Friday 30 January 2015

Jolly Rancher : Banking on Fruits

Brand : Jolly Rancher
Company : Hersheys

Brand Analysis Count : 554

Hershey has launched its iconic confectionery brand Jolly Rancher in India recently. This interesting because in the 65 year history of the brand, India is the first market outside North America where Jolly Rancher is launched.

Jolly Rancher has an iconic status in the North American market and is famous for the bold fruity flavors. In India, the brand has launched its lollipop products. The Jolly Rancher lollipops are available in three flavors - Mango, Green Apple and Water Melon.

Globally , Jolly Rancher is famous for its fruity flavors. Reports say that the brand has customized the flavors to suit the Indian palate. The brand is currently running the launch campaign featuring the actress Tamanna.

Although crowded, Indian confectionery market is growing at 18%. The launch of Jolly Rancher is a part of Hershey's strategy of building global brands. The company is planning to achieve $10 billion revenue by 2017. 
According to an ET report in 2013 , the adult consumption of chocolate and candies is growing at a faster pace in India. Products like lollipop which lost it charm in early 2000 also has made a comeback. 
Launching lollipops as the first product in India is an interesting move. Although lollipops contribute only 2% of the hard-boiled candy market, it is less crowded compared to candies. Hence the brand would be able to create some space and awareness for the brand. The company has priced the lollipop at Rs 5. 
The question is whether Indian consumer will like the tangy fruity flavors. The answer to that question will determine the fate of this brand. 

Monday 26 January 2015

When It Comes to Social Media, Pharma Tells Patients: "Do As We Say, Not As We Do"

Weeding out unsavory, "offensive," or spammy comments is a fact of social media life that has to be dealt with. In general, pharmaceutical companies avoid dealing with comments on social media sites like Facebook and Youtube, although a few do allow them and deal with them via "moderation."

Recently, I learned about a Social Media Toolkit for Patient Associations published in October, 2012, by Janssen in Belgium.  Here's what that toolkit says about moderation:
Comments from members of your network build credibility and a sense of community. However, while generally rare [my emphasis], comments may be inappropriate or irrelevant, or reflect negatively on an individual, and require some form of moderation. The moderation process should be objective and impartial and avoid the perception that comments are unethically censored. Some social media sites do not allow comments to be moderated before being published so a dedicated resource for checking social media sites daily may be necessary. It is advisable to engage settings to review and approve comments before they are published, if available. This allows timely response to comments, deletion of spam and blocking of serial pests. If moderating comments, be upfront and include a notice on the site which encourages participation and a diversity of views, requests that comments are constructive and notifies the community that the organisation reserves the right to moderate.
In addition, Janssen in Belgium recognizes that social media requires a commitment of time and resources.
"Establishing a normal pattern of use will take time and will differ across organisations. Realistically, it will be more than a few minutes per day, and, depending on your organisation’s objectives, could take 20 minutes or a couple of hours per day if you are trying to encourage participation and activity. It may not be possible to manage replying to all conversation threads and comments. If this is the case, reply to themes, incorporating responses to similar posts in a general summary response. Direct messages and questions should be addressed individually and promptly, which requires time."
Yet, other Janssen affiliates have not followed this advice.

Read more »

Friday 23 January 2015

Transparency is Good in Theory, But Not in Practice

I attended SMi's Social Media in the Pharmaceutical Industry conference this week and, as usual whenever I attend these conferences in the UK, I meet some very interesting people and get a new perspective on important issues that usually are not discussed in the U.S.

Take ethics, for example. I touched upon that topic in my presentation ("The Sorry State of Pharma Mobile Apps and What to Do About It"). But the presentation by Nick Broughton (@NickBroughton) was 100% devoted to "implementing social media ethics" in the pharmaceutical industry.

One of the principles Broughton espoused was "the first obligation is to act morally, not just compliantly." Pharma's first obligation, said Broughton, is to "act well. There's no defense if you make a mistake, especially in social media. When the rules are not clear -- and often they're not -- you have to rely on moral principles to make decisions that you can justify."

