Thursday, 29 November 2012

SPA Tracker Part 1

I have been spending some time researching companies who have a SPA agreement in place and am compiling a database which I plan to share on my blog.  So far I have about 70 companies with an agreement in place or an agreement pending FDA review.  Interestingly, I have found a significant number of companies either experience a significant delay between receiving the agreement and commencing the study, or cease operations before the the trial is ever started.  The database is a work in progress so I will be publishing it in parts alphabetically.  Here are entries from A-C:

TickerCompanyCompound IndicationSourceSPA AgreementNCT linkPrimary End Date
ASTMAastrom
ixmyelocel-T
End stage CLIhttp://investors.aastrom.com/releasedetail.cfm?ReleaseID=652908http://www.clinicaltrials.gov/ct2/show/NCT01483898?term=ixmyelocel-T&rank=1Mar-15
nilACT BiotechTelatonibGastric cahttp://www.actbiotech.com/FINALACTASCO2011PR2.pdfYesn/an/a
ACUSAcusphere
Imagify
Coronary Imaginghttp://www.acusphere.com/press_releases/ACUS_SPA_agreeement_FINAL.pdfYesn/an/a
ADLSAdvanced Life Sciences
Restanza
CABPCompany suspended operations in 5/2011Yesn/an/a
AEZSAeterna ZentarisAEZS-108Endometrial cahttp://www.aezsinc.com/en/page.php?p=60&q=543Pendingn/an/a
AGX:DE  OTN:GAGXFAgennixTalactoferrin alfa1L NSCLChttp://www.fiercebiotech.com/press-releases/agennix-receives-fast-track-designation-fda-talactoferrin-combination-sunitinib-ren-0Yeshttp://www.clinicaltrials.gov/ct2/show/NCT00706862?term=FORTIS-C&rank=1Jun-15
CMXICytomedix(Aldagen)ALD-301Critical limb ischemiahttp://www.intersouth.com/news/aldagen-reaches-agreement-with-fda-on-a-special-protocol-assessment-spa-for-phase-3-trial-of-ald-301-for-critical-limb-ischemiaYesn/an/a
NPCUFAllonDavunetideProgressive Supranuclear Palsyhttp://www.allontherapeutics.com/2012/11/patient-treatment-completed-in-pivotal-trial-evaluating-allons-davunetide/Yeshttp://www.clinicaltrials.gov/ct2/show/NCT01110720?term=Davunetide&rank=4&submit_fld_opt=Dec-12
ALSE/NAVBAlseres Pharma/NavideaAltropaneParkinson's disease imaginghttp://ir.alseres.com/releasedetail.cfm?ReleaseID=375770Yeshttp://www.clinicaltrials.gov/ct2/show/NCT00724906?term=Altropane&rank=2n/a
APRIApricus BioPrevOncoTHCChttp://www.apricusbio.com/press_02172011.htmlNever concluded n/an/a
ABIOARCA BiopharmaBucindololChronic heart failurehttp://www.businesswire.com/news/home/20100517005854/en/ARCA-Announces-Special-Protocol-Assessment-Agreement-FDAYesn/an/a
nilArgos TherapeuticsAGS-003mRCChttp://globenewswire.com/news-release/2012/07/02/272515/260946/en/Argos-Therapeutics-Receives-FDA-Approval-of-Special-Protocol-Assessment-for-AGS-003-Phase-3-Trial.htmlYeshttp://www.clinicaltrials.gov/ct2/show/NCT01582672?term=Argos+therapeutics&rank=8Jun-14
ARQLArquleTivantinibHCChttp://investors.arqule.com/common/mobile/iphone/releasedetail.cfm?ReleaseID=713700&CompanyID=ARQL&MobileID=#Yesn/an/a
OMX:BAVABavarian NordicProstvacmCRPChttp://www.bavarian-nordic.com/investor/announcements/2010-40.aspxYeshttp://www.clinicaltrials.gov/ct2/show/NCT01322490?term=Prostvac&rank=1Dec-14
BIIBBiogenPegylated interferonMShttp://www.biotechnologyevents.com/node/1720Yeshttp://www.clinicaltrials.gov/ct2/show/NCT00906399?term=Biogen+BIIB017&phase=2&rank=1Oct-12
BPAXBioSanteLibigelHSDDhttp://www.biosantepharma.com/News-Releases.php?ID=061112Pendingn/an/a
nilCell>Point
technetium-99m-EC-G
Lung cancer imaginghttp://cellpointweb.com/blog/cellpoint-announces-agreement-with-the-fda-on-a-special-protocol-assessment-for-the-phase-3-technetium-99m-ec-g-lung-cancer-imaging-trial/Yeshttp://www.clinicaltrials.gov/ct2/show/NCT01394679?term=technetium-99m&phase=2&fund=2&rank=9Jun-13
CLSNCelsionThermodoxHCChttp://www.prnewswire.com/news-releases/celsion-receives-fast-track-designation-for-thermodox-development-program-to-treat-primary-liver-cancer-101369159.htmlYeshttp://www.clinicaltrials.gov/ct2/show/NCT00617981?term=THERMODOX&rank=4Dec-12
nilCold GenesysCG0070Non muscle invasive bladder cancerhttp://www.businesswire.com/news/home/20120911005169/en/Cold-Genesys-Announces-Agreement-FDA-Special-ProtocolYeshttp://www.clinicaltrials.gov/ct2/show/NCT01438112?term=CG0070&rank=2Dec-16
CRMDCorMedixCRMD001Contrast-Induced Acute Kidney Injuryhttp://www.cormedix.com/pipeline_CRMD001.phpYeshttp://www.clinicaltrials.gov/ct2/show/NCT01391520?term=CRMD001&rank=2n/a
CYCC/PCyclacelSapacitabineAMLhttp://investor.cyclacel.com/releasedetail.cfm?ReleaseID=614179Yeshttp://www.clinicaltrials.gov/ct2/show/NCT01303796?term=SEAMLESS+cyclacel&rank=1Oct-14
CYTRCytRx
Tamibarotene
Acute Promyelocytic Leukemiahttp://www.cytrx.com/aboutYeshttp://www.clinicaltrials.gov/ct2/show/NCT00520208?term=STAR-1&rank=1Dec-12

