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Calm Down. The FDA is Not Trying to Regulate Facebook

Over the past few days, several articles have popped up with the alarming headline that the FDA is now issuing warning letters due to brands use of Facebook’s ‘Like’ function. You can read one of the takes on it here, in Scott Gotleib’s Forbes article “FDA Wants to Regulate Drug Firms on the Internet and It’s Targeting Facebook ‘Likes’.

The problem with this article, and with so many of the others I’ve read, is that the ‘Like’ function wasn’t the reason that the FDA issued the letter. Mr. Gotleib actually describes the issue, but ignores it.

He writes, “In its latest Warning Letter, FDA cited a multitude of serious violations against the marketer of a drug product called Poly-MVA. The company had sold its product through the use of testimonials that were not substantiated by good science, according to FDA. One seemingly blatant abuse, still found on the company’s website when Gaffney checked, was a testimonial from a “Mr. Doug Wray,” whose improper endorsement suggests that by taking Poly-MVA, he was cured of his multiple myeloma. In the Warning Letter, FDA also made a novel mention of the company’s Facebook “Like” of one of these exaggerated testimonials. Until now, it was never clear whether FDA would treat a “Like” (or a re-tweet for that matter) as an endorsement of the underlying content. That question seems to have been answered.”

The problem, from FDA’s perspective, was not the ‘Like’ button. It was the exaggerated claims and unsubstantiated testimonials. The FDA will ALWAYS flag those. Yes, Facebook was the medium some of these claims were issued, but Poly-MVA would have gotten that warning letter if they had pushed these claims in print, radio or whatever.

In pharma, the use of social media is a hot button issue, which brands are mostly terrified of using. I would hope that as industry observers cover issues like this one, they would more accurately describe situation and circumstances, rather than publishing mis-leading headlines that are alarmist and inaccurate.

The FDA isn’t sanctioning Facebook, it’s sanctioning false claims. So all you social media nay-sayers and alarmists out there, please calm down.

Are Meta Tags a Regulatory Time Bomb?

Your branded pharma site is non-compliant. Yes, yours.

Paying attention yet?

As pharma marketers, we operate in a world governed by strict rules. As digital pharma marketers, those strict rules can often be ambiguous, poorly-defined, or simply absent, requiring us to interpret vague requirements and/or extrapolate from other (presumably) relevant precedents. (Yeah, I know, it’s almost exactly like having a girlfriend.)

Which brings me back to your

What’s to worry about, you say? Everything’s ship-shape, buttoned-up, right? On-label messaging, appropriate fair balance, all content submitted and approved by the FDA. Looks like everyone else’s.

Well, perhaps there is one aspect of your branded product site that you’ve overlooked. One that is routinely ignored as it seems so tucked away and safe from scrutiny. But one that is on the FDA’s radar and which might be the source of some serious compliance headaches one day soon. Could it be that deep down within the HTML code of your website there exists a regulatory time bomb?

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Second Screen Marketing

You’ve heard of the big screen, many watch the small screen, but what is all of this discussion around the second screen? The second screen refers to act of using a laptop, tablet, or smartphone while watching television. We all do it, whether it’s that last email for work, or posting a status message to Facebook. It’s the easiest form of multi-tasking and devices like smartphones and tablets make it even easier to do while watching your favorite program.

In many cases, the second screen experience is a social one: Using Twitter or Facebook to live comment or discuss TV happenings using social media tools. More practically, the second screen in our hands extends the passive experience of TV watching into an interactive one once a viewer is exposed to tv content that interests them and sends them online to learn more.

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The Value of Responsive Design

First let’s start with a simple definition of what responsive design actually is. Without getting too technical, responsive design is a relatively new way of planning, designing, and developing a website so it automatically fits to the screen size of any media device. Whether for a laptop, cellphone, or tablet, responsive design will automatically adjust how the content, images, and/or videos on a webpage are displayed so the site is easily maneuverable.
No more screaming obscenities on the bus while pinching and swiping just to find the number for late-night pizza because the page won’t fit on your mobile screen!

The Good

Ordinarily, a website can take anywhere from 2 to 3 months to build. In the pharmaceutical industry, with all of its lovely regulatory processes, it can take ages. And according to the numbers, (an expected 657 million smart phones will be sold just in 2012) millions of people are browsing the Interwebs on the their mobile phones, which means as soon as your website has its basic design down, you have to start right back up and begin working on a mobile site in order to stay competitive in the digital world.

With responsive design, the website is built only once and is viewable on any digital gizmo you can get your hands on.

The Bad (but not really)

Before you get too excited and post comments about how wonderful this all sounds, be aware: Responsive design requires more upfront work than just building a website designed for a laptop or desktop. Usability experts (aka UXers, or Mind Mappers) have to spend additional time drawing out the different dimensions of each webpage before the designers and developers get their hands on the goods. Ideally, UXers, designers, and developers should all be working together during the construction of a responsive design project so at every turn, one team member can point out whether or not the proposed design or action is feasible.

However, this also presents the opportunity to create a more functional (and, in turn, profitable) website. With this methodical development style, more work is done upfront between all types of website engineers, creating the possibility for increased collective ingenuity.


Along with the potential to save time, there’s also the possibility of saving money with responsive design. If you plan on building a website and a mobile website, it may be in your best interest financially to consider building the website using responsive design. Instead of designing and developing two sites, you’re only creating one site. Instead of maintaining and hosting two sites (more costly than some might think), developers only have to manage/update one site.

Always build in Responsive Design?

Not necessarily. Some websites are specifically designed for desktop/tablet/laptop viewing only, as they should be. Take for instance the NIKEiD website. Amazing site but the mobile site has a completely different interface. The smaller mobile screen forces developers to organize all of the website functionality in finger-happy grids thus; granting easy access to mobile users who need answers on the go. The same can be said for the Priceline website. The mobile version is vastly different from the original version because the real estate on a mobile screen does not allow for calendars, apps, or advertisements.

Responsive design is a great, efficient way to increase the marketability of a website. In the healthcare industry with so many competing brands combined with the increased accessibility to the Web through multiple devices, responsive design is an innovative technique to design and develop websites that increase interaction among users that gives an edge up on the competition.