One of the moral principles discussed by several presenters at the conference was "transparency," which is very important for the industry these days. Everyone at the conference, I'm sure, would agree with EFPIA (the European Federation of Pharmaceutical Industries and Associations):  "The pharmaceutical industry recognises that it has a responsibility to show leadership in advancing responsible transparency."

The problem, I soon learned, is that transparency is good in theory, but not in practice when it comes to revealing payments to patient bloggers who "contribute" content to pharma-owned sites.

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Friday 16 January 2015

FDA Says It Will Not Regulate Low-Risk Mobile Health Apps as Medical Devices

"CDRH [FDA's Center for Devices and Radiological Health] does not intend to examine low risk general wellness products to determine whether they are devices within the meaning of the FD&C Act," says a new guidance posted today on the FDA website ("General Wellness: Policy for Low Risk Devices. Draft Guidance for Industry and Food and Drug Administration Staff").

Recall FDA's "Mobile medical apps Proposed Scope for Oversight" pyramid:


There are three parts of the pyramid:
  1. The top of the pyramid includes mobile medical apps that are traditional medical devices or a part or an extension of a traditional medical device. Clearly within the scope of being regulated as medical devices. 
  2. The middle section includes patient self- management apps and simple tracking or trending apps not intended for treating/adjusting medication. This is the area, as defined by CDRH, for enforcement discretion 
  3. The bottom section are devices that are not deemed “mobile medical apps” and, as such, have no regulatory requirements.
The guidance released today is an attempt to define the boundary between parts 2 and 3 of the pyramid and to clarify what FDA meant in a 2012 guidance when it said this:

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Thursday 15 January 2015

"Innovative" Pharma Marketing Is Not Viral

Several recent articles and blog posts have claimed there is a lack of "Innovation" among pharma marketers who are afraid to "rock the boat."

World of DTC Marketing blogger Rich Meyer, for example, blames pharma’s “conservative” legal/regulatory people for preventing DTC marketers from being more innovative. He would like to see pharma marketers focus more on innovative digital and social media channels. But pharma marketers are afraid to do that because there is less guidance from the FDA and thus more chance that they will inadvertently run afoul of the regulators (read "2014 was a Good Year for FDA & Pharma").

Another consultant - Mark Schnurman, founding partner of Filament - writing in a MM&M article, advises agency people to "try new ideas" and "find a backdoor through which you can let your risky idea see the light of day." Mr. Schnurman cited K-Mart's viral “ship my pants” campaign as an example of a risky idea that saw the light of day and succeeded.

First of all, isn't K-Mart dead in the water? Bad case study, Mark. But there's another reason why the "ship my pants" campaign is a bad example for pharma marketers to follow and it has nothing to do with regulations.

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Wednesday 14 January 2015

LAP-BAND's Social Media Campaign Definitely Violates FDA Guidelines

I heard that a number of participants at the 33rd Annual J.P. Morgan Healthcare Conference in San Francisco were "baffled" by LAP-BAND's social media campaign. LAP-BAND, marketed by Apollo Endosurgery, is a medical device that is inserted surgically around the stomach to reduce its capacity and thus aid in weight loss.

LAP-BAND has a limited indication: "for weight reduction for patients with obesity, with a Body Mass Index (BMI) of at least 40 kg/m2 or a BMI of at least 30 kg/m2 with one or more obesity-related comorbid conditions." It also has a number of possible adverse events such as "band slippage, erosion and deflation, reflux, obstruction of the stomach, dilation of the esophagus, infection, or nausea and vomiting may occur."

It seems that several tweets posted by the @LAPBAND Twitter account violate recent FDA "Guidance for Industry Internet/Social Media Platforms with Character Space Limitations— Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices" (here).

First, here's what the @LAPBAND Twitter page looks like:

Click on image for an enlarged vie.

You can SEE - but you probably can't READ - the Important Safety Information (ISI) in the upper right corner. Technically, I suppose this satisfies FDA requirements that ISI must accompany branded Rx and medical device ads that mention benefits of the product.

