This presentation from December 2014 at the Food and Drug Law Institute's Enforcement and Litigation took at look at enforcement actions from the FDA's Office of Prescription Drug Promotion for use of Internet and social media platforms.
8. The Violations
• Omission of risk information
• Inadequate presentation of
established name
• Lack of adequate directions for use
• Failure to submit 2253
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9. The 2009 Violations
• Omission of risk information
• Failure to use established name
• Inadequate communication of indication
• Overstatement of efficacy
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10. Lessons from 2014 Activity
• Promulgate your policies
• Regularly monitor prominent platforms
• Control your “agents”
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