Lil­ly, No­vo Nordisk fight in­sulin biosim­i­lars with tweaks to FDA draft guid­ance

As Amer­i­cans with di­a­betes con­tin­ue to die be­cause they can­not af­ford their in­sulin, two of the three in­sulin man­u­fac­tur­ers in the US are do­ing their best to try to al­ter FDA draft guid­ance that seeks to bring more in­sulin com­pe­ti­tion to mar­ket.

The draft guid­ance, un­veiled last No­vem­ber, ex­plains how in­sulin biosim­i­lar de­vel­op­ers may not need to con­duct com­par­a­tive clin­i­cal im­muno­genic­i­ty stud­ies un­der cer­tain cir­cum­stances.

As part of FDA’s rea­son­ing be­hind its sci­en­tif­ic think­ing on a “lack of clin­i­cal im­pact of im­muno­genic­i­ty with in­sulin,” the draft cites a re­vised guide­line from the Eu­ro­pean Med­i­cines Agency in 2015, which said that it no longer rec­om­mends a clin­i­cal im­muno­genic­i­ty study to sup­port a biosim­i­lar mar­ket­ing ap­pli­ca­tion in some cas­es.

FDA al­so points to “decades of clin­i­cal ex­pe­ri­ence with ap­proved in­sulin prod­ucts, in­clud­ing the lack of a cor­re­la­tion be­tween im­muno­genic­i­ty and safe­ty or ef­fec­tive­ness as re­flect­ed in ap­proved prod­uct la­bel­ing for in­sulin prod­ucts.”

But in com­ments sub­mit­ted 28 Jan­u­ary, No­vo Nordisk and Eli Lil­ly do their best to try to main­tain the sta­tus quo and de­lay com­pe­ti­tion from com­ing to mar­ket.

No­vo, for in­stance, said it “ex­pe­ri­enced a cir­cum­stance of un­ex­pect­ed im­muno­genic­i­ty in re­sponse to a new in­sulin ana­log which was en­coun­tered dur­ing its clin­i­cal de­vel­op­ment.”

The com­pa­ny al­so said that its ex­pe­ri­ence “ex­em­pli­fies the un­pre­dictable na­ture of im­muno­genic re­ac­tions in re­sponse to in­sulin for­mu­la­tions. As such, we be­lieve cau­tion needs to be ap­plied re­gard­ing the broad as­sump­tion” in the draft guid­ance that says that “if a com­par­a­tive an­a­lyt­i­cal as­sess­ment based on state-of-the-art tech­nol­o­gy sup­ports a demon­stra­tion of ‘high­ly sim­i­lar’ for a pro­posed biosim­i­lar or in­ter­change­able in­sulin prod­uct, there would be lit­tle or no resid­ual un­cer­tain­ty re­gard­ing im­muno­genic­i­ty.”

Lil­ly, mean­while, said that FDA should re­vise the guid­ance to ex­plain which biosim­i­lar ap­pli­ca­tions this im­muno­genic­i­ty test­ing pol­i­cy ap­plies to.

“Should FDA in­tend to ap­ply the Draft Guid­ance to in­sulin prod­ucts which were not ap­proved un­der a sec­tion 505(b)(2) ap­pli­ca­tion, Lil­ly be­lieves that good sci­ence dic­tates some amount of clin­i­cal im­muno­genci­ty da­ta should be re­quired in or­der to un­der­stand the im­pact of po­ten­tial dif­fer­ences in im­muno­genic­i­ty pro­files on clin­i­cal out­comes,” Lil­ly said.

The com­pa­ny al­so wants FDA to re­vise the guid­ance to note that it does not ad­dress is­sues with re­spect to prod­uct biosim­i­lar­i­ty and in­ter­change­abil­i­ty of de­liv­ery de­vices and pre­sen­ta­tions, in­clud­ing con­nect­ed sys­tems.

And Lil­ly laid out its case for why in­sulin biosim­i­lars should not be ap­proved as in­ter­change­able prod­ucts.

