AUTH/3381/9/20: Boehringer Ingelheim – Trajenta digital banner ad (no breach) | PMCPA Case

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Key facts

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Case number	AUTH/3381/9/20
Company	Boehringer Ingelheim Limited
Complainant	Concerned UK health professional
Product	Trajenta (linagliptin)
Material / channel	Dynamic digital banner advertisement (“crawler” banner) on Guidelines in Practice website
Ad reference	PC-GB-101179
Main allegations	Claim not consistent with licence (“for a broad range of adults with type 2 diabetes”); PI location statement too small/fast to read; “Unique convenience… one dose, once daily” misleading
Company position (summary)	PI/AE link static on every frame; “broad range” consistent with adult MA and SPC; “unique” in context of type 2 diabetes dosing characteristics; SOP and certification in place
Applicable Code year	2019
Clauses considered	3.2, 4.1, 7.2, 7.4, 9.1
Panel decision	No breach of Clauses 3.2, 4.1, 7.2, 7.4, 9.1
Complaint received	10 September 2020
Case completed	22 March 2021
Appeal	No appeal
Sanctions	None stated

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

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A UK health professional complained about a Trajenta (linagliptin) dynamic digital “crawler” banner ad (ref PC-GB-101179) on the Guidelines in Practice website.
The banner used headlines including “Simplicity” and “Reinforced” and the claim “for a broad range of adults with type 2 diabetes”.
The complainant alleged the banner text on the right-hand side (including where prescribing information could be found) was too small and cycled too quickly to read.
The complainant also challenged the claim “Unique convenience through always one dose, once daily”, arguing Trajenta was not the only medicine dosed once daily (citing Cerazette as an example).
Boehringer Ingelheim stated the banner had five rotating frames (~3 seconds each; ~15 seconds total), and that the prescribing information and adverse event reporting link were present on the right-hand side of each frame and were static throughout.
Boehringer Ingelheim argued “broad range” reflected the marketing authorisation in adults (including no dose adjustment/caution needed for elderly or adults with renal/hepatic impairment per SPC section 4.2), and “unique” was meant in the context of type 2 diabetes treatments (one dose once daily regardless of renal/liver function or age, no initiation dose, no dose adjustments).

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No breach of the Code was ruled.
No breach of Clause 4.1: Panel considered the complaint was not that prescribing information was absent, but that the link was allegedly too small/fast; Clause 4.1 was therefore not considered relevant to the allegation as framed.
No breach of Clause 9.1: On balance, and given uncertainty about how the banner appeared on the complainant’s device, the Panel did not consider the link to prescribing information was too small or cycled too rapidly to be read.
No breach of Clause 3.2: The complainant did not provide reasons/evidence showing “for a broad range of adults with type 2 diabetes” was inconsistent with the SPC; burden of proof not met.
No breach of Clauses 7.2 and 7.4: The complainant did not show the “Unique convenience…” claim (in the context of type 2 diabetes) was misleading or incapable of substantiation.

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