Marketing and promotion of pharmaceutics

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					Course Title: Pharmaceutical marketing and promotion
Course Code: 102316
Course coordinator: Abeer Abu Ghosh
Semester: second 2008
Marketing and promotion of pharmaceuticals

Drug companies spend enormous sums of money to promote their products. In
the year 2000, it was estimated in a study that over 13.2 billion USD was spent
in the USA over promotion of pharmaceuticals. This is more than what is spent
on R&D in those companies collectively.
Promotion increases sales: This is an evidence based truth and it also affects
doctors' prescribing habits in so many ways, sometimes even in writing a drug
that they know is not the best choice for a patient.

Marketing definition: creating customer value and satisfaction. Or a process by
which individuals and groups obtain what they need and want through creating
and exchanging products and value with others.
i.e: It is simply the delivery of customer satisfaction at a profit.

Market Definition: It is all actual and potential buyers.

What are consumer's needs, wants and demands?

Needs: A state of felt deprivation for basic items such as food and clothing and
complex needs such as the need for belonging e.g I am hungry.
Wants: A form that a human need takes as shaped by culture and individual
personality e.g I want a hamburger and a soft drink.

Demands: Human wants backed by buying power .i.e. I have money to buy this
meal.

Promotion definition: to encourage the existence or progress of an object,
including a product, service, an idea or an organization.

Two major objectives of any promotion program:
1. Information.
2. Persuasion.

How do consumers choose among products or services?

We have two issues that will make a product or service a successful one:
1. Customer value: value gained from owning a product and costs of obtaining
the product. (benefits/costs) or (what you get / what you give).
Marketers can increase this value by increase benefits and decrease costs or
increase benefits more than the increase in costs or decrease benefits less than
the reduction in costs.
2. Customer satisfaction: the products performance in delivery value relative to
the buyer's expectations (value delivered/expectations).

Buying function: looking for and evaluating goods or services.

Selling function: it involves promoting the product, and it includes the use of
personal selling, advertising or other direct and mass selling methods.

Marketing management philosophies:

-consumers favor products that are available and highly affordable.
-always improve production and distribution.
-consumers favor products that offer the most quality performance and
innovative features.
-consumers will buy products only if the company promotes /sells the products.
-focuses on needs, wants of target markets and delivering satisfaction better than
competitors.
-focuses on needs, wants of target markets and delivering superior value.


Steps to be followed in a marketing plan:
1- Determine the nature of product or service you want to sell.
   Its design, quality, features and packaging.
2- determine its place, distribution, channels for best availability coverage,
transport, direct or indirect.
3- determine price profitable for the company or attractive to customers,
discounts, payment period, credit.
4- promotion: planning, where or how to advertise, advertising, sales ale, public
relations.

Connections with customers:
Most marketers are targeting fewer, potentially more profitable customer while
asking themselves:
-what value does the customer bring to the organization?
-are they worth pursuing?
Focus has shifted in many companies towards:
-keeping current customers.
-building lasting relationships based on superior satisfaction and value.
Direct connections with customers:
Companies use technologies today.i.e telephone-available products, mail-order
catalogues, and e-commerce such as www.amazon.com.

Companies segment the market into groups and then they have to decide on how
to target these particular groups, the choice of a viable segment is dependent on
the following three key issues:
1-The marketing attractiveness of the target segment, its size, growth, price
sensitivity and entry and existing costs.

2-The competitive dynamics in the proposed segment. How tough in the
competition? How strongly do the competitions react to anew entrants?
Is it feasible to carve out a niche in the market without strong retaliation from
existing competitiors?
Availability of substitute drugs?

3-the strength of the strategic advantage for the target segment.
In the drug industry, one of ten starts out with a product with given strengths and
weaknesses. The task of the target –market selection consists of searching for
groups of customers for whom the product strength can form the basis for a
strategic competitive edge.

*market targeting: based on evaluating the segments with regard to its size,
growth, effects of competitions, availability of substitute products, power of
buyers or suppliers(competition),also company objectives or resources.
1-undifferentiated marketing: mass marketing such as coca cola.
2-differetiated marketing: targeted-segments such as hypertensive patients in a
population.
3-concentrated marketing: one segment is stressed on. Rolls Royce car
manufacturers concentrate their marketing efforts on potential buyers only.

Product life cycle (PLC):
This concept suggests that a product passes through four stages:
1-introduction.
2-growth.
3-maturity.
4-decline

But it is not easy to identify the specific stage a product is in at certain points. It
is difficult to forecast the sales level, length of each stage, the shape of the PLC.
1. Introduction phase: the company spends time to create awareness of its
presence and here the profits are usually in the negative.
2. Growth phase: the customer accepts the product and an increase in sales is
achieved here_ rapid growth.
3. Maturity phase : Rapid sales growth cannot go on forever. Slow down.
4. Decline phase: Change strategies. Re-place the product if possible.

See handouts

Stages of marketing:

1. Entrepreneurial marketing:
Most companies are started by individuals who visualize an opportunity and
knock on every door to gain attention. They are characterized by high levels of
creativity.
2. formulated marketing:
As small companies become successful, they will start hiring salespeople,
establishing a marketing department that carries out marketing research,
studies…etc. i.e the company is now more professional.
3. Interpreneurial marketing:
This stage takes place when many large companies get stuck in stage two and so
become non-creative and loose passion.

Marketing channels:
To reach a target market, marketers use three types of channels:

1. Communication channels: deliver and receive messages to and from buyers or
targets. Examples: newspapers, radio, TV, posters, CD s, internet. These can be
classified into:
A. dialogue channels 2 way channels such as e-mail, toll-free numbers.
B. monologue channels or one way channels such as advertisements.

2. Distribution channels:
To display or deliver the physical product or service to the buyer or users.
Distribution, wholesales, retailers are usually involved in the process.

3. Selling channels:
To effect transactions with potential buyers….. i.e. Not only distributions,
wholesales, but also banks, insurance companies that facilitate transactions.
CHOOSING THE BEST MIX OF THE THREE IS DIFFICULT BUT A
MUST!


Competition:
A critical factor in marketing management which includes all of the actual or
potential rival offerings and substitutes that a buyer might consider.

Types of competition:

-Brand competition:
A company sees its competitors as other companies that offer similar products or
services to same customers at similar prices. Toyota and Honda.

-Industry competition:
A company sees its competitors as all companies that make the same product or
class of products.
(Honda vs. all car manufactures).

