Whitepaper on the May 2009 FDA guidelines for Pharmaceutical Paid Search. Includes overview, definitions, guideline interpretations, implications for marketers, and how the industry will need to reply in order to remain compliant.

1. An Eye on Google:
Re-engaging with digital marketing in response
to recent FDA warnings
Sara Weiner Contributions by:
Senior Manager, Interactive Strategy Croom Lawrence and Carlen Lesser
RTC Relationship Marketing
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2. An Eye on Google:
Re-engaging with digital marketing in response to recent FDA warnings
Sara Weiner, RTCRM
Recent warnings by the FDA and long-standing concerns regarding digital pharmaceutical advertising have
made it increasingly difficult to safely develop interactive campaigns.1 RTCRM believes that success will not
come by deciding whether or not to do paid search or banner ads, but rather in the creative and experiential
execution of all digital strategies.
In reviewing the current landscape, it is apparent that branded and unbranded pharmaceutical efforts
alike can be employed on the digital platform, while still maintaining FDA compliance. That said, rich media
provides the best method for both delivery and user experience when FDA compliance is a concern.
Overview
• The FDA has warned that paid search copy without safety information creates a misleading experience for
patients, establishing a precedent of concern about all digital tactics
• For paid search, the issue is primarily in the functionality and logistics of the search engine technology
• There are best practices in paid search that can protect your pharmaceutical brand from noncompliance
• The one-click rule may still apply in some scenarios
• Rich media banners are the best approach for materializing a patient’s digital experience alongside
safety information
I. FDA Warns Pharma to Change Search Practices
In early April 2009, the FDA sent 14 pharmaceutical companies warning letters regarding their paid search
practices, suggesting that their ads were not in compliance with FDA standards.2 The FDA called these
ads “incomplete” and “misleading” due to the lack of risk-related detail displayed in the ads.3 While some
of the drugs included in these warnings were Black Box, some were not, creating implications for all
pharmaceutical marketers.
The companies that received letters in April were: Biogen Idec, Sanofi-Aventis U.S., GlaxoSmithKline, Forest
Laboratories Inc., Cephalon Inc., Bayer Healthcare Pharmaceuticals Inc., Johnson & Johnson Pharmaceutical
Services, Pfizer Inc., Novartis Pharmaceuticals Corp., Genentech Inc., Boehringer Ingelheim Pharmaceuticals
Inc., Merck & Co., Inc., Hoffman-LaRoche Inc., and Eli Lilly and Co.
1
U.S. Food and Drug Administration, Center for Drug Evaluation and Research.
“Warning Letters and Untitled Letters to Pharmaceutical Companies 2009.” (April 2009)
http://www.fda.gov/cder/warn/warn2009.htm
2
ibid.
3
ibid.
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 1

3. The current standard for pharmaceutical paid search is to provide risk information as quickly as possible upon
a patient’s entry to the branded website. The general “rule” is to provide this information within “one click”
from the ad. While the FDA has never issued any official guidelines for this issue, marketers have loosely
applied this approach to mean that safety information may either be on the landing page in complete
documentation, or listed as a link on the landing page. 4 This latter option results in two clicks rather than
one, but most marketers consider this approach acceptable.
In these April 2009 warnings, the FDA appears to be mandating
that some risk information should be denoted in the search Search Ad Format
ad copy itself. This mandate is in direct conflict with the search
engines’ ad copy restrictions, which do not allow enough space
• Title: 25 characters
to accommodate this information. The major search engines
require that marketers adhere to 95 characters (including • Description line 1: 35 characters
punctuation and spaces) in their ad copy.5
• Description line 2: 35 characters
The ad copy requirement is actually broken down even further
into 25-35-35 characters, on three lines. This restriction has
always proved challenging for marketers, as it leaves little room
to promote product qualities, offers, and brand reputation.
For pharmaceutical marketers, this challenge becomes even greater, as they must balance two things:
1) compliance with the FDA, and 2) the search engines’ ad copy requirements.
Generally, pharmaceutical marketers provide safety information along with any branded drug messaging, but
when one is limited to only 95 characters of text, including this lengthy information becomes impossible. This is
why the pharmaceutical industry has adopted the one-click approach.
The issue, based on the recent FDA warnings, has now become twofold: 1) does the one-click rule still apply, and
2) how do advertisers ensure that their search copy is in compliance by using only 95 characters of text?
Unless the FDA is suggesting that pharmaceutical companies abandon branded Search Engine Marketing
altogether, the one-click rule would still have to apply. There is no current mechanism for distributing safety
information in search ad copy, so this information must be located on the website, for now. We will review
how to manage pharmaceutical paid search copy, but first let us consider technological changes that might
meet the FDA’s in-ad copy suggestion.
4
Mack, John. Pharma Marketing Blog. “Death of the One-Click ‘Rule’ or
‘Received Precedent’ or Whatever!” (December 9, 2009) http://pharmamkting.blogspot.com/
2008/12/death-of-one-click-rule-or-received.html
5
Google AdWords Help Section. Advertising Policy: Editorial & Format. (2009)
http://adwords.google.com/support/bin/static.py?page=guidelines.cs&topic=
9271&subtopic=9277
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 2

