”

In other words, no need to panic, this page doesn’t exist to the world. No one can see it except for the admin. Think of it like a backend publishing tool. What this allows me to do is publish an update that appears in the News Feeds of anyone who has Liked this page from my blog. You can see one of the updates I published that explained that I was updating the page soon and looking for more entries for the wiki. It’s completely relevant to the page that people Liked and makes sense as an update. Again, don’t take advantage of this by spamming people.

This works the same as if you published something to your brand’s Facebook Wall. It would also go to the News Feed of anyone who Liked your page (previously known as being a Fan). Whether or not your Fans see it in their feeds is another story (read about it here: “Why Your Facebook Page Doesn’t Exist“).

The Like count dirty little secret

A few more things about the Like button that you probably didn’t know. First, the number you see with the button, isn’t actually the number of people who have Liked that piece of content (even though that’s what it says next to the button). It’s actually a combination of the number of Likes, shares, and comments on those Likes and shares, and Likes of the Likes, shares or comments. In other words, any activity related to that piece of content. It inflates the number of Likes quite a bit. Earlier I mentioned, Viagra.com has been shared as a Wall post or status update on Facebook 779 times, plus 590 comments have been made on those shares  and 199 Likes on these posts or updates. Grand total: 1,567. Keep in mind, Viagra.com has never been “Liked” before since there’s no Like button their site. Of course, anyone could put a Like button for Viagra on their site, which is what this one is (CLICK AT YOUR OWN RISK…I’m not kidding. You will announce to the social media world that you like Viagra.com):

As you can see, the number of people who Like Viagra.com, which actually should be zero (unless some of you clicked this), is far from it because Facebook adds up all those interactions and comes up with 1,567. It makes your numbers look a bit higher than what they really are. How did I figure this out? Well, you can use the Facebook Insights API (if you’re really smart) or you can cheat (like I did) and use this handy tool from Inside Facebook that calculates it all for you.

Like my page too

Like buttons aren’t reserved only for pieces of content. Recent changes to Facebook allow you to create a like button for a Facebook Page (like your brand “Fan” page), which can be used anywhere.

Click away to Like the Dose of Digital Page on Facebook.

All you need is the right code. You can get it here. For the URL, just put in the URL for your Facebook page (in my example: http://www.facebook.com/doseofdigital). Again, your developer should know how to do this, but if you’re stuck, contact me and I’ll try to help you out. Of course, you can also contact me if you’d like our agency, Bridge Worldwide, to do it all for you. It’s what we do.

Now you know everything about making the Like button work for you. You probably really like Like right now, so go ahead and Like it officially:

How One “Viral” Video Can Save Lives


[If you can't see the video above, click here to view it on YouTube.]

I’ve talked about the concept of viral videos in the past, most recently, in an article I wrote for iMedia Connection called, “The world’s worst digital marketing advice.” In fact, one of the pieces of advice to avoid that I had in the article was: “You should make a viral video.” Here’s what I had to say on the issue:

“This is one of my giant pet peeves. Maybe I can stop people from saying this once and for all right now. Here goes: You don’t make a viral video. A video can become viral or “go viral.” But it’s not up to you whether or not a video you create becomes viral; it’s up to us.

A video (or anything else) only becomes viral if people share it with others and those people do the same. There are ways you can increase the likelihood that your content goes viral, which I won’t cover here. However, the No. 1 thing is to make content that’s really good. Be honest: Would you share the video your marketing team just whipped up with your friends? No? Then why should I share it with mine?”

The critical part in here is the idea that you don’t make a viral video, it becomes viral. So, go ahead a make a video, but don’t make it with the expectation that it will become a “viral video.” Sure, do all you can to maximize the number of people who see it and spread the word about it as best you can, but focus on making a good video first. The reason why 99.999999999% of videos never become “viral” is because they are terrible videos. Priority number one if you hope to create a video that becomes viral is to make a good great video. Don’t skip this step.

Last week, my friend Manny Hernandez, founder of  TuDiabetes and the Diabetes Hands Foundation, filled me in on an initiative they have going on for World Diabetes Day (November 14). It’s called “The Big Blue Test.” The idea is simple: encourage people with diabetes to test their blood sugar, exercise, and test it again. People are then encouraged to share their findings with the world. It turns out that many people with diabetes don’t test their blood sugar often enough and even fewer know the positive impact that exercise can have on controlling blood sugar. It’s a great awareness idea supported by a simple concept that can have a profound impact on the health of a lot of people with diabetes. It’s a compliance message wrapped up in an interesting “social” initiative.

