Janssen Response website: prescribing information link required two clicks and misleading ‘third-party’ disclaimer

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Key facts

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Case number	AUTH/3385/9/20
Complainant	Contactable complainant (concerned UK health professional)
Company	Janssen
Material	Janssen Response website landing page (janssenresponse.co.uk) and PI link journey via disclaimer page to janssen-pi.co.uk
Products	Xeplion and Trevicta (paliperidone for injection formulations)
Main issue	PI access required two clicks; disclaimer inaccurately described destination as third-party
Applicable Code year	2019
Complaint received	09 September 2020
Case completed	16 February 2021
Breach clauses	Clause 4.4; Clause 7.2
No breach clauses	Clause 9.1
Sanctions	Undertaking received; additional sanctions: Not stated
Appeal	No appeal

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

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A UK health professional complained about Janssen’s Response website landing page (janssenresponse.co.uk), which included links to prescribing information (PI) for Xeplion and Trevicta.
Clicking a PI link first opened a disclaimer page stating the user was being directed to a “third-party website”.
The user then had to click “Go to link” to reach the PI on another Janssen-owned site (janssen-pi.co.uk).
The complainant alleged (1) the “third-party” statement was wrong because the destination was Janssen-controlled, and (2) the extra click meant PI was not accessible via a single click as required.
Janssen said the site supported two schemes (XRS and TOPS) and that only HCPs with log-in credentials could access content beyond the landing page; the landing page itself could be found via web search.
Janssen said the disclaimer wording was intended to reflect Clause 28.6 (making clear when leaving a company site), because the PI was hosted on different servers, and stated it would redesign the site to remove the two-click issue.

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Breach of Clause 7.2: the disclaimer was inaccurate in stating users were being directed to a third-party website when the destination was Janssen-owned.
Breach of Clause 4.4: PI was not accessible by inclusion or a clear and prominent direct single-click link; two clicks were required.
No breach of Clause 9.1: the Panel did not consider the particular circumstances meant high standards had not been maintained.
No appeal.

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