“Al­though pre­sen­ta­tion con­sid­er­a­tions are im­por­tant for biosim­i­lar­i­ty as­sess­ments, FDA should pay par­tic­u­lar at­ten­tion to the in­sulin prod­ucts pre­sen­ta­tions in the in­ter­change­abil­i­ty con­text. There, by virtue of au­to­mat­ic sub­sti­tu­tion based on an in­ter­change­abil­i­ty des­ig­na­tion, a pa­tient could be con­front­ed with an un­fa­mil­iar pre­sen­ta­tion with­out the ben­e­fit of pre­scriber over­sight or ad­di­tion­al train­ing,” Lil­ly added.

The oth­er in­sulin man­u­fac­tur­er serv­ing the US, Sanofi, did not sub­mit a com­ment on the draft guid­ance, ac­cord­ing to the dock­et.

All three have raised their prices sig­nif­i­cant­ly over the past decade. For in­stance, in 2012, a vial of Lil­ly’s Hu­ma­log in­sulin was priced at $130, and by 2016, the same vial was priced at $255.

Both Lil­ly and No­vo have launched au­tho­rized gener­ics ver­sions of their in­sulin prod­ucts at re­duced prices in prepa­ra­tion for biosim­i­lar com­pe­ti­tion. But an in­ves­ti­ga­tion from Sens. Eliz­a­beth War­ren (D-MA) and Richard Blu­men­thal (D-CT) found that Lil­ly’s au­tho­rized gener­ic was wide­ly un­avail­able in phar­ma­cies.


RAPS: First pub­lished in Reg­u­la­to­ry Fo­cus™ by the Reg­u­la­to­ry Af­fairs Pro­fes­sion­als So­ci­ety, the largest glob­al or­ga­ni­za­tion of and for those in­volved with the reg­u­la­tion of health­care prod­ucts. Click here for more in­for­ma­tion.

Author

Zachary Brennan

managing editor, RAPS

Lessons for biotech and phar­ma from a doc­tor who chased his own cure

After being struck by a rare disease as a healthy third year medical student, David Fajgenbaum began an arduous journey chasing his own cure. Amidst the hustle of this year’s JP Morgan conference, the digital trials platform Medable partnered with Endpoints Studio to share Dr. Fajgenbaum’s story with the drug development industry.

What follows is an edited transcript of the conversation between Medable CEO Dr. Michelle Longmire and Dr. Fajgenbaum, and it is full of lessons for biotech executives charged with bringing the next generation of medicines to patients.

Kathy High (file photo)

Gene ther­a­py pi­o­neer Kathy High has left Spark af­ter com­plet­ing $4.3B union with Roche

Kathy High dedicated the past seven years of her life shepherding experimental gene therapies she’s developed at Children’s Hospital of Philadelphia toward the market as president and head of R&D at Spark Therapeutics. Now that the biotech startup is fully absorbed into Roche — with an FDA approval, a $4.3 billion buyout and a promising hemophilia program to boast — she’s ready to move on.

Roche confirmed her departure with Endpoints News and noted “she will take some well-deserved time off and then will begin a new chapter in a sabbatical at a university.”

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Deborah Dunsire

The fourth CGRP mi­graine drug is here. Time for Lund­beck to prove it's worth $2B

They may be late, but Lundbeck is now officially in the game for preventing migraine with CGRP drugs.

The FDA has OK’d eptinezumab, the prize in Lundbeck’s $2 billion acquisition of Alder. Like rival offerings from Amgen/Novartis, Eli Lilly and Teva, the antibody blocks the calcitonin gene-related peptide, which is believed to dilate blood vessels in the brain and cause pain.

It will now be sold as Vyepti. The company has yet to announce a price. Amgen and Novartis had set the wholesale acquisition cost of their pioneering Aimovig at $6,900 for a year’s supply before raising it slightly this year; Lilly and Teva had followed suit with Emgality and Ajovy.