4. II. It’s Google’s Move
As the FDA continues to mandate such restrictions, RTCRM believes that the search engines themselves will
need to make concessions to help facilitate the delivery of risk information in paid search ads.
The FDA’s stance is that important safety information needs
to be readily available to the patient when they are exposed Proposed Ad Format
to any branded drug messaging. Though they have not issued
official guidelines, their recent warning letters imply that
the one-click rule is not a sufficient patient experience. Let’s
Brand Official Site
explore what they mean. Learn about benefits and risks of
treating condition with Brand
www.Brand.com
Currently, if a user reads a search ad but does not click through,
Full Safety Information Here
they will never see the risk detail that is only found on the
website. They will only be exposed to the ad copy and may
walk away thinking that this is all they need to know about the
brand. RTCRM believes that a technology fix is needed in order
to solve this problem. The search engines could provide a second link for “safety information” in
the context of the search ad copy. This would make patients aware that such information is readily
available, while fulfilling both the current industry mandate of “one click” as well as the new
FDA-suggested in-ad copy.
The question then becomes: If it is a technology issue, who is responsible for implementing this change?
Most likely, the answer is Google. It represents 63% of U.S. search share and arguably controls and engineers
the paid search landscape.6 Google has the ability to most effectively change the ad copy requirements
for regulated industries like pharmaceuticals. Precedent demonstrates that Yahoo! and MSN may follow
suit if Google implements this change. When MSN launched its search platform in 2005, it copied Google’s
95-character limit (a calculated way to make it easy for Google advertisers to transfer their campaigns to
MSN). Similar to MSN, Yahoo! changed its character limit to mirror Google’s when it launched Panama in
2007 (most likely in a much-needed move to allow itself more ad space and thus more revenue). Currently,
in 2009, all three major engines have similar ad copy requirements, and there is a precedent for the other
two to follow Google.
So, it’s Google’s move here. Google has an opportunity to develop unique ad copy requirements and
functionality for regulated industries such as pharmaceuticals. While increasing copy length to permit
inclusion of long-form safety information would likely lead to a poor user experience, including a second link
in the ad copy could solve the problem.
6
comScore. Core Search Report, February 2009 vs. January 2009. (March 13, 2009)
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 3

5. III. Will Google Do It?
Google is not going to move quickly on this, though it will surely receive requests from a number of agencies
and marketers. Google, understandably, prefers to maintain control over its marketplace and will wait until
it sees a business case for implementing this second link before doing so. By providing too much information
up front in the ad, Google would lose out on its revenue maker – clicks. Google does not make money when a
consumer only sees an ad. Google makes money when a consumer clicks on ad, a system called cost-per-click
(CPC). Since a pharmaceutical marketer only has to pay when a patient clicks on a search ad, Google can only
make money if this patient reads the safety information and still clicks on the ad. It sounds reasonable enough
that a patient would do this, but if we consider the amount of detail that is actually in the safety information,
including the risks and warnings, this approach may actually drive patients away, and thus keep them from
clicking on the ad. So Google, to its own detriment, could possibly make less money as a result of the in-ad
copy requirement.
Google could offset any loss in revenue by developing a supplementary cost structure, such as an additional
flat fee for this second link. It would be more likely, however, that this new link would be subject to the same
CPCs as the rest of the search ad. Another consideration in evaluating the plausibility of this change is Google’s
adamancy about user experience. The entire purpose of its algorithm (other than revenue) is to create a
relevant, seamless user experience. To develop this second link, Google would have to believe that it creates a
better user experience. To do this at no extra charge, Google would have to see the altruistic value in providing
this information to patients at the point of exposure. A pilot program would quickly prove whether this
approach was: 1) better for the patients’ experience, and 2) still lucrative for Google. Surely, a short test would
not hinder Google’s revenue forecast; consider all the incremental dollars that pharmaceutical marketers would
spend if they could invest in FDA-compliant search marketing.
Google has, indeed, already made some concessions for the pharmaceutical world regarding display URLs,
though they go against both traditional pharmaceutical advertising principles and, surprisingly, against
Google’s usually adamant stance on user experience. First let us review Google’s basic editorial regulations,
which demand that:
“Your display URL must accurately reflect the URL of the website you’re advertising. It should match the domain of
your landing page so that users will know which site they’ll be taken to when they click on your ad.” 7
Despite this publicly stated regulation, Google has seemingly found a rationale for an exception to its own
rule: It permits pharmaceutical advertisers to implement a fake unbranded URL that does not actually exist,
but rather redirects to a branded site. RTCRM disagrees with this exception to the rule and believes a fake URL
creates a larger issue for pharmaceutical FDA compliance. Manipulating a patient into landing on your branded
site via unbranded material violates a number of pharmaceutical standards. We will review this issue in detail
in section VII.
7
Google AdWords Help. Advertising Policy: Display URL. (2009)
http://adwords.google.com/support/bin/static.py?page=
guidelines.cs&topic=9271&subtopic=9280
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 4