-Form competition:
A company sees its competitors as all companies that supply the same service
Honda vs. all manufactures of all vehicles motor cycles, towers.

-Generic competition:
A company sees its competitors as all companies that compete for the same
consumer dollars. HondaVS. All companies selling major consumer durables,
foreign vacations, new homes ….etc.

External forces affecting marketing of products:

P.E.S.T: political, Economical, Social, Technological environments.

Political: politics affect how a business is operated, decisions made by
government or the presence of occupation affect our every day lives.
(Legislations, policies).

Economical: nationally and globally. Economy dictates how consumer behaves
in society.

Social: society forces as family, friends, media affect our attitudes, interests,
opinions, what we buy, how we behave.
If a change in structure of a population happens, this will affect the supply and
demand of goods and services.
Technological:

The changes in technology are changing the way businesses are operated.
Internet has a high effect. R&D departments are pressured to develop up to date
technology products in order to survive the fierce competition in the markets.



*Marketing mix principles: These are used by business as tools to assist in
pursuing their objectives. The 4 p's are: the product, price, place, promotion
These are controllable variables which must be managed carefully to meet the
needs of the target group.

Marketing Mix:
4 P‟s      vs.     4 C‟s
Product           Customer solution
Price             Customer cost
Place             Customer convenience
Promotion         Customer communication

1) Product Strategies:
When an organization introduces a product into a market, they must ask
themselves a number of questions:
   - who is the product aimed at ?
   - what benefits will they expect ?
   - how do they plan to position the product in market ?
   - what differential advantages will the product offer compared to
      competitors ?

A product must be viewed in 3 levels:

Level 1: Core product: core benefit of our product.
Level 2: Actual product: aim is to ensure that our potential buyers actually buy
one from your company (i.e. add benefits to compete).
Level 3: Augmented product: what additional non-tangible benefits can you
offer ? warranties, delivery, after sale services.
 Product decisions
Design (will it be the selling point for organization),
Quality (consistent with the rest of marketing mix features: what features will
you add that may increase benefits?)
Branding: these have power of instant sales as they convey a message of
confidence, quality and reliability. A company differentiates itself from
competitors by branding. (Copy cats).

2) Pricing:
 It costs to produce, design, distribute and promote a product, thus the price must
support these elements. Pricing is difficult and must reflect the supply &
demand relationship.

If too high or too low  loss of sales.

Pricing must take into account:
   1- Fixed and variable costs.
   2- Competition.
   3- Company objectives.
   4- Proposed positioning strategies.
   5- Target group & willingness to pay.

Pricing Strategies (Types of pricing):
Depends on company‟s objectives:
   1- Penetration pricing: low price to increase sales and market share.
   2- Skimming pricing: initial high price, then slowly lowers it to make it
      available to a wider market. Objective: skim profits of the market layer by
      layer.
   3- Competition pricing: set a price in comparison with competitors.
   4- Product line pricing: pricing different products within the same product
      range at different price points.
   5- Bundle pricing: to bundle a group of products at a reduced price.
   6- Psychological pricing: consider psychology of price, i.e. 199 USD
      instead of 200 USD.
   7- Premium pricing: price set is high to reflect exclusiveness of product.
   8- Optional pricing: to sell optional extras along with the product to
      maximize its turnover, ex: in car industry.

3) Place:
Distribute product to user at the right place and at the right time.
Distribution must be efficient and is either direct (manufacturer  consumer) or
indirect (manufacturer  wholesaler  retailer  consumer).
Distribution Strategies: depends on the type of product.
   1- Intensive distribution: to distribute low priced or impulse purchase
       products, e.g.: chocolates, soft drinks.
   2- Exclusive distribution: limit distribution to a single outlet, highly priced
       items, as selling cars through exclusive dealers.
   3- Selective distribution: a small number of retail outlets, e.g.: computers
       and TV‟s.

4) Promotion Strategies:

Promotion definition: to encourage existence or progress of an object, including
a product, service, an idea or an organization.

WHO defines promotion of medicines as:
All informational and persuasive activities by manufacturers the effect of which
is to induce the prescription, supply, purchase and/or use of medicinal products.

2 major objectives of any promotional program:
1- to inform     These conflict sometimes as the manufacturer is interested in selling and
2- to persuade persuading at the end of the day.

The end point of any pharmaceutical information is to facilitate rational decision
making of all parties involved in delivery and consumption of pharmaceutical
care.

But, unfortunately this end point conflicts usually with the second objective (to
persuade).
And the first objective (to inform) is being questioned because of the
commercial interests of a major source of the information i.e. the manufacturer:
he is interested in selling as much as possible.
Promotional programs that convey information are very useful in assisting
efficient market functioning and they usually provide decision makers and/or
consumers that a certain product is available and other important information
needed, so they can make their choices easily according to their preferences.

Promotion is usually performed by well-trained “Medical representatives” or
“Detail-men”.
Economic theories believe that generation & dissemination of information is not
free – it is costly. Thus it must not be excessive in such a way it may lead to
raise the prices of products. Sometimes, it is used to reduce competition by
creating barriers to new companies from entering the market.

There must be regulations in countries to control proliferation of misleading
messages and to restrict persuasive powers of promotion people.

In 1992, FDA‟s commissioner (Kessler) declared that he is concerned with the
statements made by researchers and medical experts at industry-sponsored
activities i.e. they are indirectly under control of industry or the company-
sponsoring that seminar or activity.

So, in order for a statement to be considered credible, the activity must be:
   - Independent
   - Objective
   - Balanced
   - With scientific rigor.

The FDA issued a paper regarding this to guide people on separating promotion
programs from educational programs.

A fundamental question in terms of pharmaceutical promotion is:
- What are the implications for the public health and social welfare of the strict
interpretations of the laws regarding the dissemination of information about
pharmaceuticals?

Federal trade commission (FTC) tries to evaluate misleading and/or deceptive
advertising.

Putting the patient first and doing promotion responsibility through truthful
information is essential if we want promotional and education at same time.

  You gather information or something either by hearing or seeing it
Promotional strategy of a company consists of:

   1- Advertising:
     Any form of communication using any form of mass media or a controlled
   message in purchased time or space. It is non-personal and paid.

Gathering information through advertising is either by hearing it or seeing it.
Usually advertisers use both approaches to convey messages.
Forms of advertising include:
  - Journals
  - Direct mail & e-mail
  - Bill boards
  - Newspapers
  - TV
  - Radio
  - Salespeople (dealers and wholesalers)
  - Newsletters
  - Directories & reference books (PDR)
  - Electronics (video material, internet)
  - Word of mouth.


