1 unchanged sentence
We are a biopharmaceutical company focused on the formulation, development and commercialization of innovative therapies for diseases and conditions of the eye using our proprietary, bioresorbable hydrogel platform technology.
−Removed: We use this technology to tailor duration and amount of delivery of a range of therapeutic agents of varying duration in our product candidates.
−Removed: We are pursuing three overall strategic goals:
−Removed: To make prescription eye drops obsolete;
−Removed: To make immediate release, back-of-the-eye injections obsolete;
−Removed: To extend our hydrogel platform technology for use beyond the eye to other areas of the body.
+Added: We use this technology to tailor duration and amount of delivery of a range of therapeutic agents in our product candidates.
We currently incorporate therapeutic agents that have previously received regulatory approval from the U.S.
Food and Drug Administration, or FDA, including small molecules and proteins, into our hydrogel technology with the goal of providing local programmed-release of drug to the eye.
−Removed: We believe that our local programmed-release drug delivery technology has the potential to treat conditions and diseases of both the front and the back of the eye and can be administered through a range of different modalities including intracanalicular inserts, intracameral implants and intravitreal implants.
−Removed: We have products and product candidates in early commercial, clinical and preclinical development applying this technology to treat post-surgical ocular inflammation and pain, ocular itching associated with allergic conjunctivitis, dry eye disease, glaucoma and ocular hypertension, and wet age-related macular degeneration, or wet AMD, among other conditions.
−Removed: In November 2018, the FDA approved our new drug application, or NDA, for DEXTENZA ®
−Removed: (dexamethasone ophthalmic insert) 0.4mg for intracanalicular use for the treatment of ocular pain following ophthalmic surgery.
−Removed: In June 2019, the FDA approved our supplemental new drug application, or sNDA, for DEXTENZA to treat post-surgical ocular inflammation.
−Removed: On July 1, 2019, we commercially launched DEXTENZA in the United States for the treatment of post-surgical ocular inflammation and pain.
−Removed: DEXTENZA is the first FDA-approved intracanalicular insert delivering dexamethasone to treat post-surgical ocular inflammation and pain for up to 30 days with a single administration.
−Removed: We have enrolled 96 patients in a pivotal Phase 3 clinical trial evaluating DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: In May 2019, we announced the results of the Phase 3 clinical trial of our product candidate OTX-TP (intracanalicular travoprost insert) for the reduction of intraocular pressure, or IOP, in patients with glaucoma and ocular hypertension.
−Removed: Both DEXTENZA and OTX-TP are local programmed-release, drug-eluting, preservative-free intracanalicular inserts that are placed into the canaliculus through a natural opening called the punctum located in the portion of the lower eyelid near the nose.
−Removed: In October 2019, we announced that we had met with the FDA who determined that the results did not achieve clinical meaningfulness for OTX-TP.
−Removed: As a result, we informed the market that we did not intend to advance OTX-TP without a partner.
−Removed: Our earlier stage assets include two development programs that have initiated clinical trials:
−Removed: OTX-TIC, an intracameral travoprost implant for the reduction of IOP in patients with glaucoma and ocular hypertension when greater IOP reduction is needed, and OTX-TKI, an intravitreal injection by fine gauge needle of a hydrogel, anti-angiogenic formulation of a tyrosine kinase inhibitor, or TKI, for the treatment of wet AMD.
−Removed: We also have a collaboration with Regeneron Pharmaceuticals, Inc., or Regeneron, for the development and potential commercialization of products containing our local programmed-release hydrogel in combination with Regeneron’s VEGF inhibitor, aflibercept, currently marketed under the brand name Eylea.
−Removed: We delivered an initial formulation to Regeneron in December 2017 that was subsequently determined to not achieve the goals of the program.
−Removed: We are currently negotiating an amendment to the initial collaboration to deliver additional formulations going forward.
−Removed: In addition to our ongoing drug product development, we currently market ReSure ®
−Removed: Sealant, a hydrogel ophthalmic wound sealant approved by the FDA to seal corneal incisions following cataract surgery.
−Removed: ReSure Sealant is the first and only surgical sealant to be approved by the FDA for ophthalmic use.
−Removed: We are also assessing the potential use of our hydrogel platform technology in other areas of the body.
−Removed: Front-of-the-Eye Programs:
−Removed: Intracanalicular Inserts
−Removed: Poor patient compliance with eye drop regimens and the need for frequent administration of eye drops at high drug concentrations due to rapid washout by the tears can create challenges in the successful management of ocular diseases and conditions.
−Removed: For example, poor patient compliance can lead to diminished efficacy and disease progression and high drug concentrations can create side effects.
−Removed: We are developing therapies to replace standard of care eye drop regimens with our innovative local programmed-release, drug-eluting intracanalicular inserts.
−Removed: The goal for our intracanalicular insert product candidates is to replace the management of many front-of-the-eye diseases and conditions using frequent, pulsed eye drop therapy, characterized by significant variations in drug concentration over time, with longer term, local programmed-release hydrogel-based therapeutic agents to improve patient outcomes.
−Removed: DEXTENZA ®
−Removed: (dexamethasone ophthalmic insert)
−Removed: DEXTENZA incorporates the FDA-approved corticosteroid dexamethasone as an active pharmaceutical ingredient into a hydrogel, drug-eluting intracanalicular insert.
−Removed: In November 2018, the FDA approved our NDA for DEXTENZA for the treatment of post-surgical ocular pain.
−Removed: In June 2019, the FDA approved our sNDA, for DEXTENZA to treat post-surgical ocular inflammation.
−Removed: In connection with our July 1, 2019 commercial launch of DEXTENZA for post-surgical ocular inflammation and pain, we have built our own highly targeted, key account manager, or KAM, sales force that focuses on the ambulatory surgical centers, or ASCs, responsible for the largest volumes of cataract surgery.
−Removed: Since the commercial launch of DEXTENZA, we have expanded our field sales team to a total of 30 KAMs.
−Removed: DEXTENZA is now available through a network of distributors.
−Removed: Our initial commercial efforts are focused on the two million cataract procedures performed annually under Medicare Part B.
−Removed: Following our receipt of FDA approval on November 30, 2018, we submitted an application for a C-code for transitional pass-through payment status.
−Removed: On May 29, 2019, we received formal notification from the Centers for Medicare and Medicaid Services, or CMS, that it had approved transitional pass-through payment status and established a new reimbursement code for DEXTENZA.
−Removed: The code, C9048, became effective on July 1, 2019.
−Removed: On December 28, 2018, we submitted an application for a J-Code for permanent payment status.
−Removed: In July 2019, we subsequently received a specific and permanent J-Code, J1096, that became effective October 1, 2019.
−Removed: A J-Code is a permanent code used to report drugs that ordinarily cannot be self-administered.
−Removed: With the effectiveness of our permanent J-Code as of October 1, 2019, our C-code is no longer in effect.
−Removed: We have completed three Phase 3 clinical trials of DEXTENZA for the treatment of post-surgical ocular inflammation and pain.
−Removed: The data from two of these three completed Phase 3 clinical trials and a prior Phase 2 clinical trial were used to support our NDA for post-surgical ocular pain;
−Removed: data from a subsequent Phase 3 clinical trial was used to support our subsequent sNDA for post-surgical ocular inflammation.
−Removed: We have completed two Phase 3 clinical trials of DEXTENZA for the treatment of allergic conjunctivitis and are currently conducting a third Phase 3 clinical trial.
−Removed: In October 2015, we announced topline results of our first Phase 3 clinical trial for the treatment of ocular itching and conjunctival redness associated with allergic conjunctivitis.
−Removed: In June 2016 we announced topline results of our second Phase 3 clinical trial for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: In the first Phase 3 clinical trial, DEXTENZA achieved the co-primary endpoint of improvement in ocular itching compared with placebo but failed to achieve on the co-primary endpoint of improvement in conjunctival redness compared with placebo, in each case, at certain prespecified timepoints.
−Removed: For the second Phase 3 trial, DEXTENZA failed to achieve the primary endpoint of improvement in ocular itching compared with placebo, at certain prespecified timepoints.
−Removed: In the third quarter of 2019, we began dosing patients in pivotal Phase 3 clinical trial evaluating DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: A total of 96 patients were enrolled in this Phase 3 clinical trial, which is a U.S.-based, multi-center, 1:1 randomized, double-masked, placebo-controlled trial testing the safety and efficacy of DEXTENZA (dexamethasone ophthalmic insert) 0.4 mg versus a placebo vehicle punctum plug using the Ophthalmic Research Associates’
−Removed: modified Conjunctival Allergen Challenge (Ora-Cac®) Model for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: The trial is designed to assess the effect of DEXTENZA compared with a placebo on allergic reactions using a series of successive allergen challenges over a 30-day period.
−Removed: The primary efficacy endpoint being evaluated in the study is ocular itching one week following the insertion of DEXTENZA.
−Removed: DEXTENZA is administered by a physician as a bioresorbable intracanalicular
−Removed: insert and designed for drug release to the ocular surface for up to 30 days.
−Removed: If this trial is successful, we plan to submit a supplemental NDA to the FDA for the indication of ocular itching associated with allergic conjunctivitis.
−Removed: We recently completed enrollment and topline results from this trial are anticipated to be reported in the second quarter of 2020.
−Removed: We are also planning to evaluate DEXTENZA in pediatric subjects that are 0 to 3 years of age undergoing cataract surgery beginning in the fourth quarter of 2020.
−Removed: The planned pediatric trial is a post-approval commitment to the FDA.
−Removed: Additionally, we have initiated several investigator-initiated trials evaluating DEXTENZA in different clinical situations.
−Removed: We have also completed a small proof-of-concept Phase 2 clinical trial of DEXTENZA for the treatment of episodic dry eye disease which suggests that DEXTENZA may have benefit in treating ocular surface disease.
−Removed: OTX-TP (intracanalicular travoprost insert)
−Removed: Our product candidate OTX-TP is an intracanalicular insert that delivers a preservative-free formulation of the drug travoprost, an FDA approved prostaglandin analog, for the reduction of intraocular pressure, or IOP, in patients with primary open-angle glaucoma or ocular hypertension.
−Removed: OTX-TP is designed to lower IOP for up to 90 days and to address the poor adherence associated with chronic, daily eye drop regimens, the current standard of care.
−Removed: On May 20, 2019, we reported topline results of a Phase 3 randomized, double blind, placebo-controlled clinical trial that was conducted across more than 50 sites and enrolled 554 subjects with open-angle glaucoma or ocular hypertension in the full analysis set, or FAS, population.
−Removed: The trial’s primary efficacy endpoint was an assessment of mean IOP at nine different time points, three diurnal time points (8:00 a.m., 10:00 a.m., and 4:00 p.m.) at each of 2, 6, and 12 weeks following insertion.
−Removed: The secondary endpoints included an evaluation of whether OTX-TP demonstrated a statistically superior mean reduction of IOP from baseline for OTX-TP treated subjects compared with placebo insert treated subjects (Table 1) compared with placebo insert treated subjects at the same nine time points.
−Removed: Topline results show that the trial did not achieve its endpoint of statistically significant superiority in mean reduction of IOP compared with placebo at all nine time points.
−Removed: OTX-TP was generally well tolerated and no ocular serious adverse events were observed.
−Removed: The most common ocular adverse events seen in the study eye were dacryocanaliculitis (approximately 7.0% in OTX-TP vs.
−Removed: 3.0% in placebo) and lacrimal structure disorder (approximately 6.0% in OTX-TP vs.
−Removed: 4.0% in placebo).
−Removed: We have met with the FDA to discuss data we reported in May 2019 from our completed Phase 3 trial.
−Removed: Our conversation with the FDA was productive and involved a discussion around the importance of compliance and how a product like OTX-TP could address the issue of non-compliance by delivering a prostaglandin analog formulated with our local programmed-release hydrogel to lower intraocular pressure for up to 12 weeks with a single insert.
−Removed: While the FDA did not feel that the data from this clinical trial met the standard of clinical meaningfulness in the population studied, there were constructive discussions about potential pathways forward in specific patient populations for whom drops are problematic.
−Removed: Based on the feedback following these discussions with the FDA, we do not intend to initiate a second Phase 3 clinical trial at this time without the assistance of a collaborative partner.
−Removed: We believe that if we were to find a partner for our OTX-TP program, we or such partner could decide to conduct additional Phase 2 clinical trials to address feedback from the FDA prior to another Phase 3 clinical trial.
−Removed: Given the potential use of OTX-TP as a chronic therapy, however, we have decided to continue an ongoing open-label, one-year safety extension study , generating six-month and one-year safety data for a limited number of subjects to support a potential future product registration.
−Removed: We anticipate data from this safety study including pharmacokinetic data later this year.
−Removed: Front-of-the-Eye Programs:
−Removed: Implants for Intracameral Injection
−Removed: OTX-TIC (travoprost implant for intracameral injection)
−Removed: OTX-TIC is our product candidate for glaucoma patients in need of a more significant reduction in IOP.
−Removed: OTX-TIC is a bioresorbable hydrogel implant incorporating travoprost that is designed to be administered by a physician as an intracameral injection with an initial target duration of drug release of four to six months.
−Removed: Preclinical studies to date have demonstrated reduction of IOP and pharmacokinetics in the aqueous humor that suggest a pharmacodynamic response of IOP reduction in humans.
−Removed: Our investigational new drug application, or IND, for our U.S.
−Removed: trial became effective in the first quarter of 2018, and we dosed the first patient in May 2018.
−Removed: This clinical trial is a multi-center, open-label, dose-
−Removed: escalation, proof-of-concept study designed to evaluate the safety, biological activity, durability, and tolerability of OTX-TIC in patients with primary open-angle glaucoma or ocular hypertension.
−Removed: We presented initial results from the first cohort, comprised of five patients, in this clinical trial at the Association of Research and Vision of Ophthalmology (ARVO) meeting in April 2019 and the American Society of Cataract and Refractive Surgery annual meeting in May 2019.
−Removed: We subsequently presented results from the second cohort, comprised of four patients, at the Glaucoma 360 conference in February 2020.
−Removed: These data demonstrated that, with a single implant, subjects were able to achieve IOP lowering from baseline for up to eighteen months.
−Removed: In addition, the hydrogel carrier, as designed, biodegraded in approximately five to seven months.
−Removed: There were no clinically meaningful changes in corneal health as measured by endothelial cell evaluation and corneal pachymetry.
−Removed: Several subjects reported low grade inflammation and peripheral anterior synechiae that we believe may be addressable with modifications to the implants.
−Removed: We are currently collecting additional data from the first two cohorts and have begun enrolling a third and fourth cohort to assess the impact of a faster degrading implant with the same therapeutic dose as administered in cohort one and a fourth cohort to assess an additional formulation with a smaller implant of OTX-TIC.
−Removed: We expect to provide topline data for the third and fourth cohorts in the second half of 2020.
−Removed: Back-of-the-Eye Programs
−Removed: We are engaged in the development of formulations of our hydrogel administered via intravitreal injection to address the large and growing markets for diseases and conditions of the back of the eye.
−Removed: Our initial development efforts are focused on the use of our extended-delivery hydrogel in combination with anti-angiogenic drugs, such as protein-based anti-VEGF drugs, or small molecule drugs, such as TKIs, for the treatment of retinal diseases such as wet AMD, retinal vein occlusion and diabetic macular edema.
−Removed: Our initial goal for these programs is to provide extended delivery over a four to nine-month period thereby reducing the frequency of the current monthly or bi-monthly immediate release intravitreal injection regimen for wet AMD and other retinal diseases.
−Removed: OTX-TKI (tyrosine kinase inhibitor intravitreal implant containing axitinib)
−Removed: OTX-TKI is a preformed, bioresorbable hydrogel fiber incorporating axitinib, a small molecule TKI with anti-angiogenic properties delivered by intravitreal injection.
+Added: We believe that our local programmed-release drug delivery technology has the potential to treat conditions and diseases of both the front and the back of the eye and can be administered through a range of different modalities including intravitreal implants, suprachoroidal implants, intracameral implants and intracanalicular inserts.
+Added: We have product candidates in preclinical and clinical development designed to utilize this technology to treat retinal diseases including wet age-related macular degeneration, or wet AMD;
+Added: glaucoma and ocular hypertension;
+Added: and ocular surface diseases and conditions including dry eye disease and ocular itching associated with allergic conjunctivitis.
+Added: We also have two FDA-approved products in commercialization in the United States:
+Added: DEXTENZA ® , an intracanalicular insert for the treatment of post-surgical ocular inflammation and pain, and ReSure ® Sealant, an ophthalmic device designed to prevent wound leaks in corneal incisions following cataract surgery.
+Added: Our earlier-stage assets include four programs in clinical development:
+Added: ● OTX-TKI, an axitinib intravitreal implant administered by fine-gauge needle for the treatment of wet AMD;
+Added: ● OTX-TIC, a travoprost intracameral implant for the reduction of intraocular pressure, or IOP, in patients with glaucoma or ocular hypertension;
+Added: ● OTX-CSI, a cyclosporine intracanalicular insert for the chronic treatment of dry eye disease;
+Added: ● OTX-DED, a dexamethasone intracanalicular insert for the short-term treatment of the signs and symptoms of dry eye disease.
+Added: We have a collaboration with Regeneron Pharmaceuticals, Inc., or Regeneron, for the development and potential commercialization of products containing our local programmed-release hydrogel in combination with Regeneron’s vascular endothelial growth factor, or VEGF inhibitor, aflibercept, currently marketed under the brand name Eylea.
+Added: We also continue to assess the potential use of our hydrogel platform technology in other areas of the body.
+Added: Retinal Disease Programs
+Added: We are engaged in the development of formulations of our hydrogel administered via intravitreal injection to address large markets for diseases and conditions of the back of the eye which we believe have significant growth potential.
+Added: Our initial development efforts for our retinal disease programs have focused on the use of our extended-delivery hydrogel in combination with anti-angiogenic drugs, such as TKIs or protein-based anti-VEGF drugs, for the treatment of retinal diseases such as wet AMD;
+Added: diabetic macular edema, or DME;
+Added: and retinal vein occlusion, or RVO.
+Added: Our initial goal for these programs is to provide extended delivery for at least six months, thereby reducing the frequency of the current monthly or bi-monthly immediate release intravitreal anti-VEGF injection regimens for wet AMD and other retinal diseases.
+Added: OTX-TKI (axitinib intravitreal implant)
+Added: Our product candidate OTX-TKI is a preformed, bioresorbable hydrogel fiber implant incorporating a small molecule tyrosine kinase inhibitor, or TKI, axitinib, with anti-angiogenic properties delivered by intravitreal injection
+Added: and designed for a duration of six months or longer.
TKIs have shown promise in the treatment of wet AMD.
−Removed: In May 2017, we reported data from preclinical studies evaluating the efficacy, tolerability and pharmacokinetics of OTX-TKI.
−Removed: In this study, OTX-TKI was well-tolerated, and high levels of drug were maintained in the tissue for up to twelve months in Dutch belted rabbits.
−Removed: In the first quarter of 2019, we began dosing patients in a Phase 1 clinical trial in Australia.
−Removed: This clinical trial is a multi-center, open-label, dose escalation study designed to evaluate the safety, durability and tolerability of OTX-TKI.
