Analysis of this 75s ad identified 2 enforcement patterns, primarily Efficacy. Patterns span Visual Distraction, Efficacy — “Family & Social Scenes” identified at 40.1s, previously cited in Jardiance (x3), Contrave, Qulipta. FDA enforcement letter on file dated Feb 5, 2026.
Recommended action: Initiate PromoMats review: Verify all efficacy claims against current approved labeling. Visual representations should align with clinical trial results referenced in the PI.
| Pattern | Dimension | Score | Evidence | CFR | |
|---|---|---|---|---|---|
| Family & Social Scenes Warm family scenes that emotionally minimize risk information |
Visual Distraction | 73 | 2 clips | 21 CFR 202.1(e)(1) | ▶ |
| Dramatic Before/After Before/after visuals that may overstate treatment outcomes |
Efficacy | 61 | 21 CFR 202.1(e)(5) | ▶ |