Journal advertising is designed to create awareness of a product while direct
mail is designed to result in an immediate response such as calling an 0800 no.
or completing a coupon and mailing it to a company. Alternatively this can be
done via e-mail (cheaper).


   Driving forces for advertising are:-
   a. Competition
   b. short patent period
   c. generic companies are strong
so you need maximum sales and profits within the shortest time possible.


   2- public relations :
Developing positive relationships with the public - develop and obtain
favorable publicity and also being able to handle successfully any
negative attention drawn to the company or product.

   3- sales promotion :
Used to obtain an increase in sales within a short term period e.g. money -
off coupons, special offers for a day.

  4- personal selling :
One to one selling – word of mouth.

   5- direct mail:
To correspond or send News letters by mail to a named person among the
targeted segment. This increases response and will increase the sales.
Promotional strategies:

 Push and pull strategies:

a. Push strategies: whereby the manufacturer concentrates some of its marketing
efforts on promoting their products to retailers to convince them to stock the
product .A combination of promotional mix strategies are used at this stage
aimed at the retailer including personal selling and direct mail.


b. Pull strategies: The manufacturer promotes their product among the target
market to create increased demand. Consumers pull the product through
distribution channels forcing the wholesalers and retailers to stock it .


AIDA:
Attention: grab attention
Interest: hold through promotional features
Desire: make desirable
Action: purchase action

SWOT Analysis:

A tool used by organizations to help the firm establish its strengths, weaknesses,
opportunities and threats.
Used as a framework to help firms develop their overall corporate, marketing or
product strategies.

SW: of a company or product (internal factors _controllable by the company).
OT: in the market (environmental _external factors-uncontrollable by the
company).

See handouts

    Is a method for integrating and cross-analyzing all of the data you
           Have collected in the market audit, situation audit and product
           positioning and identifying those opportunities which prove to be
           the best because your company and your product have the strengths
           To take advantage of them.
    A tool used by organizations to help the firm establish its Strengths
           Weaknesses, Opportunities and Threats (SWOT). A SWOT
           analysis is used as a framework to help the firm develop its overall
           Corporate, marketing, or product strategies
    Strengths and Weaknesses ( of the company or product), they are also
           known as internal factors which are controllable by the
           Organization on
    Opportunities & threats ( in the market/environment) are external
           Factors which are uncontrollable by the organization

Who do a SWOT analysis
From the situation audit, you know the major strengths and weaknesses
of the company. In your market audit, you will have identified several market
segments which are potentially viable for your product
In your product positioning, you have established the actual position of your
product in each segment. SWOT analysis is a technique that combines all of
these things and will help you arrive at a strategy, tactics
and objectives for a product
The SWOT method is designed to help produce
    The optimum segment to attack and the reasons why
    The positioning 'message" to communicate and the reasons why.
    As a combination of above, the strategy that will bring success
    Tactical objectives and their priority
    A tactical plan that will meet corporate and product goals and
      objectives.
    A final check that you have carried out a complete market and
      product review

Opportunities and threats
They come out of the following areas
   Market segment
   Environment
   Competition
Examples of the types of factors that have proved useful:
Example list of opportunities: In the market segment
    Large segment size.
    High growth rate.
    High level of customer interest.
    High degree of acceptance.
    Many new customers.
    Low level of price sensitivity

List of opportunities: In the environment

      Few government regulations
      Little negative public opinion.
      Growth economy.
      Competition:
         - few competitors
         - Weak selling power
         -no new products
        -little promotion activity

Strengths and weaknesses

These always come from within; that is, from the product itself or from
The company.
   Examples of strengths (product).

- Highly - efficient product
-Very reliable.
-Convenient packaging
-Acceptable pricing.
-Excellent technical back-up
-High versatility
-High market segment share
-Good trade mark.
-Excellent delivery
    Examples of strengths ( Company)

- Large size
-Excellent reputation
-Adequate promotion budgets --
Productive R & D.
-well-motivated sales force
-Effective sales force
-well-trained sales force
-Excellent distribution
-Excellent back-up information


Consumer buying behavior:

What influences consumers to purchase products or services?


The Process of buying:
         1- problem / need recognition
         2- information search: start asking what is the solution? which brand ?
            ask friends…..etc.
         3- evaluation of different options
         4- purchase decision
     After evaluation, buying takes place .


Post purchase behavior:

1. Doubts after purchasing sometimes takes place.
How to make customers feel proud of their purchase?
  by advertising : he will feel comfortable that they bought it from a
reputable and strong organization owns the latest advertised product.
2. Customer behavior decision making in health care:
   the decision here differs as he is not choosing. He is buying and payment is
different too. In non- prescription drugs and herbal medicines, it is similar.

3. Consumer buying behavior – frameworks :
The Economic man:

Rational in their behavior, they like to maximize personal satisfaction
through exchange, have complete information on alternatives, use
information to make a choice .

Socially- influenced people:
Pressures, interactions with others, family, friends, social class.

Personal influences:
Personality, value beliefs, attitudes…… introverts (keep to themselves
and buy via online or e- mail). Extroverts (outgoing, spend on
entertainment)

See Buying motivations handouts

Promotion is sometimes used (when it is excessive ) to create a barrier
to new companies from entering the markets .


 Sources of information for doctors and pharmacists include :
         - medical representatives
         - continuing medical education courses
         - conferences and conventions: some are sponsored by
            pharmaceutical companies .
         - colleagues
         - videos and electronics
         - discussion groups
         - newsletters and e-mails . ……….toll-free numbers to get a gift…
         - Medical journals designed to create awareness of a product.


Targets of pharmaceuticals promotion :
         - pharmacists
         - doctors
         - nurses
         - dentists
         - insurance companies
         - hospital managers
         - company managers
Some manufacturers see doctors as "learned intermediaries" and
pharmacists as "Gate- keepers".


FDA focuses on 6 terms in assessing pharmaceutical communications:
  - Content: truthful, balanced, does it match the approved labeling?
  - Context: what is the setting? How was faculty selected?
  - Audience: appropriate or not.
  - Medium of communication: appropriate for the audience?
  - Rationale of communication: does it have genuine educational merit?
  - Intent: does pattern of conduct demonstrate commitment to objective
     communication?

