Analysis of this 60s ad identified 3 enforcement patterns, primarily Fair Balance. Patterns span Visual Distraction, Fair Balance — “Family & Social Scenes” identified at 31.9s, previously cited in Jardiance (x3), Contrave, Qulipta. FDA enforcement letter on file dated Sep 9, 2025.
Recommended action: Flag for next MLR cycle: Benefit-to-risk presentation balance requires attention. Ensure risk information receives comparable prominence, duration, and audio/visual treatment.
| Pattern | Dimension | Score | Evidence | CFR | |
|---|---|---|---|---|---|
| Family & Social Scenes Warm family scenes that emotionally minimize risk information |
Visual Distraction | 66 | 2 clips | 21 CFR 202.1(e)(1) | ▶ |
| Benefit vs. Risk Time Imbalance Significantly more time spent on benefits than on risks |
Fair Balance | 58 | 1 metric | 21 CFR 202.1(e)(3)(iii) | ▶ |
| Audio/Visual Mismatch Risk info presented in audio only without matching visual reinforcement |
Fair Balance | 58 | 1 metric | 21 CFR 202.1(e)(3)(iii) | ▶ |