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  3. DTCA/I, consumer secondary audience
  4. 296 - We understand how gating works for things like banner ads on sites where medical registration is required to log in. On sites where any user can purchase access (medical journals, for instance), or where large institutions like universities often have blanket access, is a post-login screen still considered "post-gate" for advertising purposes?

Forum Update: Supporting Community-Led Discussion

The forum was created as a space for shared learning and peer support, and as the community grows, we want to lean more fully into that purpose.

Going forward, PAAB will be taking a more listening-first role in forum discussions. Rather than responding immediately to every question, we’ll be encouraging members to engage with one another, share experiences, and help build collective understanding. PAAB will continue to monitor conversations and will step in to:

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Our goal is to foster a collaborative, trusted community where knowledge is shared and strengthened by everyone’s contributions.

Thank you for being part of the conversation.

296 - We understand how gating works for things like banner ads on sites where medical registration is required to log in. On sites where any user can purchase access (medical journals, for instance), or where large institutions like universities often have blanket access, is a post-login screen still considered "post-gate" for advertising purposes?

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  • Jennifer CarrollJ Offline
    Jennifer CarrollJ Offline
    Jennifer Carroll
    wrote on last edited by
    #1

    If an advertisement exceeding the restrictions set out in Section C.01.044 of the Food and Drug Regulations is displayed on a Web site, and is accessible to individuals who are not healthcare professionals (HCPs), it would likely be considered in contravention of this regulatory provision. The type of login (e.g. through an institution's IP) would not be meaningful if it is allowing access to this material by non-HCPs. The key factor would be who may access or be exposed to the ad. It is therefore important for the market authorization holder to ensure that an adequate mechanism is in place to limit exposure to HCPs.

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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.
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