Google Pharmacy Phish

Google Pharmacy Phish

I received an e-mail today announcing the launch of "Google Pharmacy" that promised it will "improve the Google experience for people buying pills and using pharmaceutical interfaces." It included a nifty-looking Google logo that replaced the "oo" with two pills (Viagra and Cialis):

Of course, this is a "phishing" expedition - "a way of attempting to acquire information such as usernames, passwords, and credit card details by masquerading as a trustworthy entity in an electronic communication" (wikipedia).

1. I haven't clicked on the link "Visit Google's Accredited Pharmacy" although I was tempted to do it because of my interest in Google's past misdeeds that involve collusion with "rogue" pharmacies (see "Google Settles with DOJ - Admits Aiding Illegal Online Drug Sales") and 


2. Google's failed attempts to co-opt the pharmaceutical/health sector (see "Google Health is Being Shut Down").

Actually, perhaps Google should actually launch an accredited pharmacy site where people can LEGALLY purchase Rx drugs online! That might help buff up it's tarnished promise to "do no evil."

Did FDA Entrap Google with Those 14 NOV Letters?

Did FDA Entrap Google with Those 14 NOV Letters?

Con Artist Reveals All About Google Drug Ad Sting - How FDA May Have Entrapped Google Using Those 14 "Infamous" Notice of Violation Letters

In an interesting article in today's Wall Street Journal, a convicted con artist details how he was employed by federal agents -- including agents of the FDA's Office of Criminal Investigation -- to lead a sting operation against Google's illegal drug ad operation (see story here). Recall that last summer Google agreed to pay $500 million to settle DOJ charges that it helped illegal online pharmacies target ads through its AdWords platform. It was one of the largest forfeitures ever paid in the U.S. (see "Google Settles with DOJ - Admits Aiding Illegal Online Drug Sales").

"It was very obvious to Google that my website was not a licensed pharmacy," said David Whitaker, the prisoner who acted in the sting. "There was a part of me that felt bad," Mr. Whitaker wrote in his account of the undercover operation viewed by The Wall Street Journal. "I had grown to like these people." But, he said, "I took ease in knowing they.. knew it was wrong."

What is of interest to me is the timeline revealed in the WSJ article. I added a couple of events to this timeline shown below (click on the image to enlarge it for better readability).

Mr. Whitaker made first contact with Google in March 2009. On April 2, 2009, FDA made public those "infamous" 14 notice of violation (NOV) letters that effectively shut down Rx drug search advertising on Google. In October 2009, comScore data was released that documented this "prompt, precipitous, and prolonged" drop in paid search advertising (see the chart here).

At the time of the announcement of the Google settlement, I suggested that because of FDA's involvement in the case, the agency delayed issuing guidance relating to the proper use of Google Adwords for branded Rx advertising. I suggested that the FDA did this to force Google to the bargaining table and to ultimately accept the draconian settlement terms mentioned above. In other words, FDA was holding Google's pharma Adword business "hostage" until a settlement was reached. See my argument here.

Looking at the above timeline, however, I now believe the 14 letters were sent so that Google might be more easily persuaded to run illegal drug ads to make up for the revenue lost from legitimate Rx drug ads. If true, this looks like a form of entrapment.

Keep in mind that the type of ads targeted in those 14 letters had been running for many years and that I, for one, maintained they were illegal starting way back in 2006 (see The "Girl from Google"). At the time, I submitted a written complaint to the FDA. Why did the FDA wait almost 3 years before getting around to stopping these ads? The answer, I believe, is what I surmised above -- it was simply a ploy to incentivize greedy Google ad executives to fall for the sting. According to the WSJ article, Google's ad executives "worked with Mr. Whitaker to find a way around Google rules."

P.S. Google may have tried an "end run" around the entrapment by coming up with a new ad format for Rx drugs that addressed the issue cited in the 14 FDA letters. This format was announced at the November, 2009, public hearings (see "Is Google the New FDA?"). The ad was actually "beta" tested by Bayer, but to date the FDA still has not formally approved the format and not many other drug companies have used it.

Google to Shutter Sidewiki on December 5, A Day That Will Live Famously!

Google to Shutter Sidewiki on December 5, A Day That Will Live Famously!

