He offers his own perspective on the first day and where he thinks this all may lead. After spending most of the two days there myself and [presenting to the FDA on the second day], I would say that all of his first day observations are relevant for both days.

Part 1

Part 2

Part 3

We will have a live wrap-up of the FDA hearings at the WOMMA Summit this week. We will also have a live session with the FTC in attendance as our next step in developing precise and practical best practices for that agencies recent Guidelines to marketers.
  

Speaking on behalf of WOMMA, Melissa Davies (member company Nielsen) and I delivered two different "testimonies."

I addressed questions 1 and 3 from the FDA docket. My goal was to share our recent experience with the new FDA Guidelines, suggest a level of brand responsibility around sites where brands establish a "material connection" and offer a suggestion for a new vocabulary to bring whatever guidelines come from the hearings more up-to-date and aligned with the industry.

Melissa shared her POV on the real instance of Adverse Events based upon some novel research her company had done.

One thing did surprise me. Most of the presentations not-focused on adverse events were focused on digital marketing basics - search marketing, banners, et al. Its true, pharma has been held back in the basics. The FDA needs to deliver some 'pretty good' guidelines on this Web 1.0 stuff quickly and then turn its attention to the true social media practices.

There were quite a few presentations that corroborated our point that the FDA could serve the public best by delivering some basic "guardrails" and then encourage and allow marketers to define the actual best practices around implementation.

We need to create a climate condusive to innovation from the market. That's what led to Web 2.0, social media and the Internet, itself.

The FDA "socal media" Hearings are going on all day today and tomorrow. Packed agenda - 60+ speakers including Ogilvy and WOMMA. You can watch it live here from the FDA.

On Thursday night, November 12th,  from 6:30pm - 8:30pm, WOMMA and member companies -  Live World and Ogilvy PR -  will have a tweet up at the Ogilvy offices in DC (1111 19th Street - 10th floor). Tony DiResta who is WOMMA's legal counsle will give a post-hearing wrap-up and a lot of us who participated will be there offering our won thoughts. Mostly its social.

You can RSVP here or just show up.

WOMMA has just gone through a productive year with the FTC that culminated recently with the FTC Guidelines on Endorsements and Testimonials.We will have a follow up session with the FTC at this year's WOMMA Summit in November.

WOMMA's Role

Ultimately, WOMMA wants to protect the consumer and the trust that brands can build with consumers if they use social media well. Consumers increasingly expect brands to engage and be available in social media. Brands value third party word of mouth as one of the most trusted sources for opinion and purchase decision. Brands and consumers want to connect in socila media. And we have to do it right or the basic premise beneath WOM - trust - will crumble. We also want to empower marketers to productively engage within social media. Pharma has been held back in part because of their fear of additional regulations or actions.  

The FDA's 5 Questions

The FDA has set up a listening session on November 18 and 19. The agenda is full of marketers and each of us has a 10-minute slot to help inform the FDA's 5 questions. 

It is not clear yet if these are even the right 5 questions. Still, in respect to the FDA and the simple principle that we have to start somewhere, I am grateful that they opened their doors. You can review the FDA's Notice of Public Hearing here.

Here are the 3 questions we plan to address with a quick summary of our POV:

Question #1: For what online communications are manufacturers, packers, or distributors accountable?

In today’s social Web marketers and consumers alike are flocking to third party sites and platforms both to be where consumers are and to garner legitimate third-party mentions that corroborate their products’ benefits or around a topic related to a disease or condition. The power of word of mouth means that marketers want influencers/bloggers to experience their topic, product, or service that relates to a brand and then share about it authentically.

WOMMA has an aggressive POV on what is proper disclosure both in spirit and actuality. Aligned with the recent FTC Guidelines, we see the opportunity for marketers to not only practice ‘full disclosure’ of any and all material connection between brand and influencer/blogger, but also to strongly encourage those influencers to do their part to properly disclose. As with the FTC Guidelines, it doesn't take payment to define a material connection. Marketers are better off disclosing any type of material connection whether they be travel expenses for a health blogger, technology support on an unbranded community, or even the snacks at a tweetup. Disclose and let the consumer judge credibility. 

