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  3. DTCA/I, consumer secondary audience
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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.

Website Landing Page

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

    I am creating a new landing page for a website. For efficiency, I want to have the landing page to include the logo for 2 different brands. The patient or HCP would click on the section of the page that has their applicable brand/logo and enter the information required for entry (i.e., DIN in the case of the patient). Would this be allowed given that no therapeutic area would be disclosed? Would it make a difference if at the top of the page it said something like, "Brought to you by [company x} and then below it the 2 logos. In both cases the logos/sections would be separated by different background colours.

    Jennifer CarrollJ 1 Reply Last reply
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    • G GMC

      I am creating a new landing page for a website. For efficiency, I want to have the landing page to include the logo for 2 different brands. The patient or HCP would click on the section of the page that has their applicable brand/logo and enter the information required for entry (i.e., DIN in the case of the patient). Would this be allowed given that no therapeutic area would be disclosed? Would it make a difference if at the top of the page it said something like, "Brought to you by [company x} and then below it the 2 logos. In both cases the logos/sections would be separated by different background colours.

      Jennifer CarrollJ Offline
      Jennifer CarrollJ Offline
      Jennifer Carroll
      wrote on last edited by
      #2

      Hi @gmc

      In theory, two brands can share a pre-gate landing page. There are many aspects to consider including the linkages that drive patients and HCPs to the page and the content on the page once they arrive. Any text, imagery or other elements (including the logo) that suggest the therapeutic use or that the products can be used together, would render the page unacceptable. It is acceptable to state “brought to you by” but remember that the consumer page should have no links to the sponsor’s corporate site.

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      • G Offline
        G Offline
        GMC
        wrote on last edited by
        #3

        If an APS, such as a patient booklet that discusses the disease state for one of the brands, directs the patient to the brand's website and they land on the landing page that has 2 brands, does that present an issue for including the second brand on the website pre-gate page?

        Jennifer CarrollJ 1 Reply Last reply
        0
        • G GMC

          If an APS, such as a patient booklet that discusses the disease state for one of the brands, directs the patient to the brand's website and they land on the landing page that has 2 brands, does that present an issue for including the second brand on the website pre-gate page?

          Jennifer CarrollJ Offline
          Jennifer CarrollJ Offline
          Jennifer Carroll
          wrote on last edited by
          #4

          Hello @gmc

          As per our response above, there are many aspects that would impact acceptability. It is highly probable that the proposed link above would present an issue because the patient would know certain things about the medication that was prescribed to them (i.e. the indication). By linking to a pre-gate page that has a second medication which the patient has likely not been prescribed, it may be considered direct to consumer advertising. This is because the patient could start drawing inferences/conclusions about that second medication, even if they only see the name of it on a pre-gate landing page. This would be assessed and discussed during the review process.

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