−Removed: We also plan to evaluate biological activity by following visual acuity over time and measuring retinal thickness using standard optical coherence tomography.
−Removed: Two cohorts of six subjects each have been enrolled, a lower dose cohort of 200 μg and a higher dose cohort of 400 μg.
−Removed: In these cohorts, OTX-TKI was generally well tolerated and observed to have a favorable safety profile with no ocular serious adverse events noted.
−Removed: In the higher dose cohort, OTX-TKI showed a decrease in central subfield retinal thickness as measured by mean changes in central subfield thickness values by decreases in intraretinal and/or subretinal fluid in some subjects.
−Removed: We plan to continue long-term evaluation of these cohorts .
−Removed: We plan to amend our current clinical trial protocol to enroll a third, higher-dose cohort.
−Removed: This Phase 1 clinical trial is not powered to measure any efficacy endpoints with statistical significance.
−Removed: OTX-IVT (intravitreal aflibercept implant) in Collaboration with Regeneron
−Removed: In October 2016, we entered into a strategic collaboration, option and license agreement, or Collaboration Agreement, with Regeneron for the development and potential commercialization of products using our hydrogel in combination with Regeneron’s large molecule VEGF-targeting compounds for the treatment of retinal diseases, with the initial focus on the VEGF trap aflibercept, currently marketed under the brand name Eylea.
−Removed: Under the terms of the agreement, we granted Regeneron an option, or the Option, to enter into an exclusive, worldwide license under our intellectual property to develop and commercialize products using our hydrogel in combination with Regeneron’s large molecule VEGF-targeting compounds, or Licensed Products.
−Removed: The Collaboration Agreement does not cover the development of any products that deliver small molecule drugs, including TKIs, for any target including VEGF, or any products that deliver large molecule drugs other than those that target VEGF proteins.
−Removed: Under the terms of the Collaboration Agreement, we and Regeneron have agreed to conduct a joint research program with the aim of developing an extended-delivery formulation of aflibercept that is suitable for advancement into clinical development.
−Removed: We refer to the formulation we are developing with Regeneron as OTX-IVT.
−Removed: Under the terms of the Collaboration Agreement, Regeneron is responsible for funding an initial preclinical tolerability study.
−Removed: If the Option is exercised, Regeneron will conduct further preclinical development and an initial clinical trial under a collaboration plan.
−Removed: We are obligated to reimburse Regeneron for certain development costs during the period through the completion of the initial clinical trial, subject to a cap of $25 million, which cap may be increased by up to $5 million under certain circumstances.
−Removed: We do not expect our funding requirements under the collaboration to be material over the next twelve months.
−Removed: If Regeneron elects to proceed with further development beyond the initial clinical trial, it will be solely responsible for conducting and funding further development and commercialization of product candidates.
−Removed: If the Option is exercised, Regeneron is required to use commercially reasonable efforts to research, develop and commercialize at least one Licensed Product.
−Removed: Such efforts shall include initiating the dosing phase of a subsequent clinical trial within specified time periods following the completion of the first-in-human clinical trial or the initiation of preclinical toxicology studies, subject to certain extensions.
−Removed: Under the terms of the Collaboration Agreement, Regeneron has agreed to pay us $10 million upon exercise of the Option.
−Removed: We are also eligible to receive up to $145 million per Licensed Product upon the achievement of specified development and regulatory milestones, including successful results from the first-in-human clinical trial, $100 million per Licensed Product upon first commercial sale of such Licensed Product and up to $50 million based on the achievement of specified sales milestones for all Licensed Products.
−Removed: In addition, we are entitled to tiered, escalating royalties, in a range from a high-single digit to a low-to-mid teen percentage of net sales of Licensed Products.
−Removed: In December 2017, we delivered to Regeneron a proposed final formulation for the initial preclinical tolerability study.
−Removed: Regeneron initiated an initial preclinical tolerability study in early 2018.
−Removed: We and Regeneron have subsequently reached an understanding that the proposed formulation did not meet the goals of the program, was not final and have therefore ceased development of it.
−Removed: We are currently in discussions with Regeneron, in accordance with the terms of the Collaboration Agreement, regarding the development of an alternative formulation.
−Removed: ReSure ®
−Removed: We commercially launched this product in the United States in 2014.
−Removed: ReSure Sealant is approved to seal corneal incisions following cataract surgery.
+Added: In the first quarter of 2019, we began dosing patients in a multi-center, open-label, dose-escalation Phase 1 clinical trial in Australia designed to evaluate the safety, durability and tolerability of OTX-TKI.
+Added: We are evaluating biological activity by measuring retinal thickness using spectral domain optical coherence tomography, or OCT, and following visual acuity over time.
+Added: Two cohorts were initially enrolled:
+Added: a lower dose cohort of 200 µg with six subjects and a higher dose cohort of 400 µg with seven subjects.
+Added: We are actively enrolling a third cohort of 12 subjects, split between parallel arms of six subjects each.
+Added: Subjects in the first arm of the third cohort will receive a dose of 600 µg, and subjects in the second arm will receive a 400 µg dose combined with an anti-VEGF induction injection.
+Added: At the Angiogenesis, Exudations, and Degeneration Virtual Conference in February 2021, we presented interim data from the Phase 1 clinical trial.
+Added: In the Phase 1 clinical trial, OTX-TKI was observed to have a generally favorable safety profile, with no reported ocular serious adverse events.
+Added: Some subjects in the Phase 1 clinical trial have shown a decrease in intraretinal or subretinal fluid by two months, and interim data suggests that OTX-TKI might have an extended duration of action beyond that of the current standard of care.
+Added: We plan to initiate a prospective, randomized, controlled Phase 1 clinical trial in the United States under an exploratory investigational new drug, or eIND, application in mid-2021 to evaluate a single implant 600 µg dose of OTX-TKI (combined with an anti-VEGF induction injection) in comparison with a 2 mg dose of aflibercept.
+Added: We have requested a pre-investigational new drug, or IND, application meeting with the FDA to discuss the possibility of transitioning from an eIND application to a traditional IND application.
+Added: Pending our receipt and review of the topline data from the Phase 1 clinical trial in Australia and related regulatory discussions, we also plan to initiate a Phase 2 clinical trial in Australia to compare the administration of a single implant 600 µg dose of OTX-TKI (combined with an anti-VEGF induction injection) to a 2 mg dose of aflibercept dosed every 8 weeks as the comparator.
+Added: OTX-AFS (aflibercept suprachoroidal injection) in collaboration with Regeneron
+Added: As described above, in October 2016, we entered into a strategic collaboration, option and license agreement with Regeneron for the development and potential commercialization of products using our local programmed-release hydrogel in combination with, among other things, Regeneron’s large molecule VEGF-targeting compounds for the treatment of retinal diseases, with the initial focus on the VEGF trap aflibercept.
+Added: We and Regeneron amended this agreement in May 2020 to, among other things, transition joint efforts under the collaboration to the research and development of an extended-delivery formulation of aflibercept to be delivered to the suprachoroidal space which we refer to as OTX-AFS.
+Added: Under the amended agreement, we have provided certain formulations to Regeneron who have agreed to perform preclinical assessments of OTX-AFS.
+Added: Glaucoma Program
+Added: Our development efforts for our glaucoma program have focused on the use of our extended-delivery hydrogel in combination with travoprost, an FDA-approved prostaglandin analog designed to lower elevated IOP.
+Added: Our initial goal for this program is to provide extended delivery over at least four months with a single treatment.
+Added: OTX-TIC (travoprost intracameral implant)
+Added: Our product candidate OTX-TIC is a bioresorbable hydrogel implant incorporating travoprost that is designed to be administered by a physician as an intracameral injection with an initial target duration of drug release of four to six months.
+Added: We are currently conducting a multi-center, open-label, dose-escalation, proof-of-concept Phase 1 clinical trial to evaluate the safety, biological activity, durability and tolerability of OTX-TIC compared to topical travoprost (eye drops) in patients with primary open-angle glaucoma or ocular hypertension.
+Added: The trial consists of four patient cohorts:
+Added: cohort 1 is 5 subjects who are receiving a 15 µg dose, cohort 2 is 4 subjects who are receiving a 26 µg dose, cohort 3 is 5 subjects who are receiving a 15 µg with a fast-degrading implant, and cohort 4 is 5 subjects who are receiving a 5 µg with a fast-degrading implant.
+Added: We presented interim data on all four patient cohorts at the Glaucoma360 Virtual Conference in January 2021.
+Added: In this Phase 1 clinical trial, with a single implant, several subjects were able to achieve a decrease in IOP at least as large as that of the current standard of care.
+Added: Many subjects exhibited an IOP-lowering effect of more than six months in
+Added: cohorts 1 and 2 and between three and six months in cohorts 3 and 4, the cohorts in which the fast-degrading implant was used.
+Added: In the clinical trial, OTX-TIC was observed to have a generally favorable safety profile, with no reported ocular serious adverse events.
+Added: Corneal health, as measured by endothelial cell counts, pachymetry assessments and slit lamp examinations did not indicate a clinically meaningful change from baseline.
+Added: In mid-2021, we plan to initiate a Phase 2 clinical trial to evaluate two formulations of OTX-TIC for the treatment of glaucoma or ocular hypertension in patients compared to Durysta (Allergan).
+Added: The non-study eye of each patient will receive a topical prostaglandin daily.
+Added: Certain subjects in the Phase 2 clinical trial will receive the same formulation used in cohort 1 of the Phase 1 clinical trial, containing a 26 µg dose of drug and utilizing a standard implant, and others will receive the same formulation used in cohort 4 of the Phase 1 clinical trial, containing a 5 µg dose of drug and utilizing a fast-degrading implant.
+Added: Ocular Surface Disease Programs
+Added: We are engaged in the development of formulations of our hydrogel administered via intracanalicular inserts to address large markets for diseases and conditions of the surface of the eye.
+Added: Our initial development efforts are focused on the use of our extended-delivery hydrogel in combination with well-known and well-understood drugs (cyclosporine and corticosteroids) for the treatment of dry eye disease and allergic conjunctivitis.
+Added: Dry Eye Disease
+Added: OTX-CSI (cyclosporine intracanalicular insert)
+Added: Our product candidate, OTX-CSI, incorporates the FDA-approved immunomodulator cyclosporine as a preservative-free active pharmaceutical ingredient into a hydrogel, drug-eluting intracanalicular insert.
+Added: The product candidate is designed for a duration of three to four months for patients suffering from moderate to severe dry eye and to be administered by a physician as a bioresorbable intracanalicular insert.
+Added: In October 2020, we reported topline data from our five subject Phase 1 clinical trial evaluating OTX-CSI in the treatment of dry eye disease.
+Added: All subjects completed the 16-week study period with no drop-outs.
+Added: There were no serious adverse effects reported.
+Added: The inserts were observed to be generally well-tolerated, and there were no adverse events of stinging, irritation, blurred vision or tearing reported or observed.
+Added: In September 2020, we dosed the first patients in a Phase 2 clinical trial designed to assess the safety, tolerability, and durability and to evaluate the efficacy of OTX-CSI for the chronic treatment of dry eye disease.
+Added: The Phase 2 clinical trial is a U.S.-based, randomized, double-masked, multi-center trial evaluating two different formulations of OTX-CSI compared to a vehicle insert in approximately 140 subjects who are to be followed for a period of approximately 16 weeks.
+Added: Endpoints include tear production as measured by the Schirmer’s test;
+Added: signs of dry eye disease as measured by corneal fluorescein staining;
+Added: and symptoms of dry eye disease as measured by the visual analog scale, or VAS, eye dryness severity score and the VAS dry eye frequency score.
+Added: We currently anticipate receiving topline data from this Phase 2 clinical trial by year-end 2021.
+Added: OTX-DED (dexamethasone intracanalicular insert)
+Added: Our product candidate OTX-DED incorporates the FDA-approved corticosteroid dexamethasone as a preservative-free active pharmaceutical ingredient in a hydrogel, drug-eluting intracanalicular insert.
+Added: OTX-DED incorporates the same active drug as DEXTENZA, but it includes a lower dose of the drug, delivers it via a smaller insert, and is designed to release it over a period of two to three weeks, compared with up to thirty days in the case of DEXTENZA.
+Added: We believe that OTX-DED will address several of the current limitations of existing dry eye disease steroid treatments, the toxicity associated with preservatives, and the potential for abuse of topical steroids.
+Added: In February 2021, we dosed the first patient in a U.S.-based prospective, randomized, double-masked, vehicle-controlled Phase 2 clinical trial evaluating two different formulations of OTX-DED for the short-term treatment of the signs and symptoms of dry eye disease compared to a hydrogel insert in approximately 150 subjects.
+Added: We anticipate receiving topline data from this Phase 2 clinical trial in the first half of 2022.
+Added: Allergic Conjunctivitis
+Added: DEXTENZA (dexamethasone ophthalmic insert) for the Treatment of Ocular Itching Associated with Allergic Conjunctivitis
+Added: DEXTENZA, incorporating the corticosteroid dexamethasone, is our FDA-approved intracanalicular insert for the treatment of post-surgical ocular inflammation and pain.
+Added: We believe that allergic conjunctivitis represents a discrete potential market for DEXTENZA as a physician administered, hands-free, therapy administered in the office setting and designed to release preservative-free dexamethasone to the ocular surface for up to 30 days.
+Added: In April 2020, we reported topline results of a 96-subject, third pivotal Phase 3 clinical trial evaluating DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis.
+Added: DEXTENZA-treated subjects demonstrated a statistically significant (p-value < 0.0001) difference in mean ocular itching scores, compared to vehicle-treated subjects, at all three pre-specified time points.
+Added: In the fourth quarter of 2020, w e filed a supplemental new drug application, or sNDA, for DEXTENZA to include the treatment of ocular itching associated with allergic conjunctivitis as an additional indication.
+Added: The FDA has accepted our sNDA for filing and has established a target action date under the Prescription Drug User Fee Act, commonly known as PDUFA, of October 18, 2021.
+Added: If our sNDA is approved, we expect to launch DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis in the first half of 2022.
+Added: Post-Surgical Ocular Inflammation and Pain
+Added: DEXTENZA (dexamethasone ophthalmic insert) 0.4 mg for intracanalicular use for the Treatment of Post-Surgical Ocular Inflammation and Pain
+Added: As described above, DEXTENZA incorporates the FDA-approved corticosteroid dexamethasone as a preservative-free active pharmaceutical ingredient into a hydrogel, drug-eluting intracanalicular insert for the treatment of post-surgical ocular inflammation and pain.
+Added: We commercially launched DEXTENZA in the United States in July 2019.
+Added: DEXTENZA is the first FDA-approved intracanalicular insert delivering dexamethasone to treat post-surgical ocular inflammation and pain for up to 30 days with a single administration.
+Added: In September 2020, we announced that we had dosed the first patients in a Phase 3 clinical trial evaluating DEXTENZA for the treatment of post-surgical ocular inflammation and pain in children following cataract surgery.
+Added: This planned clinical trial is a post-approval requirement of the FDA in accordance with the Pediatric Research Equity Act of 2003, in connection with the FDA’s prior approval of DEXTENZA for the treatment of inflammation and pain following ophthalmic surgery in adults.
+Added: Additionally, we have received proposals for, and plan to support, several investigator-initiated trials evaluating DEXTENZA in different clinical situations.
+Added: To date, third-party clinical investigators have initiated over 25 trials to study the use of DEXTENZA in cataract surgery, other ophthalmic surgeries and other potential indications.
+Added: Seven of the trials have completed enrollment, and the remaining trials are actively enrolling and treated patients are being followed.
+Added: ReSure Sealant
+Added: In 2014, we commercially launched ReSure Sealant in the United States as a device approved to prevent wound leaks in corneal incisions following cataract surgery.
In the pivotal clinical trials that formed the basis for FDA approval, ReSure Sealant provided superior wound closure and a better safety profile than sutured closure.
The FDA required two post-approval studies as a condition for approval of our premarket approval, or PMA, application for ReSure Sealant.
−Removed: The first post-approval study, identified as the Clinical PAS, was to confirm that ReSure Sealant can be used safely by physicians in a standard cataract surgery practice and to confirm the incidence of the most prevalent adverse ocular events identified in our pivotal study in eyes treated with ReSure Sealant.
−Removed: We submitted the final study report to the FDA in June 2016, and the FDA has confirmed the Clinical PAS has been completed.
−Removed: The second post-approval study, identified as the Device Exposure Registry Study, is intended to link to the Medicare database to ascertain if patients are diagnosed or treated for endophthalmitis within 30 days following cataract surgery and application of ReSure Sealant.
−Removed: The Device Exposure Registry Study is required to include at least 4,857 patients.
−Removed: Due to difficulties in establishing an acceptable way to link ReSure Sealant to the Medicare database and lack of investigator interest, we have been unable to enroll trial sites and patients, collect patient data and report study data to the FDA.
−Removed: We have provided regular periodic reports to the FDA on the progress of this post-approval study.
−Removed: We received a warning letter from the FDA in October 2018 relating to our compliance with data collection and information reporting obligations in the Device Exposure Registry Study.
−Removed: The FDA warning letter refers to a lack of progress with the enrollment and related data collection and information reporting obligations for a required post-approval trial.
−Removed: In November 2018, we appealed this warning letter.
−Removed: In December 2018, the FDA rejected our appeal.
−Removed: Failure by us to conduct the required post-approval trial for ReSure Sealant to the FDA’s satisfaction may result in withdrawal of the FDA’s approval of ReSure Sealant or other regulatory action.
−Removed: A teleconference was held with the FDA in January 2019 resulting in tentative agreement on a proposed retrospective registry study of endophthalmitis rates to satisfy the Device Exposure Registry Study requirements.
−Removed: In a letter dated June 7, 2019 from the FDA, the agency acknowledged receipt of a letter dated March 29, 2019 from us in which we proposed conducting the proposed retrospective analysis of the IRIS Registry, comparing endophthalmitis rates from sites that purchased ReSure versus those sites that did not purchase ReSure.
−Removed: If the rates are no different, the FDA has indicated that it will consider the post-approval requirement to have been fulfilled.
−Removed: If there is a statistically significant increase in endophthalmitis rates at sites purchasing ReSure compared with those not purchasing ReSure, a
−Removed: prospective study will be required.
−Removed: The FDA has indicated it will consider our response to the warning letter adequate once it approves the study protocol for the retrospective analysis of the IRIS Registry and the outline of the prospective study.
−Removed: In December 2019, we submitted the protocol for the agreed upon retrospective study and prospective study outline, as required per the terms of the warning letter.
−Removed: We received feedback from the FDA in February 2020 and responded to the FDA in March 2020.
−Removed: We expect a response from the FDA in the middle of 2020.
−Removed: ReSure Sealant currently remains commercially available in the United States, though there is no sales support provided to the product at this time.
+Added: The FDA has confirmed that first post-approval study, identified as the Clinical PAS, has been completed.
+Added: The second post-approval study, which we refer to as the Device Exposure Registry Study, was a retrospective analysis of the IRIS Registry, comparing endophthalmitis rates from sites that purchased ReSure Sealant versus those sites that did not.