Case I: It is OK to discuss an unapproved indication of an approved drug in a
small group of experts or publish data in a journal but not a press conference!

Case II: A company published results of an open uncontrolled study of a
product saying it is superior to another product even though they have done a
well-controlled study on the older one showing opposite results!


Industry says that advertisements today help them to develop the drugs of
tomorrow!

The pharmaceutical industry argue that advertising helps to change the health
habits of people  they consult their doctors more and that advertising in
journals remains the primary source of doctor‟s up-to-date information.

They say that even breakthrough drugs without advertising may fail!

Example: Orinase® was the first oral hypoglycemic agent by Upjohn instead of
insulin, but was not promoted well and was thus not so successful due to lack of
awareness of doctors about its obvious advantages.

A new product is new only once! The first 6 months of a product‟s life are very
determining to its success.

Critics:
Promotion is sales
Scientific symposia are marketing conventions.
Free samples are educational materials.
TV commercials are public service announcements.
Direct to consumer advertising (DTCA)

Used mainly for a group of drugs called: Life style drugs as those used for
insomnia, arthritis, heartburn, allergy, impotence some may be OTC and some
may be Prescription-only drugs.


“Care for the patient is best served by care for the patient”
i.e. patient received the best care when doctor, pharmacist are truly concerned
about his well – being.

“Educate and sell at the same time”

"A new product is new only once".

Disease awareness campaigns educate patients about a disease will increase
visits to doctors and eventually increase sales, other wise, many patients will
continue using wrong medications, high expenses, risk of trauma of surgeries –
days missed of work – increase health care on country.

“Responsible promotion is valuable to society”
Information in advertising must be true.

Knowledgeable patients are usually treated better by doctors and pharmacists
which results in a better care outcome.


In newspapers or TV  costly
FDA says that if a company wants to do a DTCA it must be for an ethical drug
and include all information that is on the package insert for the drug i.e C.I,
dose, S.E …. A whole page in a newspaper, 5 minutes on TV !! costly!!

Due to these ads, doctors are more willing to prescribe drugs that patients
request and on the other hand, patients are more aware of their problems and
treatments, and thus more encouraged to see their doctors.

In addition, better-educated patients usually receive better care from their
doctors.

But, millions of TV advertisements can‟t do what a pharmacist (gate-keeper of
pharmaceutical industry) or a doctor can do in one day  he can just simply
wipe out a product with one statement to the patient or the opposite!
Two types of ads:
1. General health message (no mention of drug's name).
2. Product - specific ads.

There are a number of elements of a pharmaceutical product that contribute to
its advertising profile:

- The name – how it sounds and how easily the name can be recalled and
written?

- The image – what differentiating features of the product are remembered by
   way of promotional message, including efficacy and safety?

- The price – is this an identifying feature that overwhelms the image?

- The presentation – how it cooks, feels, what comes with it?

- The acceptance – how it is accepted by customer i.e. doctor or consumer?

- The support – who are, what are the backers of the product?



Types of DTC ads:

See handout

- Help seeking: alert ads.
About disease and symptoms
Company is identified but not the drug's brand name. patients are instructed to
see their doctor.
- Reminder ads: only mention drug's name.
- Product claim ads. Mention the name of the drug, use – urge people with a
   certain disease to see their doctor.

Issues raised by DTC advertisements involve questions of:
- Public health.
- Corporate responsibility.
- Advertising ethics.
- Consumer capacity to understand complex medical info.

DTC ads are allowed in US and New Zealand only.
DTC ads concentrate on powerful emotional factors such as:
- Value of one‟s health or loved ones.
- Fear of death.
- Fear of disability.
- Responsibility of taking care of one‟s health and that of loved ones.
- Self consciousness and vanity.
- Shame.
- Vulnerability of people who are aging, ailing.

No mention of non-pharmacological alternatives to treatment in these ads.


DTC ads are claimed to increase patient compliance.
DTC ads are claimed not to interfere with doctor / patient relationship and to
enhance there communication with them – e.g ask better questions.

It may however pressure some weak doctors to prescribe advertised medicines
without giving it deep thoughts of whether this is the best choice for the patient
in front of him.

Statistics: 1\4 people who visited doctors after a DTC received a new diagnosis
of a condition.




                  Regulations on Marketing and Promotion:

FDA_DDMAC (Division of drug marketing advertisement and communication)
commented on statements made during activities. In order for these statements
to be credible, the activity must be:
     Independent
     Objective
     Balanced
     With scientific rigor

   Federal trade commission (FTC) tries to evaluate misleading or deceptive
   advertising.
FTC Requirements:
      Advertising must be truthful and non-deceptive
      Back up claims with competent and reliable scientific evidence,
       including tests, studies or other objective data
      1973: National Association of Broadcasters and the Consumer
       Healthcare Products guidelines for TV advertising- updated
       periodically
TV advertising guidelines for OTC products        1
Advertisement should:
      Comply with all relevant applicable laws and regulation
      Urge the consumer to read and follow label directions
      Contain no claims of product effectiveness unsupported by clinical or
        other scientific evidence, responsible medical opinion or experience
        through use
TV advertising guidelines for OTC products         2
      Present no information in a manner that suggests the product
       prevents or cures a-serious condition that must be treated by a
       licensed practitioner
      Emphasize the uses, results and advantages of the particular
       product
      Reference no doctors, hospitals, or nurses unless such
       representations can be supported by independent evidence

TV advertising guidelines for OTC products           3
      Present no negative or unfair reflections about competing
       nonprescription drug products, unless those reflections can be
       supported scientifically, and presented in a manner so consumers can
       perceive differences in the uses.

Dietary Supplements
        Are not regulated as "drugs" under the FD& C Act cause they are not
          intended to diagnose, cure or treat a medical disease or condition;
        Consequently, they do not follow the Drug Facts format
         They are not regulated by the FDA or any other state or federal
         governmental agency, a s stringently as prescription or GTC drugs
        Dietary supplements are regulated under the federal Dietary
          Supplement Health and Education Act of 1994 (DSHEA)


   American medical association (AMA), Pharmaceutical manufacturing
   association set up guidelines on gifts that are acceptable to doctors from
   pharmaceutical industry:
       Acceptable
        Of modest value
        Related to doctor's work (pens, note pads…)
        Social events, modest meals as part of an overall program.