Where does the video come in? Well, to spread the word about the test, they created a video that explains the concept. What’s more, for every view of the video up to 100,000, Roche will make a donation to the Diabetes Hands Foundation up to $75,000. They’ll use the money to help the Life For a Child program, run by the International Diabetes Federation, and Insulin For Life. These two global, humanitarian organizations provide diabetes medication and supplies to children in the world’s poorest countries…a great cause to be sure. To give you an idea of how far $75,000 goes, in Ecuador, for example, less than $50 keeps a person needing insulin alive for an entire year (insulin for the program is donated by pharma with the money paying for delivery).

So, why am I sharing this with you?

There are a few reasons actually. First, I’d like to see Roche spend $75,000 and to have that money help save some lives and I know that my readers will help them spend a little of that by watching and sharing the video. Second, this is a strong campaign that we can all learn a little bit from. Here’s what you should be taking note of:

  • A low commitment way to get people involved. If you ask people to do too much, they won’t do it. That’s life. So, asking someone to watch a video isn’t too taxing. Even the challenge to people with diabetes isn’t that big…test, exercise, test, share. Simple.
  • Make a great video. This video is great. It moves fast, looks great (and sounds good too), and it keeps your attention. Remember, it doesn’t need to be a comedy for people to enjoy it.
  • Educate people with a simple message. This campaign could have included page after page and chart after chart showing the impact of exercise on blood sugar. Instead, they go with the ultimate “product demo.” Try it for yourself and see what happens. The idea is simple, easy to understand, and again, not a giant commitment for people, which dramatically increases the likelihood of them doing it.
  • It’s not a product ad. That’s right, it’s an “unbranded” campaign. You have to look around a bit to see that Roche is involved and which products they sell that are related to diabetes. Know this, people who care always know who the good guys (or bad guys) are. You don’t have to shove it into people’s faces. They’re smart. They’ll figure it out.
  • Get the right people to talk about it. That part is clearly working well…you’re reading this now aren’t you? You should know who the people are that can do the talking for you and can spread your message usually much more effectively than you can.

I hope you see some good lessons you can use if you’re looking to do a campaign like this. If you did find this helpful, how about watching the video and spreading the word? If you’re a person with diabetes, I hope you’ll actually do the test on November 14 and share your results. Even if you know the impact of exercise, sharing your findings will help build awareness among those that don’t.

So, you’re homework today…watch a video, share it with others (try the ShareThis button and pick your favorite social site), and help save a life…not too much to ask, right?

Applying Some Sanity to a Regulatory Debate

Okay…today’s post is a bit of a rant, but I think it’ll include some practical, rationale advice that will help you too. As you can tell by the featured image for this post, I find myself out of ideas on how to explain my point in a calm, bullet-pointed way, so I’m going with the rant approach. I’d like to thank a number of you for both adding clarity to my thoughts and for being the very inspiration behind this post (you each know who you are).

What am I so annoyed at?

Conservatism.

Not the political ideology…the approach to marketing and specifically legal and regulatory concerns. To be sure, I’ve been one of the biggest defenders of the legal and regulatory teams at various companies. It’s not an easy job. You’ve got people like me telling you that you’re crazy and bashing their skulls against your walls when you won’t let them do something we we’d like. But at the same time, you save us from ourselves sometimes. As one of my favorite regulatory people once said, “I’m not telling you that you can’t do it, DDMAC [i.e., the FDA] is telling you that you can’t do it.” Substitute your own industry’s watchdog group in that quote if you’d like.

That somehow managed to get me off the ledge a few times and made me redirect my ire to more appropriate targets. However, after working with many, many companies over the past couple of years, I’ve realized one thing: it isn’t always DDMAC after all. Certainly it is sometimes, but other times, perhaps more times, it’s us. We’re not really mad that the FDA is preventing us from doing something, we’re mad that our own company won’t. Again, many of these rules exist to protect the company and make a lot of sense. I get that and I’m not advocating for anarchy, but I am advocating for a bit of common sense (perhaps I should have used a picture of Thomas Paine’s essay instead of the Sanity picture…nah).

The one “rule” that is making me crazy lately deals with the concept and interpretation of “sponsorship.” Allow me to explain what I mean by this. This might be something like when a company pays to have their content included on a website in something like a special information section. WebMD has a number of these. The regulatory challenge is that since the company is paying for the placement of this content, even though they don’t control the site in any other way (e.g., WebMD), the company is, of course, still responsible for the content itself. That is, they can’t include wildly off-label or inaccurate information simply because it’s not on their own website (here’s an example of one of these pages). Got that…makes total sense.

Here’s where I get annoyed…someone along the way has taken this regulation WAY too far. It seems that everything is treated as a “sponsorship” and what is in the control of the company and what it is liable for has been absurdly expanded. It’s no longer just sponsored “sections” or pages, it’s now ads as well. Allow me to demonstrate.

