Recall that back in April, 2009, the FDA sent 14 "warning" -- actually notice of violation or NOV -- letters to major pharmaceutical companies citing as violative several short Google Adwords such as this Pfizer sponsored Adword for CADUET (find the screen shot of this as archived by FDA here and the letter FDA sent to Pfizer here):
I called such ads "bAdWords" way back in November, 2006 -- 3 and one-half years BEFORE FDA caught on (see "Lunesta, Google, and 'bAdWords'").
Last week (August 31, 2011), DDMAC sent ANOTHER letter to Pfizer about some Google-style violative "AdWords" it found in the “Online Resources” webpage of the Pfizer, Inc. (Pfizer) website for LIPITOR. One of the ads was for -- wait for it -- CADUET! THAT ad looked like this:
Either Pfizer's legal/regulatory team has NO organizational memory, or it tried to pull a fast one on FDA.
It should be noted that FDA itself did not catch this. It was submitted to FDA's "Bad Ad" program; a name no doubt inspired by my "bAdword" blog post mentioned above. And it was probably one of those other 14 companies that received letters from the FDA in 2009 that ratted on Pfizer (see "Majority of Bad Ad Complaints Submitted by Pharma 'Representatives' Deemed Worthy of 'Comprehensive Review' by FDA").