       Unacceptable
        Cash payments
        Extravagant gifts
        Reimbursement for travels, hotels, personal expenses, time

        FDA regulations are usually concerned with:
        1. False or misleading statements made by manufacturers
        2. Unapproved new drug claims
        3. Improper promotion especially if investigational drugs and nature of
           promotion.


The FDA regulates prescription drug promotion
The Division of Drug Marketing, Advertising, and Communications (DDMAC)
within the Center for Drug Evaluation and Research regulates prescription drug
promotion at the FDA. It protects the public health by helping to ensure that
prescription drug information is truthful, balanced, and accurately
communicated. This is accomplished through a comprehensive surveillance,
enforcement and education program, and by fostering optimal communication
of labeling and promotional information to both health care professionals and
consumers.
For all ads and promotional materials, sponsors (companies) submit voluntarily
their drafts materials for comments before use to the DDMAC and if it is not
according to regulations, they will send letters of warning or suggest alterations.
Also DDMAC tries to increase compliance of industry through educational
programs as advisory comments, guide lines, websites, postings i.e. discussions,
presentations or by publishing all warning letters on the internet and advisory
comments.

Heavy advertising can have dangerous effects on prescribing habits of doctors,
and this is especially true in developing countries e.g 41 % of Pakistani doctors
prescribed a drug with well known dangers to treat diarrhea in children and

14% of doctors prescribed anabolic steroids as appetite stimulants.

95% said that medical reps. and sales people were their main source of

information.

Data base being launched by WHO/ NGO on drug promotion
www.drugpromotion.info

The purpose is:

- To document volume of inappropriate drug promotion in developing and

developed countries.

-Document the impact of inappropriate promotion on health.

-Formulate recommendations.

-Provide tools to monitor drug promotion, and provide tools on how to teach

health-care professionals about drug promotion.
                                 Selling Skills:

Types of selling:
   Emotionally motivated selling.
   Catalog selling
   Mail order
   Selling of services (as lawyers, doctors..etc.)

Statistics:

-One sales man keeps 19 employees in the company
-It takes 20 times the effort to satisfy an unsatisfied customer as compared to the
effort needed to gain a new customer.
-To make anew customer costs 5 times more than keeping an existing customer.
-Every year drug companies lose about 10% of their customers.

How to be professional in selling:
   Education „updating your information‟
   You must be convinced that there is no alternative to your current job
   “working is working”
   Learn to respect yourself and others.

Medical rep: “Before any visit”
  1. One should have knowledge about:
          Drug information.
          Updated info.
          Competing products.
          Personality of the customers.
          The key to convince the doctor with our product.
          Selling skills.
          To make sure that you know your company well and also that the
             company is well known to the doctor.
          Must have detailed information about how your drug can be
             helpful and how it differs from other drugs.”
          Should know details about the disease
          It is helpful to take advantage of certain events such as knowing
             the doctor birthday and to time your visit at that day bringing a
             small gift with you.”
Must have a data base of:

-Customer profile
-Product profile: all studies done, all information collected.
-Doctor‟s card: personal information, writing habits, class.
This information should be easy to retrieve whenever needed, can be classified
easily, must give clear analysis and comparison with other competing products.
This would be helpful for any other new medical representative to make use of
previously available information.

It is important for any new medical representative to take care of the following
issues:

          The appearance of a medical representative. “the bag, clothing,
             nails, hair style…etc…”
          Ability to convince/persistent/credibility.
          The frequency of visits,” to set a programe for visits”.
          planning:
         Yearly, every 16 months, every 2 weeks, daily
“A plan is set by medical rep., then approved by regional managers, then by
the promotion department.

What doctors expect to get from medical representatives?
-An effective drug.
-Information concerning the drug.
-An idea concerning drug price.
-Available dosage forms.
-Free samples.
-Brochures
-Conferences
-Services
-Frequent visits.



What does a medical representative expect from a doctor?
-To prescribe his products
-To greet him upon his visit.
-To understand the properties of his product over competitors' ones.
-Feedback

It is important to know that doctors can remember only few numbers of
products for example some doctors may only know 15 products.
Why doctors may not prescribe your specific product??
-No frequent visits.
-If he is not convinced with your product.
-Previous trial failure of the drug.
-Simply because he does not like you.
-Negative opinion or bad relations with your company
-There is no product in your company that matches his needs.
-His loyalty to other company
-Not enough information concerning the drug.
-He is used to other specific drugs.
     Key Element For Successful Communication

