1. Are there arguments for regulating speech about drugs more comprehensively than, for example, about dietary supplements? What must an administrative record contain to sustain such a position? In particular, could FDA sustain a position that certain promotional speech about drugs is inherently misleading, unless it complies with FDA requirements? Does anything turn on whether the speech is made to learned intermediaries or to consumers? What is the evidentiary basis of such a distinction?
For many years, the FDA has been misleading the American public regarding the benefits/challenges associated with dietary supplements.
It's time to put an end to this farce and let people know the real truth, not the truth of the pharmaceutical industry and medical community. These industries/professions have been providing false and misleading information to consumers for years.
It's time to Stop the Insanity.