Yesterday, Google sent out an email (see here) informing users of its sidewiki service that it will close the service on December 5. Sidewiki allows users to post and read comments linked to specific web pages. It was launched in September, 2009, and I was one of the first people to use sidewiki to attach comments to a drug.com website (see "Google's Wacky Wiki is Whack! Pharma Should Demand Ability to Block It!").

In my presentation at the November, 2009, public hearing at FDA regarding Promotion of FDA‐Regulated Medical Products Using the Internet and Social Media Tools, I famously called on Google to "tear down this Sidewiki" (it was the anniversary of the fall of the Berlin Wall; see transcript).

Google spent a lot of effort defending sidewiki in comments it submitted to the FDA after the November hearings, saysing "The service uses an algorithm to identify the best comments, based in part on user ratings, and seeks to display only comments that are judged to be of high quality."

I said it before (see here) and I'll say it again: Google... what a maroon!

DDMAC's Bad Ad Program Catches Pfizer Using Google Style "bAdWords" on Lipitor Web Site

DDMAC's Bad Ad Program Catches Pfizer Using Google Style "bAdWords" on Lipitor Web Site

This is rich!

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:

The CADUET link ad above is practically IDENTICAL to the sponsored Google ad, which FDA warned Pfizer about more than 2 years ago!

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").

[This post originally appeared in Pharma Marketing Blog. 

Make sure you are reading the source to get the latest comments.]

Google's Settlement with Justice Department Paves Way for FDA Social Media Guidelines

Google's Settlement with Justice Department Paves Way for FDA Social Media Guidelines

Google has agreed to pay $500 million to settle DOJ charges. In the settlement, Google acknowledged that it helped illegal online pharmacies target ads through its AdWords platform. It was one of the largest forfeitures ever paid in the U.S. (see "Google Settles with DOJ - Admits Aiding Illegal Online Drug Sales").

This will help the pharmaceutical industry and FDA in their long-standing battle against US citizens buying drugs online from Canadian pharmacies.

It will also pave the way for the FDA to release long-awaited guidelines for the use of Google Adwords and other "space-limited" online applications (eg, Twitter) by the pharmaceutical industry for branded drug promotions.

I pointed out previously (see here) that as part of the DOJ criminal investigation, undercover agents for the Food and Drug Administration contacted Google posing as representatives from rogue Internet pharmacies.

I suggested that because of FDA's involvement in this case, the agency delayed issuing guidance relating to the proper use of Google Adwords for branded Rx advertising. FDA did this -- IMHO -- to force Google to the bargaining table and to ultimate accept the draconian terms mentioned above. In other words, FDA was holding Google's pharma Adword business "hostage" until a settlement was reached.

Recall that the brouhaha with Adwords as far as pharma marketers were concerned all started with FDA issuing those 14 warning letters in April 2009. These letters were all about Google's Adwords. I had also pointed out long ago that Google was aiding and abetting illegal pharma Adwords by suggesting exactly the format that the FDA later found violative (see "That Girl from Google").

Now that Google settled, FDA should be willing to give back to the search engine giant its pharma Adword business, which was substantial prior to the 14 letters.

P.S. Back in April 2009, shortly after the FDA sent out the 14 letters, I asked this question: "WHY DID IT TAKE THE FDA THIS LONG TO GO AFTER VIOLATIVE ADWORDS WHEN I WARNED THEM ABOUT THIS AS FAR BACK AS 2006?" (see here).

At that time, I thought it had something to do with the new administration in Washington, DC. But I learn now from the DOJ press release (here) that "In 2009, after Google became aware of the investigation by the Rhode Island U.S. Attorney’s Office and the FDA/OCI Rhode Island Task Force of its advertising practices in the online pharmacy area, and as a result of that investigation, Google took a number of steps to prevent the unlawful sale of prescription drugs by online pharmacies to U.S. consumers."

Maybe the release of the 14 letters was the incentive Google needed to "take a number of steps."

URL Shorteners: Tech "Glitches", Censorship, and Loss of Credibility

URL Shorteners: Tech "Glitches", Censorship, and Loss of Credibility

Now that I regularly use Twitter as part of my business (eg, see "Social Media Enable Your E-Mail Ad Blasts") I depend on URL shorteners to guide my @pharmaguy Twitter followers to more detailed information and messages on my blog and Web sites. Not only are URL shorteners good for conserving space in tweets, they also allow me to collect metrics such as clicks and referrers.

