Qulipta – Compliance Alert

Caution

This ad has patterns previously flagged by FDA.

Analysis of this 30s ad identified 2 enforcement patterns, primarily Visual Distraction. Patterns span Visual Distraction — “Outdoor & Physical Activity” identified at 0.0s, previously cited in BRUKINSA, COBENFY, Fasenra (x3). FDA enforcement letter on file dated Sep 9, 2025.

Recommended action: Flag for next MLR cycle: Visual content during safety information window (13s–25s) may distract from risk disclosure. Schedule creative revision to use static or neutral visuals during major statement.

Video Timeline

Risk disclosure: 13.2s – 25.4s (12.2s of 30.3s total — 40.3% of ad)

Risk Window

0s8s15s23s30s

Family & Social?Risk Window?

Patterns Detected (2)

Each pattern below is a known FDA enforcement concern, identified by matching this ad against 14 violation types from 34 FDA warning letters

Pattern	Dimension	Score	Evidence	CFR
Outdoor & Physical Activity Upbeat outdoor imagery shown while safety warnings are being read	Visual Distraction	50	1 clip	21 CFR 202.1(e)(1)	▶
FDA Concern: Risk information must be presented in a clear, conspicuous, and neutral manner without distracting visuals Previously cited: BRUKINSA, COBENFY, Fasenra (x3), Velsipity, Calquence
Family & Social Scenes Warm family scenes that emotionally minimize risk information	Visual Distraction	50	1 clip	21 CFR 202.1(e)(1)	▶
FDA Concern: Risk information must be presented in a clear, conspicuous, and neutral manner without distracting visuals Previously cited: Jardiance (x3), Contrave, Qulipta, Calquence, Austedo (x2)

Recommendations

high

Flag for next MLR cycle: Visual content during safety information window (13s–25s) may distract from risk disclosure. Schedule creative revision to use static or neutral visuals during major statement.

high

Escalate to regulatory affairs: FDA enforcement letter on file (Sep 9, 2025). Verify remediation status in PromoMats and confirm all content modifications address cited violations before next distribution.

Compliance Alert: Qulipta

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