From: Bruce Bebo xxxxxxxxxxx
Sent: Friday, October 18, 2002 12:40 PM
To: fdadockets@oc.fda.gov
Subject: commercial speech

To whom it may concern: 
My name is Dr. Bruce Bebo and I am writing to offer my 
comments to the US Food and Drug Administration with 
regard to the FDA's authority over "commercial speech" 
especially with regard to pharmaceutical companies' 
advertisement of prescription drugs. 

I do not believe the pharmaceutical industry needs any 
weakening of advertising laws, as they already found 
ways to spend over $2.5 billion in direct-to-consumer 
marketing in 2000, in addition to $4 billion they spent 
on marketing to doctors (not including an additional $8 
billion in prescription freebies). As a result of these 
heavy ad campaigns, the pharmaceutical industry was the 
best performing sector of the US economy the last 
several years, according to Fortune Magazine, including 
a lead in every measurable growth area in 2001. Their 
profits were driven largely by enormous returns on 
aggressively marketed pharmaceuticals - with 34 of these 
high profile drugs making up more than 50% of the 
industry's skyrocketing profits. In addition to selling 
to more and more consumers, drug companies are jacking 
up their prices at well over the rate of inflation * 
Allegra's gone up 11%, OxyContin up 15%, and Accutane up 
nearly 23%.  

The pharmaceutical industry is preying on its most 
vulnerable citizens: the sick, infirm, and aging, in its 
quest for profits. The Food and Drug Administration 
should maintain and improve its role as the watchdog for 
what Americans consume in the name of health, rather 
than assist in drug company profiteering. The FDA should 
not cave into the pharmaceutical industry as was done in 
1997, when relaxed rules on drug advertising initiated 
this steady rise in drug costs. Instead, the FDA should 
concentrate on looking out for the needs of its citizens 
and assisting federal officials in finding ways to keep 
costs down, not helping them rise further out of 
control. 

Bruce F. Bebo, Jr., Ph.D.
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