Sometimes, rather than trying too hard to think outside the box, it’s better to stay in the box.  If Art had just re-created his delicious looking mango pastry dessert from the previous episode with a few substitutions or gone with another of his favorite dessert of all time but with a few substitutions to accommodate for the gluten-free restriction, he would have come out ahead.  However, he was so hung up on what he couldn’t use:  dairy, gluten, and eggs.  Those are only three ingredients out of thousands that he has to work with on a daily basis.  And, yes, Anita’s dish did “look sad”.  Couldn’t she have done an Asian-style vegetarian dumpling or stir-fry rice noodles or hearty Asian-flavored soup?  At least Mr. Hubert tried, though his heart was also not completely in the challenge.  But, he did win points for presentation.

If you tether yourself, only then will you feel tethered.  Unleash yourself from the leash.  Rick Bayless did just that.  He remained true to his Mexican style of cooking, but eliminated the animal products and made super stars out of the veggies.

Similarly, in marketing, especially in a start-up environment, many marketers feel limited because of the small budgets or lack of personnel resources.  However, in this age of the internet, and now social media, the world is your oyster.  All you need is a little creativity, passion, and time.  But, if all you have is love, you’ll succeed just the same.

The only true Master of the evening was Rick Bayless, who displayed the proper passion for his food and respect for his guests’ gastronomic preferences.  Too bad he didn’t take home the trophy!  Michael just got lucky, because you can never go wrong with pasta among vegetarians.  Now, that’s playing it safe!  Too bad the judges didn’t see that.

There’s a great blog on pharma and healthcare at Dose of Digital.  Check out some of the archived posts on the sidebar of this blog.  It’s evident that the FDA has not clearly defined the rules of engagement in the social media space for pharma and for that matter medical devices and diagnostics companies.  The same blog discusses ways to go around current FDA regulations using mobile marketing (But, I don’t think the point is to deceive customers or patients, or maybe it is? But that’s not my focus!)

Recently, Johnson & Johnson was slapped on the wrist by the FDA’s DDMAC (Division of Drug Marketing, Advertising, and Communications) for overstating the efficacy of Ultram ER, a drug for chronic pain, and understating its risks in this Ultram warning letter.  In another similar situation, Shire Development Inc was reprimanded for inaccurately featuring Adderall XR Capsules on YouTube.  Essentially, the Adderall warning letter claims that the video overstated efficacy and understated the risks, thereby “misbranding” the drug.  So were both of these cases deserving of the reprimand?

Before answering that, consider the blog eye on fda and a related podcast that very succinctly discusses the need for pharma’s participation in Web 2.o, pharma’s reservation to do so, and the FDA’s point of view.  In brief,  Mark Senak of Fleishman-Hillard spoke with Dr. Jean-Ah Kang, who is the Special Assistant to DDMAC Director Tom Abrams.  Although I recommend that you listen to the podcast, the script is nicely transcribed at MM&M.  Basically, right now the FDA has no formal policy on the use of Web 2.0 social media.  The key message from Dr. Kang was:  “it’s not the medium, it’s the message.”  As long as the message is fair and balanced, it doesn’t matter what medium it is conveyed in, whether it be Twitter, YouTube, website, or other traditional medium such as print.  But even so, as a company with a drug or other product in a regulated industry, you still need to cover your a%#.  How?  Dr. Kang says:  “follow the law” by submitting two copies of the final promotional materials using the FDA form 2253 under the guidance of 21 CFR 314.81(b)(3)(i) to DDMAC.  If you think your marketing materials require advisory comments on the draft proposal, you can certainly solicit the DDMAC for assistance in advance via their CDER page.   What this does is covers you from a third party wrongly reprocessing and misrepresenting your product and brand.