6. IV. Should Pharma Go Unbranded?
While advertisers are waiting for a functionality that actually allows them to adhere to this FDA implication,
they still need to manage their paid search campaigns. Leading with an unbranded approach is your safest bet.
RTCRM employs similar strategies in its pharmaceutical unbranded TV practice. Here, an unbranded TV spot is
used to drive to unbranded Web content that includes an offer.
Follow-up fulfillment is usually branded and patients become
part of a long-term communication stream. For pharmaceutical
search marketers this approach would translate to an aggressive The Case for Branded Terms
unbranded keyword and ad copy campaign that drives to a
robust unbranded website. • Most-qualified patients, actively
interested in your brand
The concern, however, for all search marketers, including
• Increased awareness and brand recall
pharmaceutical companies, has always been in the quality
of the traffic from these unbranded search terms. Generally, • Drive ROI
unbranded terms have lower conversion rates than branded • Presence for navigational search and
terms, simply because these consumers are not as far along misspellings
in the consideration or purchase cycle as a branded-term • Patients follow same response funnel
searcher. The win here would be in managing unbranded as general market
terms to the extent that they can efficiently and effectively
replace branded terms.
From the other standpoint, some marketers may wonder why they should even consider branded efforts at all;
in general, branded terms drive mostly navigational clicks and the FDA letters directly warned against branded
ads. So, for pharmaceutical marketers, what is the value in branded traffic?
RTCRM believes that branded search terms have not been completely taken off the table and, where
possible, should remain as part of any search strategy. Research has shown that branded terms drive
increased ROI and the most qualified of potential customers. The traditional concern is that as a marketer your
brand website will appear in the organic search results for a branded search term anyway, so why should you
pay for additional ad space with branded terms? There are two arguments to be made here. The first is that
increasing visibility in search results improves a customer’s awareness and consideration. In fact, an Enquiro
study in late 2007 showed a 7% point increase in purchase intent for branded queries that displayed both an
organic and paid listing in the same results.8 The second argument to be made is that searches on branded
keywords generally come from a marketer’s most qualified customer target. It is likely that searches on branded
terms are in response to exposure to other marketing tactics. By removing branded paid search listings, you are
actually decreasing the chance to capture these potential customers, and most likely these are the customers
who are most ready to convert to your brand’s offerings.9
8
Enquiro Search Solutions. “The Brand Lift of Search: Enquiro Online Survey and
Eye Tracking Study.” (July 2007) http://www.enquiroresearch.com/campaigns/
TheBrandLiftofSearch.pdf
9
Brooks, Nico. Atlas Institute. “Sponsored Search: How Much Are You Paying for
Your Customers’ Navigational Behavior?” (2007)
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 5

