The Mandelbrotian set is a mathematical concept referring to a grouping of points within a complex plane, which when separated appear as minimized versions of the whole. Nassim Nicholas Taleb mentions Mandelbrot’s theory in his book The Black Swan when discussing the random affinity of nature. Rocks and leaves form the structure of mountains and trees, respectively. Other than scale, the appearance and makeup of a rock is indistinguishable from the qualitative properties of a boulder.
Technology operates in sort of the same way, particularly in the way we connect with one another. In a previous post, I mentioned the decorporeal effect that is achieved when a media object (such as an avatar or a Facebook profile) takes on the characteristics of a person’s identity.
This only happens if digital engagement is achieved with the same level of empathy as one might cultivate through face-to-face or spoken dialog. This requires trust in the digital landscape, the personae who reside within it, and the vehicles by which they interoperate. Often one becomes a subset of the other, thus forming the “social networking” structure we read so much about lately.
As new technologies are introduced, client organizations are increasingly coming to grips with the responsibilities of utilization. Consider how such tools as Twitter have impacted business climates strictly governed by legal and medical regulations. During the opening of this week’s Healthcare Communication & Marketing Association (HCMA) meeting, for example, a number of key thought leaders attempted to define the use of social media within the pharma communication space. Republican Senator Jennifer Beck took on the topic with a comparative case study:
“If our president can make the leap into [social media], we all can,” Beck told the audience. “You should be able to put the right information out there without a million regulations from FDA.”
A day later, what was reported to be the first officially branded tweet in the Pharma space emerged for the insulin product Levemir. Included in the body of the Tweet were the full product brand name and generic equivalent, as was a link to the prescribing information via a truncated URL. A view of the @racewithinsulin profile page reveals that the side effects and fair balance are part of the Twitter wallpaper. Ross Fetterolf, VP Digital Strategy at Ignite Health, called it an “historic day” for the use of social media in this context.
The approach has come under some criticism, however. John Mack reports that the majority of Twitter users don’t use the Web to post or view Tweets, and thus would not be able to see the safety information located in the background of the profile page. Mr. Mack continues his analysis from the point of view of an FDA inspector:
[T]his Tweet does not mention any benefits — it’s essentially what’s called a reminder ad, which is not required to include side effect information because it does not mention any benefits. The FDA does not regulate reminder ads, and it is not likely to cite this Tweet as violative.
However, PhRMA’s DTC Advertising Guiding Principles preclude this kind of ad on TV: “DTC television advertising that identifies a product by name should clearly state the health conditions for which the medicine is approved and the major risks associated with the medicine being advertised.”
Mr. Mack is quick to add that PhRMA has yet to develop guidance or best practice for social media in DTC advertising. Personally, I think it sometimes takes a necessary bold step to stretch the boundaries of what can be done within constraints. And I agree with Mr. Fetterolf’s comment when he says “Pharma is doing its best; baby steps forward shouldn’t be shot down because they might appear awkward.”
Still, Mr. Mack brings up some valid concerns — some technological, some marketing — which I’ll interpret by evaluating the Levemir Tweet as a fractal existing within a larger construct. Consider this a Mandelbrotian approach to understanding social media.
To start with, one must consider the wisdom of placing important safety information in the form of a background image. The image is 1550 pixels high with the bottom of the text content stopping at around 550 pixels. On smaller browser windows, the background image cannot be scrolled along with the list of status Tweets. This results in the lower paragraphs of the fair balance being cut off from the bottom, rendering any text lower than 550 pixels from the top inaccessible if the browser has a lot of chrome.
This tactic would not be extensible to users with visual disabilities, who have trouble viewing pictorial content and often rely on screen-reading software to interpret data on Web pages. For a drug with indications for diabetes (and considering that diabetes is the leading cause of blindness for adults aged 20 to 74 years), this strikes me as a misguidance. If legally-required information is not provided in a textual format, such as ALT text on an image placed within markup, then it is unlikely (if not impossible) to be read.
It is further important to understand that the power of social media is in the act of ensuring ubiquity across as many digital outlets as possible. Twitter’s value should not be interpreted as users viewing or posting to a profile page, but rather in the way the streams intersect with other forms of media. It’s not realistic to expect that a piece of content will always be viewed solely from any single point of context.
All this being said — Novo’s tactic isn’t deserving of vitriolic overreaction. The Levemir Tweet is an attempt to write the rule book before the rules are determined, nothing more or less. It’s one small advancement that constitutes a larger and more complex structure. The impact of social media shouldn’t be measured by the message or intent of a single Tweet. It’s in consumer stewardship, as applied to branded content distribution, where the “fair balance” between potential and risk will be found.