There are several URL shortening services I use regularly: bit.ly and Google.

Lately, I've been having problems with Google URL shortener. A few shortened URLs do not work and I get this error message:

This URL is supposed to link to the blog post "FDA, DOJ, & Google: Conspiracy Theory, Part 2", which you can find here (no URL shortener used).

My conspiracy short hairs immediately rose up upon seeing this error message (and others that referred to links to similar blog posts) and I tweeted that Google was censoring me. My Twitter friend @richmeyer posted this response: "Spoke to friend at Google you are not being censored they are having some issues."

I wish I had a friend at Google I could call, but I don't.

Google, however, makes it EXTREMELY easy for any anonymous person to report URLs as spam -- there's a "report spam button" on the bottom of the URL shortener page that links to a URL Shortener Spam Report form. Luckily, there is an option on that form for me to make a case that this URL is "Incorrectly marked as spam, please re-enable the short URL."

Meanwhile, while my report may or may not get reviewed by Google, everyone who clicks on my tweet containing the shortened URL will see that error message accusing me of being a spammer, security risk, or trafficker in illegal information! In other words, my credibility is taking a hit. Thank you Google!

UPDATE (14 July 2011): I was able to tell Google that the shortened URL in question (goo.gl/2givz) was NOT spam. To do this I had to click on the "Report Spam" link on the bottom of the URL shortener page -- oddly there was no "Dispute Spam" link. The Report Spam form had a "Incorrectly marked as spam, please re-enable the short URL." option, which I enabled.

BTW, I never received any communications from Google about the initial problem nor about the fix.

Tracking Public Health Trends: Twitter vs Google vs Your Nose

Tracking Public Health Trends: Twitter vs Google vs Your Nose

While my son was away at school this spring, I asked him how he was doing. "OK dad," he said, "but I have this cough the last few days." I didn't have to search Google or call our physician or tweet about it to learn what may be the underlying problem. I only had to use my nose to know it was allergy season. Given my son's history, I surmised that was the root cause of his problem.

But public health officials cannot depend upon their noses to make important decisions. They need actionable real time data. How do they get it?

The Centers for Disease Control (CDC) offers the most dependable disease surveillance data. The system depends on reports from partners in state, local, and territorial health departments, public health and clinical laboratories, vital statistics offices, healthcare providers, clinics, and emergency departments. I imagine a lot of paperwork and time are involved.

Some time ago, Google decided that search trends can be used to track diseases such as influenza. It published results of a study of its data in a white paper: "Detecting influenza epidemics using search engine query data" (find it here). They found a strong correlation between search data and CDC data as shown in the chart below:

Now, researchers at the Johns Hopkins Center for Language and Speech Processing have analyzed 2 billion public tweets posted between May 2009 and October 2010 to learn if it is possible to use Twitter to track important public health trends (see "Analyzing Twitter for Public Health").

The researchers point out the differences between search and Twitter (or other social media) with regard to the intent of the user. "In web search," says Mark Dredze (one of the researchers; see a video of his presentation of results here), "the user expresses a need for information. Whereas in social media, people actually say something about themselves." In that sense, it's easier to conclude that the Twitter poster actually has the flu, whereas the searcher may or may not.

Another advantage of Twitter is that people disclose a lot of information about themselves that can add value to the public health data. This includes information about the drugs they may be taking. That information, of course, is of interest to pharmaceutical companies.

Here are the results from the Johns Hopkins study, which analyzed 1.5 million messages (out of 2 billion total collected) that referred to health matters:

Pharmaceutical companies -- and the FDA (see "FDA is Monitoring This Blog and Perhaps You Too!") -- are already mining social media to learn what the public is saying about them, their products, and their competitors' products (see "Are J&J Agents Trolling for Adverse Events on the Internet?"). But I suspect the technology they are using is relatively primitive compared to that used by the Johns Hopkins researchers.

Alex Butler posed a question during yesterday's #hcsmeu chat: "Have we been concentrating too much on SM as pure communication and not enough on impact of 'big data' to revolutionise health care?" This lead to a lively discussion on the value of "crowdsourcing" to somehow change healthcare. For more on that topic, see "Data Mining in the Deep, Dark Social Networks of Patients."

