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# Don’t Conduct Proprietary Name Analysis: PhRMA
- URL: https://www.fdaweb.com/dont-conduct-proprietary-name-analysis-phrma/
- Published: 2022-01-06T12:00:00.000Z
- Updated: 2026-09-14T17:27:48.000Z
- Author: David McFarland
- Tags: Drugs, #legacy-id-D5150875

Pharmaceutical Research and Manufacturers of America (PhRMA) says FDA should not move forward with a proposed study on text analysis of proprietary name interpretations. The association’s 1/3 comment [letter](https://downloads.regulations.gov/FDA-2021-N-1026-0003/attachment%5F1.pdf?ref=fdaweb.com) says it is concerned that the “proposed survey will not produce data that will appropriately inform or meaningfully improve FDA’s review of proprietary drug names and, therefore, it will not provide information that has practical utility or that is necessary to the proper performance of FDA’s functions.”

PhRMA recommends changes FDA could make to the methodology and questionnaire to help improve the research’s usefulness if the agency decides to proceed with it.

In its 12/20 comment [letter](https://downloads.regulations.gov/FDA-2021-N-1026-0002/attachment%5F1.pdf?ref=fdaweb.com), Lilly says it supports efforts to encourage the use of proprietary prescription drug names that do not misbrand the product. However, it says, it also has concerns about the proposed study and questionnaire. And it also expresses concern about how degrees or levels of misbranding may be established or standardized for evaluating proposed proprietary prescription drug names.

Lilly provides specific comments on the draft survey and includes information provided by an associate professor of integrated marketing communications and marketing in the Northwestern University schools of journalism and business.