691 - With regards to the PAAB-exempt regulations, and the requirement to not link to product information - can you confirm if the definition of linkage is in the language used in the piece? For example, if you had a webinar invitation that had only the product name (no indication, disease information, etc) however that invitation was inviting someone (via website link) to a webinar/registration page etc that was all PAAB reviewed/approved, is the invitation still PAAB exempt or by virtue of having a weblink (or intention to direct to PAAB-approved material if it were paper copies etc), is the invitation now in scope of PAAB review?
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Linkages can be created in many ways, such as, by proximity, appearance (i.e. using similar imagery or branding colours), and by including language in the piece which directs the reader to a specific site/content. This content does fall under the PAAB scope of review. We suggest submitting the invite (quoting the efile number for the PAAB approved registration page) to PAAB as an exemption request, as an assessment of the combined content is required to ensure that the linkage does not affect the exemption status of the invite.