I can see the value of social media to do surveillance as was done in the studies mentioned above. Such surveillance certainly helps public health officials deal with certain diseases and other health issues (ie, obesity). But it doesn't change the fundamental problem of health care, which is the cost burden. To truly "revolutionise" healthcare -- IMHO -- you have to lower costs and make even rudimentary health care affordable for EVERYONE. But that's a matter for another post!

[This post originally appeared in Pharma Marketing Blog. 

Make sure you are reading the source to get the latest comments.]

FDA, DOJ, & Google: Conspiracy Theory, Part 2

FDA, DOJ, & Google: Conspiracy Theory, Part 2

Last week, I suggested that the FDA’s infamous 14 warning letters sent to major pharma companies regarding violative search engine ads may have been a "shot across Googles bow," intended to force Google to halt its acceptance of ads from "illegal" online pharmacies (see "How FDA, in Cahoots with DOJ, Brought Google Down").

Many people did not take my "conspiracy theory" seriously. Some pooh-poohed my suggestion that the FDA was involved. One commenter to my blog said "OMG... what a stretch...I'm sure they are laughing at you at FDA."

It turns out that the FDA WAS INVOLVED in the criminal investigation of Google by the Department of Justice (DOJ).

Today, the Wall Street Journal reports that "as part of the criminal investigation, undercover agents for the Food and Drug Administration contacted Google posing as representatives from rogue Internet pharmacies" (my emphasis; see "Google Was Warned Repeatedly About Illegal Drug Ads").

Even if the FDA was involved, my "conspiracy theory" would not hold water UNLESS the investigation of Google preceded the issuance of FDA's warning letters at the end of March, 2009.

In my previous post, I couldn't cite specific evidence that the investigation went back prior to 2009, but now the WSj article confirms this to be true.

The period 2008-2009 saw a lot of activity related to this investigation, according to documents reviewed by the WSJ. Here are some key actions during that period reported by the WSJ:

"In July 2008, the National Center on Addiction and Substance Abuse at Columbia University (CASA) wrote to Eric Schmidt, then Google's chief executive, saying it found 'prominent displays of ads for rogue Internet pharmacies' in a Google search for controlled drugs."

In December, 2008, the National Association of Boards of Pharmacy, or NABP, a group representing state regulators in the U.S. and Canada, wrote letters to Google "warning about advertising from online drug outlets that weren't verified by a NABP screening program. The organization was 'deeply concerned that these rogue Internet sites could be a front for criminals seeking to introduce adulterated medications, counterfeit drugs, or worse, to the American market,' wrote Mary Dickson, the NABP's associate executive director. The NABP says Google didn't respond."

Google DIDN'T RESPOND?! That suggests it needed convincing. What better way to get google to respond than by sending out 14 warning letters to its BEST clients, effectively shutting down Google's legitimate drug ad revenue? (read more about this in my previous post).

"'On the basis of our analysis, I think they were turning a blind-eye,' said Bryan Liang, a California Western School of Law professor who published a 2009 report that found Google and others were profiting from online ads paid for by illegal drug sellers. 'They were making a lot of money on this.'"

"In 2009, LegitScript LLC, which monitors online drug sellers, published reports alleging that 80% and 90% of Yahoo and Microsoft's respective online drug advertisers were breaking the law."

"John Horton, who runs LegitScript, said his company also conducted in 2009 an unpublished review of Google's ads and found the same level of problems. LegitScript is now employed by Google to help identify problem sites, he said."

"PharmacyChecker [the third-party company that Google hired to verify that online pharmacy advertisers were legal] said it received a subpoena from the FDA in 2009 to produce all its communications with Google regarding pharmacy verification policies."

It is clear that the FDA and DOJ were investigating Google long before the FDA sent those March, 2009, letters.

Some of the reports and activities described above happened AFTER FDA sent the letters  (eg, the LegitScript report was published in August, 2009; see here). No doubt these reports were published due to the light the FDA letters shone on Google's drug ad policies. IMHO, the letters not only impacted Google's revenue, they also elicited further data from third-parties to bolster the DOJ's case against Google.

How FDA, in Cahoots with DOJ, Brought Google Down

How FDA, in Cahoots with DOJ, Brought Google Down

FDA’s Infamous 14 Warning Letters were a Ploy to Force Google into a $500M DOJ Settlement Regarding Illegal Online Pharmacy Ads

“…something is happening here and you don't know what it is, do you, Mr. Jones?”