Question #3: What parameters should apply to the posting of corrective information on Web sites controlled by third parties?

Social media is defined by conversations and a hyper-democratized  approach to publishing. Brands and marketers want to connect more directly with customers to better understand their needs and build a stronger relationship. In addition, brands want to ensure that the full story behind products are shared outside their Web sites. They want to be where consumers are spending their time and that is increasringly across the social web.Can pharma marketers be allowed the opportunity to comment on blogs and message boards – completely transparent about their identity and interests – to help keep the information about medical products as clear as possible?  Most pharma marketers do not feel empowered to comment or "fact correct" as the historic FDA guidelines might interpret that as a new instance requiring advertiisng or labeling information. Imagine if every comment required that full page disclaimer you see in print ads.  Conversely, we must not require an unsupportable burden - the requirement to "story-correct" across the vastness of social media. Like the FTC Guidelines, the marketer must focus their energy on keeping their own communications accurate and encouraging and even enforcing accuracy from any influencers they proactively outreach to.

The challenge with health care information is to allow for this conversational interaction while always putting the full story behind products and services front and center. No blog comment field or Tweet will sustain the full content of a product Web site. We may need to allow pharma a consistent "one-click" solution where marketers can comment and link back to the full body of a product insert.  

Question #5: Specific to Adverse Events Reporting

One of the biggest effects of social media is the new opportunity for brands to hear what consumers are saying in public discussions about products, services and issues important in their lives. Smart marketers have adopted “big ears” to make sure they listen and respond to customer concerns. 

The historic and important requirements around adverse events reporting have held many health care marketers back from listening to consumers. How the intent of adverse events reporting actually applies when a patient posts a product experience in Twitter with no contact information in their “bio” or exactly when an adverse event is established over the course of several blog posts is not clear. We need to find a clearer way of recognizing an adverse event and then reporting it that does not hold back a marketer from listening to what consumers are saying in the public space.

Outcome of the Hearings
The real solution may lie in the FDA establishing clear principles and then encouraging the industry to define exact practices as we are doing at WOMMA in relation to the FTC Guidelines. Can the FDA really hope to define the exact nature of a url or how to balance their historic need to approve marketing claims with the non-stop, real-time nature of a twitter-ized social Web? Will this type of detailed regulation help or hold innovation back? We need principles that protect the consumer but do not curb marketers from innovating.

Stop by:

If you are in DC for the hearings, stop by Ogilvy on Thursday night. WOMMA, LiveWorld and Ogilvy will be hosting a post-hearing Tweetup to recap what we heard that day. RSVP Here

We just went through a deep-dive on Microsoft's Looking Glass which points to a further evolution of the market towards in-house and integrated solutions. Is that defiance of the SaS model or are they accurately anticipating where big brands need to go in the future?  

Before I get to Looking Glass, Here are a few of the trends I am seeing:

1. the early lead of service providers who do everything from the technology to the insights is falling away. In its place are dashboard technology providers that put the tools in the hands of brands and agencies - the folks that know the brand business. Even Nielsen has a simple dashboard solution.

2. technologies are focusing on 1-2 of the 7 major purposes of Listening Posts. They are slowly focusing their strengths in certain areas and being more open about admitting what their solution or organization cannot support

3. there is a whole new set of technology providers who are building a flexible framework to be applied to multiple language markets. Once you broaden your view to identifying technologies that work across 4 or 5 language and geographic markets, you suddenly see a whole new set of providers like eCairn, Attentio, Brandwatch and others popup.

4. automated sentiment rating continues to be a holy grail (solutions with 60% accuracy are near-useless) except amongst a very few who have made progress notably Crimson Hexagon and Collective Intellect.