7. The same principles should apply to pharmaceutical campaigns, and there have been some recent studies that
touch upon this, though further research should be developed to analyze specific conditions. In particular, a
study performed by Google and comScore in 2007 found that undiagnosed diabetes patients took on average
6 months to perform their research.10 It was also discovered that diabetes patients, both diagnosed and
undiagnosed, use search engines to find both condition (76%) and treatment (34%) information throughout this
cycle, indicating they need unbranded and branded ads alike to complete their research.11
In the end, it is up to each individual pharmaceutical company and its legal team to decide whether to
move forward with branded terms, but there is clearly an ROI case to be made for keeping them as part
of any search campaign.
V. An Eye Toward ROI
Whether moving forward with only unbranded terms or Basics for Running
with branded terms as well, RTCRM recommends setting Paid Search
goals and objectives before any paid search engagement.
Marketers should look to develop keywords and ad copy • Set goals and create measurement plan
that will serve these goals. Additionally, a measurement
• Develop keywords, ad copy, and
plan should be agreed upon and an analytical platform landing pages
should be implemented before the launch of any search
• Launch campaign and monitor
campaign. It is important to understand that, due to the Quality Score
dynamic landscape, search is not a “set it and forget it”
• Manage toward goals and optimize
medium. Search marketers should be prepared for frequent accordingly
management and optimization of keywords and copy
(and even landing pages) to meet objectives.
VI. Implementing Best Practices
Once an approach has been outlined and goals are in place, keywords and ad copy should be evaluated for
FDA compliance. It is important to understand how paid search works, in order to properly assess keyword
choice and copywriting strategies.
Google created an algorithm that displays search ads based on relevancy and monetization. Google uses
a Quality Score to calculate whether your ad should be displayed.12 This Quality Score is made up of a number
of related elements that, combined, allow the search engines to measure the value of displaying your ads
compared with displaying other ads in the same competitive set.
10
Google and comScore. Patient Pathway Study. (April 2008)
11
ibid.
12
Google AdWords Help. Advertising Policy: About Quality Score. (2009)
http://adwords.google.com/support/bin/answer.py?hl=en&answer=10215
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 6

8. Included in these elements is your CPC, and the more a marketer is willing to pay, the more likely one
might be able to offset a poor Quality Score. There are, of course, undisclosed factors, but according to
Google’s help section:
“In general, the higher your Quality Score, the lower your costs and
the better your ad position.”13 Elements of Google’s
Quality Score
It is important to recognize that these elements are dynamic and
the competitive landscape changes frequently, so
• Relevance of the landing page
campaign metrics may change daily. Overall, the net-net is
that a search marketer must deliver a better Quality Score • Relevance of ad copy
than its competitors, and must do it within the extremely • Historical performance
limiting 95-character ad copy structure. • Competitive landscape
In order to acquire this high-quality score, there are basic best • Click-through rate (CTR)
practices to follow in writing search ad copy. Most important • Undisclosed factors
in any approach is to ensure both relevancy and a cohesive user
experience. Ad copy should not promise one thing and drive to a
website that provides something else. The engines hate this, and
so do consumers.
Best Practices in Writing Search Copy
• Use the searched-upon keyword in ad copy to increase relevancy, both for the
consumer and the algorithm
• Use “Official Site” in copy to create trust with the consumer and add credibility to the ad
• Use concrete calls-to-action to drive CTR and aid the consumer in their research
• Use display URLs that match the domain of your website
• Ad copy should respond to the query and tell the consumer what they will get
by clicking on the ad
13
Google AdWords Help. Advertising Policy: About Quality Score. (2009)
http://adwords.google.com/support/bin/answer.py?hl=en&answer=10215
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 7