That’s how I’m feeling today as I try to understand what’s really behind the news about Google’s advertising policies, online pharmacies, and FDA’s 2009 warning letters to major pharmaceutical companies. If my thinking is correct, drug industry search engine ads were “collateral damage” in a war between Google and the FDA.

Yesterday, the Wall Street Journal reported that Google is “close to settling a U.S. criminal investigation into allegations it made hundreds of millions of dollars by accepting ads from online pharmacies that break U.S. laws” (see “Google Accepted Ads from Illegal Online Drug Stores”).

Not so coincidentally, a few days ago, Google disclosed that it was setting aside $500 million to potentially resolve a case with the Justice Department (DOJ) that involved "the use of Google advertising by certain advertisers."

“The investigation has examined whether Google knowingly accepted ads from online pharmacies, based in Canada and elsewhere, that violated U.S. laws,” said the WSJ article.

The FDA has long struggled to rein in American’s penchant for buying drugs from online Canadian pharmacies and this investigation of Google by DOJ is likely part of that effort. But, as I surmise below, caught up in the case may have been legitimate major pharmaceutical companies as well.

Consider FDA’s infamous 14 warning letters that the agency mysteriously sent in a single day in March, 2009, to major pharmaceutical companies about Google Rx Adwords, saying the ads were misleading because they didn't include risk information (see “FDA Warns Drug Firms Over Internet Ads”).

Could that have been a “ploy” to bring Google to its knees and cave in regarding online pharmacy ads?

In other words, the FDA’s warning letters may have been a “shot across Google’s bow,” intended to force Google to halt its acceptance of ads from “illegal” online pharmacies. FDA could have been saying, “What’s more important to you? Ads from online pharmacies or ads from major pharmaceutical companies?”

FDA’s actions were a strong incentive because "sponsored link exposures to U.S. Internet users declined more than 50 percent immediately after ... FDA warning letters were issued to pharmaceutical manufacturers," according to a comScore study (see “FDA Letters Caused a Prompt, Precipitous, & Prolonged Drop in Pharma Paid Search Engine Advertising”).

It’s likely that this case goes way back because in September 2010, Google disclosed that it had filed a lawsuit against “advertisers we believe have deliberately broken our rules,” in particular involving “rogue online pharmacies” that “illegally sell drugs on the Web” (see “Google’s $500M Charge Related To Pharma Advertising Probe”).

In June 2010, I reported that Google launched a NEW Rx drug ad format that includes everything FDA requires that a drug company include in its direct-to-consumer advertising: fair balance, and direct links to side effects, precautions, dietary information, etc. (see “Finally, A Google Drug Search Ad Format That Has All FDA Could Want... But Pharma Can't Use It!”). The “ads” are really more like public service announcements. They come from National Institutes of Health (NIH) and compete with paid ads from pharmaceutical companies who cannot use the new format (see “Google's New OneBox Rx ‘Ads’ Steal Clicks from Organic Branded Rx Search Results”).

To compensate for that deficiency, Google also has come up with a new ad format for the industry (see “Is Google the New FDA?”).

All of these actions by Google could be designed to appease FDA and DOJ and regain the drug industry’s ad revenue lost as a result of FDA’s warning letters way back in 2009.

You have many contacts among the regulators
to get you facts when someone attacks your advertising
but nobody has any respect, anyway they already expect
you to all give a check to FDA and other organizations
Ah you've been with the professors and they've all liked your looks
With great lawyers you have discussed clicks and sidewikis
You've been through all of Ayn Rand’s books
You're very well read, it's well known
But something is happening here and you don't know what it is
do you, Mr. Pharma?

Google's New OneBox Rx "Ads" Steal Clicks from Organic Branded Rx Search Results

Google's New OneBox Rx "Ads" Steal Clicks from Organic Branded Rx Search Results

At last week's ePharma Summit, John Mangano, comScore's Marketing Solutions Vice President, presented data suggesting that Google's OneBox NIH Rx ads "effectively reduces organic search visitation driven to pharma sites pushing the traffic to NIH content instead" (see chart below).

