Tetris Pharma: LinkedIn sponsored message for Ogluo reached a non-HCP (public promotion) and lacked required safety/INN elements

📅 2021 | 🖉 Dr Anzal Qurbain
📊

Key facts

CaseAUTH/3745/2/23
CompanyTetris Pharma
ProductOgluo (glucagon)
ChannelLinkedIn sponsored message (inbox messaging format)
Main issuePromotion of a prescription only medicine to a member of the public
Secondary issuesMissing non-proprietary name adjacent to brand name at first appearance; missing prominent adverse event reporting statement in message body
Applicable Code year2021
Breach clauses5.1, 12.3, 12.9, 26.1
Complaint received08 February 2023
Case completed03 April 2024
AppealNo appeal
SanctionsUndertaking received (additional sanctions: Not stated)

Download the full case report (PDF)


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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI
📋

What happened

  • A named complainant (not a health professional) received a LinkedIn sponsored message (Feb 2022) promoting Ogluo (glucagon), a prescription only medicine.
  • The message introduced Ogluo, described product features (ready-to-use pen, room temperature stability, licensed from age 2+), and suggested potential health-economic benefits (eg reducing ambulance call outs).
  • The message asked to chat about which “patients could benefit” and included a link to prescribing information.
  • The complainant alleged: (1) promotion of a POM to the public, (2) no non-proprietary name adjacent to brand name at first mention, and (3) no adverse event reporting statement in the message body.
  • Tetris said the campaign was targeted to UK healthcare professionals using multiple LinkedIn criteria (location + job title/company + skills/field of study), and that the format was private inbox messaging (not shareable like feed ads).
  • Tetris accepted the missing non-proprietary name at first appearance was due to human error during review/approval and uncertainty about how the subject line would appear.
  • Tetris accepted the adverse event reporting statement was not in the message body (it was one click away in linked prescribing information) and said later PMCPA guidance clarified this was not sufficient.
  • Tetris denied failing to maintain high standards and denied public promotion, arguing it took reasonable steps to target HCPs only.
⚖️

Outcome

  • Breach of Clause 26.1 (Promoting a prescription only medicine to the public).
  • Breach of Clause 12.3 (Failing to include the non-proprietary name immediately adjacent to the brand name at its first appearance in an electronic advertisement).
  • Breach of Clause 12.9 (Failing to include the prominent adverse event reporting statement).
  • Breach of Clause 5.1 (Failing to maintain high standards).
  • No appeal.
🔒

Unlock the full case analysis

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value
£249/year
Annual — save £99
or
£29/mo
Monthly
Join Now — Instant Access

⭐ Charter Member — Until 31 March

See the full compliance picture for every pharma company

291 Company Intelligence Reports — breach patterns, appeal history, industry ranking, PDF export. £1,999/year £2,499

Get Charter Access →

📰 Weekly PMCPA Case Breakdown

One real case. One key lesson. Every week — free.

Subscribe Free