AUTH/3543/7/21: Novo Nordisk v Eli Lilly – ‘Barber’s Box’ GLP‑1RA comparison presentation (Trulicity) | PMCPA Case

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Key facts

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Case	AUTH/3543/7/21
Parties	Novo Nordisk v Eli Lilly and Company Limited
Product	Trulicity (dulaglutide)
Material	Presentation: ‘Barber’s Box comparison of GLP‑1 receptor agonists’ (PP-DG-GB-0573, January 2020)
Audience	Health professionals treating patients with type 2 diabetes
Main issue	Misleading comparative impression from shaded “Barber’s Box” visuals and selective CVOT subgroup statements implying advantage without adequate caveats/substantiation
Applicable Code year	2019
Complaint received	19 August 2020
Case completed	11 August 2022
Appeal	No appeal
Breach clauses	7.2; 7.3; 7.4; 7.8
Sanction(s)	Undertaking received
Slide deck status	Retired on 26 March 2020

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

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Novo Nordisk complained about Eli Lilly’s promotional presentation, ‘Barber’s Box comparison of GLP‑1 receptor agonists’ (PP-DG-GB-0573, January 2020), used to compare dulaglutide (Trulicity) with liraglutide (Victoza) and semaglutide (Ozempic).
The slide deck used a shaded “Barber’s Box” framework (efficacy, safety/tolerability, cost, patient factors) to visually indicate comparative favourability.
Novo Nordisk alleged the deck cherry-picked SPC content and selected data, used subjective shading, and drew ambiguous conclusions—particularly around cardiovascular outcome trials (CVOTs) and subgroup analyses.
The Panel focused on whether the visual shading and selected CVOT subgroup statements implied advantages that were misleading and not adequately supported on the slides themselves.
The slide deck at issue was retired on 26 March 2020.
Administrative note: although the complaint was received in August 2020, it was not processed until July 2021 due to an error.

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Breach rulings: Clauses 7.2, 7.3 and 7.4 (misleading / substantiation issues linked to insufficient information and caveats around shaded comparative boxes), and Clause 7.8 (misleading implication of advantage from selective CVOT subgroup presentation).
No breach rulings (as alleged): certain narrow allegations under Clauses 7.2, 7.3, 7.4, 7.8, 7.9 and 9.1 were not established on the specific points raised (including some claims about Slide 22 shading, omission of certain safety comparisons, pen numbers, and the principle of using the framework itself).
No appeal.

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