+Added: We completed the retrospective study in accordance with our agreement with the FDA and submitted the final study report for the Device Exposure Registry Study to the FDA in January 2021.
+Added: We anticipate
+Added: that the FDA will review the report within 90 days of our submission and notify us as to whether our obligation to conduct the post-approval study has been satisfied.
+Added: While ReSure Sealant remains commercially available in the United States, commercial and sales support for this product are modest at this time.
We have received only limited revenues from ReSure Sealant to date and anticipate only limited sales for 2021.
+Added: AffaMed License Agreement
+Added: In October 2020, we entered into a license agreement and collaboration with AffaMed Therapeutics Limited, or AffaMed, for the development and commercialization of DEXTENZA and OTX-TIC in mainland China , Hong Kong , Macau , and Taiwan ;
+Added: South Korea ;
+Added: and the ASEAN markets ( Brunei , Cambodia , Indonesia , Laos , Malaysia , Myanmar , the Philippines , Singapore , Thailand and Vietnam ).
+Added: Under the terms of the agreement, we received an upfront payment of $12 million and are eligible to receive development, regulatory and commercial milestone payments and clinical development support payments of up to $91 million in the aggregate, as well as royalties from future product sales.
+Added: Royalties are tiered and will range from the low teens to low twenty percent range.
+Added: In return, we agreed to grant AffaMed exclusive rights to develop and commercialize DEXTENZA for the treatment of post-surgical inflammation and pain following ophthalmic surgery and ocular itching in patients with allergic conjunctivitis, and OTX-TIC for the reduction of elevated intraocular pressure in patients with primary open-angle glaucoma or ocular hypertension in specified Asian markets.
+Added: We retain the right to develop and commercialize DEXTENZA and OTX-TIC in all other global markets.
Additional Potential Areas for Growth
We continue to leverage the potential of our hydrogel platform to explore areas for growth with our focus on formulating, developing and commercializing innovative therapies for diseases and conditions of the eye.
−Removed: We are also assessing the potential use of our hydrogel platform technology in other areas of the body and are studying several localized delivery platforms including via wound inlays;
−Removed: sinus and ear inserts;
−Removed: and subcutaneous, peripheral, and intra-articular injections.
In September 2018, we entered into a second amended and restated license agreement, or Second Amended Agreement, with Incept LLC, an intellectual property holding company, or Incept.
−Removed: The Second Amended Agreement expands the scope of our intellectual property license to include products delivered for the treatment of acute post-surgical pain or for the treatment of ear, nose and/or throat diseases or conditions, subject to specified exceptions.
+Added: The Second Amended Agreement expanded the scope of our intellectual property license to include products delivered for the treatment of acute post-surgical pain or for the treatment of ear, nose and/or throat diseases or conditions, subject to specified exceptions.
Market Background
−Removed: Our clinical stage product candidates and our marketed product are based on a proprietary bioresorbable hydrogel technology platform that uses polyethylene glycol, or PEG, as a key component.
+Added: Our clinical stage product candidates and our marketed products are based on a proprietary bioresorbable hydrogel technology platform that uses polyethylene glycol, or PEG, as a key component.
Bioresorbable materials gradually break down in the body into non-toxic, water soluble compounds that are cleared by normal biological processes.
1 unchanged sentence
Our technology platform allows us to tailor the physical properties, drug release profiles and bioresorption rates of our hydrogels to meet the needs of specific clinical indications.
−Removed: We have used this platform to engineer each of our intracanalicular insert product candidates, our intracameral product candidates, our intravitreal implant product candidates, and ReSure Sealant.
+Added: We have used this platform to engineer each of our intracanalicular insert, intracameral implant, and intravitreal implant product candidates;
+Added: our suprachoroidal formulations;
+Added: and ReSure Sealant.
Our technical capabilities include a deep understanding of the polymer chemistry of PEG-based hydrogels and the design of the specialized manufacturing processes required to achieve a reliable, preservative-free and high purity product.
−Removed: Our product candidates target large and growing markets.
−Removed: Grand View Research estimates that the global ophthalmic drugs market size was valued at approximately $30 billion in 2018 and is expected to grow at a CAGR of 4.5% from 2018 to 2026.
−Removed: Increased funding by public and private bodies for conducting research on ocular disorders along with the presence of strong emerging pipeline drugs are among the key factors responsible for the growth of this market.
−Removed: We have in-licensed a significant portion of the patent rights and the technology for ReSure Sealant and our hydrogel platform technology product candidates from Incept, LLC, or Incept, an intellectual property holding company.
−Removed: Amarpreet Sawhney, our former President and Chief Executive Officer and former Chairman of the Board of Directors, is a general partner of Incept and has a 50% ownership stake in Incept.
−Removed: Our founders and management team have significant experience in developing and commercializing medical products for other companies using bioresorbable hydrogel technology, including FDA-approved and currently marketed medical products such as SpaceOAR (marketed by Boston Scientific, Inc.), a hydrogel spacer used to reduce a common and debilitating side effect that men may experience after receiving prostate cancer radiotherapy;
−Removed: DuraSeal Dural Sealant ®
−Removed: (marketed by Integra Lifesciences, Inc.), a sealant for cranial and spine surgery;
−Removed: and Mynx ®
−Removed: (marketed by Cardinal Health, Inc.), a sealant for femoral artery punctures after angiography and angioplasty.
Product Pipeline
−Removed: The following table summarizes the status of our key product development programs and our marketed product.
−Removed: We hold worldwide exclusive commercial rights to the core technology underlying all of our products in development
−Removed: and have not granted commercial rights to any marketing partners other than the Option on commercial rights we granted to Regeneron for the delivery of protein-based anti-VEGF drugs in our hydrogel depot for the treatment of retinal diseases.
+Added: The following table summarizes the status of our key product development programs and DEXTENZA, our marketed product.
+Added: We hold worldwide exclusive commercial rights to the core technology underlying all of our products in development and have not granted commercial rights to any marketing partners other than the option on commercial rights we granted to Regeneron for the delivery of protein-based anti-VEGF drugs in our hydrogel depot for the
+Added: treatment of retinal diseases and a license agreement and collaboration with AffaMed for the development and commercialization of DEXTENZA and OTX-TIC in the geographies agreed to between the parties .
We are pursuing three overall strategic goals:
3 unchanged sentences
The key tactics of our strategy to achieve these goals are:
−Removed: Commercialize DEXTENZA ®
−Removed: (dexamethasone ophthalmic insert) 0.4mg for intracanalicular use for the treatment of ocular pain following ophthalmic surgery.
−Removed: DEXTENZA is the first FDA-approved intracanalicular insert delivering dexamethasone to treat post-surgical ocular inflammation and pain for up to 30 days with a single administration.
−Removed: We launched the commercialization of DEXTENZA in July of 2019 and have built a commercial field force consisting of 30 key account managers, eight field reimbursement specialists and five medical sales liaisons.
−Removed: Create proprietary solutions for ophthalmic diseases and conditions based on our bioresorbable hydrogel and complete clinical development of and seek marketing approval for other intracanalicular insert product candidates and implants for intracameral injection for diseases and conditions of the front of the eye.
−Removed: Allergic Conjunctivitis.
−Removed: In the first quarter of 2020, we completed enrollment of our pivotal Phase 3 clinical trial evaluating DEXTENZA for the treatment of ocular itching in connection with allergic conjunctivitis.
−Removed: A total of 96 patients were enrolled in this trial.
−Removed: This trial represents the third
−Removed: Phase 3 clinical trial in allergic conjunctivitis conducted by us and, if successful, we plan to submit a supplemental NDA to the FDA for an indication of ocular itching associated with allergic conjunctivitis.
−Removed: We recently completed enrollment and topline data from this trial is anticipated to be reported in the second quarter of 2020.
−Removed: Our IND for our U.S.
−Removed: Phase 1 trial of OTX-TIC became effective in the first quarter of 2018, and we dosed the first patient in May 2018.
−Removed: Data generated to date has demonstrated that, with a single implant, subjects were able to achieve IOP lowering for up to eighteen months.
−Removed: In addition, the hydrogel carrier, as designed, biodegraded in approximately five to seven months.
−Removed: There were no clinically meaningful changes in corneal health as measured by slit lamp examination, endothelial cell evaluation, and corneal pachymetry.
−Removed: We are currently collecting additional data from the first two cohorts and have begun a third and fourth cohort to assess the impact of a faster degrading implant with the same therapeutic dose as administered in cohort one and a fourth cohort to assess an additional formulation with a smaller implant.
−Removed: Pursue development of our intravitreal implant and other technologies for back-of-the-eye diseases and conditions.
−Removed: In the first quarter of 2019, we began dosing patients in a Phase 1 clinical trial in Australia.
−Removed: After review of data from the first cohort of patients in the Phase 1, the independent Data Safety and Monitoring Committee recommended moving to a higher dose of OTX-TKI and we are currently treating the next cohort of subjects.
−Removed: We have treated two cohorts of six subjects each.
−Removed: Two cohorts have been enrolled, a lower dose cohort of 200 μg and a higher dose cohort of 400 μg.
−Removed: In the first two fully enrolled cohorts to date, OTX-TKI was generally well tolerated and observed to have a favorable safety profile with no ocular serious adverse events noted.
−Removed: In the higher dose cohort, OTX-TKI showed a decrease in central subfield retinal thickness as measured by mean central subfield thickness values by decreases in intraretinal and/or subretinal fluid in some subjects.
−Removed: The Company plans to continue long-term evaluation of the first two cohorts.
−Removed: In December 2017, under the Collaboration Agreement with Regeneron, we delivered a proposed final formulation of our extended-delivery hydrogel in combination with Regeneron’s large molecule VEGF-targeting compound aflibercept, currently marketed under the brand name Eylea, for an initial preclinical tolerability study by Regeneron.
−Removed: Regeneron initiated this preclinical study in early 2018.
−Removed: We and Regeneron have subsequently reached an understanding that the proposed formulation did not meet the goals of the program, was not final and have therefore ceased development of it.
−Removed: We are currently in discussions with Regeneron, in accordance with the terms of the Collaboration Agreement, regarding the development of an alternative formulation.
−Removed: Apply our local programmed-release intracanalicular insert technology for the treatment of additional diseases and conditions of the front of the eye .
−Removed: We intend to apply our proprietary PEG-based bioresorbable hydrogel technology platform to product candidates that are designed to provide local programmed-release of therapeutic agents to the eye using active pharmaceutical ingredients that are currently used in ophthalmic drugs approved by the FDA and that are or are expected to become available on a generic basis prior to anticipated launch dates.
−Removed: By focusing on the development of products based on FDA-approved therapeutic agents, we believe that we can advance potential products efficiently and predictably through the development cycle based on well-defined clinical and regulatory approval pathways.
−Removed: We believe this strategy represents an attractive risk-reward profile relative to new drug development.
−Removed: We currently have a number of preclinical programs that we have positioned for further development including OTX-CSI for episodic dry eye, for which we filed an IND in the United States in December 2019 and intend to initiate a Phase 1 clinical trial in the middle of 2020;
−Removed: OTX-BPI for acute ocular pain;
−Removed: and OTX-BDI for post-operative inflammation, pain and bacterial infection.
+Added: ● Advance our four core clinical development programs through Phase 2.
+Added: We believe the greatest potential value inflection points for us are the topline data readouts of the Phase 2 clinical trials of our four core clinical development programs:
+Added: OTX-TKI for the treatment of wet AMD, OTX-TIC for the treatment of glaucoma or ocular hypertension, OTX-CSI for the treatment of dry eye disease, and OTX-DED for the short-term treatment of the signs and symptoms of dry eye disease.
+Added: ● Expand Commercialization of DEXTENZA for the treatment of ocular inflammation and pain following ophthalmic surgery.
+Added: We expect to grow our salesforce to increase our active number of accounts and penetrate each account more deeply.
+Added: We intend to focus sales efforts on ambulatory surgical centers, or ASCs, that generate the largest volumes of cataract surgeries in the United States.
+Added: We are also seeking to expand the label for DEXTENZA—beginning with our sNDA to add ocular itching associated with allergic conjunctivitis as an approved indication—to permit the product’s use outside of the surgical setting and into ophthalmologists’ offices.
+Added: ● Apply our local programmed-release hydrogel-based technology to create additional proprietary solutions for ophthalmic diseases and conditions.
+Added: In collaboration with Regeneron, we are conducting preclinical research
+Added: and development activities regarding an extended-delivery formulation of the VEGF trap aflibercept, currently marketed under the brand name Eylea, to be delivered to the suprachoroidal space.
+Added: We are assessing preclinical product candidates for the ophthalmic space that leverage not only our proprietary PEG-based bioresorbable hydrogel technology platform but also active pharmaceutical ingredients used in FDA-approved ophthalmic drugs that are or are expected to become available on a generic basis.
+Added: Finally, we are frequently in discussions with other companies operating in the ophthalmic space regarding potential collaborations to combine our local programmed-release hydrogel technology with their proprietary drug formulations to address additional diseases and conditions of the eye.
+Added: ● Address rest-of-world commercial opportunities through licensing and collaborations agreements .
+Added: In the fourth quarter of 2020, we announced a license agreement and collaboration with AffaMed for the development and commercialization of DEXTENZA and OTX-TIC in specified Asian markets.
+Added: From time to time, we may consider additional arrangements with other companies to address markets outside of the United States.
● Utilize our hydrogel platform to enable local programmed-release of therapeutics to areas of the body outside the eye.
−Removed: In September 2018, we entered into the Second Amended Agreement with Incept to expand the scope of our intellectual property license to include products delivered for the treatment of acute post-surgical pain or for the treatment of ear, nose and/or throat diseases or conditions, subject to specified exceptions.
−Removed: We intend to explore programs outside of the eye not only on our own but also potentially through partnerships or collaborations with third parties who have expertise and experience with other therapeutics as well as other areas of the body.
+Added: We have licensed certain of Incept’s intellectual property rights for the development of product candidates for the treatment of acute post-surgical pain or for the treatment of ear, nose and/or throat diseases or conditions, subject to specified exceptions.
+Added: We intend to explore programs outside of the eye not only on our own but also potentially through collaborations with third parties who have expertise and experience with other therapeutics as well as other areas of the body.
+Added: Eye disease can be caused by many factors and can affect both the front and back of the eye.
The front of the human eye consists of the cornea on the surface of the eye, the lens and the aqueous humor, which is a transparent fluid that fills the anterior chamber between the lens and the cornea.
4 unchanged sentences
It helps to protect the eye from microbes and to lubricate the eye.
−Removed: The back of the eye contains the retina, which is the light sensing layer of tissue, the vitreous humor, which is a transparent gel that fills the vitreous chamber between the lens and the retina, and the optic nerve, which transmits visual information from the retina to the brain.
+Added: Diseases and conditions affecting the front of the eye have generally been treated with either surgery or with medications delivered to the ocular surface by eye drops.
+Added: The back of the eye contains the retina, which is the light sensing layer of tissue;
+Added: the vitreous humor, which is a transparent gel that fills the vitreous chamber between the lens and the retina;
+Added: and the optic nerve, which transmits visual information from the retina to the brain.
Eye disease can be caused by many factors and can affect both the front and back of the eye.
−Removed: Diseases and conditions affecting the front of the eye are generally treated either with surgery or with medications delivered to the ocular surface by eye drops.
−Removed: Intravitreal injections or oral pills are typically used to deliver medications to the back of the eye.
+Added: Intravitreal injections or oral pills have typically been used to deliver medications to the back of the eye.
Cross Section of Eye
Tear Drainage System
−Removed: Front-of-the-Eye Diseases and Conditions
−Removed: Ocular Inflammation and Pain
−Removed: Ocular inflammation and pain are common conditions caused by a variety of factors, including ophthalmic surgery, allergic conjunctivitis and dry eye disease.
−Removed: Post-Surgical Ocular Inflammation and Pain
−Removed: Ocular inflammation and pain are common side effects following ophthalmic surgery.
−Removed: Frequently performed ophthalmic surgeries include cataract, refractive, vitreoretinal, cornea, and glaucoma procedures.
−Removed: Physicians prescribe anti-inflammatory drugs, such as corticosteroids, which are typically administered through eye drops multiple times per
−Removed: day, following ocular surgery as the standard of care.
−Removed: These drugs improve patient comfort and also accelerate recovery through disruption of the inflammatory cascade resulting in decreased inflammation and reduced activity of the immune system.
−Removed: Physicians also frequently prescribe non-steroidal anti-inflammatory drugs, or NSAIDs, as adjunctive or combination therapy to supplement the use of corticosteroids.
−Removed: If left untreated, inflammation of the eye may result in further ocular complications, including pain, scarring and vision loss.
−Removed: Market Scope has estimated that approximately 6.1 million ocular surgeries were to be performed in the United States in 2019.
−Removed: Allergic Conjunctivitis
−Removed: Allergic conjunctivitis is an inflammatory disease of the conjunctiva resulting primarily from a reaction to allergy- causing substances such as pollen or pet dander.
−Removed: The primary sign of this inflammation is redness and the primary symptom is acute itching.
−Removed: Allergic conjunctivitis ranges in clinical severity from relatively mild, common forms to more severe forms that can cause impaired vision.
−Removed: According to a study on the management of seasonal allergic conjunctivitis published in 2012 in the peer-reviewed journal Acta Ophthalmologica , allergic conjunctivitis affects 15% to 40% of the U.S.
−Removed: The first line of defense against allergic conjunctivitis is avoidance of the allergen.
−Removed: If this is not successful, physicians typically prescribe a combination of a topical mast cell stabilizer and anti-histamine.
−Removed: These treatments act to reduce the signs and symptoms of the early phase allergic reaction.
−Removed: For the subset of patients with chronic or more severe forms of allergic conjunctivitis, anti-histamines and mast cell stabilizers are often not sufficient to treat their signs and symptoms.
−Removed: These refractory patients are frequently treated with topical corticosteroids administered by prescription eye drops.
−Removed: Dry Eye Disease
−Removed: Dry eye disease affects the ocular surface and is characterized by dryness, inflammation, pain, discomfort and irritation.
−Removed: The current standard of care for moderate to severe dry eye disease is the use of artificial tears and topical anti- inflammatory and immune modulating drugs administered by prescription eye drops.
−Removed: The anti-inflammatory and immune modulating prescription drug market for the treatment of moderate to severe dry eye disease consists of Restasis ®, for increasing tear production, marketed by Allergan;
−Removed: Cequa™
−Removed: for increasing tear production, marketed by Sun Ophthalmics in the United States;
−Removed: lifitegrast, for the treatment of the signs and symptoms of dry eye disease, marketed by Novartis under the brand name Xiidra®;
−Removed: and off-label use of corticosteroids.
−Removed: Based on our review of industry sources, we estimate that approximately 20 million people in the United States have dry eye disease, including approximately five million people who suffer from moderate to severe dry eye disease.
−Removed: Dry eye disease is a chronic, multifactorial disease affecting the tears and ocular surface that can result in tear film instability, inflammation, discomfort, visual disturbance and ocular surface damage.
−Removed: Dry eye disease can have a significant impact on quality of life and can potentially cause long‑term damage to the ocular surface.
−Removed: Due to the impact of dry eye disease on tear film dynamics, the condition can affect performance of common vision‑related activities such as reading, using a computer and driving, and can lead to complications associated with visual impairment.
