Direct-to-Consumer Advertising: Have We Got a Deal for You!

Medicis Pharmaceutical, the maker of Dysport a drug approved by the US Food and Drug Administration (FDA) to smooth skin furrows between the eyebrows, recently introduced a marketing campaign that offers people who use Dysport drug discounts and a patient satisfaction rebate guarantee. The campaign, which runs through April 30, was intentionally designed to elevate Dysport’s image and cannibalize market share in the anti wrinkle market from Allergan the maker of Botox and the market leader.

The Dysport promotion, running on the product’s Web site and in a few glossy magazines like Us Weekly, offers a $75 rebate check on an initial Dysport treatment for wrinkles between the eyebrows, a procedure that can cost consumers $300 to $500. Satisfied customers can receive a $75 rebate on a follow-up Dysport treatment, while dissatisfied customers who want to switch can receive a $75 rebate on a Botox treatment.

While this is an unprecedented and novel campaign, it demonstrates the lengths that Medicis is willing to go through to garner market share from Botox which enjoyed a monopoly on injectable toxins in the US until the introduction of Dysport last year. Last year, worldwide sales of Botox were roughly $1.3 billion. Industry analysts estimate that Medicis may be able to capture a 20 to 25 percent share of the US market.  

While the marketing campaign may seem a bit odd and brash, Medicis isn’t the first pharmaceutical company to use rebates and drug discounts to inspire patient brand loyalty. For example, Sepracor offers a seven-day free trial of its popular sleeping pill Lunesta. Merck is running a print ad with a voucher for a free 30-day supply of its Januvia tablets for Type 2 diabetes. Another Merck ad carries a $20 coupon for the allergy and asthma drug Singulair. However, the use of product rebates and drug discounts is mostly used to market so-called vanity medicine drugs (like Latisse, Botox and Dysport) which have been approved by FDA for clinical use but are not covered by medical insurance. Patients who use these drugs are paying out of pocket and, in essence, are buying from physicians. Many worry that this practice may induce doctors and patients to make medical decisions based on money not safety or efficacy. 

In the case of Botox and Dysport neither product is entirely risk free. For those of you who may not know, both are purified forms of botulinum toxin — a toxin produced by Clostridium botulinum that interferes with nerve transmission and involuntary muscle contractions. The injections cause temporary cosmetic problems like droopy eyelids or uneven eyebrows. And these drugs now carry federally mandated “black box” warnings on their labels stating that botulinum toxins have been associated with rare but potentially life-threatening health problems.

Although promotional programs like the one being offered by Medicis may be inappropriate or seemingly reckless, it—like those of Sepracor and Merck—are permissible under current direct-to-consumer (DTC) advertising regulations. Isn’t it time to reevaluate regulations that allow powerful, potentially-dangerous prescription drugs to be treated as consumer goods where price, not medical need, safety or efficacy, promotes their acceptance and use?

Until next time...

Good Luck and Good Looking!!!!!!!!!!

Allergan Sues FDA over Wrinkle in Off Label Use of Botox

Allergan, the maker of Botox and Latisse sued the US Food and Drug Administration (FDA) in federal court yesterday because it believes that regulations banning off label promotion of prescription drugs violates the company’s right to freedom of speech and impedes its ability to provide physicians with information regarding patient safety.

The company contends in a lawsuit filed Thursday that it should be able to educate doctors about the risks and benefits of using treatments for unapproved uses. Botox is approved for several uses by the Food and Drug Administration. In addition to its use as a wrinkle treatment, it is approved for eye muscle disorders and excessive underarm sweating. But physicians often use it for unapproved, or off-label, indications including muscle-spasm conditions.

The impetus for the lawsuit is an FDA requirement that the company provide new risk information education to physicians on Botox as a therapeutic treatment. According to an Allergan spokesperson, "Our reason for seeking action now relates to the fact that we have recently been required by FDA to initiate a REMS (Risk and Mitigation) program for Botox to ensure that physicians are equipped to evaluate the risks and benefits of treatment." In April, health officials warned doctors and patients about potentially deadly risks of using Botox and similar drugs for unapproved uses to treat certain types of muscle spasms. The drugs carried risks of rare botulism symptoms, particularly when given to children to help relax uncontrollable muscle movements.

Allergan estimates that 20% of Botox usage is off-label for unapproved indications. Because of this, the company believes that it is important to “proactively provide comprehensive information to physicians about these off-label uses, such as dosing guidelines, patient selection criteria and proper injection technique to ensure that physicians are equipped to treat patients as safely and successfully as possible. And, “without judicial relief, Allergan is unable to engage in a truthful and relevant information exchange with the medical community for fear of prosecution." 