But it's the tweets themselves that FDA should be looking out. Let me explain why.

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Saturday 10 January 2015

Brand Update : Moods wants you to Play It Right

After around three years, Moods have come out with another campaign. The new campaign themed " Play it Right" is also a sort of repositioning for the brand. In the last campaign, the brand adopted a naughty " Your Time, Your Place " positioning.

The new campaign   themed around the man who is playing it right takes the focus back to the man. In one of the earlier campaign - My Man, the campaign put the focus on the women which made the campaign standout from the rest of the crowd. The " Your time, your place " was a clutter-breaking campaign with a touch of humor. 
The new campaign - Play it Right is neither clutter- breaking nor humorous. The theme of a smart man getting what he wants is a much used theme and Moods have not done anything different in terms of execution. 

Watch the ad here : Moods- Play it Right
The brand could have brought some kind of creativity into the ads rather than depending on the old theme with a careless execution. 

According to Economic Times, the Indian organized condom market is worth around Rs 700 crore . Mankind leads the market with a share of 28 % . Moods is trailing in the fourth place with 12% share. 

Friday 9 January 2015

Are Online Peer-to-Peer Physician Discussions Overrated?

Congrats to Thibaud Guymard (@thibaudguymard), Digital Marketing Manager at MSD France, and his Comuniti team for winning the Prix Or de la Communication Médicale & Hospitalière in Paris at the yesterday.


Comuniti is a online community lunched in early 2014. It is part of MSD France's Univadis service exclusively for healthcare professionals.

"Contact your colleagues and talk exclusively with health professionals," says the Comuniti promo. "Work with your colleagues in public or private groups. Ask medical questions and find precise answers."

These capabilities offered by Comuniti are a first for Univadis, which has been around for a long time (listen to this podcast: "What is Univadis?").

Of course, it has to compete with other, similar services offered by independent companies and organizations. But MSD France hopes that Comuniti, coupled with the heaps of content available through Univadis, will be a magnet for French HCPs.

But are HCPs really interested in having discussions with their peers on so-called "peer-to-peer"  physician networks? I discussed this with Jeff Tangney, CEO & Founder, Doximity, and Shona Davies, Global Communications & Programme Leader for Univadis worldwide. You might be surprised at what they have to say about the value of online physician peer-to-peer discussions.

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Wednesday 7 January 2015

FDA's 2015 Guidance Agenda - Just Like the 2014 Agenda - Promises Publication of Guidance Regarding Use of Links to 3rd-Party Internet Sites

FDA/CDER has published its 2015 Guidance Agenda (here). Here's what's under the Advertising Category:
  • Brief Summary and Adequate Directions for Use: Disclosing Risk Information in Consumer-Directed Print Advertisements and Promotional Labeling for Human Prescription Drugs
  • Direct-to-Consumer Television Advertisements – DTC Television Ad Pre-Dissemination Review Program for Human Drugs
  • Health Care Economic Information in Promotional Labeling and Advertising for Prescription Drugs Under Section 114 of the Food and Drug Administration Modernization Act
  • Internet/Social Media Advertising and Promotional Labeling of Prescription Drugs and Medical Devices – Use of Links to Third-Party Sites
  • Manufacturer Communications Regarding Unapproved Uses of Approved Medical Products
  • Providing Regulatory Submissions in Electronic and Non-Electronic Format – Promotional Labeling and Advertising Materials for Human Prescription Drugs
Some of these guidances -- such as the DTC Television Ad Pre-Dissemination Review Program guidance -- have already been released as draft documents (see, for example, this review). I suppose the FDA is planning on publishing "final" guidance documents based on comments to the draft documents. Or maybe just "revised" draft documents.

I highlighted one item on the list having to do with "Internet/Social Media Advertising" -- Use of Links to Third-Party Sites. This was also on FDA's 2014 Guidance Calendar, but as we know no guidance was issued in 2014.

