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  3. DTCA/I, consumer secondary audience
  4. 749 - We would like to disseminate a branded dosing app to HCPs via the Apple/Google stores. Since app stores are open to the public, is this possible if (A) the app description/screenshots are limited to name-only and (B) the app reviews are disabled? The app itself would be password protected, so could only be opened by HCPs (consumers could download the app but not open it).
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The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB), including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.

749 - We would like to disseminate a branded dosing app to HCPs via the Apple/Google stores. Since app stores are open to the public, is this possible if (A) the app description/screenshots are limited to name-only and (B) the app reviews are disabled? The app itself would be password protected, so could only be opened by HCPs (consumers could download the app but not open it).

Scheduled Pinned Locked Moved DTCA/I, consumer secondary audience
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  • Jennifer CarrollJ Offline
    Jennifer CarrollJ Offline
    Jennifer Carroll
    wrote on last edited by
    #1

    Yes. The responsibility of the manufacturer is to ensure the entire consumer visible content does not go beyond “name, price, quantity”. This includes both the app store content (including search terms) and the portion of the app visible prior to verification. While disabling the “reviews” helps to mitigate risk, it is not required. If the reviews remain active however, the sponsor would be responsible for monitoring and moderating them. So disabling “reviews” can help avoid non-compliance with the regulations.

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