−Removed: In addition, the vast majority of dry eye patients experience acute episodic exacerbations of their symptoms, which are commonly referred to as flares, at various times throughout the year.
−Removed: These flares can be triggered by numerous factors, including exposure to allergens, pollution, wind and low humidity, intense visual concentration such as watching television and working at a computer, hormonal changes, contact lens wear, smoking and sleep deprivation, which cause ocular surface inflammation and impact tear production and/or tear film stability.
−Removed: Based on third‑party academic research, we believe dry eye disease results in approximately $55 billion in direct and indirect costs in the United States each year, of which approximately $3.8 billion are direct medical costs.
−Removed: The exact prevalence of dry eye disease is unknown due to the difficulty in defining the disease and the lack of a single diagnostic test to confirm its presence.
−Removed: The Beaver Dam Offspring Study, a major epidemiological study published in 2014 in the American Journal of Ophthalmology , reported that in a cohort of over 3,000 patients, dry eye disease was self‑reported by 14.5% of the patients.
−Removed: The prevalence of dry eye disease increases with age, and we expect that the number of dry eye disease cases will increase as the U.S.
−Removed: population continues to age.
−Removed: The most commonly used treatments for dry eye disease in the United States are over‑the‑counter eye drops, often referred to as “artificial tears,”
−Removed: and three prescription pharmaceutical products, Restasis ®
−Removed: Xiidra ®
−Removed: and Cequa™.
−Removed: Artificial tears are intended to be palliative in nature to supplement insufficient tear production or improve tear film instability, but do not treat the underlying inflammation in dry eye disease.
−Removed: Restasis increases tear production and Xiidra treats the signs and symptoms of dry eye disease, however, both Restasis and Xiidra are typically used chronically for dry eye patients
−Removed: who have continuous symptoms.
−Removed: Restasis had sales in 2018 of approximately $1.2 billion in the United States.
−Removed: Xiidra, which was commercially launched in the United States in August 2016, had sales of approximately $255.1 million for the nine-month period ended September 30, 2018.
−Removed: As each of Restasis and Xiidra have a relatively long onset of action, they are not generally used for the short‑term treatment of episodic dry eye flares.
−Removed: In addition, they have significant issues with stinging and burning.
−Removed: According to IMS Health data, approximately 20.0 million prescriptions were filled in the United States in 2019 for anti-inflammatory drugs administered by prescription eye drops for ocular diseases and conditions, resulting in sales of approximately $4.5 billion.
−Removed: These prescriptions consisted of approximately 8.3 million prescriptions and $752 million in sales for single-agent corticosteroids, 3.2 million prescriptions and $366 million in sales for NSAIDs, 4.6 million prescriptions and $294 million in sales for corticosteroid and antibiotic combination products and approximately 3.8 million prescriptions and $2.9 billion in sales of Restasis and Xiidra for dry eye disease.
−Removed: According to IMS Health data, approximately 7.0 million anti-allergy eye drop prescriptions were filled in the United States in 2019, resulting in sales of approximately $487 million.
−Removed: The steroid market for eye drops to treat ocular diseases and conditions consists of both branded and generic products.
−Removed: Branded steroids include Lotemax and Alrex (loteprednol etabonate) marketed by Bausch & Lomb, and Durezol (difluprednate) marketed by Alcon.
−Removed: Commonly used generic steroids include prednisolone, dexamethasone and fluorometholone.
−Removed: In addition, an injectable suspension of dexamethasone, Dexycu, is commercially available and approved for treatment of post-operative ocular inflammation.
−Removed: Glaucoma is a large market and a disease that is estimated to impact more than 2.7 million people age 40 or older in the United States.
−Removed: The primary goal of glaucoma treatment is to slow the progression of this chronic disease by reducing intraocular pressure, and many medications can accomplish this.
−Removed: Importantly, however, adherence to current topical glaucoma therapies is known to be particularly poor with reported rates of non-adherence from 30% to 80%.
−Removed: These low compliance rates may be associated with disease progression and loss of vision, and may be part of the reason that glaucoma is a leading cause of blindness in people over 60 years of age.
+Added: We currently focus on some of the largest markets in ophthalmology.
+Added: According to the Market Scope 2019 reports, our product candidates seek to address select indications within segments of ophthalmology that, in the aggregate, account for more than $20 billion global annual sales.
+Added: Retinal Diseases
+Added: One of the principal retinal diseases is wet AMD, a serious disease of the central portion of the retina, known as the macula, that is responsible for detailed central vision and color perception.
+Added: Wet AMD is characterized by abnormal new blood vessel formation, referred to as neovascularization, which results in blood vessel leakage and retinal distortion.
+Added: If untreated, neovascularization in wet AMD patients typically results in formation of a scar under the macular region of the retina.
+Added: The current standard of care for wet AMD is treatment with drugs that target VEGF, one of several proteins involved in neovascularization.
+Added: Wet AMD is the leading cause of blindness in people over the age of 55 in the United States and the European Union.
+Added: According to the 2019 Market Scope Retinal Disease Report, there are approximately 8.0 million people in the United States who suffer from vision-threatening retinal diseases.
+Added: This population is expected to grow at a 2.4% compound annual growth rate through 2024.
+Added: Because eye drops are unable to carry effective drug concentrations to the back of the eye, intravitreal injections or oral medications are used to deliver medications to this location.
+Added: However, the frequency of intravitreal injection can be a significant burden on patients, caregivers and clinicians.
+Added: For example, the current treatment protocol for wet AMD involves monthly or bi-monthly injections.
+Added: Intravitreal injections can lead to patient discomfort, a transient increase in IOP, and ocular inflammation and infection.
+Added: Although serious adverse event rates after treatment with anti-VEGF compounds are low, intravitreal injections can result in severe complications and damage to the retina and other structures of the eye, such as ocular hemorrhage and tears in the retinal pigment epithelium.
+Added: The global market for retinal disease was approximately $13.0 billion in 2019 and was estimated to grow at approximately 11% per year through 2024 according to Market Scope.
+Added: market accounted for just over 50% of the global market or $6.8 billion in 2019.
+Added: The anti-VEGF market for the treatment of wet AMD consists predominantly of three drugs that are approved for marketing and primarily prescribed for the treatment of wet AMD:
+Added: Eylea, marketed in the United States by Regeneron;
+Added: Lucentis, marketed in the United States by Genentech;
+Added: and Beovu, marketed in the United States by Novartis.
+Added: Avastin, a cancer treatment drug, marketed by Genentech, is also used off-label for the treatment of wet AMD.
Glaucoma is a progressive and highly individualized disease in which elevated levels of IOP are associated with damage to the optic nerve, which results in irreversible vision loss.
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Patients with ocular hypertension are at high risk of developing glaucoma.
+Added: Glaucoma impacts more than 2.7 million people age 40 or older in the United States.
+Added: The primary goal of glaucoma treatment is to slow the progression of this chronic disease by reducing IOP, and many medications can accomplish this.
+Added: Importantly, however, adherence to current topical glaucoma therapies is known to be particularly poor with reported rates of non-adherence from 30% to 80%.
+Added: These low compliance rates may be associated with disease progression and loss of vision and may be part of the reason that glaucoma is a leading cause of blindness in people over 60 years of age.
In a healthy eye, fluid is continuously produced and drained to maintain pressure equilibrium and provide nutrients to the ocular tissue.
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The ability of patients to use and place daily eye drops is challenging.
−Removed: The products that we are developing are designed to address the issue of compliance by delivering a prostaglandin analog formulated with our programmed release hydrogel to lower intraocular pressure for several months with a single insert.
−Removed: According to IMS Health data, approximately 35.6 million prescriptions were filled in the United States in 2019 for drugs administered by eye drops for the treatment of glaucoma, resulting in sales of approximately $3.3 billion.
−Removed: A typical prescription provides approximately one month of treatment.
−Removed: We expect prescription volume to grow, in large part as a result of the aging population.
−Removed: According to IMS Health, PGAs accounted for approximately half of the prescription volume in the glaucoma market in 2019.
+Added: The products that we are developing are designed to address the issue of compliance by delivering a prostaglandin analog, or PGA, formulated with our programmed release hydrogel to lower IOP for several months with a single insert.
+Added: The global market for glaucoma was estimated by Market Scope at $4.8 billion in 2019 with the U.S.
+Added: market representing $1.9 billion.
The market for drugs administered by eye drops for the treatment of glaucoma consists of both branded and generic products.
Branded products have maintained premium pricing and significant market share.
−Removed: These products include Travatan Z (travoprost) marketed by Alcon and Lumigan (bimatoprost)
−Removed: marketed by Allergan.
+Added: These products include Travatan Z (travoprost) marketed by Alcon and Lumigan (bimatoprost) marketed by Allergan.
The relevant patents covering travoprost expired in December 2014.
Commonly used generic drugs include latanoprost and timolol.
−Removed: The Use of Eye Drops and their Limitations
+Added: Ocular Surface Diseases
+Added: Dry Eye Disease
+Added: Dry eye disease is a chronic, multifactorial disease affecting the tears and ocular surface that can result in dryness, inflammation, irritation, pain, tear film instability, visual disturbance and ocular surface damage.
+Added: Dry eye disease can have a significant impact on quality of life and can potentially cause long-term damage to the ocular surface.
+Added: Due to the impact of dry eye disease on tear film dynamics, the condition can affect performance of common vision-related activities such as reading, using a computer and driving, and can lead to complications associated with visual impairment.
+Added: In addition, the vast majority of dry eye patients experience acute episodic exacerbations of their symptoms, which are commonly referred to as flares, at various times throughout the year.
+Added: These flares can be triggered by
+Added: numerous factors, including exposure to allergens, pollution, wind and low humidity, intense visual concentration such as watching television and working at a computer, hormonal changes, contact lens wear, smoking and sleep deprivation, which cause ocular surface inflammation and impact tear production and/or tear film stability.
+Added: There are approximately 17.2 million patients diagnosed with dry eye disease in the United States, according to the Market Scope 2019 Dry Eye Products Market Report.
+Added: Approximately 8.6 million of those patients are diagnosed with moderate to severe dry eye while the remaining 8.6 million patients are diagnosed with episodic dry eye disease.
+Added: The prevalence of dry eye disease increases with age, and we expect that the number of dry eye disease cases will increase as the U.S.
+Added: population continues to age.
+Added: The current standard of care for moderate to severe dry eye disease is the use of artificial tears and topical anti- inflammatory and immune modulating drugs administered by prescription eye drops.
+Added: The anti-inflammatory and immune modulating prescription drug market consists of Restasis®, for increasing tear production, marketed by Allergan;
+Added: Cequa™ for increasing tear production, marketed by Sun Ophthalmics in the United States;
+Added: lifitegrast, for the treatment of the signs and symptoms of dry eye disease, marketed by Novartis under the brand name Xiidra®;
+Added: and off-label use of corticosteroids.
+Added: As each of Restasis and Xiidra have a relatively long onset of action, they are not generally used for the short- term treatment of episodic dry eye flares.
+Added: In addition, patients have reported significant issues with stinging and burning when using several of the current treatments.
+Added: The global market for dry ocular surface disease, which we refer to as dry eye disease, was estimated by Market Scope at $5.1 billion in 2019 with the U.S.
+Added: market representing $2.1 billion, composed of approximately $1.5 billion in prescriptions and $0.6 billion in over-the-counter medications.
+Added: Within the prescription category, Restasis recorded sales in 2019 of approximately $1.2 billion in the United States while Xiidra recorded estimated sales of $0.3 billion in the United States.
+Added: Allergic Conjunctivitis
+Added: Allergic conjunctivitis, another ocular surface disease, is an inflammatory disease of the conjunctiva resulting primarily from a reaction to allergy- causing substances such as pollen or pet dander.
+Added: The primary sign of this inflammation is redness and the primary symptom is acute itching.
+Added: Allergic conjunctivitis ranges in clinical severity from relatively mild, common forms to more severe forms that can cause impaired vision.
+Added: According to a study on the management of seasonal allergic conjunctivitis published in 2012 in the peer-reviewed journal Acta Ophthalmologica , allergic conjunctivitis affects 15% to 40% of the U.S.
+Added: The first line of defense against allergic conjunctivitis is avoidance of the allergen.
+Added: If this is not successful, physicians typically prescribe a combination of a topical mast cell stabilizer and anti-histamine.
+Added: These treatments act to reduce the signs and symptoms of the early phase allergic reaction.
+Added: For the subset of patients with chronic or more severe forms of allergic conjunctivitis, anti-histamines and mast cell stabilizers are often not sufficient to treat their signs and symptoms.
+Added: These refractory patients are frequently treated with topical corticosteroids administered by prescription eye drops.
+Added: It is estimated that up to 10 million people in the United States seek medical attention annually for the inflammatory response associated with allergic conjunctivitis caused by both seasonal and perennial allergens.
+Added: According to IMS Health data, approximately 6.1 million anti-allergy eye drop prescriptions were filled in the United States in 2020, resulting in sales of approximately $401.2 million.
+Added: The market to treat allergic conjunctivitis consists of antihistamines, mast-cell stabilizers and steroid eye drops and consists of both branded and generic products.
+Added: Branded steroids include Lotemax and Alrex (loteprednol etabonate) marketed by Bausch & Lomb, and Durezol (difluprednate) marketed by Alcon.
+Added: Commonly used generic steroids include prednisolone, dexamethasone and fluorometholone.
+Added: Pataday and Patanol formerly led the prescription market in this category but have recently been made available as over-the-counter products.
+Added: Post-Surgical Ocular Inflammation and Pain
+Added: Ocular inflammation and pain are common side effects following ophthalmic surgery.
+Added: Frequently performed ophthalmic surgeries include cataract, refractive, vitreoretinal, cornea, and glaucoma procedures.
+Added: Physicians prescribe anti-inflammatory drugs, such as corticosteroids, which are typically administered through eye drops multiple times per day, following ocular surgery as the standard of care.
+Added: These drugs improve patient comfort and also accelerate recovery through disruption of the inflammatory cascade resulting in decreased inflammation and reduced activity of the immune system.
+Added: Physicians also frequently prescribe non-steroidal anti-inflammatory drugs, or NSAIDs, as adjunctive or combination therapy to supplement the use of corticosteroids.
+Added: If left untreated, inflammation of the eye may result in further ocular complications, including pain, scarring and vision loss.
+Added: Market Scope has estimated that approximately 4.7 million ocular surgeries were to be performed in the United States in 2020, of which approximately 3.2 million are estimated to be cataract surgeries.
+Added: In 2021, Market Scope estimates 5.1 million cataract surgeries are to be performed.
+Added: We focus our sales efforts on patients covered by Medicare Part B which accounts for roughly 50% of all cataract surgeries or approximately 2 million surgeries annually.
+Added: At the current wholesale acquisition price of $538.83 per insert, we estimate that there is a near-term addressable market of approximately $1 billion per year in the surgical space.
+Added: According to IMS Health data, approximately 17.7 million prescriptions were filled in the United States in 2020 for anti-inflammatory drugs administered by prescription eye drops for ocular diseases and conditions, resulting in sales of approximately $4.3 billion.
+Added: These prescriptions consisted of approximately 7.4 million prescriptions and $580.0 million in sales for single-agent corticosteroids, 2.8 million prescriptions and $293.4 million in sales for NSAIDs, 3.7 million prescriptions and $262.7 million in sales for corticosteroid and antibiotic combination products and approximately 3.6 million prescriptions and $2.9 billion in sales of Restasis and Xiidra for dry eye disease.
+Added: The Use of Eye Drops and its Limitations
Eye drops are widely used to deliver medications directly to the ocular surface and to intraocular tissue in the front of the eye.
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As a result of these limitations, eye drops are often suboptimal as a therapeutic option for the treatment of many diseases and conditions of the front of the eye .
−Removed: Back-of-the-Eye Diseases and Conditions
−Removed: There are a range of back-of-the-eye diseases and conditions that adversely affect vision.
−Removed: One of the principal back-of-the-eye conditions is wet AMD, a serious disease of the central portion of the retina, known as the macula that is responsible for detailed central vision and color perception.
−Removed: Wet AMD is characterized by abnormal new blood vessel formation, referred to as neovascularization, which results in blood vessel leakage and retinal distortion.
−Removed: If untreated, neovascularization in wet AMD patients typically results in formation of a scar under the macular region of the retina.
−Removed: The current standard of care for wet AMD are drugs that target VEGF, one of several proteins involved in neovascularization.
−Removed: Wet AMD is the leading cause of blindness in people over the age of 55 in the United States and the European Union.
−Removed: According to a study on the burden of AMD published in 2006 in the peer-reviewed journal Current Opinion in Ophthalmology , approximately 1.2 million people in the United States suffer from wet AMD.
−Removed: In addition, AMD Alliance International reported that approximately 200,000 new cases of wet AMD arise each year in the United States.
−Removed: The incidence of wet AMD increases substantially with age, and we expect that the number of cases of wet AMD will
−Removed: increase with growth of the elderly population in the United States.
−Removed: The anti-VEGF market for the treatment of wet AMD consists predominantly of three drugs that are approved for marketing and primarily prescribed for the treatment of wet AMD;
−Removed: Lucentis marketed in the United States by Genentech;
−Removed: Eylea marketed in the United States by Regeneron;
−Removed: Beovu marketed in the United States by Novartis;
−Removed: Avastin, a cancer treatment drug, marketed by Genetech, is also used off-label for wet AMD.
−Removed: In 2019, sales of Lucentis and Eylea totaled approximately $6.5 billion in the United States and $11.4 billion globally.
−Removed: Because eye drops are unable to carry effective drug concentrations to the back-of-the-eye, intravitreal injections or oral medications are used to deliver medications to this location.
−Removed: However, the frequency of intravitreal injection can be a significant burden on patients, caregivers and clinicians.
−Removed: For example, the current treatment protocol for wet AMD involves monthly or bi-monthly injections.
−Removed: Intravitreal injections can lead to patient discomfort, a transient increase in IOP, and ocular inflammation and infection.
−Removed: Although serious adverse event rates after treatment with anti-VEGF compounds are low, intravitreal injections can result in severe complications and damage to the retina and other structures of the eye, such as ocular hemorrhage and tears in the retinal pigment epithelium.
+Added: Challenges of Back-of-the-Eye Injections
+Added: An intravitreal injection is a procedure to place a medication directly into the space in the back of the eye called the vitreous cavity, which is filled with a jelly-like fluid called the vitreous humor gel.
+Added: The procedure is usually performed by a trained retina specialist in the office setting.
+Added: Intravitreal injections are used to administer medications to treat a variety of chronic conditions;
+Added: wet AMD, DME and RVO are among the most common conditions treated with intravitreal anti-VEGF drugs.
+Added: Anti-VEGF drugs and steroids help to reduce fluid leakage associated with these disorders.
+Added: While anti-VEGF treatment regimens can be very effective therapies, there are a number of significant drawbacks, driven primarily by the frequency of injections that typically range from every six to eight weeks.
+Added: The actual injection at the time of administration is uncomfortable for patients and can be a deterrent in terms of compliance.
+Added: Then there is the burden to both patients and their caregivers of regular office visits.
