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196 - I understand a branded paid search ad cannot use keywords that go beyond name-price-quantity. However, if a person searches for the brand name keyword in conjunction with the disease-state keyword, does this not identify them as a patient or someone who is already knowledgeable about the product? Could a branded ad be presented if the searcher has already made the brand-disease connection themselves?
DTCA/I, consumer secondary audience
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No. There are only 3 audiences from a drug advertising regulatory perspective. Consumers, patients, and HCPs. Conducting an internet search containing the drug and the corresponding disease does not make you a patient or an HCP. The composite of the purchased keywords, the metadescriptor, the landing page and its URL must not exceed name, price, and quantity for a prescription product. These elements may not create a link between name and therapeutic use for a product indicated for the treatment of a schedule A disease. On a separate note, keep in mind that product ads cannot be directed to patients anyways (i.e. for Rx products, patient information must be non-promotional).