Is it better to have loose guidelines than to have an exhaustive list of rules and regulations spelled out by the DDMAC?  Apparently not.  The brouhaha continues.  Just a few days ago, DDMAC issued draft guidance for industry presenting risk information in prescription drug and medical device promotion.  The guidance hardly touches on the use of social media and the Web 2.0 environment.  There seems to be an even stronger response to the lack of guidance provided in this document, especially since DDMAC reprimanded 14 companies via “Warning Letters and Untitled Letters” for using sponsored links on Google in March of this year.  The letters basically claim:  The sponsored links are misleading because they make representations and/or suggestions about the efficacy of _fill in the blank drug_, but fail to communicate any risk information associated with the use of this product. In addition, the sponsored links inadequately communicate _fill in the blank drug _indication and fail to use the required established name. So, if you want to provide input to the draft guidance document, you have 90 days to do so, or you can join the bandwagon with others already planning to!

The landscape is much more complicated than what meets the eye.  How do you formulate policy around promotional materials in a regulated industry in a medium that can be altered, such as a wiki, or that must be communicated in 140 characters or less, i.e. Twitter?  For example, is it okay to Tweet:  “Joe used Viagra and he’s never looked better.  Ask your doctor how you can too!”  And, even if you can, I wonder what the effectiveness of such new media tools will be for the companies looking to promote their regulated products?  And, even more interestingly, how will and should the combination of various marketing channels change to optimize delivery of the promotional message?

I would love to hear your thoughts.  Yours truly – startupmarketingdiva.
P.S. follow me on Twitter @startupmktgdiva

*Note:  I recently published this post also at radymarketing.wordpress.com

Here are the basic key Twitter metrics to consider:  Number of followers, number following, number of updates, number of @replies, and number of @RT (i.e. “ReTweets”).  I found this last one to be the most intriguing especially after reading The Genius Index: One Scientist’s Crusade to Rewrite Reputation Rules in this month’s issue of Wired Magazine.  In a nutshell, this article is about Jorge Hirsch, a physicist who lives in a world defined by the “publish or perish” mantra, who decides to re-write the algorithm that defines a scientist’s reputation.  It’s not just about the journal impact factor (i.e. the caliber of journal that a scientist’s research is published in), but rather how many times a scientist’s work is cited by other researchers.  This is referred to the h-index (aka “the hirsch index” of course).

Similarly, it’s almost meaningless to note how many followers you have on Twitter.  Because, sooner or later, you’re going to get bots and spammers following you as well.  Plus, some Tweeters follow simply so that you can turn around and follow them – a kind of a diplomatic gesture, I suppose, in the Twitter world.  But, when a Tweet is ReTweeted, that’s when the signal to noise ratio increases for that particular Tweet and Tweeter.

There are groups working on a number of other metrics for Twitter – check out TwInfluence, which is a site where you can measure your influence as a Twitterer.  I don’t know the actual algorithm, but it calculates your degree of influence based on the velocity at which you acquire followers, taking into account their degree of influence, and the number of followers you accumulate over time, among many other metrics.  And, just today, I came across a search engine built especially for the social web called TOPSY (in the interest of full disclosure, one of the founders is my cousin).  It seems that TOPSY’s value is that it returns information in real time and more importantly, it filters the signal from the noise by using  reputation as a key metric.  So, for example, on Twitter, it filters the Tweets (and the links in the Tweets) that are most valuable based on the reputation of the author.  So your search returns information in the context of what people are actually talking about.

There’s a lot going on.  The dust storm is just starting and it’ll be a while before it settles.  But, like the early days of the internet, when the ‘hit counter’ ruled, similarly, in these early days of Twitter, ReTweets are a key metric to consider, or so it seems.

I’d like to hear your comments.  Yours truly – startupmarketingdiva.  Follow me on Twitter @startupmktgdiva.

*Note: This post was also published at radymarketing.wordpress.com

Purpose.  That’s the key word.  What is the purpose of your existence, whether in reality or virtuality?  I’m convinced that for now, I don’t think I need to worry about a website for my marketing consulting work.  I will use my blog as my virtual storefront for disseminating info about myself and my professional marketing services.  But, for the rest of you, whether you’re on your own or part of a corporate enterprise, think about the purpose before you decide to ‘kill your website’.