+Added: These patients may not be mobile enough to travel to the office on their own and therefore require not only the assistance of a caregiver but also transportation to and from the office.
+Added: And finally, while intravitreal injections are typically safe, there is the potential risk of endophthalmitis (infection in the eye), inflammation, bleeding into the vitreous gel and retinal detachment that comes with injections.
+Added: As a result of these limitations, there is a significant unmet need for technologies that will allow for a longer duration of effect and an overall reduced number of injections.
Ocular Wound Closure
According to the World Health Organization, cataracts are the leading cause of visual impairment eventually progressing to blindness.
−Removed: According to the American Academy of Ophthalmology Cataract and Anterior Segment Panel’s 2011 Preferred Practice Pattern Guidelines, cataract extraction is the most commonly performed eye surgery in the United States.
−Removed: Market Scope has estimated that in 2019 there were to be approximately 4.3 million cataract extractions performed in the United States.
+Added: According to the American Academy of Ophthalmology Cataract and Anterior Segment Panel’s 2011 Preferred Practice Pattern Guidelines, cataract extraction is the most commonly performed eye surgery in the United States.
+Added: Market Scope has estimated that in 2019 there were approximately 4.0 million cataract extractions performed in the United States.
A cataract is a clouding of the lens inside the front of the eye.
−Removed: During cataract surgery, a patient’s cloudy natural lens is removed and replaced with a prosthetic intraocular lens.
+Added: During cataract surgery, a patient’s cloudy natural lens is removed and replaced with a prosthetic intraocular lens.
Clear corneal incision that allows entry to the eye is the typical method for performing cataract surgery.
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However, sutures do not completely prevent fluid leakage, are time-consuming to place and have been associated with patient discomfort, corneal distortion, and shallowing of the interior chamber.
−Removed: An additional visit may be required to remove sutures, thus adding time, inconvenience and expense to the surgical process.
Sutures may also lead to astigmatism, a distortion of the cornea.
+Added: An additional visit may be required to remove sutures, thus adding time, inconvenience and expense to the surgical process.
These shortcomings limit the use of sutures in ophthalmic surgery.
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We apply our expertise with an established bioresorbable hydrogel technology to the development of products for local programmed-release of known, FDA-approved therapeutic agents for a variety of ophthalmic diseases and conditions and to ophthalmic wound closure.
−Removed: Our founders used this same hydrogel technology to develop FDA-approved and currently marketed medical products for other companies such as SpaceOAR (marketed by Boston Scientific, Inc.), a hydrogel spacer used to reduce a common and debilitating side effect that men may experience after receiving prostate cancer radiotherapy;
−Removed: DuraSeal Dural Sealant ®
−Removed: (marketed by Integra Lifesciences, Inc.), a sealant for cranial and spine surgery, and Mynx ®
−Removed: (marketed by Cardinal Health), a sealant for femoral artery punctures after angiography and angioplasty.
Our bioresorbable hydrogel technology is based on the use of a proprietary form of PEG.
Our technical capabilities include a deep understanding of the polymer chemistry of PEG-based hydrogels and the design of the highly specialized manufacturing processes required to achieve a reliable, preservative-free and pure product.
−Removed: We tailor the
−Removed: hydrogel to act as a vehicle for local programmed-release drug delivery to the eye and as an ocular tissue sealant.
−Removed: We have used bioresorbable hydrogels to engineer each of our intracanalicular insert product candidates, our intracameral implant product candidates, ReSure Sealant and our intravitreal implant product candidates.
+Added: We tailor the hydrogel to act as a vehicle for local programmed-release drug delivery to the eye and as an ocular tissue sealant.
We create our hydrogels by cross-linking PEG molecules to form a network that resembles a three-dimensional mesh on a molecular level.
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The figure below depicts the formation and bioresorption of the hydrogel for ReSure Sealant.
−Removed: Intracanalicular Insert-Based Local Programmed-Release Therapies for Front-of-the-Eye Diseases and Conditions
+Added: Intracanalicular Inserts
A punctum is a natural opening located in the inner portion of the eyelid near the nose.
There is a punctum in each of the lower eyelids and the upper eyelids.
−Removed: The puncta open into nasolacrimal ducts, which collect and drain tears produced by the eyes’
−Removed: lacrimal glands.
+Added: The puncta open into nasolacrimal ducts, which collect and drain tears produced by the eyes’ lacrimal glands.
Tears produced in the lacrimal glands sweep across the eye surface and drain through the puncta to the nasal cavity.
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We provide the intracanalicular insert as a thin dry rod to facilitate insertion through the narrow punctal opening.
−Removed: Upon hydration with tear fluid, the insert swells, softens, and conforms to roughly the size and shape of the vertical
−Removed: canaliculus, to secure it in place.
+Added: Upon hydration with tear fluid, the insert swells, softens, and conforms to roughly the size and shape of the vertical canaliculus, to secure it in place.
We incorporate the active pharmaceutical ingredient in the form of micronized particles embedded directly in the hydrogel or as bioresorbable microspheres.
−Removed: We have included a fluorescent label, or marker, in our intracanalicular insert hydrogel to serve as a visualization aid for the healthcare professional to confirm the insert’s presence.
+Added: We have included a fluorescent label, or marker, in our intracanalicular insert hydrogel to serve as a visualization aid for the healthcare professional to confirm the insert’s presence.
The viewer applies a blue handheld light and a clear yellow filter aid to see the insert in the eyelid as shown in the figure below.
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Our active pharmaceutical ingredient selection criteria include:
−Removed: prior approval by the FDA for the targeted ophthalmic indication;
+Added: ● prior approval by the FDA for the targeted ophthalmic indication, except for our OTX-TKI program in which the active pharmaceutical ingredient, axitinib, is not currently approved for an ophthalmic indication;
● expiration of relevant patent protection prior to or within our anticipated development timeline;
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● compatibility with our drug delivery system.
−Removed: Anticipated Benefits of Our Intracanalicular Inserts, Intracameral Implants and Intravitreal Implant Compared to Eye Drops
−Removed: We believe our intracanalicular insert, intracameral implants and intravitreal implant product candidates may offer a range of favorable attributes as compared to eye drops, including:
+Added: We believe our intracanalicular insert, intracameral implant and intravitreal implant product candidates may offer a range of favorable attributes as compared to eye drops and immediate release back-of-the-eye injections, including:
● Improved patient compliance .
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We have designed our inserts and implants to deliver drug in a programmed fashion in order to avoid the peak and valley dosing and related side effects and spikes in IOP associated with eye drops.
−Removed: We also believe programmed-release dosing may improve the therapeutic profile of the active pharmaceutical ingredient because it eliminates periods of little or no drug presence between eye drop administrations.
−Removed: Further, we are designing our product candidates so that their drug release profiles can be tailored or programmed to match the treatment needs of the disease.
+Added: We also believe programmed-release dosing may improve the therapeutic profile of the active pharmaceutical ingredient because it eliminates periods of little or no drug presence between eye drop or back of the eye injection administrations.
+Added: Further, we are designing our products and product candidates so that their drug release profiles can be tailored or programmed to match the treatment needs of the disease.
For example, steroids for ophthalmic purposes generally require administration over four weeks, with tapered dosing over this period.
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Our inserts and implants do not involve the use of preservatives, such as BAK, which have been linked to side effects including burning, stinging, hyperemia, irritation, eye dryness and, less frequently, conjunctivitis or corneal damage.
−Removed: Intravitreal Implants for Back-of-the-Eye Diseases and Conditions
+Added: Intracameral Implants
+Added: We are engaged in the clinical development of our hydrogel administered via intracameral injection to address retinal diseases.
+Added: Intracameral implants refer to biodegradable or bioresorbable implants placed into the anterior chamber or front of the eye for the treatment of ocular conditions.
+Added: The implants are designed to be held in place by currents and gravity present in the anterior chamber of an eye.
+Added: As an example, in the case of OTX-TIC, the implant is designed to infuse with
+Added: liquid, settle into the inferior angle of the eye and demonstrate little to no movement.
+Added: The implants are preferably polymeric, biodegradable and provide sustained release of at least one therapeutic agent to both the trabecular meshwork and associated ocular tissue and the fluids within the anterior chamber of an eye.
+Added: Intravitreal Implants
We are engaged in the clinical development of our hydrogel administered via intravitreal injection to address the large and growing markets for diseases and conditions of the back of the eye.
−Removed: Our initial development efforts are focused on the use of our programmed-release hydrogel in combination with anti-angiogenic drugs such as protein-based anti-VEGF drugs or small molecule drugs, such as TKIs for the treatment of retinal diseases, including wet AMD , retinal
−Removed: vein occlusion and diabetic macular edema.
−Removed: Our initial goal for these programs is to provide extended delivery of a protein-based large molecule or small molecule TKI drug targeting VEGF and other targets over a four to six month period following administration of a bioresorbable hydrogel incorporating the drug by an injection into the vitreous humor, thereby reducing the frequency of the current monthly or bi-monthly intravitreal injection regimen for wet AMD and other retinal diseases and potentially providing a more consistent, uniform release of drug over the treatment period.
−Removed: We are pursuing a multi-pronged strategy to seek to maximize the potential of this technology.
−Removed: We are researching the delivery of small molecule TKIs from our hydrogel implant and we initiated an open-label, proof-of-concept Phase 1 clinical trial i n Australia in the first quarter of 2019.
−Removed: This clinical trial is a multi-center, open-label study designed to evaluate the safety, durability and tolerability of OTX-TKI for up to nine months.
−Removed: We have conducted preclinical work on this compound and have achieved local programmed-release and pharmacodynamic effect in vivo for up to twelve months.
−Removed: We believe this class of drugs is well suited for use with our platform given its high potency, multi-target capability, and compatibility with a hydrogel vehicle.
−Removed: In the absence of a sophisticated drug delivery system, these drugs have been difficult to deliver to the eye for acceptable time frames at therapeutic levels without causing local and systemic toxicity due to low drug solubility and very little short half-lives in solution.
−Removed: We believe our local drug delivery technology gives us potential advantages in this regard.
−Removed: By selecting a compound that is compatible with our hydrogel platform technology and that will have expiration of relevant patents within the timeline of our development program, we avoid the need to license the TKI molecule, thus retaining full worldwide rights to any products we develop.
−Removed: We are a lso evaluating an intravitreal implant through our collaboration with Regeneron, consisting of a PEG-based hydrogel matrix containing embedded micronized particles of aflibercept.
−Removed: Aflibercept is marketed by Regeneron under the brand name Eylea.
−Removed: We designed the injection to be delivered to the vitreous chamber of the eye using a fine gauge needle.
−Removed: We entered into the Collaboration Agreement with Regeneron in October 2016 for the development and commercialization of protein-based anti-VEGF drugs, with the initial product candidate incorporating the drug aflibercept into our hydrogel.
−Removed: As previously discussed, we are currently in discussions with Regeneron regarding the development of an alternative formulation of a proposed product candidate.
−Removed: Our intravitreal implant consists of a PEG-based hydrogel suspension, which contains embedded micronized protein particles of an anti-angiogenic compound.
+Added: Our intravitreal implant product candidates consist of a PEG-based hydrogel suspension, which contains embedded micronized particles of active drug.
We designed the intravitreal implant to be injected and retained in the vitreous humor, as depicted in the figure below, to provide local programmed-release intravitreal delivery of anti-VEGF compounds.
+Added: Our initial intravitreal implant development efforts are focused on the use of our programmed-release hydrogel in combination with anti-angiogenic compounds such as protein-based anti-VEGF drugs or small molecule drugs, such as TKIs, for the treatment of retinal diseases, including wet AMD, RVO and DME.
+Added: Our initial goal for these programs is to provide extended delivery of a protein-based large molecule or small molecule TKI targeting VEGF and other indications over a six-month period or longer following administration of a bioresorbable hydrogel incorporating the drug by an injection into the vitreous humor.
+Added: This approach would reduce the frequency of the current monthly or bi-monthly intravitreal injection regimen for wet AMD and other retinal diseases and potentially provide a more consistent, uniform release of drug over the treatment period.
+Added: We believe TKIs are well suited for use with our platform given their high potency, multi-target capability, and compatibility with a hydrogel vehicle.
+Added: In the absence of a sophisticated drug delivery system, these drugs have been difficult to deliver to the eye for acceptable timeframes at therapeutic levels without causing local and systemic toxicity due to low drug solubility and notably short half-lives in solution.
+Added: We believe our local drug delivery technology gives us potential advantages in this regard.
We have designed our intravitreal implant for delivery using typically available syringes and fine gauge needles compatible with the current standard of care.
−Removed: Once in the vitreous humor, the hydrogel is designed to retain properties of TKI and anti-VEGF compounds until they are released.
−Removed: We have designed the hydrogel to liquefy, dissolve and be
−Removed: cleared from the eye through hydrolysis over time.
+Added: Once in the vitreous humor, the hydrogel is designed to retain properties of
+Added: TKI and anti-VEGF compounds until they are released.
+Added: We have designed the hydrogel to liquefy, dissolve and be cleared from the eye through hydrolysis over time.
We design our hydrogels to control the hydrogel biodegradation rate and, as a result, the timing of TKI and anti-VEGF compound release.
+Added: By selecting a compound that is compatible with our hydrogel platform technology and that will have expiration of relevant patents within the timeline of our development program, we avoid the need to license the TKI molecule, thus retaining full worldwide rights to any products we develop.
+Added: Suprachoroidal Injections
+Added: The suprachoroidal space, which we refer to as the SCS, is a potential space between the sclera and choroid that traverses the circumference of the posterior segment of the eye.
+Added: The SCS is believed to be an attractive site for drug delivery because drugs are able to target the choroid, retinal pigment endothelium and retina with high bioavailability while maintaining low levels of drug elsewhere in the eye.
ReSure Sealant for Ocular Wound Closure
−Removed: ReSure Sealant is our bioresorbable hydrogel product for wound closure following cataract surgery.
+Added: ReSure Sealant is our bioresorbable hydrogel device for wound closure following cataract surgery.
A surgeon applies ReSure Sealant as a liquid painted onto the corneal incision.
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In the pivotal clinical trials that formed the basis for FDA approval, ReSure Sealant provided superior wound closure and a better safety profile than sutured closure.
−Removed: We commercially launched ReSure Sealant in February 2014 on a region-by-region basis in the United States through a network of independent distributors.
−Removed: In early 2017, we terminated these distributors and hired a contract sales force of four representatives to sell ReSure Sealant.
−Removed: In July 2017, in connection with a broader reduction in force, we terminated these representatives.
−Removed: At this time, we have no sales support provided to ReSure Sealant.
−Removed: In the future we may have our currently deployed Key Account Managers carry the product along with DEXTENZA.
−Removed: We also believe that the market opportunity for a surgical sealant following cataract surgery may be modest because sutures are used in a minority of cataract surgeries and, currently, there is no direct reimbursement for ReSure Sealant.
−Removed: As a result, we do not expect to generate meaningful levels of revenue from the sale of ReSure in 2020.
Development Pipeline and Marketed Products
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Product / Program
+Added: Preclinical Stage Product Candidates
+Added: Wet AMD, DME and RVO
+Added: Suprachoroidal implant (Aflibercept)
+Added: In collaboration with corporate partner Regeneron.
+Added: Early-Stage Clinical Product
+Added: Intravitreal implant (Axitinib)
+Added: Australian Phase 1 clinical trial ongoing.
+Added: Plan to initiate Phase 1 trial in the United States under eIND in Q2 2021.
+Added: Plan to initiate a Phase 2 clinical trial in Australia, pending the receipt and review of topline data from the Phase 1 clinical trial in Australia.
+Added: Glaucoma or ocular hypertension
+Added: Intracameral implant (Travoprost)
+Added: Phase 1 clinical trial ongoing.
+Added: Plan to commence Phase 2 clinical trial mid-2021.
+Added: Treatment of dry eye disease
+Added: Intracanalicular insert (Cyclosporine)
+Added: Phase 2 clinical trial ongoing;
+Added: topline data anticipated in Q4 2021.
+Added: Short-term treatment of signs and symptoms of dry eye disease
+Added: Intracanalicular insert (Dexamethasone)
+Added: Commenced Phase 2 clinical trial in first quarter 2021;
+Added: topline data anticipated in first half 2022.
+Added: Late Stage Clinical Product
+Added: Allergic conjunctivitis
+Added: Intracanalicular insert (Dexamethasone)
+Added: PDUFA target action date of October 18, 2021.
Approved Product
1 unchanged sentence
Intracanalicular insert (Dexamethasone)
−Removed: Approved by the FDA in November 2018 for post-surgical pain and approved by the FDA in June 2019 for inflammation;
−Removed: product commercially launched in July 2019 upon the receipt of a C-code for transitional pass through payment;
−Removed: permanent J-Code became effective as of October 1, 2019.
+Added: Product commercially launched in the United States in July 2019.
ReSure Sealant
1 unchanged sentence
Ocular sealant
−Removed: Approved by the FDA in January 2014;
−Removed: commercially launched in the United States in February 2014.
−Removed: In October 2018, we received a FDA warning letter that we appealed in November 2018.
−Removed: The appeal was rejected in December 2018.
−Removed: In December 2019, we submitted a post-approval study protocol.
−Removed: We received further feedback in February 2020 from FDA and responded in March 2020.
−Removed: Late Stage Clinical Product
−Removed: (Active Pharmaceutical
−Removed: Product / Program
−Removed: Allergic conjunctivitis
−Removed: Intracanalicular insert (Dexamethasone)
−Removed: Phase 2 trial completed in November 2014;
−Removed: topline results from the two Phase 3 trials;
−Removed: first Phase 3 trial reported in October 2015 and second Phase 3 trial reported in June 2016;
−Removed: a third Phase 3 trial commenced in the second half of 2019, is fully enrolled as of January 2020 and topline results are expected in the second quarter 2020.
−Removed: Episodic dry eye disease
−Removed: Intracanalicular insert (Dexamethasone)
−Removed: Results of Phase 2 trial reported in December 2015;
−Removed: Phase 3 clinical and regulatory pathways identified;
−Removed: advancement subject to available capital
−Removed: Intracanalicular insert (Travoprost)
−Removed: Phase 2a trial completed in May 2014;
−Removed: Phase 2b topline results reported in October 2015;
−Removed: topline data from the first Phase 3 trial reported in May 2019;
−Removed: the FDA determined that the data was not clinically meaningful in September 2019, program not anticipated to move forward without a corporate partner.
−Removed: Early Stage Clinical Product
−Removed: Glaucoma and ocular hypertension
−Removed: Intracameral implant (Travoprost)
−Removed: Initiated Phase 1 clinical trial in the first half of 2018 in the U.S.
−Removed: with initial results from cohort 1 reported in April 2019 and initial results from cohort 2 reported in February 2020.
−Removed: Topline data from cohorts three and four expected in the second half of 2020.
+Added: Product commercially launched in the United States in February 2014.
+Added: Retinal Disease Programs
+Added: OTX-TKI (axitinib intravitreal implant)
+Added: Our current intravitreal implant development efforts are focused on the use of our sustained-release hydrogel in combination with anti-angiogenic compounds, including anti-VEGF compounds, for the treatment of wet AMD.