5. brands are splitting between those that want simple and fast and those that want tailored and highly relevant. Radian6 smartly stepped into the simple and fast space and continues to excel there even as others launch comparable "monitoring-only" solutions. A few brands have buy-in to invest the time and money for more tailored solutions. Which brings us to:

Microsoft's Looking Glass

We recently met with the development team at Microsoft responsible for their monitoring/listening solution dubbed Looking Glass. The solution is a 3 server-based model and sits on top of or integrates with Silverlight for the display layer, SQL server and Sharepoint. It is a work in progress and has some significant advantages over other solutions depending on which of the 7 reasons you need a Listening Post and what other Microsoft investments you have made.   

Here are 4 reasons that Looking Glass may be great for enterprise listening:

1. It uses Bing for blog and Web search. That engine will likely provide a strong heart for teh service for years to come.

2. Its real power is in the customizability down to its ability to pull in new data feeds. That means that enterprise can combine data feeds that are most relevant to them (the future of Social IRM is in the integration with CRM databases. This platform will handle that.

3. The Silverlight-powered display is good-looking. Don't underestimate the power of great information design to make listening solutions usable.

4. Like Visible Tech it features task-delegation functions. If you want to assign someone to respond to a Tweet or a post, you can do that within the system and track those responses.

This is meant for the more advanced enterprise willing to invest the integration and customization hours never mind the hosting/serving of it. As we move towards more advanced models of integrating cgm listening into the enterprise like the Social IRM model, the Looking Glass model may be a strong solution. Everyone awaits the debut of the next Google Labs experiment where they deliver the 30 ton megaton bomb on teh listening market with their own solution. I only presume that is somewhere inside their skunkworks....

This year's Word of Mouth Marketing Association (WOMMA) Summit is something else. It is the fruit of two years effort by a lot of smart marketers to bring the best of social media and word of mouth marketing together. We wanted to help experienced marcom experts share best practices in the best way possible - via our peers. As current Board President of WOMMA, I can proudly say that this event reflects the essential and exciting role WOMMA plays now.

Here are 7 reasons why this year's WOMMA Summit is a must-attend event for any marketer who needs to apply social media in a disciplined, impactful way:

1. The best insight comes from real brand cases. WOMMA Summit will feature disciplined cases from Ford, Tropicana, General Mills, Coca Cola, Pepsi, Microsoft, CDW, IBM, SAP, Walmart, BestBuy, HP and more. Learn from real practices.

2. Our session "The Role of the FTC in Word of Mouth and Social Media Marketing" will feature the Chuck Harwood, Assistant Deputy Director. he will help everyone better understand the new FTC Guidelines and WOMMA's next effort to define best practice disclosure

3. The Brands Council at WOMMA will host its own meetups for brands allowing marketers to share experiences and get advice from their peers.

4. Ray Day, VP of Global Communications at Ford, and Scott Monty will keynote and share insights about how Ford has woven social media into the fabric of the company.

5. A post-hearing analysis session dedicated to the FDA Hearings on social media in health product marketing.

6. A full "track" dedicated to Research and Measurement AND the release of a final draft of the WOMMA Measurement Guidebook. I don't know about you but measurement - both performance and ROI - is the most important issue from brands who want to expand their use of social media. You will get practical, applicable-now models.

7. The first annual WOMMY Awards will identify the best of the best in social media and word of mouth marketing (I think there were over 200 entries!)

Bonus reason: The band, Sugarland, will keynote about their extraordinary work with fans and that's just cool.

This will be a terrific and talked about event. Just go to the Website and judge for yourself. In tough economic times, we each have to choose what is essential to our business. This event was designed to deliver an essential experience for brands and marketers needing to learn expert and best practices for social media from the people actually doing it not just talking about it!

When: November 18-20
Where: The Paris in Las Vegas (a Harrah's property!)
How: Go here to register 
Go here to learn more

Register today with the code "fanofogilvy" and receive $200 off the fee. There will be no other discounts.
I will be there. Tons of brands will be there. I hope to see you there. 

A sister company of Ogilvy inside WPP, Group M, released a bit of interesting research a week back. Essentially, their study pointed to the positive effect of social media on the performance of search.

"...a 50% lift in click-through rates across the board when consumers had been exposed to social media and paid search."

