Seeding trials may also utilize inappropriate promotional rewards, which may exert undue influence or coerce desirable outcomes. Documents released during a court case indicate that the Assessment of Differences between Vioxx and Naproxen To Ascertain Gastrointestinal Tolerability and Effectiveness (ADVANTAGE) trial of Vioxx conducted by Merck may have been a seeding trial, with the intention being to introduce the drug to physicians rather than test its efficacy. It appears Merck knew about the potential criticism they would face; an internal email suggested: "It may be a seeding study, but let's not call it that in our internal documents". The 2003 study was originally published in the "Annals of Internal Medicine" but was strongly criticized for its deception by the journal's editors in a 2008 editorial, calling for greater responsibility in academia to end the practice of "marketing in the guise of science". In the STEPS trial Pfizer presented their drug Neurontin in a way that merged pharmaceutical marketing with research. This trial and other practices led to the company's loss in "Franklin v. Parke-Davis". Product Placement is an advertising technique used by companies to subtly promote their products through a non-traditional advertising technique, usually through appearances in film, television, or other media. In the marketing field, seeding is considered the process of allocating marketing to specific customers, or groups of customers, in order to stimulate the internal dynamics of the market, enhance the diffusion process and encourage faster adoption of the product throughout the entire population. In a marketing seeding program, a company offers some sort of promotion (free product, discounts, service trials, etc.) to a niche group of people with the intention that this would stimulate WOM. An early example of a seeding trial was during the development of Post-it notes, produced by 3M. In 1977, secretaries to senior management staff throughout the United States were sent packs of Post-its and invited to suggest possible uses for them. They soon found them to be extremely useful and became "brand champions" for the product, an early example of viral marketing. Companies that have used seeding trials include Procter & Gamble, Microsoft, Hasbro, Google, Unilever, Pepsi, Coke, Ford, DreamWorks SKG, EMI, Sony, and Siemens. Two of the main managerial decisions revolving around seeding focus on seeding of advertising in a multinational market and the process of seeding the product itself. Determining how many and which consumers within a particular social network should be seeded to maximize adoption is a challenging task for a firm.