+Added: initial implants have delivered anti-VEGF compounds in vitro over our targeted four to six month period, which we believe could make it possible to reduce the frequency of the current monthly or bi-monthly intravitreal injection regimen for wet AMD.
+Added: In addition, our preclinical studies demonstrated a sustained pharmacodynamic effect in vivo of over six months with a small molecule TKI.
+Added: We believe axitinib is well suited for use with our platform given its high potency, multi-target capability, and compatibility with a hydrogel vehicle.
+Added: In the absence of a sophisticated drug delivery system, TKIs have been difficult to deliver to the eye for acceptable time frames at therapeutic levels without causing local and systemic toxicity due to low drug solubility and very short half-lives in solution.
+Added: We believe our local programmed-release drug delivery technology gives us potential advantages in this regard.
+Added: In Vitro and preclinical results
+Added: We have conducted in vivo pharmacokinetic and pharmacodynamic studies with hydrogels loaded with axitinib injected intravitreally.
+Added: Pharmacokinetic data showed retinal tissue drug concentrations in excess of 3,000 times the published concentration needed to inhibit VEGF by 50% after six months and pharmacodynamic results show sustained efficacy for six months.
+Added: Phase 1 clinical development
+Added: We are conducting an open-label, proof-of-concept Phase 1 clinical trial of OTX-TKI for the treatment of patients with neovascular age related macular degeneration, or wet AMD, caused by excessive blood vessel growth in the back of the eye due to VEGF.
+Added: OTX-TKI is a bioresorbable hydrogel implant incorporating axitinib that is designed to be delivered via intravitreal injection into the vitreous humor of the eye and has an initial target duration of drug release for approximately six to nine months.
+Added: Preclinical studies to date have demonstrated suppression of vascular leakage and good pharmacokinetics in the relevant ocular tissues.
+Added: The Phase 1 clinical trial was submitted to the Therapeutic Goods Administration, Australia’s regulatory authority for therapeutic goods, in July 2018.
+Added: In the first quarter of 2019, we began dosing subjects in a Phase 1 clinical trial in Australia.
+Added: This clinical trial is a prospective, multi-center, open-label, does escalation study designed to evaluate the safety, durability, tolerability, and biological activity of OTX-TKI.
+Added: We are evaluating biological activity by following visual acuity over time and measuring retinal thickness using standard optical coherence tomography, or OCT.
+Added: Two cohorts have been enrolled, a lower dose cohort of 200 μg of six subjects and a higher dose cohort of 400 μg of seven subjects.
+Added: In the first two fully enrolled cohorts, OTX-TKI was generally well tolerated and observed to have a favorable safety profile with no ocular serious adverse events noted.
+Added: In the higher dose cohort, OTX-TKI showed a decrease in central subfield retinal thickness as measured by mean change in central subfield thickness values by decreases in intraretinal and/or subretinal fluid in some subjects.
+Added: We amended our clinical trial protocol to enroll two additional cohorts, cohort 3a consisting of six patients being administered a 600 µg dose and cohort 3b consisting of six patients being administered a 400 µg dose plus an induction injection of the anti-VEGF drug aflibercept.
+Added: Cohort 3a is fully enrolled and patients are being monitored while cohort 3b is still enrolling.
+Added: In February, interim data from this Phase 1 clinical trial of OTX-TKI was presented at the Angiogenesis, Exudation and Degeneration 2021 Virtual conference hosted by the Bascom Palmer Eye Institute, University of Miami Health System.
+Added: We believe that OTX-TKI has demonstrated a preliminary signal of biological activity as observed by a clinically-meaningful decrease in retinal fluid as measured by high resolution OCT that provides cross-sectional images of the anatomical structure of the retina.
+Added: As observed in cohort 2 (400 µg dose) and cohort 3a (600 µg dose), some subjects showed a decrease in intraretinal or subretinal fluid by two months after injection.
+Added: In cohort 3b (400 µg dose plus anti-VEGF induction injection of aflibercept), two subjects were observed to have a decrease in intraretinal and/or subretinal fluid as early as a week after injection.
+Added: In addition, the OTX-TKI implants in cohort 1 were observed to have biodegraded in all subjects within 9 to 10.5 months of injection.
+Added: It has also been observed that the implants are able to be adequately monitored and that there is limited to no movement of the implant in the anterior segment of the eye.
+Added: These findings are supported by the graphs below that present the mean change in central subfield thickness, or CSFT, and in best corrected visual acuity, or BCVA, across the four cohorts as well as specific patient images from cohorts 2, 3a and 3b showing declines in intraretinal and/or subretinal fluid over time.
+Added: OTX-TKI has been observed to have a favorable safety profile and be generally well-tolerated to date.
+Added: There have been no ocular serious adverse events reported.
+Added: Plasma concentrations of the active drug (axitinib) were measured to be below the limit of quantification of assay, or BLQ < 0.1 ng/ml, at all sampled time points for all patients in cohorts 1 and 2.
+Added: This assessment indicates that there is no measurable systemic exposure to axitinib.
+Added: We believe that the interim data suggests that OTX-TKI is durable and may extend the duration of action beyond several months.
+Added: As noted in the table below, 50% of cohort 1 (200 µg dose) subjects, or 3 out of 6, and 57% of cohort 2 (400 µg dose) subjects, or 4 out of 7, did not require rescue medication at or before six months post-injection.
+Added: Further, several subjects in cohort 2 demonstrated durability of therapy for over 6 months and one subject demonstrated
+Added: durability out to 13.5 months without rescue.
+Added: In cohort 3a, one subject has demonstrated durability of therapy up to six months so far.
+Added: Follow-up remains ongoing for all cohorts.
+Added: Planned Phase 1 Clinical Trial (United States)
+Added: We also plan to initiate a randomized, masked Phase 1 clinical trial of up to 20 subjects in the United States under an eIND application in mid-2021 to evaluate 15 subjects dosed with a 600 µg dose of OTX-TKI in comparison to 5 subjects receiving a 2 mg dose of aflibercept every eight weeks for the treatment of wet AMD, DME and RVO.
+Added: The clinical trial will evaluate biological activity, as measured by CSFT and BCVA, tolerability and durability.
+Added: We have requested a pre-IND meeting with the FDA to discuss a possible plan to transition from an eIND application to a traditional IND application.
+Added: Planned Phase 2 Clinical Trial (Australia)
+Added: Pending our receipt and review of the topline data from the Phase 1 clinical trial in Australia and related regulatory discussions, we plan to initiate a Phase 2 clinical trial in Australia to compare the administration of a single dose of 600 µg OTX-TKI in combination with an anti-VEGF induction injection of a 2 mg dose of aflibercept, a current standard of care anti-VEGF therapy, to a 2mg dose of aflibercept alone as the comparator.
+Added: The Phase 2 clinical trial is anticipated to include approximately 100 subjects with wet AMD but who have responded to current standard of care anti-VEGF treatment and currently show an absence of fluid.
+Added: The Phase 2 clinical trial will be designed to evaluate efficacy, as measured by CSFT and BCVA, tolerability and durability.
+Added: Regulatory Pathway
+Added: If we receive positive data from the Phase 1 clinical trial in the United States, we plan to initiate a Phase 2 clinical trial and two Phase 3 clinical trials in the United States for the treatment of wet AMD, DME and RVO.
+Added: If our development efforts are successful, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
+Added: See “—Government Regulation—Section 505(b)(2) NDAs” for additional information.
+Added: OTX-AFS (aflibercept suprachoroidal implant) in Collaboration with Regeneron
+Added: Regeneron Collaboration Agreement
+Added: In October 2016, we entered into a strategic collaboration, option and license agreement with Regeneron for the development and potential commercialization of products using our extended-delivery hydrogel formulation in combination with Regeneron’s large molecule VEGF-targeting compounds for the treatment of retinal diseases, with the initial focus on the VEGF trap aflibercept, currently marketed under the brand name Eylea.
+Added: We and Regeneron amended this agreement in May 2020 to, among other things, transition joint efforts under the collaboration to the research and development of an extended-delivery formulation of aflibercept to be delivered to the suprachoroidal space.
+Added: We refer to the collaboration, option and license agreement, as amended to date, as the Collaboration Agreement.
+Added: Under the terms of the Collaboration Agreement, we granted Regeneron an option, or the Option, to enter into an exclusive, worldwide license under our intellectual property to develop and commercialize products using our hydrogel in combination with Regeneron’s large molecule VEGF-targeting compounds, or Regeneron Licensed Products.
+Added: The Collaboration Agreement does not cover the development of any products that deliver small molecule drugs, including TKIs, for any target including VEGF, or any products that deliver large molecule drugs other than those that target VEGF proteins.
+Added: Under the terms of the Collaboration Agreement, we and Regeneron agreed to conduct a joint research program with the aim of developing an extended-delivery formulation of aflibercept that is suitable for advancement into clinical development.
+Added: Regeneron has agreed to pay our personnel and material costs of ours for specified preclinical development activities in connection with the revised workplan, as well as costs of certain specialty equipment.
+Added: Under the terms of the Collaboration Agreement, Regeneron is responsible for funding an initial preclinical tolerability study.
+Added: If the Option is exercised, Regeneron will be obligated to conduct further preclinical development and an initial clinical trial under a collaboration plan.
+Added: We are obligated to reimburse Regeneron for certain development costs during the period through the completion of the initial clinical trial, subject to a cap of $25 million, which cap may be increased by up to $5 million under certain circumstances.
+Added: We do not expect our funding requirements under the collaboration to be material over the next twelve months.
+Added: If Regeneron elects to proceed with further development beyond the initial clinical trial, it will be solely responsible for conducting and funding further development and commercialization of product candidates.
+Added: If the Option is exercised, Regeneron is required to use commercially reasonable efforts to research, develop and commercialize at least one Regeneron Licensed Product.
+Added: Such efforts shall include initiating the dosing phase of a subsequent clinical trial within specified time periods following the completion of the first-in-human clinical trial or the initiation of preclinical toxicology studies, subject to certain extensions.
+Added: Under the terms of the Collaboration Agreement, Regeneron has agreed to pay us $10 million upon exercise of the Option.
+Added: If Regeneron elects to exercise the Option, we are also eligible to receive up to $145 million per Regeneron Licensed Product upon the achievement of specified development and regulatory milestones, including successful results from the first-in-human clinical trial;
+Added: $100 million per Regeneron Licensed Product upon first commercial sale of such Regeneron Licensed Product;
+Added: and up to $50 million based on the achievement of specified sales milestones for all Regeneron Licensed Products.
+Added: In addition, we are entitled to tiered, escalating royalties, in a range from a high-single digit to a low-to-mid teen percentage of net sales of Regeneron Licensed Products.
+Added: As amended, the Option is exclusive for twenty-four months following May 8, 2020.
+Added: The field of the potential license remains limited to Regeneron Licensed Products delivered by local administration to or around the eye for diagnostic, therapeutic, or prophylactic purposes relating to ophthalmic diseases or conditions.
+Added: The Collaboration Agreement will automatically terminate upon the failure of Regeneron to conduct or complete certain preclinical activities within specified timeframes or provide required notices regarding such certain preclinical activities to us, in each case subject to specified exceptions, unless Regeneron exercises its Option, the matter has been referred to the joint research committee, or the parties have otherwise agreed in writing.
+Added: The Agreement will also terminate if Regeneron has not exercised its Option prior to the expiration of the Option Period.
+Added: If Regeneron has timely exercised its Option, the Collaboration Agreement will expire on a Regeneron Licensed Product-by-Regeneron Licensed Product and country-by-country basis upon the expiration of the later of 10 years from the date of first commercial sale in such country or the expiration of all patent rights covering a Regeneron Licensed Product in such country.
+Added: We have agreed to grant Regeneron a fully paid-up, non-exclusive license to continue to develop and commercialize the Regeneron Licensed Products following expiration.
+Added: The Collaboration Agreement is terminable by Regeneron at its convenience, for any or all of the Regeneron Licensed Products, upon prior written notice.
+Added: Either party may, subject to a
+Added: cure period, terminate the Collaboration Agreement in the event of the other party’s uncured material breach, in addition to other specified termination rights.
+Added: Glaucoma Program
+Added: OTX-TIC (travoprost intracameral implant)
+Added: Our development efforts for our glaucoma program have focused on the use of our extended-delivery hydrogel in combination with travoprost, an FDA-approved prostaglandin analog designed to lower elevated IOP.
+Added: Our product candidate OTX-TIC is a bioresorbable hydrogel implant incorporating travoprost that is designed to be administered by a physician as an intracameral injection into the anterior chamber of the eye with an initial target duration of drug release of four to six months.
+Added: In Vitro and Preclinical results
+Added: Preclinical studies to date have demonstrated clinically meaningful IOP lowering and good pharmacokinetics in the aqueous humor.
+Added: Phase 1 clinical development
+Added: We are conducting a prospective, multi-center open-label, dose-escalation proof-of-concept Phase 1 clinical trial of OTX-TIC in the United States that we initiated in the second quarter of 2018 for the treatment of patients with moderate to severe glaucoma or ocular hypertension.
+Added: The clinical trial is designed to evaluate the safety, biological activity, durability and tolerability of OTX-TIC compared to topical travoprost (daily eye drops) in patients with open-angle glaucoma or ocular hypertension.
+Added: The clinical trial consists of four patient cohorts:
+Added: cohort 1 is 5 subjects who are receiving a 15 µg dose, cohort 2 is 4 subjects who are receiving a 26 µg dose, cohort 3 is 5 subjects who are receiving a 15 µg dose with a fast-degrading implant, and cohort 4 is 5 subjects who are receiving a 5 µg dose with a fast-degrading implant.
+Added: We presented initial results from the first cohort, comprised of five patients, in this clinical trial at the Association of Research and Vision of Ophthalmology (ARVO) meeting in April 2019 and the American Society of Cataract and Refractive Surgery annual meeting in May 2019.
+Added: This data demonstrated that, with a single implant, subjects were able to achieve IOP lowering for up to thirteen months at a level at least as good as standard of care topical eye drop that was placed in each subject’s non-study eye.
+Added: In addition, the hydrogel carrier, as designed, biodegraded in five to seven months.
+Added: There were no clinically meaningful changes in corneal health as measured by endothelial cell evaluation and corneal pachymetry.
+Added: Several subjects reported low-grade inflammation and peripheral anterior synechiae that we believe may be addressable with modifications to the implants.
+Added: At the Glaucoma360 2021 Virtual Conference, we presented interim results, presented below, from all four patient cohorts in the Phase 1 clinical trial.
+Added: We believe that OTX-TIC shows potential as a sustained-release therapy with a long duration of action.
+Added: OTX-TIC has demonstrated a clinically meaningful mean change from baseline as measured by IOP at 8:00 am, 10:00 am and 4:00 pm comparable to topical travoprost therapy as early as two days following injection across all four cohorts.
+Added: With regard to duration, three out of five subjects (60%) in cohort 1 and four out of four subjects (100%) in cohort 2 exhibited duration of IOP-lowering effect comparable to travoprost therapy at six months.
+Added: Two out of five subjects (40%) in cohort 3 and one out of 2 subjects (50%) in cohort 4 assessed to date exhibited duration of IOP-lowering effect comparable to travoprost at six months.
+Added: The OTX-TIC implant was observed to biodegrade in between five and seven months in cohorts 1 and 2.
+Added: In cohorts 3 and 4, the fast-degrading implants biodegraded between three and five months.
+Added: Within all four cohorts, implants were not observed to move when viewed with a slit lamp biomicroscope and were visible at all examinations in all patients using gonioscopy.
+Added: Corneal health as measured by endothelial cell counts, pachymetry assessments, and slit lamp examinations indicated no clinically meaningful changes from baseline in any of the four cohorts.
+Added: IOP elevation were observed in three subjects in cohort 3 at the approximate time of the implant resorption.
+Added: Planned Phase 2 Clinical Trial
+Added: In mid-2021, we plan to initiate a Phase 2 clinical trial to evaluate formulations of OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension in patients.
+Added: Certain subjects in the Phase 2 clinical trial will receive the same formulation used in cohort 1 of the Phase 1 clinical trial, containing a 26 µg dose of drug and utilizing a standard implant, and others will receive the same formulation used in cohort 4 of the Phase 1 clinical trial, containing a 5 µg dose of drug and utilizing a fast-degrading implant.
+Added: The Phase 2 clinical trial will be a randomized, double-masked, active-controlled study with a total of approximately 105 subjects between three arms of approximately 35 subjects each.
+Added: The control arm will receive an injection of Durysta™.
+Added: The non-study eye of each patient will receive topical prostaglandin daily.
+Added: The trial will evaluate IOP changes from baseline among other endpoints.
+Added: Regulatory Pathway
+Added: If our planned Phase 2 clinical trial is successful, we would then be required to successfully complete two well-controlled Phase 3 clinical trials conducted under an IND to obtain marketing approval from the FDA.
+Added: If we were to obtain favorable results from these two pivotal clinical trials, we expect that we would submit an NDA to the FDA for marketing approval of OTX-TIC under Section 505(b)(2) of the FDCA.
+Added: See “—Government Regulation—Section 505(b)(2) NDAs.”
+Added: Ocular Surface Disease Programs
+Added: We are engaged in the development of formulations of our hydrogel administered via intracanalicular inserts to address large markets for diseases and conditions of the surface of the eye.
+Added: Our initial development efforts are focused on the use of our extended-delivery hydrogel in combination with well-known and well-understood corticosteroids and cyclosporine for the treatment of dry eye disease, allergic conjunctivitis and inflammation and pain following ophthalmic surgery.
Dry Eye Disease
−Removed: Ongoing preclinical studies;
−Removed: IND filed in December 2019;
−Removed: planned Phase 1 trial beginning in middle of 2020.
−Removed: Acute ocular pain
−Removed: Ongoing preclinical studies
−Removed: Post-operative pain, inflammation & antibacterial
−Removed: Besifloxicin and dexamethasone
−Removed: Ongoing preclinical studies
−Removed: (Active Pharmaceutical
−Removed: Product / Program
−Removed: Anti-angiogenic hydrogel implants
−Removed: Intravitreal implant (Tyrosine kinase inhibitor anti-angiogenic compound)
−Removed: Initiated a Phase 1 clinical trial in Australia in the second half of 2018.
−Removed: Interim data on first two cohorts reported in March 2020.
−Removed: Wet AMD DME and RVO
−Removed: Intravitreal implant (Protein-based anti-angiogenic compound)
−Removed: Under negotiation with corporate partner Regeneron to advance preclinical studies with agreed upon new formulations
−Removed: DEXTENZA ®
−Removed: (dexamethasone ophthalmic insert)
−Removed: DEXTENZA incorporates the FDA-approved corticosteroid dexamethasone as an active pharmaceutical ingredient into a hydrogel, drug-eluting intracanalicular insert.
−Removed: We are commercializing DEXTENZA for the treatment of post-surgical ocular inflammation and pain and are developing it for additional indications including ocular itching associated with allergic conjunctivitis.
−Removed: We have designed DEXTENZA to deliver therapeutic levels of dexamethasone over a period of approximately 30 days.
−Removed: The FDA approved the NDA for DEXTENZA for the treatment of post-surgical ocular pain in November 2019 and subsequently the sNDA for inflammation in June 2019.