        question            allow and encourage questions
                            to make clear what your
                            message is understood well
        feedback            ask for confirmation but also
                            check and reconfirm
       visual aids          visualize instead of only using
                            words visualization can be
                            manifold,also use gestures
                            ,analogies ,symbols
   clear assumptions        verify what your way of
                            communicating is understood
                            well(also see next two points)
don‟t assume what others    don‟t assume what your
          know              knowledge is familiar to
                            the"receiver". This refers to
                            technical terms ,background
                            principles language _your
                            "encoding" in general.
 set frame then details     give an overview ,familiarize
                            with the topic in general,the
                            proceed to detail
                            communication
     keep it simple         don‟t try to impress by
                            complication; reduce to the
                            maximum
 give/get sufficient info   find the right balance (check
                            out by feedback) don‟t overdo
                            nor "underdo".
                                               ‫‪Definitions‬‬
‫‪- Market‬‬                   ‫انسٕق عبارة عٍ يجًٕعت انًشخزٍٚ ٔانبائعٍٛ انذٍٚ ٚزغبٌٕ فٙ شزاء ٔبٛع سهعت‬
‫‪- Customer‬‬                              ‫انشبٌٕ ْٕ انفزد انذ٘ ٚكٌٕ نذّٚ انحاجت ٔانزغبت ٔانمذرة نشزاء سهعت‬
‫‪- Salesperson‬‬
                  ‫يُذٔب انًبٛعاث ْٕ انشخص انًُخذب يٍ انشزكت نٛمٕو ببٛع ٔحسٕٚك سهع أ خذياث انشزكت نذٖ انشبائٍ‬
‫‪- Product‬‬                                 ‫انًُخج ْٕ انسهعت أ انخذيت انذ٘ حٕفزِ انشزكت ٔٚهبٙ حاجت انشبٌٕ‬
‫‪- Manufacturer‬‬                       ‫انًصُع ْٙ انجٓت انخٙ حجًع ٔححٕل انًٕاد انخاو انٗ يُخٕجاث نٛخى بٛعٓا‬
‫يُذٔب حٕسٚع -‬                 ‫انًٕسع ْٕ انشخص انذ٘ ٚمٕو بإٚصال انسهع ٔانخذياث يٍ انشزكت انٗ انشبٌٕ‬
‫‪- Wholesaler‬‬                           ‫حاجز انجًهت ْٕ انٕسٛط بٍٛ انشزكت انًصُعت أ انٕكٛم ٔحجار انًفزق‬
‫‪- Retailer‬‬            ‫حاجز انًفزق ْٕ انٕسٛط بٍٛ حاجز انجًهت أ انٕكٛم أ انشزكت انًصُعت ٔانشبٌٕ انُٓائٙ‬
‫‪- Agent‬‬                                          ‫انٕكٛم ْٕ انشزكت انخٙ حًهك حمٕق حصزٚت فٙ بٛع سهعت يا‬
‫‪- Competitor‬‬                    ‫انًُافس ْٕ انجٓت انذ٘ نذّٚ انمذرة عهٗ حٕفٛز سهعت أ خذيت حهبٙ َفس انحاجت‬
‫‪-Promotion‬‬                ‫انذعاٚت ْٙ انٕسٛهت انفعانت نهٕصٕل نهًسخٓهك انُٓائٙ عبز اعالَاث َٔشزاث ٔغٛزْا‬
‫‪- Marketing‬‬
                 ‫انخسٕٚك ْٕ عًهٛت فٓى انسٕق ٔحٕفٛز انسهع ٔانخذياث انخٙ حهبٙ االحخٛاجاث عٍ طزٚك انذعاٚت ٔاالعالٌ‬
‫‪- Selling‬‬      ‫انبٛع ْٕ اَخمال سهعت أ خذيت يٍ بائع انٗ يشخز٘ نخهبٛت يُفعت يشخزكت يع حٕفز االٚجاب ٔانمبٕل‬
‫‪- Sample‬‬                  ‫انعُٛت ْٙ يُخٕج ٚسخخذو كجشء يٍ انذعاٚت نخعزٚف انشبٌٕ بًٛشاث ٔصفاث انصُف‬
‫‪- Leaflet‬‬                                                  ‫انُشزة ْٙ يهخص نخٕظٛح يشاٚا ٔفٕائذ انصُف‬
‫‪- Billboard‬‬                                                                      ‫ْٙ نٕحت اعالَٛت خارجٛت‬
‫‪- Mobiler‬‬                                                           ‫ْٕ يجسى عٍ انصُف الغزاض دعائٛت‬
‫‪- Dangler‬‬                                                                                  ‫يخذنٛاث دعائٛت‬
‫سُذ لبط -‬                                           ‫ْٙ ٔثٛمت رسًٛت ٔلإََٛت الثباث دفعت لبعج يٍ انشبٌٕ‬
           ‫سُذ صزف-‬                                          ‫ْٙ ٔثٛمت رسًٛت ٔلإََٛت الثباث يبهغ حى دفعّ نشخص يا‬
‫فاحٕرة -‬           ‫ْٙ ٔثٛمت رسًٛت ٚسجم فٛٓا كًٛت ٔسعز انسهع انخٙ خزجج يٍ انشزكت ٔٔصهج انٗ انشبٌٕ‬
‫دفخز يزحجعاث -‬                 ‫ْٙ ٔثٛمت رسًٛت حسخخذو السخالو كًٛت َٕٔع انبعاعت انخٙ رجعج يٍ انشبٌٕ‬
‫سُذ ارجاع -‬                      ‫ْٙ ٔثٛمت رسًٛت حبٍٛ انكًٛت ٔانمًٛت انًانٛت نهبعاعت انخٙ رجعج يٍ انشبٌٕ‬
‫دفخز طهبٛاث-‬
Customer request


Marketing Plan


Budget
Target                                                             SMART
Distributor


Merchandizer
Product Life Cycle


Quality Customer Service
ISO 9000


Inflation
Purchase
Market Share
Customs
VAT
Supply and Demand




Policy
Procedure
Strategy
Plan
FORM
Smart: specific, measurable, ambition, realistic, time measured.
                  The six buying motivations

.Making a gain :
 Buying to increase yield or money return ( profit ) , being economical
, saving money . Also , gaining time .
    .A cattle farmer is treating his herds regularly to assure their
health to increase meat and milk production to make more
money .
    .A dealer or distributor includes a new public hygiene
insecticide in his product range in order to expand
     business and improve profits .
.fear of loss :
 buying to protect an investment from damage or loss . The loss may
be real or perceived . Could be loss of life , yield , profit , money ,
property or anything of value . Protect health ,
 guarantees long life .
     .Most people buy household insurances because they are
              afraid of losses through burglaries .
.pleasure :
  Buying because of enjoyment.Close to the gain motivation ,but
  prospect is not primarily concerned with gain. Here we may
identify comfort , convenience,enjoyment,beauty,luxury,good health
,food.

    .A distributor takes a buying decision for a given product
      because he knows that after reaching a certain volume he
      gets a free weekend to spend in a holiday resort .

    .Somebody buys a tennis racket ( sports equipment )
      because he enjoys playing tennis .
Avoidance of pain

Buying because it will remove physical or mental pain. Close to fear of loss.
Most people do not like discomfort. Drugs / Pharmaceuticals are an obvious
example. Also less work, safety, freedom from worry, security protection.
       * A housewife buys a dish washing machine because she doesn't like to
          Wash dishes by hand.

        * Drugs bought for motion sickness to avoid vomiting during a trip.


Pride

Buying because of inner feelings of wanting the best. Pride is when someone makes
a decision resulting in a good inner feeling. They don't care what others know, think and
say. (Could be self improvement, style, high quality, etc.)
        * A cattle farmer wants good ecto parasite control in all this herds even
         They are hardly ever seen by anyone but the farmer himself

        * A dealer paints all 4 sides of his warehouse even though nobody ever
         sees the backside of the building.


Social approval

Buying because of the influences or reactions of others. Where decision is made to
cause prospect to appear to be a good farmer, businessman, grower
Or pillar of society. Also for prestige purposes. Prospect cares what others know,
think or says.

        * A cattle breeder buys a product, because his neighbour, who has a big
         farm, bought it.

