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426 - Can I post a branded online banner on a website such as Canoe santé that already provides information on a prescription drug (i.e. there is information on the drug and the disease it treats).
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No. I believe that Canoe Sante is non-gated. I therefore assume that the ‘information’ you are referring to exists completely independently from the manufacturer and it’s agents so as to be exempt from the advertising regulations. BUT, linking such content to advertising would render the combined entity subject to the advertising regulations. This would be problematic as this combined entity exceed the name/price/qty provisions that related to DTC Rx advertising. Even if the environment were to be gated, I’d advise against this as the independently generated content may exceed the limitations of the TMA and likely does not contain fair balance. Thus it would likely even contravene the HCP advertising regulations if it were rendered subject to them through paid placement of a banner ad in a gated environment.