I'll be adding to the list periodically and updating so please feel free to comment if there are any companies beginging with A-C that I may have missed.  I would welcome input into expected dates for completion where I have blanks.  I will be compiling a summary review once the whole list is published and welcome your comments.

Monday, 8 October 2012

Next item in the SPA basket: Orexigen

One of my long term SPA positions is Orexigen (OREX), whose lead candidate Contrave (Naltrexone 4mg, 8mg/Bupropion HCL 90mg extended release tablet, referred to as NB in the excerpts from FDA materials below) is in development for the treatment of obesity and weight management, including weight loss and maintenance of weight loss, in patients with an initial body mass index ≥30 kg/m2 or ≥27 kg/m2 with one or more risk factors (e.g. diabetes, dyslipidemia, or hypertension).
I am not going to review the entire clinical development history here, but instead will focus on safety and the LIGHT Study, and my thoughts on likelihood for approval long-term.  
In terms of efficacy in achieving weight loss, my personal assessment is that the categorical weight loss achieved with Contrave is slightly better overall than Arena’s Belviq, and slightly inferior overall compared with Vivus’ Qsymia.
The company has been asked to perform a cardiovascular outcomes study to better characterize CV risk prior to approval of this product.  This was requested because of a signal detected in review of the original NDA safety database.  Readers should refer to the FDA briefing document from the first Advisory Committee meeting for full information.
“Bupropion, as an inhibitor of neuronal reuptake of norepinephrine, has the capacity to increase blood pressure and pulse. In the NB phase 3 clinical trials, subjects treated with NB32 had small but statistically significant mean increases in systolic and diastolic blood pressure and pulse rate relative to placebo. The treatment effect was most pronounced during the first eight weeks of treatment. NB32-treated subjects who lost at least 5% of baseline body weight (i.e., responders) had more favorable changes in blood pressure and pulse than NB32 nonresponders, but placebo responders had the most favorable changes overall in blood pressure and pulse. The frequency of hypertension-related adverse events was significantly higher in NB32 compared with placebo subjects.
Given the study subject demographics, and the size and duration of the phase 3 studies, the number of major adverse cardiac events (MACE) was too small to make reliable inferences about NB’s effect on cardiovascular risk. A rigorous assessment of NB’s cardiovascular risk profile would require a dedicated study in an appropriate population of overweight and/or obese individuals. The Division and Orexigen are in the early stages of discussing the design elements of such a study”.
What did the original reviewer find in terms of CV safety?
Here is a recap of the relevant CV findings:
                    A greater percentage of subjects experienced blood pressure and pulse TEAEs in the Total NB group compared with the placebo group (5.9% and 4.2%, respectively). This was primarily attributable to the Hypertension (5.3% Total NB and 4.0% placebo). No serious blood pressure and pulse events were reported.
                    Blood pressure-related TEAEs (including hypertension and increased blood pressure terms) in both the NB32 and placebo groups were reported mostly by subjects with a history of hypertension or antihypertensive medication use at baseline, occasionally led to treatment discontinuation, and required medication in approximately two-thirds of subjects.
                    In Trial NB-304 (individuals with diabetes), 40 (12.0%) subjects in the NB32 group and 11 (6.5%) in the placebo group had a blood pressure-related TEAE during double-blind treatment. Ten percent (4/40) in the NB32 group were severe compared to none (0/11) in the placebo group.
Pulse:
                    At both Weeks 4 and 8, the Total NB group had a statistically significant difference from placebo of +2.1 bpm.
                    By Week 56, the statistically significant difference from placebo was +1.4 bpm.
                    Increases in pulse from baseline (≥5, ≥10, and ≥20 bpm) and pulse increases ≥90 bpm at two consecutive or the final visit were observed at higher incidences in NB-treated subjects.
Systolic Blood Pressure:
                    At Week 4 and at Week 8, the Total NB group had a statistically significant difference from placebo of +2.4 mm Hg.
                    By Week 56, the statistically significant difference from placebo was +1.5 mm Hg.
                    Subjects in the Total NB group were 2.5 x as likely to experience 2 or more SBP readings ≥150 mm Hg and were 2x as likely to experience 2 or more SBP readings ≥160 mm Hg.
Diastolic Blood Pressure:
