Neuromarketing: Pharma Threat?


Some people find drug company marketing reprehensible, and apparently nobody more so than these four organizations: the Center for Digital Democracy, U.S. PIRG, Consumer Watchdog, and the World Privacy Forum. They have filed a complaint with the Federal Trade Commission accusing drug companies of everything except kidnapping and insider trading. The complaint runs to 144-pages, and cites such transgressions as,

  • The practice of medical “condition targeting,” covering such illnesses as depression, COPD, diabetes, and asthma, based on a person’s use of online health information services and digital behaviors;
  • The eavesdropping on online discussions of health consumers via social media data mining, enabling pharmaceutical companies to hone marketing campaigns for drug brands;
  • The collection of data on a consumer’s actions related to health concerns via online profiling and behavioral tracking in order to track and target them for medical advertising;
  • The use of viral and so-called “word-of-mouth” techniques online to drive interest in prescriptions, over-the counter drugs, and health remedies;

Some of these sound kind of tenuous, but the corker is the last one:

  • The influencing of subconscious perceptions via pharma-focused “neuromarketing.”

[From CDD, U.S. PIRG, Consumer Watchdog, and World Privacy Forum Call on FTC to Investigate Interactive Marketing of Pharmaceutical and Health Products and Services to Consumers and Health Professionals.]

I’d be the first to agree that drug marketing could be reined in; my own pet peeve is the spending of billions of dollars to market drugs without a proven performance advantage over cheaper, off-patent drugs. That’s fine for a shampoo maker where the consumer decides whether or not the product is worth its price, but not for a firm who wants to be reimbursed by the government or private insurance (and hence, by you and me via taxes and higher insurance premiums).

Still, this complaint is so wide-ranging I think it is unlikely to have any impact at all.

I’d be really interested to see some of the supposed examples of “neuromarketing influencing our subconscious perceptions.” About the only reference I was able to find was an OTOI webinar on how pharma companies could improve their websites via eye-tracking and other biometric measures. This is hardly a unique effort, as just about every website could benefit from this kind of study (even those of advocacy groups!).

If anyone comes up with a good example of drug company brainwashing-via-neuromarketing, I’ll be sure to write about it here. Drop me a note or post it in the comments.
Image via Shutterstock

  1. Brad Einarsen says

    The funniest aspect of the complaint to the FTC is that they simply list the marketing tactics that EVERY (savvy) brand uses, from birth control to toothpaste to cars… Somehow they feel that by describing it as something “big pharma” does will imbue it with a more ominous overtone and spark more fear.

    It’s almost like it’s the large, multinational NGOs are using our own neurological processes against us… hey! They’re “neuromarketing” at us… how evil.

    The one point that they have correct is:

    “The eavesdropping on online discussions of health consumers via social media data mining, enabling pharmaceutical companies to hone marketing campaigns for drug brands;”

    Thanks, Nielsen, for that faux pas (

    1. Roger Dooley says

      My initial reaction was similar. “My goodness, these evil firms are using word-of-mouth marketing! Not fair!”

      Thanks for the link. As a community builder/administrator, I do wish site owners had better legal alternatives to deal with content scrapers that are violating their site’s TOS.


  2. Rich and Co. says

    We never underestimate the power of inflammatory marketing — which is what these organizations are doing as well.

    Fear/inflammatory marketing is used because it’s so darn reliable — the way nature “designed” it to be!

    As we all know “logic” and “facts” are (completely) irrelevant. In fact, they trigger even greater fear/defensive brain processes and behavior.

    All that matters is whether the amygdala of key people is triggered — mainly policy makers and media producers and editors. Fox News has shown us all “the way” — “feed the fear.”

    This toothpaste is coming out of the tube — one way or another. Best to plan for is now.

  3. Linda Jackson says

    My general reaction to pharma companies is distasteful especially from the “viral, WOM” spam that tries to sell me ED drugs and sleep aids. If that is the message they hope to send, so be it; however, we would all be well served if the organizations named above would work with the Pharma companies to craft a better message, delivery system and anti-spam solution.

