Yesterday evening, the Associated Press reported about a subpoena received by the drug company Amgen Inc. over promotional "and other" activities. While not much details were given, it noted that the subpoena sought documents from Amgen's sales and marketing activities, medical education, clinical studies, pricing and contracting, license and distribution agreements, and corporate communications. Experts at a device conference a couple of months ago told attendees that the government has been looking at these very same documents at device companies in efforts to find evidence of a violation. Their strongest advice--conduct audits and make sure you respond to them appropriately.
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