        * Somebody buys a fancy car because he wants to impress his friends,
          neighbour, etc.
                           FEATURES AND BENEFITS

                        BINACA GOLD MOUTH WASH


    FEATURES                                              BENEFITS

                                    FOR CONSUMERS


- Has a disinfectant effect                     - Reduce the germ count in the
                                           mouth

- Eliminate up to 50% of the bacterial           - Good preventive measure
flora                                          against plaque

- Reduces the formation of plaque and            - Fights tooth damage
  acid build-up

- Removes bad breath                             - Gives the mouth a lasting
                                           freshness

- Concentrated                                  - Long usage – ECONOMICAL


                                  FOR THE PHARMACY


- 30% trade discount                           - SR 4.00 per pack sold

- Bonus                                         - Additional profit

- Prescribed by Dentists                       - More sales

- Product information, How to use it?          - No waste of pharmacist's time
  are printed in Arabic on each pack             to explain it to his customer
                      SPASMO-CIBALGIN



FEATURE                                               BENEFITS

                                FOR PATIENTS



- Analgesic, antispasmodic                 - Effective against spasm/
                                            pain.

- Two in one                              - Controls both spasm and
                                            pain.

- Available in tablets and                - Both adults and children
  Suppositories (adults and                 can use Spasmo-Cibalgin
  children)

- Free from barbiturate                   - Patients can drive and
                                            perform their work without
                                           drowsiness.

- Small pack size                         - Economical



                          FOR THE PHARMACY

- Relatively high priced item             - Good margin per pack solid

- Bonus up to 25%                         - Additional profit
SALES PRESENTATION WORKSHEET


  Features                Benefits
                    BUYING MOTIVATION EXERCISE

 In the following statements, what motives are In1icated?




A) Ali was telling me about your special offer of the month




B) Are you taking back the unsold damaged goods at the end of the end of the next month?


C) "It is important to De that people can see that my son is


Free from lice"



D) If I use Voltaren table will I have to worry about Stomach troubles?



E)"Sure I would like to have undamaged fruits in my farm?




F) I will pay cash in order to get the 10% discount"




G) I will not, take such a big order of NEOCID shampoo, I don't believe that, we have much lice
infestation in this area"
 H) "Plant care products are so low I can't afford your GESAL
    Prices".




I) "A customer buys a toothpaste, because he doe not want to loose   his teeth due to tooth decay"




G) Haj season is coming, do you have excess sock of this product?




                                       Stages of PLC
Introduction Stage of the PLC
Summary of Characteristics, Objectives, & Strategies



                                                   Low sales
        Sales



        Costs                               High cost per customer



       Profits                                  Negative or low



Marketing Objectives                     Create product awareness and
                                                     trial


                                             Offer a basic product
       Product



        Price                            Usually is high, use cost-plus
                                                    formula


     Distribution                          High distribution expenses




     Advertising                        Build product awareness among
                                                 early adopters
Growth Stage of the PLC
Summary of Characteristics, Objectives, & Strategies



        Sales                                 Rapidly rising sales



        Costs                              Average cost per customer



       Profits                                   Rising profits



Marketing Objectives                        Maximize market share



                                          Offer new product features,
       Product                                    extensions



        Price                              Price to penetrate market




     Distribution                       Increase number of distribution
                                                   outlets


     Advertising                        Build awareness and interest in
                                                  the mass




Maturity Stage of the PLC
Summary of Characteristics, Objectives, & Strategies


          Sales                                              Peak sales




          Costs                                        lowcost per customer


         Profits
                                                 High profits,then lower profits



Marketing Objectives                                 Maximize profits while
                                                     defending market share

                                                   Diversify brand and models
        Product



          Price                                     Price to match competitor




      Distribution                                     Build more intensive

                                                            distribution



      Advertising                               Reduce to level needed to retain
                                                            product

Maturity Stage of the PLC
Company tries to increase consumption of the current product.
Changing characteristics such as quality, features, or styles to attract new users.
Company tries to improve sales by changing one or more marketing mix elements.
Decline Stage of the PLC
Summary of Characteristics, Objectives, & Strategies



        Sales                                   Declining sales



        Costs                                Low cost per customer



       Profits                                  declining profits



Marketing Objectives                        Reduce expenditure and
                                             maintain, reposition


                                             Phase out weak items
       Product



        Price                                      Cut price




     Distribution                           Go selective, phase out
                                             unprofitable outlets


                                        Reduce to level needed to retain
     Advertising                                    product
11
1,1

      1811




             111




              >
       Agencies Team Up in War against Internet
       Health Fraud
By Linda Bren

... Cures Alzheimer's and HIV/AIDS
... Proven effective in treating over 650 infectious diseases
... Recognized in scientific journals to be a revolutionary breakthrough in treating         arthritis

        These health product claims found on the Internet can provide hope for those suffering from
        painful or debilitating diseases. But they are false claims, leading to false hopes. They are also
        fraudulent, illegal, and the cause of recent government enforcement actions against the companies
        that made them.

        In the ongoing war against Internet health fraud, federal and state government organizations have
        united, in an effort dubbed Operation Cure.AII, to crack down on unscrupulous marketers who use
        the Internet to prey on the sickest and most vulnerable consumers.

       Operation Cure. AII, a partnership of the Federal Trade Commission, the Food and Drug
       Administration, Health Canada (the Canadian federal health department), and various state attorneys
       general and state health departments, combines a law enforcement effort with a consumer education
       campaign.

       Almost 100 million adults in the United States use the Internet to find health related information,
       according to i3 poll conducted by the market research firm Harris Interactive. "The Internet provides
       many benefits. But, its unique qualities--including its broad reach, relative anonymity, and ease of
       creating new Web sites or removing old ones--pose new enforcement challenges," says Bernard A.
       Schwetz, D.v.M., Ph.D., acting principal deputy commissioner of the FDA. "FDA and the FTC are
       working together to protect the public from those who try to take advantage of consumers through this
       new technology."

       In June, the FTC, which developed and leads Operation Cure. AII, announced enforcement actions
       against six companies that fraudulently marketed health product on the Internet. These actions mark
       Operation Cure. AII's fourth group of targeted enforcement efforts to address marketing of unproven
       health products on the Internet.



       Five of the companies have agreed to settle the charges. Settlements included such actions as
       removal of ~II unsubstantiated claims for products, warnings about potential dangerous
       interactions with some prescription drugs, a notice to purchasers with an offer for a full refund,
       and agreement to pay fines for consumer redress. The FTC has filed a complaint in federal
       district court against the sixth company.

