Boehringer Ingelheim: Pradaxa website landing page alleged public promotion (AUTH/3329/3/20) – No breach | PMCPA Case

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Key facts

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Case number	AUTH/3329/3/20
Complainant	Concerned UK health professional (anonymous)
Company	Boehringer Ingelheim
Medicine	Pradaxa (dabigatran)
Channel/material	pradaxa.co.uk landing page (ref PC-UK-100029 V1)
Allegation	Promotion of a prescription-only medicine to the public via a patient/public website route
Applicable Code year	2019
Clauses considered	2, 9.1, 26.1
Panel decision	No breach
Complaint received	14 April 2020
Case completed	1 July 2020
Appeal	No appeal

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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A UK health professional complained about the pradaxa.co.uk landing page, which showed two routes: one for UK health professionals and one for “Patients Prescribed Pradaxa/Members of the Public”.
The complainant alleged that inviting patients/members of the public to click for more information constituted promotion of a prescription-only medicine (Pradaxa/dabigatran) to the public.
Boehringer Ingelheim said the site was primarily promotional for health professionals, but because it was open access it provided a clearly separated public/patient section to divert non-HCPs away from HCP promotional content.
Boehringer Ingelheim stated there were no outbound communications directing the public to the site; public access would typically be via internet searches for “Pradaxa” or “dabigatran”.
The company said the public/patient button led to non-promotional, factual reference information, including a short overview, possible side effects, and links to PILs, SPCs, a patient alert card (via eMC), and the EPAR (via EMA).

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No breach of Clause 26.1 (advertising prescription only medicines to the public).
No breach of Clause 9.1 (high standards).
No breach of Clause 2 (discredit to the industry).
The Panel considered the complainant had not discharged the burden of proof that the public/patient information constituted promotion.

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