Rather than have a sponsored section on WebMD, you place a banner ad on WebMD. Okay. No problem, right? Wrong.

The new regulatory concern these days is figuring out what page the ad is placed on and what content surrounds it. Similarly, for the sponsored page, what other content, but that is not controlled by the company, is included on the page? The rationale?

Here’s an almost direct quote that I heard last week: “If we placed and paid to have something on the site, then we’re responsible for whatever is around it even if we have no control whatsoever over what’s around it.”

Seriously?

I’ve heard this from five different companies in the past two weeks. It’s a trend.

It’s leading to some behavior I find odd and unnecessary. For example, one company has removed their Facebook page because they were concerned about the ads (that Facebook controls) being placed next to their page’s content. What? The rationale from the legal and regulatory teams is that the company is somehow responsible for the content of those ads and the ads could expand the product’s claims and….

I don’t know what came after that…my ears stopped working, but I think you can fill in the blanks. I understand not wanting to have your ad next to an article bashing your product. That’s another story. That’s not desirable certainly, but it’s also not a violation of any laws.

So, let’s look at this rationally. First, this phenomenon appears to be especially acute on any site that you could remotely categorize as “social media.” That is, the rules seem a bit more lax when we’re not talking about Facebook. Social media always seems to make people panic. This tends to create a few interesting double standards. We’ll come back to that in a minute.

First, I want to share a perfect analogy that explains why all of this is so crazy. It comes from Peter Pitts, a former Associate Commissioner at the FDA and current partner at PR firm, Porter Novelli. I’d encourage you to read his entire commentary found in this white paper, but here’s the part I loved:

“…what does “sponsored mean? Let’s do a brief thought experiment. Consider a televised PGA tour event. When a product logo for an erectile dysfunction medicine appears on the screen and the announcer intones, “This portion of the Masters is sponsored by DRUG NAME HERE,” nobody out there in the viewing audience takes that to mean the “sponsor” has chosen the speed of the greens, the height of the rough or the pairing of golfers in the tournament. But say “sponsored” on a social media site and watch the sparks fly at internal regulatory review.”

Question for all of you: does that one simple statement make all of this debate about what you are responsible for seem a bit ridiculous all of a sudden? It did for me. It points out a perfectly created double standard that keeps social media as a pariah and “traditional” channels on the whitelist. Allow me to elaborate.

First, from Peter’s analogy, it’s okay if we “sponsor” a sporting event (or Race for the Cure or a NASCAR) and it doesn’t matter what appears next to our sponsorship. We don’t control, as Peter said, the pairings of golfers. Everyone’s fine with that. No one would assume otherwise because assuming otherwise would be insane.

But there’s more…

We don’t worry about what commercial follows ours on TV or what the news story leads into our commercial during the evening news.

We don’t care what ads appear above or below ours or what results appear on the same page as our paid Google AdWords.

We don’t think about what billboard is next to ours or what buildings it is near.

We don’t agonize over which stories are printed next to our ads in a magazine.

We don’t fret about which ads show up next to (or as a pre-roll to) our YouTube videos or channels. For example, here’s one of J&J’s videos (see red boxes):

I didn’t even bother highlighting the “Promoted Video” right under AOL’s ad.

So, how come regulatory and legal folks seem to be fine when we’re talking about TV, billboards, print, YouTube, Google, and yet worry about Facebook and some other places?

The FDA has never (read that last word again) told anyone that they are responsible for content they don’t control. So, if you place an ad or sponsor a section of a website, you should only need to worry about what you can control. You can control the content of what you give to the website to publish. That’s it. Of course, if you actually control more than that, then you’ve got a different issue. But you don’t control what ads show up next to your page on Facebook, so you’re not responsible for worrying about whether or not they cause your content to be in violation (side note: Facebook can actually turn off those ads in some cases, contact me if you need help).

Some of you might be saying that there’s a distinction between placing an ad (like a banner) and having a sponsored section. No way. You create the content for both and you dictate where each appears. For the sponsored section, you know where it’s going to go on the third party site (e.g., where on WebMD). For banner ads, you should know every single place where they show up. If not, talk with your media buying agency and get that info from them now. In each case, you created the content and helped decide on the placement. What you don’t get to decide is everything else that appears around it. Not the search results next to your Google AdWords, not the billboard under yours, not the TV commercial that follows your…none of these. Since you don’t control this why do you feel responsible? Why do you think that the FDA is going to come down on you? Show me one example and I’ll leave you alone.

We call these “ghost rules” around our office and they only do one thing really well: kill good thinking and innovation.

Rant over…thanks.

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