It sounds to me like the lawsuit is more about increasing the annual sales of Botox for a growing number of unapproved indications rather than ensuring patient safety. These types of lawsuits have becoming increasingly popular because of previous legal precedent that extends an individual’s right to freedom of speech to corporations and other entities. However, more importantly, if Allergan is successful, it could signal the end of the regulations and ban on off label promotion of prescription drugs and devices. Is eliminating a few wrinkles from aging baby boomers (like me) worth all the trouble?

Until next time...

Good Luck and Good Job Hunting (hmm...maybe if I look younger I might be able to find a job?)

 

Brooke Shields Is Hawking Latisse for Allergan

I was in the gym the other day, trying to regain my “girlish figure,” and I happened to see Brooke Shields in television ad hawking Latisse, the new eye lash-enhancing prescription medication from Allegan. For those women (or men for that matter) who haven’t heard, Latisse was recently approved for hypotrichosis of the eye lashes. Hypotrichosis is medically-defined as a reduced amount of hair, and in this case, it refers to eyelashes. Who knew that reduced eyelash hair was a burgeoning unmet medical need? Anyway, back to Brooke.

I like Brooke Shield and I think that her very personal and public account of her struggles with postpartum depression after the birth of her first child was courageous and laudable. And, I thought she was pretty damn good in Pretty Baby and the Blue Lagoon too. But, I question her decision to use her celebrity among women to promote a prescription drug that was approved almost exclusively for cosmetic use. Yes, I know that women’s cosmetics are a multibillion industry and woman worldwide work hard to get longer and fuller lashes. But, this begs the question: Are the possible health risks associated with Latisse—an attenuated form of botulism toxin used in Allergan’s anti-wrinkle treatment Botox—worth it, simply to get longer and fuller lashes; a look that can be achieved by daily application of non prescription and much cheaper mascara? Again, as is the case with most women’s healthcare choices, the decision should be left up to individuals.

Personally, I hope that Brooke’s eyebrows—which were quite formidable back in the day—remain as manageable as they appear to be today after using Latisse to thicken her eyelashes. Not that there is anything wrong with thick eyebrows!

Until next time...

Good Luck and Good Job Hunting!!!!!!!  

 

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The Curious Case of Wrinkles, Botox and FDA

One day after the US Food and Drug Administration (FDA) approved Dysport, a new product that will compete with Botox, the agency ordered that labels for all botulinal toxin-based drugs must carry a black box safety warning. For those of you who may not know, that is the most stringent kind of safety warning label—viewed by many in the industry as “the kiss of death”— that the agency can order to appear on the products that it regulates. 

Black boxes (literally a black box with bold-face risk information) are typically reserved for medications that are know to have serious or life-threatening side effects or risks. For example, many antidepressants—most recently serotonin re uptake inhibitors (SRIs)—carry black box warnings of increased danger of suicidal thoughts and actions. 

Over the last 20 years FDA approved Botox to treat crossed eyes, eyelid spasm, severe underarm sweating and cervical dystonia (a painful and severe neck condition that can cause an abnormal head position) Cosmetic Botox was approved to treat skin folds and wrinkles in 2002. Allergan, the company that manufactures Botox, reported $1.3 billion in worldwide sales of the drug in 2008. 

Botox and Dysport are injectible products made from the highly paralytic toxins produced by the bacterium Clostridium botulinum. Botulinal toxins interfere with muscle contractions and patients with botulism food poisoning exhibit what is known as “flaccid paralysis.” Afflicted individuals cannot breather and will die without early intervention. FDA order the black box safety warning labels because there were numerous reports of serious health problems, complications and deaths caused by the drug spreading from the site of injection to other parts of the body. 

Most of the problems with Botox resulted from the overuse of Botox for unapproved treatments like limb spasticity in children with cerebral palsy (although misuse of the product for cosmetic purposes may have also contributed to the problems). The agency will now require that all botulism-based products carry a black box warning explaining that the medication has the potential to spread from the site of injection to other body sites—with the potential to cause serious problems like difficulties swallowing or breathing. Also, it will require manufacturers of botulinal products [Allergan (Botox) and Ipsen/Medicis Pharmaceuticals (Dysport)] to send physicians letters warning of the risks and to craft medical guides given to patients at the time of injection. 

The new warning labels will likely do little to discourage the rampant use of Botox and Dysport for cosmetic indications. After all, beauty will always come before safety! 

Until next time... 

Good Luck and Good Job Hunting (looking younger may help)

 

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Hello Gorgeous: Move Over Botox, Latisse Is Here!

Allergan, the drug maker that brought us Botox is at it again! The company has a new FDA-approved drug called Latisse that can be used to grow longer, lusher eyelashes. It will be available by prescription at the end of this month.

Latisse contains the same prostaglandin analog that is found in Allergan’s Lumigan, an eye drop treatment for glaucoma. A side effect of the analog is to make the eyelashes of many patients who use the eye drops longer and fuller. Other side effects can include red, itchy eyes and changes in eyelid pigmentation.