Perhaps none will be issued in 2015 either. Why not?

Read more »

Sunday 4 January 2015

Pril : Nurturing Relationship by Washing Dishes Together !

Brand : Pril
Company : Jyothy Laboratories

Brand Analysis Count : # 553

Pril is the brand which created the dishwash liquid category in the Indian market. A brand globally owned by Henkel  was created in 1951. Sold in over 22 countries, the brand was launched in India in 1999. At that time, the brand was owned by Henkel India which was the subsidiary of Henkel AG. In 2011, Henkel India sold its brands ( in India) to Jyothy Laboratories Ltd. 

Pril was the pioneer in the liquid diswash category. The Rs 10,000 crore Indian dishwash category was dominated by the dishwash bar product-form. The bar product-form had its own limitations like being soggy and messy. Pril saw a need for a hygienic upmarket alternative for the soggy dishwash bars. Pril was launched as a hygienic alternative to the dishwash bars. The brand was launched with the positioning of " tough on grease , soft on hands " platform. 

The journey of the brand was never easy. Its difficult to change the habits of the consumers. According to Business Line  the liquid form of dishwash is used by on 15 % of the consumers. Although the potential seems to be high, to create the shift from one product form to another is not an easy task.
To break the strong-hold of the dishwash bar product form, Pril  entered the market with follwoing product attributes
  • Strong de-greasing property - establishing parity with bars
  • Fragrance ( De-odorizing ability) - established point of difference 
  • Germ killing capability - established point of difference.
  • Hygienic - established point of difference with bars.
The efforts of the brand reaped rewards in creating a category that was growing more than the traditional bar-product form. The brand has created a shift from the soap form to the liquid form in certain segments of the market.
According to Business Standard, Pril now have a market share of over 16 % growing at 26% p.a. The brand is estimated to be worth around Rs 450 crores. 
The brand used a direct comparison with the dishwash bar product category in its campaigns. The brand used celebrities like Sonali Bendre and Shobhana in its ads . In the earlier campaigns during 2009-13 , the brand highlighted its de-greasing and de-odorizing attributes to create a point-of-difference while highlighting the soggyness of the dishwash bar category.
The brand last year tried to ladder up its pitch into relationship. In the latest campaign featuring the new-generation couples, the brand is trying to appeal to a higher level attribute of " relationship".
One may wonder how a dishwash product can " nurture relationship " but Pril claims that by sharing common household chores like washing dishes together, one will further strengthen relationship. The brand uses the tagline " Bartan Chamkein, Aur Ristey Bhi "  meaning  - both utensils and relationship will sparkle. 


The campaign is well made and the brand has to be credited to think beyond just product attribute. Laddering is a risky strategy since the higher-order attribute should be clearly linked to the brand. In this case, the brand was able to establish that link in a beautiful manner. The campaign also gives an upmarket feel to the product. So much for a product like dishwash liquid !

Pril although the first mover in the liquid dishwash market is not having a wonderful time. The category competition is intense with fewer options to create sustainable differentiation. The laddering up of Pril in a way is a smart move to create some amount of visibility in the crowded market. 

Friday 2 January 2015

2014 Was Another Record Year for FDA: Fewest Number of Untitled/Warning Letters Ever!

In 2014, the FDA approved 41 new drugs -- the most since 1996 (see here). That's quite a "record" even if 37% of the approvals were made in December alone.

But FDA wasn't as anxious to set any advertising enforcement records in 2014. The Agency sent out only a meager 9 Untitled Letters and 1 Warning Letter last year (see chart on left).

Could the reason for this be that pharmaceutical marketers are getting better at complying with FDA regulations?

Or is the FDA afraid of being sued by the pharmaceutical industry in the wake of the 2012 Caronia decision in the U.S. Second Circuit that found off-label promotion was protected by free speech?

Or perhaps FDA depends more and more on "user fees" paid by the drug industry and does not want to "bite the hand that feeds it"?

I think the latter is the most likely explanation. Read on to learn why.

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