9. VII. Relevancy vs. The FDA
These current practices work very well in the telecom, retail, automotive, and financial verticals, but in
pharmaceuticals, copywriting for paid search ads is not as clean cut. Relevancy gets trickier, and your 95
characters of ad copy need to work harder. While the above practices still apply, FDA regulatory nuances need
to be incorporated. Relevancy still matters, but ensuring compliance with the FDA’s standards, and keeping in
mind its recent perception of misleading materials, matters more.
Due to the short nature of search copy, it’s better for pharmaceutical marketers to use the 95 characters of
ad copy as a drive-to-site strategy and to avoid using it to sell or explain the drug.
If pharmaceutical marketers choose to move forward both with branded and unbranded paid search efforts,
there are guidelines to consider when writing the ad copy.
FDA Compliance in Writing Pharmaceutical Search Copy*
• Do not use a brand name/URL and the indication in the same ad copy without mentioning risk
• Do not run branded copy with unbranded keywords, nor unbranded copy with branded keywords
• Use brand name and mention of the generic molecule in same copy
• Do not use unbranded display URLs that redirect to branded sites
*based on FDA guidelines for reminder ads, product claim, and help-seeking ads
As with other verticals, RTCRM recommends that, overall, pharmaceutical marketers follow the same approach
as previously outlined, including using the branded or unbranded keyword in the search ad copy, where
possible, to increase relevancy. Specifically, for pharmaceutical marketing, it is important to keep in mind the
following guidelines in order to comply with the most recent FDA positioning:
a) Do not use a brand name and the indication in the same ad copy 14: In the case of pharmaceuticals, branded
keywords should call up general branded copy that does not mention any indications. Use of the brand
name should be run alongside mention of the generic molecule. If someone searches on Brand it would be
safest to display something similar to: “Brand Official Site. Full Generic Molecule. Safety Information Here.
www.Brand.com.” This ad copy must redirect to the branded site. In this example, a marketer maintains trust
by using “Official Site,” relevancy by including the keyword in the ad copy, and FDA compliance because
there is no misleading information or indication noted.
b) Do not use unbranded keyword with branded copy (and vice versa) 15: In the case of pharmaceuticals,
unbranded keywords should not call up branded copy. This inverse combination puts the patients in a
position to assume that the branded drug treats the unbranded query. Similarly, the reverse situation, which
would use a branded keyword with unbranded copy, may create an assumption of treatment or indication.
14
U.S. Food and Drug Administration, Center for Drug Evaluation and Research. Statement of FDA
Before Special Committee on Aging, United States Senate. (Sept. 2005)
15
U.S. Food and Drug Administration, Center for Drug Evaluation and Research,
FDA Draft Guidances Aim to Improve Health Information. (Feb. 2004)
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 8

10. For the purposes of the following chart and discussion, we will use osteoporosis as the condition
under evaluation:
Search Ad Copy Risk Evaluation
Keyword
Risk Sample Ad Copy Landing Page Issue
Query
* Similar to accepted reminder ads
Brand Official Site.
* Not permitted for Black Box brands
Full Generic Molecule.
Low Brand www.Brand.com * Safety information should be on landing page
Safety Information Here.
(one click)
www.Brand.com
* Requires legal approval on case-by-case basis
* Acknowledges risks, but doesn’t provide
Brand Official Site.
material up front
Learn About Benefits and Risks of
Mid Brand www.Brand.com * Safety information should be on landing page
Treating Osteoporosis with Brand
(one click)
www.Brand.com
* Requires legal approval on case-by-case basis
Osteoporosis Management
* Similar to accepted help-seeking ads
osteoporosis Learn Tips and Get Support to Help
Low www.unbranded.com * Requires legal approval on case-by-case basis
management Manage Your Osteoporosis
* No safety information needed
www.unbranded.com
* Unbranded to branded material, similar
Brand Official Site. to regulated product claim ads
osteoporosis Full Generic Molecule. * Misleading indication experience for
High www.Brand.com unbranded keyword search
management Safety Information Here.
www.Brand.com * Need safety information available
* FDA letters warned against this
Osteoporosis Management * Unbranded to branded material, similar
to regulated product claim ads
osteoporosis Learn Tips and Get Support to Help
High www.Brand.com * Misleading landing page for unbranded
management Manage Your Osteoporosis keyword search
www.Brand.com * FDA letters warned against this
Osteoporosis Management * Unbranded to branded material, similar
to regulated product claim ads
osteoporosis Learn Tips and Get Support to Help
High www.Brand.com * Misleading Display URL for unbranded
management Manage Your Osteoporosis keyword search
www.healthybones.com * FDA likely to warn against in future
There are some nuances to consider here, and pharmaceutical companies should discuss this issue thoroughly
with internal legal teams. Overall, RTCRM recommends reviewing all current ad copy to look for instances
where messaging may be construed as being “misleading” or including broad generalizations, per the
recent warning letters.16
16
U.S. Food and Drug Administration, Center for Drug Evaluation and Research,
Warning Letters and Untitled Letters to Pharmaceutical Companies 2009. (April 2009)
http://www.fda.gov/cder/warn/warn2009.htm
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 9