To illustrate the OneBox format, I did a search on Lipitor and the result is shown below (click on image for an enlarged view):

Just below the paid Lipitor ad at the top is the NIH OneBox "ad," which is not really an ad because it is not a paid placement. But I'll just call it an ad because it looks like one and perhaps Google users may think it's an ad.

When the OneBox "ad" format was introduced in June, I asked "Will these NIH ads compete with drug company's paid search drug ads, not to mention natural search results? Or can the two work in concert to increase the clickthrough rate on the paid ads?" (see "Finally, A Google Drug Search Ad Format That Has All FDA Could Want... But Pharma Can't Use It!").

Mangano did not mention any effect that OneBox Rx ads may have on paid search Rx ads. But it is logical to conclude that Google stands to gain paid ad revenue when pharma marketers have to compete with OneBox ads by buying more paid search placements to make up for the loss of organic search visits.

Finally, A Google Drug Search Ad Format That Has All FDA Could Want... But Pharma Can't Use It!

Finally, A Google Drug Search Ad Format That Has All FDA Could Want... But Pharma Can't Use It!

Google just launched a NEW Rx drug ad format that includes everything FDA requires that a drug company include in its direct-to-consumer advertising: fair balance, and direct links to side effects, precautions, dietary information, etc. It even includes a logo that identifies it as a special ad sanctioned by a trusted authority! Unfortunately, the new format is only for the National Institutes of Health (NIH) and NOT available to pharmaceutical advertisers.

Below is the result shown on Google after a search on "Lipitor" (click on image for an enlarged view):

At the very top is the typical AdWord that Pfizer paid for. It's puny and uninformative and does not mention what medical condition Lipitor is approved for. Just below it is the NIH ad, which has all the required and interesting information. It even includes a little colorful pill that draws your attention to the ad and marks it as special. When you click on the NIH ad [actually, it's not technically an ad, but a natural search result that ALWAYS appears at the top of the natural search results; in that sense it's an UNPAID ad]. although not a paid ad] you are taken to a page on the NIH site set up especially for atorvastatin, the active ingredient in Lipitor.

This new drug ad format is the latest initiative of Google Health, which last year launched "Health OneBox" that offered easy-to-read details on illnesses and conditions with a single search.

Will these NIH ads compete with drug company's paid search drug ads, not to mention natural search results? Or can the two work in concert to increase the clickthrough rate on the paid ads?

Either way, Google stands to increase revenue from pharma paid ads. The NIH ads are just another instance of pharma losing share of voice on search engines. They must counteract that with even more advertising. Hopefully, Google's new ad format specifically designed for pharma (see here) will win FDA approval. That format can compete more effectively with the NIH ads. Not that there's anything wrong with the NIH ads!

Should Google Allow Pharma an Exception to Its Ban on Redirect URLs? (UPDATED)

Should Google Allow Pharma an Exception to Its Ban on Redirect URLs? (UPDATED)

Back in April 2009, I suggested that FDA might go after pharma marketers for using paid search redirects in Google Adwords (see "The Next FDA Concern May be the Use of 'Redirect' URLs"). Such ads use visible URLs such as "flaccidmember.com" but, when clicked, lead to viagra.com or cialis.com. Such an is considered to be "unbranded" and beyond FDA regulation. That is, it can say "Stay harder longer with this treatment for erectile dysfuntion" and lead directly to the branded website.

The problem with that strategy is that Google's Adword policy forbids the use of redirect URLs -- for most advertisers. It appears that Google was making an exception for the pharmaceutical industry (see "Redirect URLs in Adwords: Who Knew What When?").

Last week I thought Google may have rescinded this exception. Tyler Ransburgh of What's Your Digital IQ Blog wrote about his problem using a redirect URL in a pharma ad. "I work in pharma," said Tyler, "I have an exception to the rule. Right? Well, I reached out to Google to get an answer on why I am getting caught in this web" (see "Google blocks Pharma paid search redirects")

When Tyler did reach out to Google, here's the reply he got:

"In response to advertiser and user feedback, and in an effort to provide relevant results and a high quality experience for our users, we have made the decision to no longer allow certain exceptions to our display URL policy. Please note that this amendment to our policy applies to all advertisers, regardless of previous exceptions for, or acceptance of, any campaigns. To provide a quality experience for our users and partners, the display URL policy will be strictly enforced."

I'd like to think that my blog posts were part of the "feedback" that Google considered.

