Lexology December 6, 2024
The Food and Drug Administration’s (“FDA”) Office of Prescription Drug Promotion (“OPDP”) has issued its fifth Untitled Letter of the year, matching last year’s total number of enforcement letters. As a reminder, OPDP issued four Untitled Letters and one Warning Letter in 2023. So far this year, FDA has not issued any Warning Letters. With only about three weeks left in the year, it is likely that we will again see a low number of letters from OPDP. Interestingly enough, three of the five letters involved celebrity influencers, which is not surprising given their visibility and reach.
The latest Untitled Letter was issued to a pharmaceutical company over a social media post for its botulinum toxin injectable product used to...