 Bill Drummy Heartbeat Digital CEO Visit Website |
Bill Drummy is CEO of Heartbeat Digital, an independent interactive marketing and software company he founded in 1998. Heartbeat is headquartered in New York, with offices in Brussels, Geneva, Paris and London.
Named one of pharma’s “100 Most Inspiring People,” by PharmaVoice, Bill has provided strategic guidance at the highest levels for Amgen, GSK, sanofi-aventis, UCB and many other leading pharma and biotech companies.
Bill’s reputation as a strategic thinker is well-known; he’s regularly published on industry issues and has been a featured speaker at major industry conferences, including DTC National ePharma Summit, and the Conference on Marketing.
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Digital Expert Q&A
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In light of recent FDA warning letters, how should pharmaceutical marketers proceed when it comes to search-engine marketing? Is the practice of “sponsored links” still possible given FDA’s demands for the inclusion of fair-balance information?Answered April 24th, 2009 by Expert:The FDA’s recent crackdown will certainly change ‘business-as-usual’ in search marketing. But in the end we think that’s a good thing.
I will explain. The FDA’s action — requiring complete fair balance if there is anything that can be construed as a claim in a sponsored link — will effectively kill the use of claim-including sponsored links on Google and other search engines. Because Google limits search ad copy to a total of 95 characters, it will be impossible to include complete fair balance in the ad.
But the effectiveness of branded sponsored links was already so poor that we don’t think pharma marketers are really losing very much. Squeezing a claim into the ad may have made marketers think they were effectively messagining their audience, but the data showed otherwise. Branded advertisements of this sort have been woeful performers in terms of click-through rates — the key metric for a search ad. In fact, we have found that non-branded ads — addressing the disease state rather than the brand’s direct messeage — perform up to 3x better than branded messages. So it has actually been more effective (and cost effective) to use non-branded search ads to drive people to an branded website, where branded information can be delivered more completely, including a fulsome explication of fair balance.
Think of it this way — if the consumer is already familiar enough with the condition to be receptive to branded advertising, just giving them the brand name, and noting that it is FDA approved for the condition, should be enough to get them to investigage further. (And we don’t think theFDA’s new position that would prevent this.) But if the consumer is not well-versed in the condition, she is not prepared for a branded communication in the first place. That’s why non branded search ads perform so much better.
So although it was not the intention of the FDA to make pharma companies smarter search marketers, that may indeed be the effect.
1 commentOne response to to “In light of recent FDA warning letters, how should pharmaceutical marketers proceed when it comes to search-engine marketing? Is the practice of “sponsored links” still possible given FDA’s demands for the inclusion of fair-balance information?”
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Thanks for addressing this issue Bill, but I have to respectfully disagree with the thesis here, that the recent crackdowns are a “good thing”. I contend that they are anything but. Two reasons, one more tactical, one philosophical.
On a philosophical level, issuing warnings for violating non-existent rules is no substitute for actual rules. While the recent warnings have given a few examples of what not to do (a few of them were already clear rules such as using generic name), they’ve left plenty of important decisions ambiguous. None of the letters addressed the impact of search queries on compliance. Can a brand show a reminder ad for an unbranded search or an unbranded ad for a branded search? That doesn’t yet seem clear to me as all of the advertisers who got letters mixed brand/indication in the ad itself. While all of the letters cited “sponsored listings”, one letter actual showed algorithmic results in the “promotional materials” screen shot. This opens up another can of worms. How are algorithmic results regulated? The copy for these results is largely under complete control of the marketer, so are we to assume that they should be treated like paid results? Or what about Black Box drugs? How does the rule against reminder ads for them impact what they do from a search perspective? I am of the mind that much more direct guidance would be helpful here so marketers and their agencies don’t have to wait to get a warning letter to figure out what they are and aren’t permitted to do.
Tactically, while you are likely correct that non-branded ads get better click-through rates than branded ads, I’d challenge the supposition that a good click-through rate defines good performance. The only folks that presumption holds true for are the search engines, who generate revenue each time a searcher clicks an ad. I feel that by forcing pharmaceutical companies to run unbranded ads, they are essentially being required to pretend to be something they are not, a more non-biased information site. This tactic will likely lead to higher click-through-rates, but substantial decreases in backend activity. Basically, this tactic moves the ability to sift out folks who are seeking truly editorial content to the point after which the advertiser has paid for the click.
Rules are what they are and I am all for clearer guidelines to keep marketers in check and help them operate within the constraints of the law. I can’t say the fallout frm these letters is going to be a good thing for SEM however.
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