11. Another consideration, briefly mentioned in section III, is display URLs. Google has issued an exception for
pharmaceutical marketers allowing them to use a fake, unbranded display URL that drives to a branded site.
Many pharmaceutical marketers implement this strategy, and Yahoo! Search Marketing has considered
adopting it as well.17 However, RTCRM believes that the fake, unbranded display URL practice creates a
misleading and deceptive user experience. It is unlikely that the FDA will continue to permit this practice much
longer, because it appears to be in direct conflict with current branded and unbranded advertising guidelines.
The following example may help explain why RTCRM feels that this practice is in violation of current FDA
guidelines. Let us say that a patient searches on a health term such as osteoporosis and sees an ad for
www.healthybones.com. Here, the patient understandably thinks he or she is clicking on an ad for unbranded
content. With their interest captured, they then click on this fake, unbranded display URL and are redirected
to a branded website. This is not what the patient asked for, nor was it their expectation when they
clicked. Instead the patient is manipulated into exposure to branded content. This violates traditional
pharmaceutical advertising principles, the recent FDA stance, and arguably Google’s positioning on relevancy
and user experience.
Remember, the basic best practice for search marketing is to
create as much relevancy as possible between ad copy and Sample Search Ad: Fake
website content. In fact, Google directly states in its editorial Display URL*
policy that:
Osteoporosis
“Your ads and keywords must directly relate to the content on
Learn Tips and Get Support to
the landing page for your ad. When users see your ad, they Help Manage Your Osteoporosis
should be able to understand what kind of product, service, or www.healthybones.com
other content they will find on your site. Products or services *Sample paid search ad reflecting misleading experience
promoted in your ad must be reflected on your landing page;
ads can be disapproved if a promoted product is not offered or
available for sale as promised.” 18
This mandate is to ensure a cohesive and relevant user experience. RTCRM adamantly agrees with this
approach both for general and pharmaceutical marketers. Since the practice of using a fake, unbranded display
URL to drive to a branded website weakens relevancy and creates a poor and misleading user experience, it
leaves RTCRM wondering why Google would permit such a disconnect.
Generally, Google is known for its integrity in protecting user experience, as is apparent in its Webmaster
Guidelines. These specifically ask marketers to consider the following questions:
“Does this help my users? Would I do this if search engines didn’t exist?” 19
17
Yahoo! Search Marketing NYC division (in-person interview) (April 4, 2009)
18
Google AdWords Help Section. Advertising Policy: Editorial & Format. (2009)
http://adwords.google.com/support/bin/static.py?page=guidelines.cs&topic=9271&view=all
19
Google Webmaster Guidelines: Quality Guidelines. (2009)
http://www.google.com/support/webmasters/bin/answer.py?answer=35769
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 10

12. It is apparent that this unbranded display URL “exception” is in direct conflict with both the Google editorial
policy and its Webmaster Guidelines. Why would Google permit this? Remember, lack of relevancy hurts
Quality Score and a low Quality Score can increase CPC. Could it be possible that the inherent irrelevancy of
this fake display URL within their own relevancy-based algorithm actually makes Google additional revenue?
VIII. The One-Click Rule
Let us assume that a marketer chooses to deliver a truthful patient experience through the proper combination
of keywords, ad copy, and landing page. The next important component to consider is the location of any
safety information.
Again, the one-click rule has been loosely interpreted to mean that the safety information can live in a link on
the landing page, rather than be fully documented on the landing page itself. This is actually two clicks, rather
than one. To properly comply with the FDA, safety information related to the brand should be fully disclosed on
the landing page. However, if we look back at the patient pathways and mindsets that we reviewed in section
VII, there are exceptions to evaluate.
FDA Compliance for Safety Information Within One-Click
• A patient who searches on a branded keyword should receive a branded website that fully
discloses any safety information
• A patient who searches on an unbranded keyword should receive an unbranded site.
Here, the safety information is not required
RTCRM recommends reviewing all keyword/ad copy/landing page combinations, with the patient’s
experience in mind, when considering whether the one-click rule is applicable. Let us review some examples:
a) We have already established that a patient who searches on a branded keyword such as Brand should receive
branded copy and be sent to a branded site. If this copy states something such as, “Brand Official Site. Learn
about Benefits and Risks of Treating Osteoporosis with Brand”, a patient would expect to find this benefit
and risk information immediately upon click-through. The promise a marketer needs to fulfill in this scenario
is to provide the safety information upon first entry to the website, fully documented on the landing page.
This, in fact, would be a best practice regardless, as again, relevancy of landing-page content helps determine
a search ad’s Quality Score.
b) On the flip side, if a patient receives the unbranded-keyword-to-unbranded-copy combination previously
described in section VII, then they do not need to see the safety information upon entry to the website.
As an example, let us say a patient searches on osteoporosis management, and receives copy that reads
“Osteoporosis Management. Learn Tips and Get Support to Help Manage Your Osteoporosis.” In this scenario,
risks have not been mentioned in the ad copy and the ad copy speaks directly to their search query. Generally,
safety information is not required on an unbranded site to begin with, and when we consider the patient’s
experience pathway in getting to this unbranded website, it is clear that they do not have an expectation of
seeing any safety information.
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 11

