PAAB Resource Appendix

Fair balance in Small Space Ads

Indication and Fair Balance Placement for Non-continuously Rotating Ads

In instances where the rotating ad is designed to stop rotating after one or more cycles, the final frame essentially becomes its own complete static ad. Banner ads are viewed incidentally by the healthcare professional (HCP). There is no assurance that the HCP consumed disclosure elements presented during the prior rotating phase of the banner ad.

Case 16: Non-continuous rotating ad

Not acceptable

300 x 250 Rotation stops on this frame

The inclusion of the indication prompts the requirement for the rest of the lowest level fair balance. As this frame does not have the complete lowest level fair balance, it would not be acceptable. While the fair balance may have been included on a prior frame, the ad is no longer rotating and there is no assurance that the HCP was looking at the ad at that time.



Case 17: Non-continuous rotating ad

Acceptable

300 x 250 Rotation stops on this frame

As outlined in bullet 'A' on page 3 of the corresponding advisory, this frame is acceptable as it contains the indication and the lowest level fair balance. Lowest level fair balance is an appropriate fair balance level for the claim "#1 dispensed IL-28".



Case 18: Non-continuous rotating ad

Not acceptable

300 x 250 Rotation stops on this frame

While the lowest level fair balance is included, as required to balance the claim "#1 dispensed IL-28", the indication is also required. Surely, the indication was presented on an earlier frame, as required by PAAB Code section 2.10, but the ad is no longer rotating and there is no assurance that the HCP was looking at the ad during the rotating phase.



Case 19: Non-continuous rotating ad

Acceptable

300 x 250 Rotation stops on this frame

As outlined in bullet 'B' on page 3 of the corresponding advisory, the lowest level fair balance (without mention or implication of any claim or the therapeutic use), is an acceptable last frame in a non-continuous rotating banner ad. Importantly, the content is comprised exclusively of topics that allude neither to benefits nor to particular risks.



Case 20: Non-continuous rotating ad

Not acceptable

300 x 250 Rotation stops on this frame

It is unclear what Verant is first line for. Once the claim is completed for clarity, it will require accompaniment by highest level fair balance. While this requirement can be met by including middle fair balance on the banner with a link leading to the highest level fair balance, neither highest nor middle level fair balance will fit on this banner. Also note that the indication would be required. A more realistic option would be to remove "think" and "1st line" while inserting "Learn about Verant's place in therapy" above or inside the existing button.



Case 21: Non-continuous rotating ad

Acceptable

300 x 250 Rotation stops on this frame

As outlined in bullet 'C' on page 3 of the corresponding advisory, this is acceptable. The same would apply to "Learn more about Verant's dosing" or "Learn more about Verant's mechanism of action". The rationale is the same as in Case 19.



Case 22: Non-continuous rotating ad

Not acceptable

300 x 250 Rotation stops on this frame

This now static banner links the drug to its therapeutic use. Indication and lowest level fair balance is required EVEN if this information had been included in the rotating phase of this banner.



Case 23: Non-continuous rotating ad

Acceptable

300 x 250 Rotation stops on this frame

As outlined in bullet 'C' on page 3 of the corresponding advisory, this is acceptable. This is a possible alternative to inserting the disclosures required in Case 22.





All examples and drugs are fictitious for training purposes. These ads have been designed for desktop viewing.