Debated is the genesis of the first direct-to-consumer (DTC) drug concept in the U.S. Going back to at least 2011, Pfizer’s “unorthodox” Diplomat Specialty Pharmacy partnership aimed to launch Lipitor DTC in the face of generic competition. To be sure, there, the strategy did not—nor could it—resemble the more typical DTC format that Pfizer and just about every other large brand in the space offers today. DTC programs today rely heavily on telehealth, which since the pandemic, has greased the consumer access skids, generating significant DOJ activity[1] and creating reams of work for legal and compliance teams to sort through design and strategy.