Since then we've gotten some feedback indicating that Google has NOT changed its policy regarding pharma's use of URL redirects in Adwords. See this Pharma and SEM Marketing Blog post by SEM Dave Anderson who indirectly received this comment from Google: "Our policy has not changed: pharmaceutical manufacturers continue to have an exception to allow a URL redirect, which is not currently recognized by our automated system." Which seems to directly contradict the comment received by Tyler Ransburgh from a Google Adword support team person who advised Tyler to "be assured that you have reached the appropriate AdWords support team for your AdWords related concern and I’ll be unable to escalate your issue further." Tyler, you see, had asked to speak to this person's supervisor and was rebuffed!

I also received an email from Aaron Stein, someone who claims to be part of Google's PR department. I present the full email message:

Hi John,

This is Aaron Stein from Google PR. I noticed your post this morning and wanted to reach out to you because it is not accurate. If you do a search for cholesterol you'll see that our policy has not changed. I've attached a screenshot to show this as well.

If you wouldn't mind, can you add a correction to your post with the statement below? Happy to chat further about this.

"Our policy has not changed: pharmaceutical manufacturers continue to have an exception to allow a URL redirect, which is not currently recognized by our automated system. All pharmaceutical manufacturers' search ads campaigns continue to run, unchanged, today."

Thanks John, I'll be in touch.

Aaron Stein
Google | Global Communications & Public Affairs

The question, however, is Should Pharma Advertisers Use Redirect URLs in Search Engine Ads? I ask you help to answer this question in a NEW survey, which asks your opinion of this practice. It asks specifically to indicate your level of agreement/disagreement with the following statements about Pharma's use of paid search engine ads:

• Regardless of search engine rules that may allow pharma advertisers to use redirect URLs ("vanity URLs"), pharma should ONLY use display URLs in ads that ACCURATELY reflect the landing page URLs of the websites being advertised (ie, pharma should obey the rules established for all other advertisers).
• Pharma advertisers should be allowed an exception to search engine rules regarding redirect URLs because FDA regulations prevent them from displaying a drug brand name in short ads, even when the brand name is only part of the display URL.
• Redirect URLs should NEVER be used by pharma advertisers because they mislead the consumer into believing that the links will take them to independent disease information websites, not branded drug sites.

Results of this survey may be summarized in Pharma Marketing News. After you answer a few short questions, you will be able to see the summary of all responses to date. No comments or other identifying information is included in the summary.


Your comments are confidential (anonymous) unless you specifically provide your contact information at the end of the survey and allow us to attribute comments to you personally.



Take the survey Now!

Drug Companies Are Flocking to Facebook for Eyeballs, Not Conversation

Drug Companies Are Flocking to Facebook for Eyeballs, Not Conversation

More and more pharmaceutical companies are launching Facebook pages that promote their products. The latest is Allergan, which launched a celebrity Facebook campaign for Juvederm, a dermal filler used for "long-lasting correction of moderate to severe facial wrinkles and folds." Allergan also makes Botox.

According to an MM&M story, "Ex-Extra host and broadcast journalist Dayna Devon will dispense personal tips to Facebook fans each week, and is sharing her experience with Juvederm through the social networking site."

But why open up a Facebook page, which looks like just another product website (see screen shot below), especially if you are not going to accept and publish comments to the Wall?

IMHO, Allergan and other pharma companies are not launching Facebook pages to "engage" consumers in "dialogue." First, there is no "dialogue." Of course, the excuse is that pharma is waiting for the FDA to publish guidelines that will allow them to use ALL the nifty social networking features of Facebook, including online dialogue. Here's an example of how the FDA is being blamed for not "allowing" comments on pharma Facebook pages:

@RosettaHC tweeted: Juvederm launches Facebook page. No open comments allowed. (FDA: when's guidance coming?) http://bit.ly/aPpC8v #hcsm #fdasm

If it looks like a Web 1.0 site and acts like a Web 1.0 site, why not just stick to a Web 1.0 site and forget about Facebook?

The REAL reason for launching Facebook pages is because of Facebook's POPULARITY and the number of "eyeballs" it can deliver, not the the number of conversations. According to the latest Hitwise analysis, Facebook has surpassed Google in terms of Web site traffic (see figure below and "Facebook More Popular Than Google? Let the Ad Wars Begin").