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Tal Zaks (Moderna via YouTube)

For two decades, a new vac­cine tech­nol­o­gy has been slow­ly ap­proach­ing prime time. Now, can it stop a pan­dem­ic?

Two months before the outbreak, Moderna CMO Tal Zaks traveled from Cambridge, MA to Washington DC to meet with Anthony Fauci and the leaders of the National Institutes of Health.

For two years, Moderna had worked closely with NIH researchers to build a new kind of vaccine for MERS, one of the deadliest new viruses to emerge in the 21st century. The program was one test for a new technology designed to be faster, cheaper and more precise than the ways vaccines had been made for over a century. They had gathered evidence the technology could work in principle, and Fauci, the longtime head of the National Institute of Allergy and Infectious Diseases and a longtime advocate for better epidemic preparedness, wanted to see if it, along with a couple of other approaches, could work in a worst-case scenario: A pandemic.

“[We were] trying to find a test case for how to demonstrate if our technology could rapidly prepare,” Zaks told Endpoints News.

Zaks and Fauci, of course, wouldn’t have to wait to develop a new test. By year’s end, an outbreak in China would short circuit the need for one and throw them into 24/7 work on a real-world emergency. They also weren’t the only ones with new technology who saw a chance to help in a crisis.

An ocean away, Lidia Oostvogels was still on vacation and relaxing at her mother’s house in Belgium when her Facebook started changing. It was days after Christmas and on most people’s feeds, the news that China had reported a novel virus to the World Health Organization blurred into the stream of holiday sweaters and fir trees. But on Oostvogels’s feed, full of vaccine researchers and virus experts, speculation boiled: There was a virus in China, something contained to the country, but “exotic,” “weird,” and maybe having to do with animals. Maybe a coronavirus.

Lidia Oostvogels

“I was immediately thinking like, ‘Hey, this is something that if needed, we can play a role,'” Oostvogels told Endpoints.

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Tim Mayleben (file photo)

Es­pe­ri­on's goldilocks cho­les­terol fight­er wins FDA ap­proval — will its 'tra­di­tion­al' pric­ing ap­proach spur adop­tion?

It’s more effective than decades-old statins but not as good as the injectable PCSK9 — the goldilocks treatment for cholesterol-lowering, bempedoic acid, has secured FDA approval.

Its maker, Esperion Therapeutics, is betting that their pricing strategy — a planned list price of between $10 to $11 a day — will help it skirt the pushback the PCSK9 cholesterol fighters, Repatha and Praluent, got from payers for their high sticker prices.

The sky-high expectations for the pair of PCSK9 drugs that were first approved in 2015 quickly simmered — and despite a 60% price cut, coupled with data showing the therapies also significantly cut cardiovascular risk, sales have not really perked up.

Esperion is convinced that by virtue of being a cheaper oral therapy, bempedoic acid will hit that sweet spot in terms of adoption.

“We’re kind of like the old comfortable shoe,” Esperion’s chief commercial officer Mark Glickman remarked in an interview with Endpoints News ahead of the decision date. “It’s an oral product, once-daily and nontitratable — these are things that just resonate so true with patients and physicians and I think we’ve kind of forgotten about that.”

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James Collins, Broad Institute via Youtube

UP­DAT­ED: A space odyssey for new an­tibi­otics: MIT's ma­chine learn­ing ap­proach

Drug development is complex, expensive and comes with lousy odds of success — but in most cases, if you make it across the finish line brandishing a product with an edge (and play your cards right) it can be a lucrative endeavor.

As it stands, the antibiotic market is cursed — it harbors the stink of multiple bankruptcies, a dearth of innovation, and is consequently barely whetting the voracious appetites of big pharma or venture capitalists. Enter artificial intelligence — the biopharma industry’s cure-all for the pesky process of making a therapeutic, including data mining, drug discovery, optimal drug delivery, and addressable patient population.

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Gilead los­es two more patent chal­lenges on HIV pill, set­ting up court­room fight in Delaware

Gilead sustained two more losses in their efforts to rid themselves of an activist-backed patent lawsuit from the US government over a best-selling HIV pill.