"Every day consumers express their intent via search. Now, we better understand how that intent is established via social media and the interplay between the channels," says Chris Copeland, chief executive officer of GroupM Search for the Americas. "There is a valuable audience for advertisers to focus on who are engaged with brands through social media and search. The study further validates our view that media discovery -- specifically. a brand's owned and earned media -- is as important to success as the paid media we handle every day. Generating upper-funnel awareness and influencing consideration through social media can produce better down-the-funnel performance with paid media, such as paid search."

"The study reveals that people who search and engage with social media, especially those exposed to a brand's influenced social media, are far more likely to search for lower-funnel terms than consumers who do not engage with social media. Furthermore, consumers exposed to a brand's influenced social media and paid search programs are 2.8 times more likely to search for that brand's products compared to users who only saw paid search."

New Responsibility

The final Guidelines do hold bloggers and brands responsible for what they say about products and services and, more importantly, their disclosure to their followers of any material connection between them. The FTC has refined its message over th past week by clarifying that they will look mostly to the marketers to enforce the disclosure requirements.  There are some vague areas. The definition of whether of giving product samples is considered a "sponsorship" hinges on the undefined value of a product (stick of gum? probably not. laptop? oh yes.) and whether there is a history between marketer and blogger or if the blogger has a history of routinely accepting products for reviews. I agree, this is an area that needs to be sharpened if anyone every has a hope of enforcing a guideline.

Not About Advertising; It's About Word of Mouth

But the "sky is falling" claims of some marketers are just not warranted. Randall Rothenberg who heads up the IAB wrote a long, impassioned letter to the FTC Chairman via Huffington Post. I respect IAB and Randall. His book, "Where the Suckers Moon" is one of the best ad books on the market. Their representation of their members is laudable. And if this were all about "advertising" than he might have a point. It's about word of mouth marketing.

As consumers, we have grown used to reading and watching the opinions of peers and 'strangers with expertise'via their blogs, Twitter feeds and facebook pages. This extends the reach of offline word of mouth and together they represent the most trusted source for opinions and purchase decisions around many products and services. That trust is dependent on the transparency of the relationship between marketer and blogger/influencer and the assurance that the opinion a blogger states is truly her own. At WOMMA we want to protect that power which is why we have our own Code of Ethics that guides our members' behavior in this space.

Randall's chief complaint is how the FTC holds online influencers/bloggers to a different standard than traditional media. The former must disclose receipt of products and other considerations that qualify as a material connection. The latter do not. 

I agree this is lopsided. I respectfully request that all traditional journalists disclose when they receive a product from a marketer.(we are really talking about the traditions of the fourth estate not the broader 'communications' field) 

Rather than the IAB stance that hopes to relieve bloggers of any special requirement to disclose, we should really just get everyone to disclose. Let the consumer decide who is credible regardless of whether they write periodically under a recognized media masthead or not. I actually think Mr. Rothenberg is onto something when he says this is confusing. The confusion starts with consumers not always knowing the source of content they browse in the great aggregator - Google. What is traditional media - governed by a journalistic code and what is the emerging media of everyone - which is often oblivious to that code? Rather than treat blogs like traditional media, let's follow a new standard which calls for full disclosure. If journalists and traditional media follow suit, great. If they don't, at least full disclosure by bloggers protects their consumers. I don't seriously think that media companies will jump on the disclosure bandwagon. But if bloggers disclose, they will keep their side of the street clean.  This will protect the power of word of mouth for brands and consumers alike leaving them to collaborate and share about what matters most to them.

The Answer is a Simple Disclosure

The IAB points out many weaknesses in the FTC approach. Their primary concern seems to be whether bloggers will be wrongfully prosecuted for non compliance and whether the Guidelines are constitutional. Sharper minds than mine will debate if there truly is a constitutional issue here. The FTC has already commented that they have no intention of going after bloggers even admitting that they have no real enforcemnt 'engine.' All a blogger has to do to align themselves with the new Guidelines is add a few brief words to their post in a clear way - "they sent me this book (laptop, mobile phone, case of soap, airplane ticket) free of charge to give me an experience with the product. The opinions that follow are my own..."

