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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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.