Allergan conducted a 16 week clinical trial with about 280 volunteers to assess the safety and efficacy of Latisse. In the study, half of the participants used Latisse daily for 16 weeks. Study results showed that the eyelashes of patients treated with Latisse typically grew 25 percent longer, 106 percent thicker and 18 percent darker. While 3.6 percent of patients experienced eye itching and red eyes, none exhibited a change of eye color. These results were reviewed by the Food and Drug Administration, which approved the drug in late December, 2008.

While some medical experts are concerned about these Latisse’s side effects, the financial upside for the drug is considered by some analysts to be substantial. At present, the annual size of the worldwide mascara market is about $5 billion. Allergan expects sales of Latisse to eventually rival those of Botox —Allergan’s other FDA-approved drug used for therapeutic and cosmetic purposes. Sales for cosmetic use of Botox were $600 million in 2007.

Longer, lusher lashes will come at a price for the people who chose to get a prescription for Latisse. Unlike mascara which is relatively inexpensive (so I am told), a monthly dose of Latisse will cost $120. However, according to my wife, longer, lusher lashes are the equivalent of the Holy Grail for most women. When I mentioned the Latisse’s monthly cost, she said quickly replied “I don’t care. I would still do it”—this from a woman who rarely wears any make up. Although my wife doesn’t constitute a valid statistical sample size, her responses suggests that Latisse just might be the biggest thing to hit cosmetic medicine market since well—uh— Botox!

Until next time…..

 

Good Luck and Good Job Hunting (try Allergan, they are hiring!)

 

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The Demise of RNAi?

There is mounting evidence that RNAi, once hailed as a panacea for the pharmaceutical and biotechnology industries, may not be all that it was claimed to be. Yes, there are several new RNAi drug candidates in late stage clinical development but it isn’t clear, at this point, whether any of these products will ever make it to market. Companies like Allergan, Alnylam, Opko Health and Merck, which recently bought the RNAi company Sirna Therapeutics for $1.1 billion, have invested hundreds of millions of dollars and literally “bet the farm” on RNAi therapeutics.

The use of DNA and RNA as therapeutics is not a new or novel idea. Isis Pharmaceuticals, a pioneer and champion of oligonucleotide therapeutics, has only be able to bring a single, oligonucleotide-based product to market in the past 20 years. Ask any Isis executive and they will tell you that turning DNA or RNA into drugs is a challenging process that is fraught with many difficulties. Most notably, there are bioavailability, delivery and target specificity hurdles that most be over come before the utility of these drugs as therapeutic agents can be realized. That said the attractiveness of these molecules as therapeutics (and perhaps their real danger) is the simplicity and elegance of their mechanism(s) of action. Most scientists tend to “fall in love” with elegant and parsimonious solutions to complex processes—why would we not, they are type of discoveries that we all train and live for! And, as many of us know, when people “fall in love”, there is a tendency to overlook or not notice warning signs that things may not be as they seem.

The scientific community fell quickly and deeply in love with RNAi soon after the first papers appeared touting its benefits and possible therapeutic applications. Scientists were so convinced and confident about RNAi that they induced the financial community to invest billions of dollars into the emerging technology. The love and affection for RNAi reached its pinnacle in 2006 when two scientists, who played a crucial role in discovering its mechanism of action, won the Nobel Prize. Since then, the harsh realities of RNAi drug development have begun to be realized by companies that invested in the technology.

I have been around long enough to understand that there are fads in science. In the mid 1990s it was combinatorial chemistry, in the late 1990s it was genomics, proteomics and computational chemistry and in the 2000s it is RNAi. Don’t get me wrong–all of these technologies have helped to advance science and  provide researchers with sophisticated tools that have helped to expedite the drug discovery and development process. That said, none of these technologies, by themselves, yielded the plethora of new medications or therapeutics that their advocates promised. Industry veterans know that there are no easy solutions or panaceas in drug discovery and development. The process is inherently time-intensive, painstaking and tedious. And, despite what we scientists want to believe in our “heart of hearts,” there are no guarantees that simplicity and elegance will translate into safe and effective medications.

Until next time….

Good Luck and Good Job Hunting!!!!!!!!!!

Allergan to Close a Botox Manufacturing Plant in Ireland

Allergan Inc., the maker of Botox, will close a plant in Ireland, eliminating 300 jobs, and transfer production to a factory in Costa Rica.

Ireland has lost about 10 percent of its manufacturing jobs over the last six years, as labor costs climb. As many of you may know, many US pharmaceutical and biotechnology companies set up production facilities in Ireland over the past 10 years or so because of its well trained workforce and lower labor costs.  However, because the Irish economy has grown so quickly and its middle has prospered, labor costs have been rising and manufacturers are now looking elsewhere to control costs. Unfortunately, this is likely to be harbinger of things to come for markets that were once sources of cheap, skilled labor.

Until next time….

Good Luck and Good Job Hunting Lasses and Laddies!!!!!!!!