  4. Duff says

    The United States is the only country in which direct-to-consumer marketing for prescription drugs is legal. Consequently, we also have the largest use of prescription drugs per capita of any country. Personally, I think direct-to-consumer marketing of prescription drugs should be made illegal, neuromarketing or not.

  5. Denise says

    I agree with Duff.

    Regardless if the pharma companies are using “neuromarketing” or any other “eavesdropping” technique is not the point. It’s very different selling cars, toothpaste or shampoo direct to customers than it is drug.

    We are talking about chemicals that have the potential to do lethal harm if used incorrectly (and sometimes similar harm even if used correctly). ALL drugs have side effects, especially if multiple medications are used. Yes, the pharma companies are evil companies when they start crossing the line in jeopardizing people’s health and lives. There should be no direct consumer marketing.

    As far as it being a demo of good branding tactics no different than anyone else, I have a real problem with any business going too far in tracking my behavior online. If I gave permission, that’s one thing. I consider it an invasion of my privacy.

  6. Page says


    I hope you are not a researcher since you seem perfectly willing to jump to an unwarranted conclusion based on almost no evidence.

    Direct to consumer drug advertising is legal in the United States and New Zealand, the US is not the only country that permits it, New Zealand does as well. Among seven richest countries in the world, U.S. spends $790 per capita (on prescription drugs) compared with $599 in Canada, the next highest country, and $292 in New Zealand.

    I would suggest that the reason the US has the highest prescription drug expenditures is that we are in love with the “pill fairy” and affliction which also affects our neighbor to the North, who does not allow direct to consumer advertising and does negotiate for better prices from pharma.


  7. Brendon B Clark says

    Having worked in mental health for years, I’ve seena lot of pharma marketing up close and, though it may grate on some people, they market as well as, or better than, many other products. T

    For years drug reps have been plying their trade in surgeries, wards and clinics, building relationships, becoming what some would now call “trusted advisors” as if it’s a new thing.

    They sell through relationships, trust, familiarity which breeds liking, sponsoring the right things, appearing in the right places, by telling you you have aproblem and offering you a solution, all of the things many other companies would love to emulate.

    I doubt you could argue their marketing is foul, except to say that the problems they would lead us to believe we’ll all have aren’t as bad, life threatening, pervasive or abnormal as they make out. But hey, that’s marketing, right…

    1. Roger Dooley says

      Drug companies definitely know a thing or two about marketing, Brendon. I only find their techniques problematic if they push expensive but no more effective products that we all end up footing the bill for.

      They also know a thing or two about lobbying. In the US, the government agreed to NOT negotiate with the drug companies on reimbursement prices in return for meaningless concessions. Pure insanity. I sold an industrial product to the government years ago, and I had to certify that I wasn’t selling the same product at a lower price to anyone else. That simple policy applied to drugs would save billions.


  8. Tom Wueste says

    I think what bothers people about marketing of pharmaceuticals, as opposed to most other products, is that we expect our doctors to make fact-based decisions on our behalf. The unfortunate truth is our doctors are influenced by the same things that influence the rest of humanity: they will recommend the drugs they have free samples of, or reciprocate the salesperson who brings the staff ‘free’ pizza, or the better-looking salesperson. The doctors will give in to patients’ pressure to prescribe consumer-advertised medicine.


  9. Page says

    I think we patients need to be a lot more proactive about managing our medical care than “just do what the doc says”. Doctors rely on phama detailers to keep them up to date. Maybe they shouldn’t but they do and it so easy, I’m sure they will continue to do so.

    We have the whole internet to research out prescriptions and check for generics and side effects. If we are so lacking in critical thinking as to fall for the appeals of Bach remedies, homeopathy, vaccine avoidance, vitamins and food supplements instead of real medicine and real drugs, it will improve the gene pool.

  10. Rich and Co. says

    We find that the pharma and health care firms are doing some of the best evidence-based marketing of any industries. We follow it and apply many of their findings.

    Is that a “good” or “bad” thing? Likely both at the same time. Moral judgements are very tricky.

    Claiming moral superiority and tagging other people as immoral, bad, dumb, selfish, etc is just another self-serving trick out brains play with us. Ho hum.