Urged on by activists seeking to divert a portion of Gilead’s revenue to clinics and prevention programs, the Department of Health and Human Services made a claim to some of the patents for the best-selling HIV prevention drug, Truvada, also known as PrEP. Gilead responded by arguing in court that HHS’s patents were invalid.

Today, the US Patent and Trademark Office ruled that Gilead was likely to lose the last two of those challenges as well. The USPTO ruled against Gilead on the first two patents earlier this month.

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Christos Kyratsous (via LinkedIn)

He built a MERS treat­ment in 6 months and then the best Ebo­la drug. Now Chris­tos Kyrat­sous turns his sights on Covid-19

TARRYTOWN, NY — In 2015, as the Ebola epidemic raged through swaths of West Africa, Kristen Pascal’s roommates sat her down on their couch and staged an intervention.

“Are you sure this is what you want to be doing with your life?” she recalls them asking her.

Special report

Pascal, a research associate for Regeneron, had been coming home at 2 am and leaving at 6 am. At one point, she didn’t see her roommate for a week. For months, that was life in Christos Kyratsous’ lab as the pair led a company-wide race to develop the first drug that could effectively treat Ebola before the outbreak ended. For Pascal, that was worth it.

“I’m ok, I don’t have Ebola,” Pascal told them. “I see that death toll rising and I can’t not do something about it.”

Last August, Regeneron learned they had succeeded: In a large trial across West Africa, their drug, REGN-EB3, was vastly more effective than the standard treatments. It was surprise news for the company, coming just 10 months into a trial they thought would take several years and a major victory in the global fight against a deadly virus that killed over 2,000 in 2019 and can carry a mortality rate of up to 90%.

For Kyratsous and Pascal, though, it brought only fleeting reprieve. Just four months after the NIH informed them REGN-EB3 worked, Kyratsous was back in his office reading the New York Times for updates on a new outbreak on another continent, and wondering alongside Pascal and senior management whether it was time to pull the trigger again.

In late January, as the death toll swelled and the first confirmed cases outside China broke double digits, they made a decision. Soon they were back on the phone with the multiple government agencies and their coronavirus partners at the University of Maryland’s Level 3 bio lab. The question was simple: Can Kyratsous and his team use a process honed over two previous outbreaks, and create a treatment before the newest epidemic ends? Or worse, if, as world health experts fear, it doesn’t vanish but becomes a recurrent virus like the flu?

“Christos likes things immediately,” Matt Frieman, Regeneron’s coronavirus collaborator at the University of Maryland, told Endpoints. “That’s what makes us good collaborators: We push each other to develop things faster and faster.”

Kristen Pascal (Regeneron)

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The first time Regeneron tried to respond to a global outbreak, it was something of a systems test, Kyratsous explains from his office at Regeneron’s Tarrytown headquarters. Kyratsous, newly promoted, has crammed it with photos of his family, sketches of viral vectors and a shark he drew for his 3-year-old son. He speaks rapidly – an idiosyncrasy his press person says has only been aggravated this afternoon by the contents of his “Regeneron Infectious Diseases”-minted espresso glass – and he gesticulates with similar fluidity, tumbling through antibodies, MERS, the novel coronavirus, Ebola-infected monkeys.

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Bank­rupt an­tibi­otics mak­er Ar­a­digm turns to old part­ner/in­vestor for fi­nal $3M fire sale

Grifols once paid Aradigm $26 million for a stake in its inhaled antibiotics. But with Aradigm now in bankruptcy, the Spanish drugmaker is dishing out a final $3.2 million to buy it all.

The fire sale — which comes one year after Aradigm filed for Chapter 11 following a regulatory trifecta for disaster — will see Grifols obtain assets and IP to Apulmiq (formerly Pulmaquin and Linhaliq in Europe), Lipoquin and free ciprofloxacin. In addition to waiving its claims in the bankruptcy case, Grifols also agreed to milestone payments up to $3 million more upon any regulatory approvals.