−Removed: We have also completed two Phase 3 clinical trials for the treatment of allergic conjunctivitis with topline data reported out in 2015 and 2016, respectively.
−Removed: In the first Phase 3 clinical trial, DEXTENZA achieved the co-primary endpoint of improvement in ocular itching compared with placebo but failed to achieve on the co-primary endpoint of improvement in conjunctival redness compared with placebo, in each case, at certain prespecified timepoints.
−Removed: For the second Phase 3 trial, DEXTENZA failed to achieve the primary endpoint of improvement in ocular itching compared with placebo, at certain prespecified timepoints.
−Removed: We commenced a third Phase 3 trial for the treatment of ocular itching associated with allergic conjunctivitis in the second half of 2019.
−Removed: We have completed enrollment with topline results expected to be reported in the second quarter of 2020.
−Removed: We selected dexamethasone as the active pharmaceutical ingredient for DEXTENZA because it:
−Removed: is approved by the FDA and has a long history of ophthalmic use;
−Removed: is available on a generic basis;
−Removed: is highly potent and is typically prescribed for prevention of ocular inflammation and pain following ocular surgery;
−Removed: is available from multiple qualified suppliers;
−Removed: has physical properties that are well suited for incorporation within our hydrogel technology.
−Removed: Embedded within our DEXTENZA intracanalicular insert are dexamethasone drug particles that gradually erode and release the drug in a programmed fashion until the drug is depleted.
−Removed: As the dexamethasone drug particles erode and the hydrogel degrades by hydrolysis, the intracanalicular insert softens, liquefies and is cleared through the nasolacrimal duct.
−Removed: We provide the DEXTENZA drug product in a preservative-free formulation in a sterile, single use package.
−Removed: The standard regimen for dexamethasone eye drops following cataract surgery is an initial administration of four times daily for one week, with a gradual tapering in the number of eye drops over a four week period.
−Removed: Such a regimen is often confusing to patients as they must remember to taper the number of times per day they administer the steroid, while also taking multiple drops of other drugs, such as antibiotics and NSAIDs.
−Removed: We believe that local programmed-release of drug to the eye may result in better control of ocular inflammation and pain as compared to prescription eye
−Removed: drops and that a low dose amount may provide enhanced safety by eliminating spikes in IOP associated with high dose steroid eye drops.
−Removed: Although dexamethasone is clinically effective in the treatment of late-phase inflammatory allergic reactions, the safety limitations associated with eye drop administration, including the potential to generate spikes in IOP due to the high levels of drug, have limited its widespread adoption as a treatment for the treatment of allergic conjunctivitis.
−Removed: These spikes in IOP can lead to drug induced glaucoma, although the incidence is low.
−Removed: Further, use of oral anti-histamine medications as well as anti-histamine eye drops for allergic conjunctivitis may dry out the eye and exacerbate the discomfort to some patients.
−Removed: We believe, based on our clinical trial results to date, that periodic use of the DEXTENZA for allergic conjunctivitis could create a low, tapered, consistent dose of dexamethasone, potentially minimizing or eliminating side effects associated with the eye drop formulation, while retaining the drug’s anti-inflammatory effects.
+Added: OTX-CSI (cyclosporine intracanalicular insert)
+Added: OTX-CSI incorporates the FDA-approved immunomodulator cyclosporine as a preservative-free active pharmaceutical ingredient into a hydrogel, drug-eluting, intracanalicular insert.
+Added: The product candidate is designed for patients suffering from moderate to severe dry eye and to be administered by a physician as a bioresorbable
+Added: intracanalicular insert.
+Added: OTX-CSI is designed to release cyclosporine to the ocular surface for approximately three to four months to increase tear production for the chronic treatment of dry eye disease.
+Added: Phase 1 clinical development
+Added: We filed an IND for OTX-CSI in the United States in December 2019 and initiated a Phase 1 clinical trial in the first quarter of 2020.
+Added: The Phase 1 clinical trial was a U.S.-based, open-label, single-center trial that included five subjects (ten eyes) who were followed for approximately four months.
+Added: The study was designed to evaluate the safety, tolerability and durability of OTX-CSI and assess the biological activity by measuring signs and symptoms of dry eye disease over this time period.
+Added: On October 8, 2020, we announced topline data from our Phase 1 clinical trial evaluating OTX-CSI in the chronic treatment of dry eye disease.
+Added: All subjects completed the 16-week study period with no drop-outs.
+Added: There were no serious adverse effects reported.
+Added: The inserts were observed to be well-tolerated, and there were no adverse events of stinging, irritation, blurred vision or tearing reported or observed.
+Added: Tear production as measured by the Schirmer’s test improved from mean values of 4.2 mm at baseline to 8.2 mm at Week 12.
+Added: One of five subjects (20%) had a greater than 10 mm increase from baseline in Schirmer’s score at Week 12.
+Added: Subjects saw an improvement in signs of dry eye disease as measured by corneal total fluorescein staining (a mean value of 6.7 at baseline, improved to a mean value of 2.7 at Week 12, on a scale of 0 to 15).
+Added: Further, subjects saw an improvement in symptoms of dry eye disease as measured by the VAS eye dryness severity score (a mean value of 51 at baseline, improved to a mean value of 33 at Week 12, on a scale of 0 to 100) and the VAS dry eye frequency score (a mean value of 51 at baseline, improved to a mean value of 31 at Week 12, on a scale of 0 to 100).
+Added: The onset of action of OTX-CSI was seen as early as two weeks for both signs and symptoms of dry eye disease and was observed to continue over the sixteen-week study period.
+Added: Phase 2 clinical development
+Added: In September 2020, we dosed the first patients in a Phase 2 clinical trial designed to assess the safety, tolerability and durability and to evaluate the efficacy of OTX-CSI in the chronic treatment of dry eye disease.
+Added: The Phase 2 clinical trial is a U.S.-based, randomized, double-masked, multi-center, vehicle-controlled trial evaluating two different formulations of OTX-CSI compared with a hydrogel vehicle insert in approximately 140 subjects who are to be followed for a period of 16 weeks.
+Added: Included patients must have been diagnosed with dry eye disease in both eyes for a period of greater than six months and have a visual analog scale, or VAS, eye dryness severity score of greater than 30.
+Added: The primary endpoints are incidence of treatment-emergent adverse events and the absolute value and change from baseline at week 12 in tear production as measured by the Schirmer’s test.
+Added: Secondary endpoints include signs of dry eye disease as measured by corneal fluorescein staining and symptoms of dry eye disease as measured by the VAS eye dryness severity score and the VAS dry eye frequency score.
+Added: Regulatory Pathway
+Added: We anticipate receiving topline data from our ongoing Phase 2 clinical trial in the fourth quarter of 2021.
+Added: If our planned Phase 2 clinical trial is successful, we would then be required to successfully complete two well-controlled Phase 3 clinical trials conducted under an IND to obtain marketing approval from the FDA.
+Added: If our development efforts are successful, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
+Added: See “—Government Regulation—Section 505(b)(2) NDAs” for additional information.
+Added: OTX-DED (dexamethasone intracanalicular insert)
One of the causes of dry eye disease is inflammation.
Topical anti-inflammatory drugs are used as one of several therapies to treat dry eye disease and are administered by eye drops.
−Removed: As the understanding of dry eye disease, specifically the inflammatory components of dry eye disease, has evolved, the use of corticosteroids has become a standard to offer short-term relief of signs and symptoms of the disease.
+Added: As the understanding of dry eye disease, specifically the inflammatory components of dry eye disease, has evolved, the use of corticosteroids has become a common to offer short-term relief of signs and symptoms of the disease.
Physicians typically prescribe a topical corticosteroid for a period of two to four weeks, tapered over the course of delivery as the inflammation and symptoms subside.
−Removed: As with allergic conjunctivitis, there are safety limitations associated with the use of corticosteroids for dry eye disease that have limited wide spread adoption.
−Removed: We believe that DEXTENZA has potential as a short-term therapy for more severe cases of episodic dry eye caused by inflammation, followed by the delivery of an immunosuppressant drug such as cyclosporine after the inflammation has been reduced.
−Removed: Overview of DEXTENZA Clinical Development
−Removed: We are conducting clinical development of DEXTENZA for the treatment of post-surgical ocular inflammation and pain and ocular itching associated with allergic conjunctivitis.
−Removed: The following summarizes our clinical development to date for DEXTENZA.
−Removed: In March and April 2015, we reported topline results from two Phase 3 clinical trials for the treatment of post-surgical ocular inflammation and pain.
−Removed: In the first Phase 3 clinical trial, DEXTENZA met both primary efficacy endpoints, absence of pain at day 8 and absence of inflammatory cells at day 14, with statistical significance.
−Removed: In the second Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint for absence of pain at day 8 with statistical significance but did not meet the primary efficacy endpoint for absence of inflammatory cells at day 14.
−Removed: We met with the FDA in April 2015 to discuss the path forward for seeking marketing approval of DEXTENZA for the treatment of post-surgical ocular inflammation and pain.
−Removed: In this pre-NDA clinical meeting, the FDA indicated that the existing data from our Phase 2 and two Phase 3 clinical trials are appropriate to support an NDA submission for DEXTENZA for a post-surgical ocular pain indication.
−Removed: The FDA further indicated that we would need additional data from a third Phase 3 clinical trial for the inflammation endpoint to support the potential labeling expansion of DEXTENZA’s indications for use.
−Removed: We initiated a third Phase 3 clinical trial for DEXTENZA for the treatment of post-surgical ocular inflammation and pain in October 2015.
−Removed: In September 2015, we submitted to the FDA an NDA for DEXTENZA for the treatment of post-surgical ocular pain.
−Removed: In July 2016, we received a CRL from the FDA regarding our NDA for DEXTENZA.
−Removed: This CRL pertained to deficiencies in manufacturing process and controls identified during a pre-NDA approval inspection of our manufacturing facility.
−Removed: In January 2017, we resubmitted our NDA to the FDA.
−Removed: Following a re-inspection of manufacturing operations by the FDA which was completed in May 2017, we received an FDA Form 483 containing inspectional observations focused on manufacturing processes and analytical testing related to the manufacture of drug product for commercial production.
−Removed: In July 2017, we received a CRL from the FDA regarding our NDA for DEXTENZA for the treatment of post-surgical ocular pain.
−Removed: The FDA concerns included deficiencies in manufacturing processes and analytical testing related to manufacturing of drug product identified during the pre-NDA approval inspection.
−Removed: We resubmitted our NDA for DEXTENZA for the treatment of post-surgical ocular pain in June 2018.
−Removed: In November 2018, we received approval for the pain indication.
−Removed: In June 2019, we received approval for the inflammation indication.
−Removed: In November 2014, we completed a Phase 2 clinical trial evaluating the safety and efficacy of DEXTENZA for the treatment of allergic conjunctivitis.
−Removed: Based upon the encouraging results of this Phase 2 clinical trial and a subsequent meeting with the FDA, we began enrollment for an initial Phase 3 clinical trial of DEXTENZA
−Removed: for the treatment of ocular itching and conjunctival redness associated with allergic conjunctivitis in June 2015.
−Removed: We announced topline results from this trial in October 2015.
−Removed: We initiated a second Phase 3 clinical trial of DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis in November 2015.
−Removed: We announced topline results for the second Phase 3 clinical trial in June 2016.
−Removed: In the third quarter of 2019, we initiated a third Phase 3 clinical trial for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: We completed enrollment and topline results from this trial are anticipated in the second quarter of 2020.
−Removed: In January 2015, we initiated a Phase 2 exploratory clinical trial of DEXTENZA for the treatment of episodic dry eye disease.
−Removed: We reported topline results from this trial in December 2015.
−Removed: We are also planning to evaluate DEXTENZA in pediatric subjects that are 0 to 3 years of age undergoing cataract surgery beginning in the fourth quarter of 2020.
−Removed: The planned pediatric trial is a post-approval commitment to the FDA.
−Removed: Clinical Trials for Post-Surgical Ocular Inflammation and Pain
−Removed: Completed Phase 2 Clinical Trial
−Removed: In 2013, we completed a prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked Phase 2 clinical trial evaluating the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain following cataract surgery.
−Removed: We conducted this trial in 60 patients at four sites in the United States pursuant to an effective IND.
−Removed: We randomized patients in a 1:1 ratio to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: One patient randomized into the DEXTENZA group was excluded from the trial because the investigator was unable to insert the insert, resulting in 29 patients in the DEXTENZA group and 30 patients in the vehicle control group.
−Removed: We evaluated patients in this trial at days 1, 4, 8, 11, 14 and 30 following surgery.
−Removed: One of our goals for this trial was to determine the appropriate primary endpoints for a subsequent Phase 3 clinical development program.
−Removed: The two primary efficacy measures in this trial were absence of inflammatory cells in the anterior chamber of the study eye and absence of pain in the study eye.
−Removed: When viewed with a slit lamp biomicroscope, these inflammatory cells, referred to as cells in a slit lamp examination, appear like dust specks floating in a projected light beam.
−Removed: The presence of these cells in the anterior chamber indicates inflammation.
−Removed: In this trial, absence of pain was based on a patient reported score of zero on a scale from zero to ten of ocular pain assessment.
−Removed: The first primary efficacy endpoint was the difference in the proportion of patients in each treatment group with absence of cells in the anterior chamber of the study eye at day 8 following surgery.
−Removed: The second primary efficacy endpoint was the difference in the proportion of patients in each treatment group with absence of pain in the study eye at day 8 following surgery.
−Removed: We evaluated as secondary measures the absence of flare in the anterior chamber of the study eye at each evaluation date, absence of inflammatory cells in the anterior chamber of the study eye and absence of pain in the study eye at each evaluation date other than day 8 and insert retention and visualization.
−Removed: Flare is a scattering of light in the aqueous humor when viewed during a slit lamp biomicroscopic examination.
−Removed: Flare occurs when the protein content of the aqueous humor increases due to intraocular inflammation.
−Removed: We enrolled patients in this trial who were at least 21 years of age undergoing unilateral clear corneal cataract surgery.
−Removed: We excluded patients from the trial if, among other reasons, they had intraocular inflammation or ocular pain in the study eye at screening or had glaucoma or ocular hypertension.
−Removed: In this trial, DEXTENZA met the primary efficacy endpoint with statistical significance for absence of pain compared to the vehicle control at day 8 (p<0.0001).
−Removed: We determined statistical significance based on a widely used, conventional statistical method that establishes the p-value of clinical results.
−Removed: Typically, a p-value of 0.05 or less represents statistical significance.
−Removed: The differences between DEXTENZA and the vehicle control for absence of pain also were statistically significant at each other evaluation date (p<0.0002).
−Removed: These results are shown in the graph below.
−Removed: graph and other graphs appearing further below, we use the abbreviation “N”
−Removed: to reference the number of patients in each group.
−Removed: In this trial, DEXTENZA did not meet the primary efficacy endpoint with statistical significance for absence of cells in the anterior chamber compared to the vehicle control at day 8.
−Removed: However, there was a trend of improved absence of anterior chamber cells at each evaluation date, with statistical significance at day 14 (p<0.0027) and day 30 (p< 0.0002).
−Removed: These results are shown in the graph below.
−Removed: Based on post hoc analysis, DEXTENZA showed statistical significance for absence of flare compared to vehicle control at each evaluation date.
−Removed: These results are shown in the graph below.
−Removed: In this trial, there were three serious adverse events, none of which was considered related to the study treatment.
−Removed: The trial investigator determined the relatedness of the serious adverse events to study treatment based on his or her professional medical judgment and in accordance with the study protocol, which required the investigator to determine that a reasonable possibility did not exist that the study treatment caused the adverse event.
−Removed: None of the three serious adverse events:
−Removed: syncope, intracranial hemorrhage and cellulitis of the arm, were ocular in nature.
−Removed: In addition, there were a variety of adverse events in both the DEXTENZA group and the vehicle control group, with the adverse events in the vehicle control group outnumbering the adverse events in the DEXTENZA group.
−Removed: In the DEXTENZA group, the only adverse event that occurred more than once was reduced visual acuity, which occurred twice.
−Removed: The most common adverse events in the vehicle control group were reduced visual acuity, conjunctival hyperemia and corneal edema.
−Removed: Overall, 19 adverse events were noted in the DEXTENZA group and 30 adverse events were noted in the vehicle control group.
−Removed: All adverse events were transient in nature and completely resolved by the end of the trial.
−Removed: Completed Phase 3 Clinical Trials
−Removed: In 2014, we initiated a pivotal clinical trial program that consisted of two prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked Phase 3 clinical trials evaluating the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain following cataract surgery.
−Removed: We initiated the first of these Phase 3 clinical trials in February 2014 and the second trial in April 2014.
−Removed: Patient enrollment was completed in September 2014, and the topline efficacy data from these clinical trials was reported in March and April 2015.
−Removed: We initiated a third Phase 3 clinical trial in the October 2015.
−Removed: Patient enrollment in the third Phase 3 clinical trial was completed in May 2016 and the topline efficacy data was reported in November 2016.
−Removed: We enrolled 247 patients at 16 sites in the first Phase 3 clinical trial, 241 patients at 16 sites in the second Phase 3 clinical trial and 438 patients at 21 sites in the third Phase 3 clinical trial in the United States pursuant to our effective IND.
−Removed: We randomized patients in a 2:1 ratio in the first two Phase 3 clinical trials and in a 1:1 ratio in the third Phase 3 clinical trial to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: We evaluated patients at days 2, 4, 8, 14, 30 and 60 following surgery in the first two Phase 3 trials and at days 2, 4, 8, 14, and 30 in the third Phase 3 clinical trial.
−Removed: The two primary efficacy measures in these trials were absence of inflammatory cells in the anterior chamber of the study eye when measured with a slit lamp biomicroscope and absence of pain in the study eye.
−Removed: To meet the efficacy end point for absence of inflammatory cells, there needed to be a complete absence of inflammatory cells.
−Removed: In these trials,
−Removed: absence of pain was based on a patient reported score of zero on a scale from zero to ten of ocular pain assessment.
−Removed: The first primary efficacy endpoint for these trials was the difference in the proportion of patients in each treatment group with absence of inflammatory cells in the anterior chamber of the study eye at day 14 following surgery.
−Removed: Pivotal clinical trials for other ophthalmic steroid drugs approved by the FDA for marketing in the United States also have evaluated this endpoint at day 14.
−Removed: The second primary efficacy endpoint for these trials was the difference in the proportion of patients in each treatment group with absence of pain in the study eye at day 8 following surgery.
−Removed: For clarification of the endpoints, the day of surgery and insertion of DEXTENZA or the placebo is considered to be day 1.
−Removed: We evaluated as secondary efficacy measures the level of flare, an indicator of inflammation in the anterior chamber of the study eye at each evaluation date until day 30 and absence of inflammatory cells in the anterior chamber of the study eye and absence of pain in the study eye at each evaluation date other than the day used for the primary efficacy measure until day 30.
−Removed: The secondary analyses on primary endpoints were intended to be exploratory assessments that can be used to support the results from the primary endpoints.
−Removed: We enrolled patients in these two trials who were at least 18 years of age undergoing unilateral clear corneal cataract surgery.