                    At Weeks 4 and 8, the Total NB group had a statistically significant difference from placebo of +1.9 and +2.1 mm Hg, respectively.
                    By Week 56, the statistically significant difference from placebo was +1.2 mm Hg.
                    Shifts to high potentially clinically significant (PCS) DBP values were 3 to 4 times more frequent in the Total NB group as compared to Placebo in the first 12 weeks. The incidence remained higher in the Total NB group until Week 28 where the incidence of shifts to high PCS between groups was generally similar between placebo and Total NB until trial end.
Cardiovascular Events
                    MACE events (CV death, MI, CVA) occurred in 3 NB patients vs 1 Pbo patient.
                    Overall Cardiovascular AEs—including atherosclerotic disease, arrhythmias, and congestive heart failure-- were similar between the Total NB and placebo groups.
                    Ischemic CV events were too few in number to adequately assess CV risk in this patient population.
It is important to note that CV events were not centrally adjudicated and were very small in number for the total database; N=4
Key Points:
Table 34 in the briefing document is very helpful.  It shows that at baseline, the average systolic BP is 119 mmHg in the Contrave group, this increases to 120.5 mmHg by week 56 for patients on therapy.  In my opinion a systolic BP of 121 mm Hg would most likely be considered normal and not associated with any increased CV risk.   Similarly Table 37 looks at changes in diastolic blood pressure.  The diastolic BP was 77 mm Hg at baseline and was reduced to 76 mm Hg by week 56 (+0.51 mm Hg placebo adjusted change).  Again, to me the absolute magnitude of this change does not suggest any increased risk of CV events.
Table 40 looks at absolute changes in pulse rate, another concern flagged by the reviewer. At baseline, the mean bpm was 72, at week 56 it was 72.3. Again, this to me is not really a red flag in terms of incremental CV risk.
Ultimately the company reached agreement with FDA to conduct a cardiovascular outcomes study prior to approval for which the protocol received a SPA. The details are here:
This trial is set to recruit N=9880 obese patients at high risk for CV events (assuming a background event rate of ~1.5%). An important factor is that patients not achieving pre-defined weight loss goals at 16 weeks of therapy must discontinue treatment, thus reducing the risk of unnecessary drug exposure (something that did not happen in the SCOUT trial for Meridia). Contrave CV risk will be deemed acceptable if OREX can exclude a doubling of CV risk (i.e., the upper bound of 95% CI not crossing 2.0) in the interim analysis, or if it can exclude 1.4 x risk in the final analysis. The interim analysis can be conducted after 87 events (expected to occur in 2013). OREX believes that if 50 or less of the 87 CV events occur in the Contrave arm, it will be able to reach approvable safety in the interim analysis.  The important point here is that if the interim safety analysis fails to exclude a doubling of risk, it does not mean the trial has failed overall, but will continue with further safety analyses prior to study end.
What has impressed me most about this trial has been the rapidity with which enrollment has occurred. The trial opened on 6/6/2012 and was ~50% enrolled by 8/31/2012. Enrolling nearly 5,000 patients in 3 months is pretty impressive in my opinion.  The company expects to close enrollment by the end of Q4 12 and to have accrued sufficient CV events for the interim analysis sometime in 2013. 
What are my concerns with the trial?
This trial is enriched with obese patients at higher risk for CV disease than the patients who were enrolled in the original phase 3 studies.  The inclusion criteria for greater CV risk are below:
  1. At increased risk of adverse cardiovascular outcomes:
·         Cardiovascular disease (confirmed diagnosis or at high likelihood of cardiovascular disease) with at least one of the following:
·         History of documented myocardial infarction >3 months prior to screening
·         History of coronary revascularization
·         History of carotid or peripheral revascularization
·         Angina with ischemic changes (resting ECG), ECG changes on a graded exercise test (GXT), or positive cardiac imaging study
·         Ankle brachial index <0.9 (by simple palpation) within prior 2 years
·         ≥50% stenosis of a coronary, carotid, or lower extremity artery within prior 2 years
AND/OR
·         Type 2 diabetes mellitus with at least 2 of the following:
·         Hypertension (controlled with or without pharmacotherapy at <145/95 mm Hg)
·         Dyslipidemia requiring pharmacotherapy
·         Documented low HDL cholesterol (<50 mg/dL in women or <40 mg/dL in men) within prior 12 months
·         Current tobacco smoker

