434 - For traditional online banner ads, how can one be expected to fit the verbatim indication on the first 'frame' also containing a claim? Traditional banners are only a few pixels in size, which seems to prohibit effective advertising for products with larger indications.



  • You are referring to the PAAB code 2.10 which requires that the segment of patients for whom the product is authorized sets the context for the promoted benefits. Code 2.10.1 clarifies that this info must be presented with or “prior to the first set of marketing benefit claims”. This requirement applies regardless of the media. Advertisers have made their banners work within the regulatory requirements in several different ways. For example, some have elected to include only the indication on frame 1 (and start the claims of benefit on frame 2 or later). Others have elected to convert their claim of benefit into a claim neutral question. For example, rather than stating "Drug X is the most dispensed…" in frame 1, they’d simply ask "Which drug is the most dispensed…?" without identifying the product on the frame (e.g. no product logo). Frame 2 would then include the drug name and indication. There are several other ways to make this work. The key to all solutions is the ability to automatically rotate between frames. If this is not possible on the site in question and the banner space is very small, this is simply not an appropriate environment to include advertising claims. In such cases, consider a name only ad or an ad containing only a message exempt from PAAB preclearance. As your question mention’s the word "verbatim", I feel that I should clarify that section 2.10.2 states that the TMA content “Drug X is indicated for” (or equivalent) must be presented verbatim at least once within the advertising message of the APS. Don’t confuse "at least once within the advertising message" with "among or prior to the first set of marketing benefit claims".


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