464 - Can unbranded patient materials (covering disease state) have a look & feel/creative that is consistent with a DTC campaign?

  • Disease state materials provided by physicians to their patients are not truly “unbranded” if the recipients can readily create a link to product branded materials such as DTC Rx advertising employing similar look & feel (e.g. product television commercials). As unbranded disease materials are distributed by physicians to patients based on their condition (as opposed to which medications they are taking), the materials should be unbranded with no link to a particular product.