Analysis of this 60s ad identified 3 enforcement patterns, primarily Visual Distraction. Patterns span Visual Distraction, Efficacy — “Outdoor & Physical Activity” identified at 19.6s, previously cited in BRUKINSA, COBENFY, Fasenra (x3). FDA enforcement letter on file dated Dec 15, 2025.
Recommended action: Flag for next MLR cycle: Visual content during safety information window (24s–51s) may distract from risk disclosure. Schedule creative revision to use static or neutral visuals during major statement.
| Pattern | Dimension | Score | Evidence | CFR | |
|---|---|---|---|---|---|
| Outdoor & Physical Activity Upbeat outdoor imagery shown while safety warnings are being read |
Visual Distraction | 49 | 5 clips | 21 CFR 202.1(e)(1) | ▶ |
| Daily Activities Relatable lifestyle visuals that divert attention from safety disclosures |
Visual Distraction | 49 | 3 clips | 21 CFR 202.1(e)(1) | ▶ |
| Comparative Claims Claims suggesting superiority without adequate supporting data |
Efficacy | 74 | 1 clip | 21 CFR 202.1(e)(5) | ▶ |