This is the first time we've seen pharma promotion on Instagram.
It's very One Click Rule-y, isn't it? Diclegis is an old-school morning sickness treatment with a fascinating history originally launched in 1956 (same year as Thalidomide) under the name Benedictin, it was actually hounded off the market in the 80s by a series of bogus lawsuits claiming that it caused birth defects, despite substantial evidence of its safety. Duchesnay, a Montreal pharma specializing in therapeutics for pregnant women, won FDA approval to market the drug last year.
The company seems to have built a PR campaign around Kardashian's endorsement (which can cost companies up to $1 million). It's a classic celebrity PR play, and a smart one, given Kardashian's 40 million (and presumably largely female) Instagram followers. But will it pass muster with the folks at OPDP
Here's what the FDA has said about promotion in character-limited formats:
In communicating benefit information on Internet/social media platforms with character space limitations, firms should consider the following points:
- Benefit information should be accurate and non-misleading and reveal material facts within each individual character-space-limited communication (e.g., each individual message or Tweet)
- Benefit information should be accompanied by risk information within each individual character-space-limited communication
- If a firm concludes that adequate benefit and risk information, as well as other required information, cannot all be communicated within the same character-space limited communication, then the firm should reconsider using that platform for the intended promotional message.
Or, as we paraphrased last year when the draft guidances came out: We're not going to let you off the hook on fair balance, even when operating in space-constrained media.