Let's Define 'Best Practice' Disclosure Next

All a brand has to do is ask them to disclose, monitor if they do and take a reasonable action if they don't. The details of "best practice" disclosure are what we need to iron out next. Rather than rail against the FTC that their current first pass is confusing or worse, unconstitutional, WOMMA will do what it always has done, roll up our sleeves and define the best practice model, in this case, for disclosure between brands and bloggers. Like our Code of Ethics referenced by the FTC, this new guide for how disclosure should be handled by brands may go a long way to satisfy the FTC that the industry really is earnest in protecting consumers. 

Come to our Summit in November to meet the FTC (and FDA!) and participate with our panel as we define very specifically the best way for brands to achieve the highest levels of disclosure. The FTC has started a process. Now they want the industry to continue with the hard work of making it real.  

Previously, I have covered theresearch and activation of influencers in a Social IRM stratgey. Overall, this is an approach to managing influencers with the same discipline that we try to manage customers - without any of the abuse. By that I mean, the approach to CRM that tries to stimulate customers right to the brink of annoyance but hopefully not over. Like how many emails you send to them with offers before those emails convert to spam. The industry I would most like to see have a CRM overhaul is the magazine business. I am a 15-year or more loyal reader and subscriber to Metropolis Magazine. Do I get any love or acknowledgment? Do they still send me subscription renewals 6 months before they are due hoping that I will think the sub is up and send a check?

Anyhow, the principal of Social IRM is far more benign. It is ultimately built on the premise of 'Value Exchange' covered in a previous post. You cannot 'game' influencers nor can you push them where they don't want to go. The discipline of Social IRM is about serving them better and creating a protocol inside the brand marketer for constantly delivering value that is talkworthy.

Once you have engaged influencers in an experience they care about and they find it worthwhile to post, comment, tweet, video post or otherwise share word of mouth (WOM), how can you add scale to have a bigger impact?

Scale or Amplification
There are 7 key ways to add reach to a influencer program. If there are others, I would love to hear about them. One of the key tenants of Social IRM is that you are engaging relevant influencers on behalf of the brand. This means outdoors experts on behalf of REI or enterprise IT managers for SaS services targeting....enterprise. These folks are not always going to have the largest reach. Certainly they may not have what the professional alpha bloggers have. So the question remains, how can you have their WOM reach more people - without spoiling the WOM?

7 Ways to Scale
Aggregate the voices: If we collect all of what people are saying about the brand or relevant topic and pull it altogether via a content aggregator we can potentially increase the reach. I say potentially because either you will be integrating that aggreagation in a high-traffic site or driving awareness via an ad campaign to the aggregator. Just creating one doesn't do it. Good examples include:

Traditional media relations: Some of the things we do online are media-worthy.Traditional press may find it interesting that we are co-creating a new product with customers or whatever we are doing. 

Partnerships for reach: Finding a great partner who has a relevant constituency is a fundamental PR and marketing tactic that is equally relevant to the social space. Perhaps the online community around the Appalachian Mountain Club would work with REI on its "Stories of the Appalachian Trail" project (I made this up) and notify their members.

SEO & SEM: Making our content as visible and findable as possible via both organic and a "strategic" SEM buy can ensure that we earn as much search engine traffic for our WOM program as possible. Again, the aggregator is key as a hub that we can build some decent Google Juice around.

An Enthusiast Network: If you maintain long-term relationships with a group of enthusiasts - enthusiasts for the brand or the topic of interest (overnight hiking?) gives you a network of relevant folks to invite into an activity. This can also reduce your cost of "influencer acquisition." We are launching a software platform with several clients now that enables us to grow this type of network and deliver valuable content and offers directly to them for sharing (i.e. this is our value exchange).

Generally no one tactic is the answer. Think of this more as a checklist and all may apply. If you want to go beyond scoring a handful of posts from influencers and stimulate an environment where sharing on a topic is productive for all and reaches as many relevant folks as possible, consider an amplification strategy with these tactics.