There is a chance that Contrave and exacerbate risk and lead to significantly worse outcomes in this group. Per the review of the original NDA, blood pressure related adverse events occurred more often in patients with pre-existing hypertension, in some cases leading to patients coming off the study. However, a couple of factors are reassuring; Firstly, patients who are non-responders will discontinue therapy mitigating long term inappropriate drug exposure risk.  Secondly, from the FDA’s responder analysis (see figures 7, 9 & 11) for individual CV parameters, you can see that Contrave non-responders experienced increases in blood pressure and heart rate, whereas Contrave responders experienced reductions in the same parameters.  By eliminating the non-responders from the trial, we should in theory mitigate any potential risk posed by the small observed increases in blood pressure and heart rate.
The other concern is around costs of the study and the company’s state of funding.  While the cost of the trial is estimated to be ~$100MM, Orexigen does not have sufficient funds today to finance through approval.  In a best case scenario, if sufficient events accrue for a positive interim analysis by Q4 13, one would anticipate a filing of a response to the CRL by mid-2014, and approval late 2014.  The study still needs to run to completion until 2017. The company's guidance is that current cash, cash equivalents and marketable securities will last through the anticipated timing of the resubmission of the Contrave NDA alone, so they will definitely have to raise cash at some point, I would guess before the interim safety analysis.  I will be watching to add more to my position at that point.
Overall, I think the pro’s outweigh the cons for holding this position long term, especially given the significant potential near term catalysts.
This article is not meant as trading advice.  Please conduct your own due diligence and trade securities at your own risk.