13. Again, RTCRM believes that it is most important to evaluate the experience of a patient exposed to any
marketing material when deciding upon a search strategy.
IX. Evaluating All Digital Media Tactics
While the FDA warning letters targeted paid search specifically, other digital tactics may soon come under
scrutiny as well. Organic search, contextual targeting, and banner ads all include similar elements that the
FDA may oppose. These elements include ad copy, landing page content, and a patient’s exposure to safety
information. RTCRM believes that pharmaceutical advertisers can still engage with the majority of digital
tactics, and that it is more the creative and patient experience, than the mechanism of deployment, that should
be the focus of evaluation.
Digital Media Risk Evaluation
Risk Tactic Issue Recommendation
Short ad copy requirements result Continue with unbranded search keywords and
Mid Paid Search in mandatory click-through copy, but maintain best practices. Review branded
to view safety information. copy on case-by-case basis with legal team.
Revisit idea of including “risks” in titles
Technical function of organic search leaves and descriptions to meet FDA compliance.
Low Organic Search
some copy out of marketer’s control. Work closely with SEO agency to implement
pharmaceutical principles.
Continue with content targeting, but actively
Inability for proactive control of contextual monitor distribution reports. Use very generic
Contextual
High material that appears next to your ad may and conservative copy. Unbranded would be best
Targeting
create misleading experience for patient. approach. Branded not generally recommended.
No Black Box.
Follow similar best practices for paid search
and concentrate on unbranded copy to
Similar to paid search. Lack of space for unbranded website.
Mid Banners safety information in banner creates need
for click-through to website. Option to include multiple click tags within
banners to provide safety information
upon exposure.
Best option for creating comprehensive and Follow best copy practices and include safety
Rich Media explanatory patient experience. Plenty of information in its own panel. Use rich media as
Low
Banners room to include safety information upon a microsite experience to promote both branded
first exposure. and unbranded content.
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 12

14. Organic Search
There are certain intricacies that are inherent in organic search that need to be properly configured in order
for pharmaceutical marketers to maintain compliance. While the FDA has issued no official guidance around
organic search, RTCRM highly recommends close vetting of titles and descriptions, which are the controllable
elements of organic search. With organic search, character counts, unlike with paid search, are much longer
and do allow for the inclusion of risk
terminology. By reviewing and rewriting
titles and descriptions, pharmaceutical Organic Google Listing
marketers can avoid noncompliance
with Links
issues, and actually improve the patient
experience moving forward.
Sometimes, the search engines will
pull from body copy rather than from
the description. Marketers do not have
control over this, as it is an engineering
and technical function. Another element
marketers do not always have control
over are the sporadic links that Google
sometimes displays under organic listings.
If Google and the other search engines
seek to make concessions for their
pharmaceutical marketers, they should
include the ability to manage these
listings as well. If one of these links always contained safety information and a marketer used FDA-compliant
titles and descriptions, then the entire organic listing would provide the proper user experience based on recent
FDA warnings. More information on Google organic search optimization can be found at http://www.google.
com/webmasters/start/.
Contextual Targeting
Many marketers choose to opt in to the search engines’ content networks, which display text ads alongside
articles of content based on the keywords or themes in that content. Some pharmaceutical marketers may
avoid content networks altogether because as a marketer you cannot control the content alongside your ad. It
makes it very difficult to manage the patient experience when you do not know what this experience may be.
While it is possible to work with the search engines to understand where your ads are appearing, due to the
opaque nature of content network buys, this does not always offer full protection. When evaluating a content
network strategy, marketers should consider the likelihood of an ad showing up next to misleading or
negative content. For some categories this may be less of a concern, but for Black Box drugs content targeting
is not suggested. RTCRM recommends properly vetting the content network situation on a case-by-case basis.
In particular, marketers may want to consider turning off branded content campaigns altogether.
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 13