    The human brain, as do most other animals, will always “abuse” whatever resources are available. That is inherent in the “active” and aggressive nature of life. The shy and introverted life forms went extinct long ago.

    Contra the “evil marketers” view, include:

    – Aggressive neuromarketing can also be seen as saving time and energy for all involved since it helps focus on efficient meeting of needs.
    – We blame media and marketers for delivering us what our brains crave and demand. “The fault dear Brutus..” By definition, if our brains didn’t demand all this they wouldn’t exist. Duh

  11. Jeff Chester, Washington, DC says

    This col. fails to address the serious issues raised in our complaint related to pharma companies using neuromarketing and other techniques designed to deliberately bypass a consumer’s rational decision-making process. I suggest your readers review the complaint and the citations. The complaint has struck a nerve with some from the marketing community, since it made public pharma and drug marketing techniques targeting consumers and health professionals that few in the public or policymaker community know about. It’s already had an impact at the FTC and other regulators. This col. should be in the forefront of calling for responsible regulation on neuromarketing.

  12. Roger Dooley says

    Jeff, thanks for dropping by. To save Neuromarketing readers the trouble of reading a 144-page complaint and further pursuing the citations, can you explain the specific “neuromarketing” techniques the plaintiffs think are being employed and find problematic? Why would we talk about regulating neuromarketing while focus groups and questionnaires run wild?


  13. Robin says

    It’s all in the cookies.

  14. Jeff Chester, Washington, DC says

    I will come back and respond to your question. Meanwhile, we are glad German privacy officials are regulating neuromarketing. Our blog post is here:

    Excerpt citing law firm post: [O]n November 23, the data protection authority (DPA) of the German Federal State of Hamburg imposed a €200,000 fine against the Hamburg-based savings & loan Hamburger Sparkasse due to violations of the German Federal Data Protection Act (the BDSG) for, among other reasons, using neuromarketing techniques without customer consent…Indeed, according to the head of the Hamburg DPA, Prof. Johannes Caspar, the intent was to send a clear signal to the market against the use of modern neuromarketing and comparable methods in violation of data protection law. The case also clearly illustrates that German regulators are willing to enforce the new data protection regime and are well prepared to impose significant fines upon companies rather than giving them merely a warning notice…The decision of the Hamburg DPA may also attract attention beyond Germany and influence the interpretation of data protection laws in other countries, in particular with respect to the compliance of neuromarketing and brain sciences techniques with data protection laws. Due to the sensitivity of such activities, it is likely that regulators in the EU will follow the approach taken by the Hamburg DPA.”

  15. Brad Einarsen says


    Your post seems to be confusing “neuromarketing” (the use of human pre-programmed neurological responses to increase marketing effectiveness) with “privacy and data protection” (the use of private customer data only with consent).

    The source post in German (as translated by Google Translate) indicated that the fine was for misusing data to create customer profile. Whether they framed their arguments in a way that was neurologically optimized is not discussed.

    Neuromarketing isn’t really something you can opt-in or opt-out of. It is simply the formation of marketing messages that will resonate.

    Now, if you use private customer data to select from a menu of optimized messaging that will resonate with customers, I suppose you could draw a linkage between privacy and neuromarketing… but I would still classify that as a privacy issue rather than a neuromarketing issue.

    Other opinions on this distinction? Roger?

  16. Jeff Chester, Washington, DC says

    I fear the neuromarketing industry doesn’t get it. Its use to facilitate data collection and foster interactive marketing triggers privacy related safeguards from regulators. As with privacy and interactive (behavioral) marketing issues, the EU is ahead of the U.S. The German decision signals to the FTC that it’s now time to regulate data collection and online marketing that uses neuromarketing. Expect a growing call for regulation from consumer and privacy groups across both sides of the Atlantic.

    1. Roger Dooley says

      Jeff, I don’t understand what “data collection and online marketing that uses neuromarketing” means. Can you expand on this or give an example? And explain how “privacy” is related to neuromarketing, since the whole idea of neuromarketing studies are to create general strategies, not individually targeted ones. It seems that somehow topics like behavioral targeting, retargeting, etc. are being jumbled with “neuro” concepts.



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