Thursday, 4 October 2012

My thoughts on Sarepta

Although I do not have any positions in Sarepta Therapeutics (SRPT), yesterday I was consistently berated by the entire Twitterverse for suggesting that their phase 2 for Eteplirsen in Duchenne Muscular Dystrophy (DMD) study would not in fact be sufficient to pass the FDA’s sniff test for accelerated approval.  Here I will spell out why:
1.       Regulatory Precedent
The FDA has laid out guidance for any sponsor developing a therapy for rare diseases which is nicely summarized here  The presentation includes a nice description of the size of NDA submission programs for recently approved orphan therapies.
The good news is that orphan products are eligible for Fast-Track, Accelerated approval paths and Priority reviews, however, the same regulatory standards that apply to regular drugs still have to be met:
Regulatory Approval Standard
                        Orphan drugs are held to the same statutory requirements for demonstrating effectiveness and safety
                        Orphan drugs must: Demonstrate substantial evidence of effectiveness/clinical benefit (21CFR 314.50)
                        Substantial evidence of benefit requires: Adequate and well-controlled clinical study(ies) (§314.126)
 “Study has been designed well enough so as to be able “to distinguish the effect of a drug from other influences, such as spontaneous change…, placebo effect, or biased observation” (§314.126)”
So, does the P2 study in question have “Substantial Evidence of Effectiveness”, is it “adequate and well-controlled”?
There is absolutely no rational argument that n=4 patients receiving therapy is adequate to establish conclusive efficacy.  I have yet to see any baseline demographics on these study participants so who knows if it was well controlled between the two study arms, not to mention the selection bias for who was entered into this study to begin with.  Only the initial 24 weeks were blinded to treatment so the risk of observer bias cannot be excluded for the 48 week data presented yesterday; the investigators knew all study participants were on treatment at that data point.  Single center studies also introduce an element of bias which must be taken into consideration when reviewing these results.  Bias aside, all participants had to be on steroids to be enrolled in the study.  Steroids can effect ambulation performance; can anyone tell me what dosage of steroid these participants had throughout the course of the study and if there were any differences between the two groups?
According to the FDA Guidance:
What constitutes substantial evidence of effectiveness?
-Typically two adequate and well-controlled studies
Independent substantiation of experimental results – single clinical experiment not usually considered adequate scientific support for conclusion of effectiveness
Let’s just assume for one wildly optimistic second that that FDA was to consider Accelerated approval with a single study, what would be the regulatory requirements?
                        Accelerated Approval  is based on surrogate endpoint  where  the surrogate is reasonably likely to predict clinical benefit
                        and usually requires post-marketing studies to verify and describe clinical benefit
OK, that doesn’t sound too bad. Afterall we have the muscle biopsy data.  But wait a second, let’s take a closer look at that.  According to the company data which can be found here:
Treatment Arm

Mean Change from Baseline in % Dystrophin-Positive Fibers

p-value
Eterplirsen (both doses): 48 wks of Tx (n=8)

47.0

≤0.001

Eteplirsen 50 mg/kg (n=4)

41.7

≤0.008

Eteplirsen 30 mg/kg (n=4)

52.1

≤0.001
Placebo/Delayed Tx: 24 wks of Tx (n=4)

