Evolus is facing off against a much larger drugmaker in Allergan with its launch for new wrinkle-fighter Jeuveau, and now the company’s marketing strategy is turning heads. This month, the one-drug company invited medical aesthetics experts to Cancun, Mexico, for a meeting in support of its rollout, spawning a series of favorable social media posts that looked like something out of a Fyre Festival documentary—and critics are calling its ethics into question.
Doctors from Houston, Miami, North Carolina, New York, Chicago, Malibu and elsewhere traveled to Cancun to attend the Evolus meeting. In their posts about the trip, some experts called the confetti-covered event a “launch party” or “launch conference.” At least one post indicated a sponsorship, but many did not. The Federal Trade Commission has warned that sponsored posts must be tagged as such.
Many of the posts incorporate the hashtag #newtox, indicating support for the Jeuveau launch. On Wednesday, Evolus said it made its first Jeuveau shipment to about 3,000 practices around the U.S.
Evolus’ vice president of corporate communications, Crystal Muilenburg, told FiercePharma via email the company is taking a “modern approach” to launching the drug that’s “highly focused on digital and social media.”
“The market is ready for a new option, which is why providers have started creating buzz around the launch,” Muilenburg said.
Evolus only pays advisers for participation in advisory boards, and doesn’t compensate them for social media posts, she said. Further, the company doesn’t provide “preferential treatment, access to product or payment to anyone as a result of their social media presence,” she added.
“Our view under the FTC’s endorsement guidelines is that there is no connection between the compensation paid for separate advisory services and a provider’s independent content,” Muilenburg said. “However, if we have a speaker agreement with a provider or if we ever thought about utilizing paid influencers, their role would require them to provide disclosures and fair balance.”
Muilenburg noted that many posts incorporated a number of hashtags about varying treatment options. In speaking with The New York Times, the company’s CEO, David Moatazedi, said the event was similar to meetings its competitors hold.
It’s unclear what exactly Evolus paid for as part of the trip, but the event certainly raised questions. Bonnie Patten, the executive director of Truth in Advertising, told the Times the event was “incredibly problematic” because social media followers look to doctors for their expertise.
Evolus, a small company, isn’t a member of the group PhRMA, but top drugmakers abide by the lobby group’s marketing code. Adopted in 2009, the code (PDF) states that “to ensure the appropriate focus on education and informational exchange and to avoid the appearance of impropriety, companies should not provide any entertainment or recreational items, such as tickets to the theater or sporting events, sporting equipment, or leisure or vacation trips, to any healthcare professional who is not a salaried employee of the company.”
And while Evolus’ rivals must abide by strict doctor-payment disclosure laws, Moatazedi told analysts on a conference call last year that because there isn’t a therapeutic use for Evolus’ drug, “we don’t believe that the rules like Sunshine laws apply to Evolus,” according to a transcript on Seeking Alpha. The company also has more pricing flexibility because it doesn’t have a therapeutic use, he said.
Aside from questions over pharma marketing ethics, there’s another potential problem with the posts: side effects disclosures. Back in 2015, Kim Kardashian came under FDA fire for promoting morning sickness med Diclegis without disclosing side effects. In a revised post, Kardashian provided a fuller view of the drug. In its FDA-approved label, Jeuveau has a warning that the toxin’s effects can spread and cause difficulty swallowing and breathing.
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The Cancun trip came ahead of this week’s launch for Jeuveau, a new treatment for frown lines taking aim at Allergan’s entrenched Botox. Last year, Botox pulled in $907 million from cosmetic indications. The med also has therapeutic indications that generated $1.64 billion last year, but that hasn’t stopped industry watchers from fretting over the competition.
For its part, Allergan is taking the new threat seriously and is heavily promoting Botox. At a recent aesthetics day, the company touted a large DTC effort, prompting Wells Fargo analyst David Maris to ask for an update on a conference call this month.
The company’s chief commercial officer, Bill Meury, said on the call that there “is both a youth movement and a prevention movement underway” in the market. The company has embarked on three “digital ventures” he said, including Allergan Data Labs in Irvine, California. That group is “launching the largest digital marketing campaign ever for Botox on Mother’s Day, which we expect will attract tens of thousands of new users and loyalty members,” Meury said earlier this month.
Allergan intends to compete on “quality, innovation and customer service, not on price,” Meury told analysts.
“That is the only sustainable strategy in our view,” the exec added. “When it comes to neurotoxins, customers and patients are more outcomes and service sensitive than price sensitive. We are well positioned to defend this business.”
Before Jeuveau’s rollout, RBC Capital Markets analyst Randall Stanicky ran a survey with experts and found that 61% of doctors rated their willingness to switch away from Botox at a six or higher on a scale out of 10. The doctors said they’d be looking for about a 28% discount from Jeuveau to Botox to make the change.
Both Evolus and Allergan have a lot riding on the battle. Jeuveau is Evolus’ only marketed drug, and Botox is a long-standing performer for Allergan, which has faced numerous setbacks and is seeking to recover. Amid a noted stock slide in recent years for the company, some investors have questioned Allergan’s management. Other players in the field are Nestle’s Dysport and Merz’s Xeomin, but currently Botox holds about 70% of the market share.
Editor’s note: This story was updated with comments from Evolus’ VP of corporate communications, Crystal Muilenburg.