        Among the many false and unsubstantiated claims challenged in these recent cases were
        promises that:

                   People could cancel their surgery, radiation or chemotherapy in favor of herbal
           cures that cost hundreds of dollars;
          A device that delivered mild electric current would kill the parasites that cause such
           serious diseases as cancer and Alzheimer's; and
          Those with HIV or AIDS could use S1. John's wort as a safe treatment for the
           disease. (The FDA and FTC warn that S1. John's wort may have potentially
           dangerous interactions with other medications,including· someprovenHIV I AID
           Smed ications.j

"It's bad enough when someone, with little or no evidence, touts unproven remedies to
vulnerable populations such as people infected with HIV or AIDS," says Walter H. Carr,
part,ners,hip council chairman of the National AIDS Health Fraud Task Force Network, "It's
even more frightening when they do so despite--and without so much as a mention of--emerging
risks that those remedies pose to the very people to whom they are pitching their sale. St. John's
wort and protease inhibitors: They don't mix,"

Since the launch of Operation Cure.AII in 1999, the FDA and FTC have won a number of
battles against Internet health fraud. The FDA's efforts to curtail online marketing of unapproved
drugs have resulted in at least 12 product seizures, 11 product recalls, 43 arrests, and 22
convictions. The FDA continues to investigate more than 80 incidences- of -Internet health fraud
and unapproved drug products.

Since 1999, the FTC has brought 13 law enforcement actions against Internet marketers for
unsubstantiated health claims, One case resulted in a $1 million settlement with the maker of a
shark cartilage product promoted as a cure for cancer, Another settlem"ent required consumer
refunds for electronic devices and herbal remedies that were sold as cures for cancer, AIDS,
Gulf War syndrome, and many other diseases. All were required to remove their bogus claims
from the Web. In addition, the FTC estimates that more than 100 other Web sites have taken
down their sites or removed
their claims after the FTC contacted them.

 "Consumers should avoid Web sites that promise quick and dramatic cures for serious
 diseases," says Howard Beales, director of the FTC's Bureau of Consumer Protection. "And
 they should always consult a physician or other health-care professional before using any
 product or treatment."
DTC ads
What are the rules?
Confusion exists about the different types of prescription drug ads and FDA regulation of
DTC ads. The full set of regulation covering DTC ads is quite specific. What follows is a brief
synopsis of the most important rules.


The three types of DTC ads
      Help seeking: these ads aim to alert consumers about a disease or condition and its
       symptoms and let them know that treatment is available. A drug's brand name can not
       be used, but the company sponsoring the ad is identified. People are exhorted to see
       their doctor.
      Reminder: these ads give the name of a drug but do not mention any disease or
       condition to be treated. They are designed to build brand recognition and prompt
       people to ask their doctors about the drug.
      Product claim: these ads mention both a drug's brand name and its intended use. They
       aim explicitly to prompt people with a specific disease or condition to go to the doctor
       to inquire about the drug. Such ads must meet more exacting requirements. Most DTC
       drug ads today are product claim ads.


   The requirements


   All types of DTC drug ads:
          Must comply with FDA and other federal rules regarding advertising fairness and
           accuracy and "false advertising". In addition, no drug ad can (a) falsely report
           scientific data, (b) declare clinical superiority for a drug without scientific data to
           back it up, or (c) represent a drug as a treatment for a disease for which it has not
           been FDA approved.


       Help seeking and reminder ads:
          Do not have to contain detailed information – or give a source where consumers
           can get such information – on a drug's effectiveness or potential side effects.
Product claims ads:
   Must present a "fair balance" of benefit and risk information. This means, for
    example, that a print ad is not supposed to have huge type touting a drug's benefits
    and small type listing major side effect. Likewise, a 60 second TV ad can't spend
    50 second on benefits and 10 second on potential problems.
   Must, if they are in print (newspapers, magazines, internet), contain a "brief
    summary" of a drug's side effect, indications and effectiveness as well as any
    precautions and warnings about its use. This information must be consistent with
    and derive from a drug's official product labeling. The FDA in consultation with
    manufacturers dictates such labeling. In practice, this summary information is not
    brief at all. It can run to 1,000 words or more and usually takes up a sizeable chunk
    of space even when small print is used (which is almost always it is). However,
    this information may be, and usually is, printed on an adjacent page. In practice
    then, it is usually far less visible.
   Must, if they are broadcast (TV and radio); include prominent mention of a drug's
    "major" side effects or limitations and any important contraindications. In
    addition, such ads must give a toll free telephone number, a web site or internet
    address, and reference to print ads or available written material on a drug that can
    be obtained in a public place. Information sought from these sources must be sent
    out within two business days. Thus, DTC drug ads in broadcast media are
    exempted from airing the detailed "brief summary" information that is required in
    print ads.
                   ..................................................................................
.........................................
How to Report Suspicious Claims
The FTC and FDA encourage people to report suspicious health claims. Since January 2000,
the FDA has checked out more than 3,000 tips submitted by consumers about suspicious
online prescription Web sites, according to Tom McGinnis, R.Ph., the FDA's director of
pharmacy affairs.

To file a complaint regarding a possible fraudulent, deceptive, or unfair business practice,
call toll-free, 1-877 -FTC-HELP (1-877-382-4357), or use
the complaint form at www.ftc.qov.

If you find a Web site you think is illegally selling human drugs, animal drugs, medical
devices, biological products, foods, dietary supplements, or cosmetics over the Internet, use
the complaint form at
www.fda.qov/oc/buyonline/buyonlineform.htm .               -
--L. B.



 Be Suspicious
 Promoters of fraudulent health-care products often use similar claims and practices to lure
 consumers into buying their goods. The FTC and FDA advise consumers to be suspicious
 of:

          Claims that the product is "natural" or "non-toxic," suggesting it does not have side
           effects. "Natural" or "non-toxic" does not necessarily mean safe. Some "natural"
           supplements contain potent stimulants; others can result in negative interactions with
           medicines.
         Testimonials from people who claim amazing results. Testimonials often are
            undocumented and are not a substitute for scientific proof.
         Claims that a product is a "scientific breakthro~h," "miraculous cure," "secret
           Ingredient" or "ancient remedy."
         Claims that the product is an effective cure fdr a wide range of
            ailments.
         Claims that use Impressive-sounding medical terms.
         Claims that the pro¢uct is available from only one source, and
            payment is required in advance.
         Claims of a "money-back" guarantee.
         Web sites that fail to list the company's name, physical address,
phone number or other contact information.

				
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