38.3

≤0.009

Placebo/50 mg/kg Delayed-Tx (n=2)

42.9

ns

Placebo/30 mg/kg Delayed-Tx (n=2)

34.2

ns

                         
The patients in the 30mg/kg arm actually generate more dystrophin positive fibers than the higher dose group, yet, this did not translate into a significant improvement on the 6-minute walking test.
Treatment Arm

Mean Change from Baseline in 6MWT (meters)

Estimated Treatment Effect (Eteplirsen minus Placebo/Delayed-Tx)

p-value
Placebo/Delayed-Tx (n=4)

-60.3




Eteplirsen 50 mg/kg (n=4)

+27.1

87.4 m

≤0.001
Eteplirsen Both Doses (n=6)

+7.3

67.3 m

≤0.001
Eteplirsen 30 mg/kg (n=2)

-31.5

28.8 m

ns


In other words, taken as is, this surrogate does not predict clinical benefit (as defined by distance on the 6MWT) at all.  Can anyone explain this?  I doubt it, I am certainly not convinced this is an accurate biomarker, nor is it particularly pleasant to be subjecting these participants to multiple muscle biopsies.  (For the sake of brevity, I’m going to skip what I have learned about DMD trial end points and biomarkers from a brief review of the literature).  Surely a blood based biomarker would be more practical?  It seems that is what the company had in mind.  According to the original study protocol here they were prospectively testing this as a secondary outcome.
Secondary Outcome Measures:
·         Secondary efficacy endpoints will be the change from baseline in: CD3, CD4, and CD8 lymphocyte counts in muscle biopsy tissue

The presence of these lymphocytes is correlated with muscle damage in DMD, so you would hope treatment would show a depletion in counts with treatment. So what happened to these data, did they mysteriously disappear?  I have feeling they were negative and the company just decided not to disclose them.
2.       The regulatory bar set for other companies developing DMD therapies
Obviously Sarepta is not the only company in the race to develop a therapy for DMD.  A quick search on clinicaltrials.gov reveals numerous open, industry-supported, phase 3 clinical programs in this condition -in other words, phase 3 programs are required despite the unmet medical need.
The most similar agent to Eteplirsen in development is GSK2402968. Of note, they have N=54 patients in their phase 2 study
and over N=180 in their phase 3 programs.
If you examine the P2 GSK protocol, you can see that they actually reduced variability in the results of their study by having subjects complete 2 separate 6MWT at baseline as part of the inclusion criteria. 
“Able to complete 6 Minute Walk Distance (6MWD) test with minimal distance of at least 75 meters, with reproducible results (within 20% of each other) at Screening Visit 1, Screening Visit 2 and at the baseline visit prior to randomization”.  This reduces the risk that any differences at important study visits were due to normal variability.
They also had tighter controls around changes to steroid doses that were allowed during the study. 

Sarepta did not assess the reproducibility of their results at baseline at all.

What I find particularly interesting is the statistical powering of the GSK phase 3 program:

Primary Outcome Measure: To assess the efficacy of subcutaneous 6 mg/kg GSK2402968 versus placebo; specifically to have 90% power to detect a difference in 6MWD between GSK2402968 and placebo of 30 meters, assuming a common standard deviation of 55meters.    In other words, 6MWT is so variable that a 55 meter difference between 2 individuals would not even be considered significant.

Clearly the clinical development folks at GSK have put a lot thought into their study protocol and have looked at baseline individual variability a bit harder than Sarepta.  What would the Sarepta data look like if they were adjusted for such a measure of standard deviation? 

To reiterate, I have no financial position in Sarepta.  I advise everyone to take a closer look at the data and consider the prospect that this drug may not be all it has been hyped up to be.  Based on these facts, the suggestion that it will be approved via an accelerated approval pathway based on the existing data is frankly ridiculous.
This article is not intended as trading advice.  Conduct your own due dilligence prior to buying or selling securities.