15. The Evolution of Rich Media Advertising
The ads have the l
Banner Ads Figure 8 Rich media creates greater increases in brand metrics
ad awareness (aka
than standard Web ads
Similar to search ad copy, there is not enough room in a standard banner to provide full disclosure of risks rich media ads. Ad
and safety information. Banners can, however, have multiple click-through links, so safety information can be percentage points
included in the same manner that RTCRM would like to see Google develop for search ads. Working with your for GIF/JPG ads, c
increase for rich m
creative and technical developers can provide solutions for including multiple links in your banner assets.
Pharma, Entertai
Lift in Awareness
MarketNorms sho
X. Safe Haven in Rich Media significantly outpe
ads when it comes
Rich media is really the best option for Rich Media Performance
Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control
likelihood to remem
is especially true f
pharmaceutical marketers to include safety Across Verticals such as auto, elect
information alongside branded content. pharmaceuticals a
Safety information and/or risk assessments are Figure 9 Rich media increases ad awareness for all industries Figure 9.
fully functional in rich media units and can even Best Practice Adv
have their own panel in the ad. In general, RTCRM
Maximize the
recommends using rich media wherever possible, Various researc
because it is more engaging for the patient, Evolution’s “Th
allows the marketer to deliver more content, and Online Advertis
provides the agency with greater tracking and data brand awarene
when the ads f
measurement for analysis. prominently th
ad’s animation
Rich media units, with all their inherent brand quickly a
functionality, increase engagement. Performing as ads often do
Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control;
much like a mini-website, rich media can house note - Electronics and Travel contain fewer than 30 campaigns for GIF/JPG than a constan
an entire patient experience and brand exposure Tread with car
in one unit. Although more expensive, they factor.” Recall
Figure 10 Rich media also increases message association for
usually perform better than standard banner ads, many industries
necessarily a g
remember a few
resulting in a better ROI in the end. In fact,
forget but for t
a study performed by Dynamic Logic and DoubleClick in 2005 found that rich media drove higher online 10,000 times.
awareness across all major verticals including pharmaceuticals.20 More recently, EyeBlaster (a major rich media
Some Industries
vendor) demonstrated that in a review of 35 ad campaigns totaling 340 million impressions, rich media banners Rich Media and M
had a higher overall conversion rate (1.60%) than standard banners (0.70%).21 Rich media also im
association for mo
Additionally, because of the engaging and experiential nature of these multiple-panel units, the industry examined in the M
has adopted more advanced analytics when it comes to measuring rich media’s success. All of the major rich consumer electron
media vendors provide a hefty list of measurable elements. Examples of some of the more complex metrics companies found
are: panel expands, percent of video viewed, and impression by Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control
date and hour.22 With better measurement message associat
shown in Figure 1
comes more advanced ROI modeling – something that all marketers, pharmaceuticals included, can benefit
from implementing. 9
20
DoubleClick. The Evolution of Rich Media Advertising: Current Market Trends, Success Metrics and Best Practices. (Sept. 2005)
21
EyeBlaster. Path to Conversion: Getting the Right Mix. (2009)
http://www.eyeblaster.com/Data/Uploads/ResourceLibrary/Path%20to%20Conversion_2009.pdf
22
EyeWonder. Technologies: AdWonder Reporting Platform. Ad Tracking and Reporting.
http://www.eyewonder.com/technologies_adtracking.php
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 14

16. XI. Conclusion
In the end, each pharmaceutical company will need to work with its legal team to make any final decisions
regarding digital tactics.
While RTCRM believes that the pharmaceutical industry can safely continue marketing through paid search,
the fears that have arisen as a result of the FDA warning letters are understandable. Where concern is too
great or the patient experience too risky, rich media offers the safest haven for comprehensive alignment of
a pharmaceutical brand and its safety information.
Where marketers are willing to optimize their paid search campaigns in compliance with the FDA, RTCRM
suggests following the basic guidelines outlined in this discussion. In the end, relevancy and compliance
are the two most important factors to consider and, as discussed, can be managed in a way that does not
distract from the patient’s experience. Both branded and unbranded paid search can be implemented in
a conservative yet search engine–friendly way, allowing pharmaceutical marketers to continue to reach
prospective patients with highly relevant ads.
And as the pharmaceutical companies continue to see value in search marketing and are willing to work extra
hard to fit compliant terminology within 95 characters of ad copy, Google too should consider working to
engineer a functionality that can include this safety information in the first exposure.
RTC Relationship Marketing Headquarters in Washington, DC
1055 Thomas Jefferson Street, NW
Suite 200
Washington, DC 20007
202.625.2111
An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 15