−Removed: We excluded patients from these trials if, among other reasons, they had intraocular inflammation or ocular pain in the study eye at screening or had glaucoma or ocular hypertension.
−Removed: We evaluated safety in all patients at each study visit with an assessment of general eye conditions, including visual acuity and IOP, along with any adverse events.
−Removed: In the first Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint with statistical significance for the absence of cells in the anterior chamber compared to the vehicle control at day 14.
−Removed: 33.1% of DEXTENZA treated patients showed an absence of inflammatory cells in the anterior chamber of the study eye on day 14 following drug product insertion, compared to 14.5% of those receiving placebo vehicle control intracanalicular inserts (p=0.0018).
−Removed: DEXTENZA also met the primary efficacy endpoint with statistical significance for absence of pain compared to the vehicle control at day 8.
−Removed: 80.4% of patients receiving DEXTENZA reported absence of pain in the study eye on day 8 following insertion of the drug product, compared to 43.4% of those receiving placebo vehicle control intracanalicular inserts (p< 0.0001).
−Removed: In the second Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint for absence of pain at day 8 with statistical significance but did not meet the primary efficacy endpoint for absence of inflammatory cells at day 14.
−Removed: In the second Phase 3 clinical trial, 77.5% of patients receiving DEXTENZA reported an absence of pain in the study eye on day 8 following insertion of the drug product, compared to 58.8% of those receiving placebo vehicle control intracanalicular inserts, a difference which was statistically significant (p=0.0025).
−Removed: However, 39.4% of DEXTENZA treated patients showed an absence of inflammatory cells in the anterior chamber of the study eye on day 14 following drug product insertion, compared to 31.3% of those receiving placebo vehicle control intracanalicular inserts, a difference which was not statistically significant (p=0.2182).
−Removed: In the third Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint with statistical significance for the absence of cells in the anterior chamber compared to the vehicle control at day 14.
−Removed: 52.1% of DEXTENZA treated patients showed an absence of inflammatory cells in the anterior chamber of the study eye on day 14 following drug product insertion compared to 31.2% of those receiving placebo vehicle control intracanalicular inserts (p< 0.0001).
−Removed: DEXTENZA also met the primary efficacy endpoint with statistical significance for absence of pain compared to the vehicle control at day 8 .
−Removed: 79.3% of patients receiving DEXTENZA reported absence of pain in the study eye on day 8 following insertion of the drug product, compared to 61.3% of those receiving placebo vehicle control intracanalicular inserts (p< 0.0001).
−Removed: Secondary analyses on primary endpoints for the three Phase 3 clinical trials were also completed.
−Removed: In the first Phase 3 clinical trial, statistically significant differences were seen for absence of pain at all time points (days 2, 4, 8, 14, 30 and 60) in the DEXTENZA treatment group compared to the vehicle control group.
−Removed: Statistically significant differences were seen for the absence of inflammatory cells at day 30 in the DEXTENZA treatment group compared to the vehicle control group, and there were no statistically significant differences seen at the other time points.
−Removed: Statistically significant differences between the DEXTENZA treatment group and the vehicle control group were seen for flare at days 8, 14 and 30.
−Removed: In the second Phase 3 clinical trial, statistically significant differences were seen for absence of pain at days 2, 4, 14 and 30 in the DEXTENZA treatment group compared to the vehicle control group.
−Removed: A similar proportion of patients in
−Removed: the DEXTENZA treatment group and the vehicle control group were observed to have an absence of inflammatory cells at days 2, 4, 8, and 30.
−Removed: A statistically significant difference between treatment groups was not seen for the absence of inflammatory cells until the day 60 visit, at which time a greater proportion of patients in the DEXTENZA treatment group compared to the vehicle control group were observed to have an absence of inflammatory cells at day 60 (p=0.0012).
−Removed: Statistically significant differences between the DEXTENZA treatment group and the vehicle control group were seen for flare at days 14, 30 and 60.
−Removed: In the third Phase 3 clinical trial, statistically significant differences were seen for absence of pain at all time points (days 2,4, 14, and 30) in the DEXTENZA treatment group compared to the vehicle control group.
−Removed: Statistically significant differences were seen for the absence of inflammatory cells at days 4, 8, and 30 but not seen at day 2.
−Removed: Statistically significant differences between the DEXTENZA treatment group and the vehicle control group were seen for flare at all measured time points (days 2, 4, 8, 14, and 30 ).
−Removed: There were no ocular or treatment-related serious adverse events in the DEXTENZA treatment group in either of the first two completed Phase 3 clinical trials.
−Removed: There was one ocular serious adverse event in the vehicle control group in the first two completed Phase 3 clinical trials:
−Removed: hypopyon, or inflammatory cells in the anterior chamber.
−Removed: There were two patients with three serious adverse events in the DEXTENZA treatment group in the first Phase 3 clinical trial (1.2% incidence), compared with two patients with four serious adverse events in the vehicle control group (2.4% incidence).
−Removed: There were two serious adverse events in the DEXTENZA treatment group in the second Phase 3 clinical trial (1.3% incidence), compared with three serious adverse events in the vehicle control group (3.8% incidence).
−Removed: There were three serious adverse events in the DEXTENZA treatment group in the third Phase 3 clinical trial (1.4% incidence), compared with two serious adverse events in the vehicle control group (0.9% incidence).
−Removed: One serious adverse event in the DEXTENZA group was ocular in nature (retinal detachment) .
−Removed: None of the serious adverse events in either group were deemed to be treatment-related.
−Removed: Patients were randomized in a 2:1 ratio in the first two Phase 3 clinical trials and in a 1:1 ratio in the third Phase 3 clinical trial between the treatment group and the vehicle control group.
−Removed: In the first Phase 3 clinical trial, 98 adverse events were noted in the DEXTENZA group and 59 adverse events were noted in the vehicle control group.
−Removed: In the second Phase 3 clinical trial, 74 adverse events were noted in the DEXTENZA group and 47 adverse events were noted in the vehicle control group.
−Removed: In the third Phase 3 clinical trial, 91 adverse events were noted in the DEXTENZA group and 109 adverse events were noted in the vehicle control group.
−Removed: All adverse events were either resolved or considered chronic/stable at the time of subject exit from the study.
−Removed: We expect to be able to use the safety data from these Phase 3 trials to support our other DEXTENZA clinical development programs, including for allergic conjunctivitis.
+Added: However, safety limitations associated with the use of corticosteroids for dry eye disease have limited widespread adoption.
+Added: We believe that OTX-DED has potential as a short-term treatment of the signs and symptoms of dry eye disease caused by inflammation.
+Added: OTX-DED incorporates the FDA-approved corticosteroid dexamethasone, its preservative-free active pharmaceutical ingredient, into a hydrogel, drug-eluting intracanalicular insert.
+Added: OTX-DED incorporates the same active drug as DEXTENZA, but it includes a lower dose of the drug, delivers it via a smaller insert, and is designed to release it over a period of two to three weeks.
+Added: Phase 2 clinical trial
+Added: We filed an IND in December 2020 for OTX-DED.
+Added: In February 2021, we initiated a U.S.-based, randomized, double-masked, vehicle-controlled, multi-center Phase 2 clinical trial evaluating two different-strength formulations of OTX-DED (0.2 mg and 0.3 mg of dexamethasone) versus hydrogel implant in a total of approximately 150 subjects with dry eye disease, approximately 50 patients per arm.
+Added: The subjects will be followed for approximately two months after randomization.
+Added: This trial is designed to assess the safety and efficacy of these two formulations of OTX-DED for the short-term treatment of signs and symptoms of dry eye disease.
+Added: Included patients will be required to have diagnosed dry eye disease in both eyes for at least six months, a VAS eye dryness severity score of at least 30 and bulbar conjunctival hyperemia grade of at least 2 (Cornea Contact Lens Research Unit scale).
+Added: The primary endpoint is mean change in bulbar conjunctival hyperemia from baseline measured at 15 days post treatment by central reading center photographic assessment.
+Added: Secondary endpoints include eye dryness symptoms using VAS, total corneal fluorescein staining using the National Eye Institute scale and adverse events, both ocular and non-ocular.
Regulatory Pathway
−Removed: In September 2015, we submitted to the FDA an NDA for DEXTENZA for the treatment of post-surgical ocular pain.
−Removed: In July 2016, we received a CRL from the FDA regarding our NDA for DEXTENZA pertaining to deficiencies in manufacturing process and controls identified during a pre-NDA approval inspection.
−Removed: We resubmitted our NDA to the FDA in January 2017.
−Removed: Following a re-inspection of manufacturing operations by the FDA which was completed in May 2017, we received an FDA Form 483 containing inspectional observations focused on manufacturing processes and analytical testing related to the manufacture of drug product for commercial production.
−Removed: In July 2017, we received a CRL from the FDA regarding our NDA for DEXTENZA for the treatment of post-surgical ocular pain, which states that the FDA has determined that it cannot approve the NDA in its present form.
−Removed: In May 2017, we submitted our initial response to the Form 483 and, in November 2017, we submitted our responses to the FDA’s remaining inspectional observations in an effort to close out the items identified in the Form 483.
−Removed: We resubmitted our NDA for DEXTENZA for the treatment of post-surgical ocular pain in June 2018.
−Removed: In November 2018, we received FDA approval for DEXTENZA for the pain indication.
−Removed: In January 2019, we submitted a sNDA for DEXTENZA for the treatment of post-surgical ocular inflammation.
−Removed: In June 2019, we received FDA approval for DEXTENZA for the inflammation indication.
−Removed: Although we conducted our Phase 3 clinical trials of DEXTENZA in patients who have undergone cataract surgery, these trials were intended to support, and DEXTENZA ultimately received, a label for patients who have undergone any ocular surgery.
−Removed: Clinical Trials for Allergic Conjunctivitis
+Added: We anticipate receiving topline data from our ongoing Phase 2 clinical trial in the first half of 2022.
+Added: If our planned Phase 2 clinical trial is successful, we would then be required to successfully complete two well-controlled Phase 3 clinical trials conducted under an IND to obtain marketing approval from the FDA.
+Added: If our development efforts are successful, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
+Added: See “—Government Regulation—Section 505(b)(2) NDAs” for additional information.
+Added: Allergic Conjunctivitis
+Added: We believe that allergic conjunctivitis represents a discrete potential market opportunity for preservative-free DEXTENZA because it is a physician-administered, hands-free, therapy administered in the office setting and designed to release the FDA-approved corticosteroid dexamethasone to the ocular surface for up to 30 days.
+Added: Although dexamethasone is clinically effective in the treatment of late-phase inflammatory allergic reactions, the safety limitations associated with eye drop administration, including the potential to generate spikes in IOP due to the high levels of drug due to potential patient abuse to treat this symptomatic condition, have limited its widespread adoption.
+Added: These elevations in IOP can lead to drug-induced glaucoma, although the incidence is low.
+Added: Further, use of oral anti-histamine medications as well as anti-histamine eye drops for allergic conjunctivitis may dry out the eye and exacerbate the discomfort to some patients.
+Added: Based on our clinical trial results to date, we believe that using DEXTENZA for allergic conjunctivitis could create a low, tapered, consistent dose of dexamethasone, potentially minimizing or eliminating side effects associated with the eye drop formulation, while retaining the drug’s anti-inflammatory effects.
Completed Phase 2 Clinical Trial
In November 2014, we completed a prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked Phase 2 clinical trial evaluating the safety and efficacy of DEXTENZA for the treatment of allergic conjunctivitis.
−Removed: We conducted this trial using a modified version of a controlled exposure model commonly used to assess anti-allergy medications known as the Conjunctival Allergen Challenge model, or CAC TM , which is a proprietary model owned by ORA, Inc., the clinical research organization we used to manage the trial.
+Added: We conducted this trial using a modified version of a controlled exposure model commonly used to assess anti-allergy medications, Ora, Inc.’s modified Conjunctival Allergen Challenge (Ora-Cac ® ), which we refer to as the CAC Model.
The modified CAC achieves a very high transient dose exposure by placing allergen directly into the space between the eyelid and the surface of the eye of the patient.
3 unchanged sentences
We randomized patients in a 1:1 ratio to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: We evaluated patients using three allergen challenges in series for each of the two efficacy measures at 14, 28 and 42 days following placement of the intracanalicular insert.
+Added: We evaluated patients using three
+Added: allergen challenges in series for each of the two efficacy measures at 14, 28 and 42 days following placement of the intracanalicular insert.
The primary efficacy measures for this trial were ocular itching graded by the patient and conjunctival redness graded by the trial investigator, in each case based on a five point scale from zero to four.
28 unchanged sentences
A total of 73 patients were enrolled in this trial and were randomized in a 1:1 ratio to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: This trial was conducted using the modified CAC model.
+Added: This trial was conducted using the CAC Model.
We evaluated patients using three allergen challenges in series for each of two efficacy measures at days 7, 14 and 28 following placement of intracanalicular insert as described below.
4 unchanged sentences
The secondary endpoints were similar to the primary efficacy endpoints except that each variable was assessed at day 14 and day 28 following insertion of the intracanalicular insert.
−Removed: The primary efficacy measure of conjunctival redness is typically included in Phase 3 trials for allergic conjunctivitis but has not been required for FDA approval of drugs for allergic
−Removed: conjunctivitis.
+Added: The primary efficacy measure of conjunctival redness is typically included in Phase 3 trials for allergic conjunctivitis but has not been required for FDA approval of drugs for allergic conjunctivitis.
Most commercially available prescription medications for the treatment of allergic conjunctivitis have an ocular itching indication only.
19 unchanged sentences
A total of 72 patients were enrolled in this trial and randomized in a 1:1 ratio to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: This trial was conducted using the modified CAC model.
−Removed: Patients were evaluated using three allergen challenges in series for each of two efficacy measures at days 7, 14 and 28 following
−Removed: insertion of the intracanalicular insert.
+Added: This trial was conducted using the CAC Model.
+Added: Patients were evaluated using three allergen challenges in series for each of two efficacy measures at days 7, 14 and 28 following insertion of the intracanalicular insert.
In this Phase 3 clinical trial, we placed the intracanalicular inserts 48 to 72 hours after exposure to the allergen.
7 unchanged sentences
In this trial, DEXTENZA did not meet the primary efficacy endpoint of ocular itching at the three time points measured on day 7 post-placement of the intracanalicular insert.
−Removed: The mean difference in ocular itching in the DEXTENZA treatment group compared to the placebo group measured 7 days following insertion of the inserts, at 3, 5, and 7 minutes was -0.18, -0.29, and -0.29 units, respectively, on a five point scale and did not achieve statistical significance.
+Added: The mean difference in ocular itching in the
+Added: DEXTENZA treatment group compared to the placebo group measured 7 days following insertion of the inserts, at 3, 5, and 7 minutes was -0.18, -0.29, and -0.29 units, respectively, on a five point scale and did not achieve statistical significance.
In addition, the trial did not achieve the requirement of at least a 0.5 unit difference at all three time points 7 days following insertion of the inserts and at least a 1.0 unit difference at a majority of the three time points between the treatment group and the placebo group 7 days following insertion of the inserts.
7 unchanged sentences
Ocular adverse events reported more than one patient in either treatment group included increased IOP, which was experienced by two patients in the DEXTENZA group, as well as dacryostenosis acquired and dacryocanaliculitis, each experienced by two patients in the vehicle control group.
−Removed: Both cases of IOP increased were considered treatment related, as were both cases of dacrycanaliculitis and a single case of dacryostenosis.
+Added: Both cases of IOP increased were considered treatment related, as were both cases of dacryocanaliculitis and a single case of dacryostenosis.
All other ocular adverse events were reported by single patients in either the DEXTENZA or vehicle control group, with most in the PV group considered treatment related.
−Removed: Third Phase 3 Clinical Trial - Ongoing
−Removed: We initiated our third Phase 3 clinical trial of DEXTENZA for the treatment of allergic conjunctivitis in August 2019.
−Removed: We recently completed enrollment and expect to report topline efficacy results in the second quarter of 2020.
−Removed: This third Phase 3 clinical trial is a prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked trial.
−Removed: A total of 96 patients were enrolled in this trial and randomized in a 1:1 ratio to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: This trial was conducted using the modified CAC model.
−Removed: Patients were evaluated using three allergen challenges in series for each of two efficacy measures at days 7 and 14 following insertion of the intracanalicular insert.
−Removed: The single primary efficacy measure for this trial was ocular itching graded by the patient based on a five point scale from zero to four.
−Removed: The primary efficacy endpoints were the differences between the treatment group and the vehicle group of at least 0.5 units on the five point scale 7 days post-insertion of the intracanalicular insert for all three time points measured for ocular itching and differences of at least 1.0 unit for the majority of the three time points measured 7 days post-insertion of the intracanalicular insert for ocular itching.
−Removed: The secondary endpoints for ocular itching were similar to the primary efficacy endpoints except that each variable was assessed at day 14 following placement of the intracanalicular insert.
−Removed: The secondary endpoints for conjunctival redness were the differences between the treatment group and the vehicle group of at least 0.5 units on the five point scale 7 days post-insertion of the intracanalicular insert for all three time points measured and differences of at least 1.0 unit for the majority of the three time points measured 7 days post-insertion of the intracanalicular insert.
−Removed: We enrolled patients in this trial who are at least 18 years of age with a positive history of ocular allergies and a positive skin test reaction to a perennial allergen and a seasonal allergen.
−Removed: We excluded patients from this trial if, among other reasons, they had an active ocular infection or itching or conjunctival redness at screening.
−Removed: We evaluated safety in all patients at each study visit with an assessment of general eye conditions, including visual acuity and IOP, along with any adverse events.
−Removed: Regulatory Pathway
−Removed: We have completed two Phase 3 clinical trials evaluating DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis and we are conducting a third Phase 3 clinical trial that commenced in the third quarter of 2019.
−Removed: Subject to obtaining favorable results from this third Phase 3 clinical trial, we plan to submit an sNDA to the FDA for DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: We expect that we would submit this sNDA under Section 505(b)(2) of the FDCA.
−Removed: See “—Government Regulation—Section 505(b)(2) NDAs”
−Removed: for additional information.
−Removed: Based on discussions with the FDA, we expect to use safety results from our Phase 3 clinical trials of DEXTENZA for the treatment of post-surgical ocular inflammation and pain to support the sNDA for DEXTENZA for the ocular itching indication.
−Removed: Clinical Trial for Dry Eye
−Removed: Phase 2 Clinical Trial
−Removed: In January 2015, we initiated a prospective, randomized, parallel-arm, vehicle-controlled, multicenter, bilateral, double-masked Phase 2 feasibility study evaluating the safety and efficacy of DEXTENZA for the treatment of episodic dry eye disease.
−Removed: We enrolled 43 patients and evaluated 86 eyes at two sites in the United States pursuant to our effective IND.
−Removed: The clinical trial was not powered for statistical significance.
−Removed: We randomized patients in a 1:1 ratio to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
−Removed: Designed as an exploratory study, patients were initially administered a placebo vehicle control intracanalicular insert for 45 days to establish a baseline for the investigational drug treatment.
−Removed: Patients who responded to the placebo insert in treatment of their dry eye disease were excluded from the trial.
−Removed: Patients who continued to exhibit symptoms of dry eye disease during the initial 45 days, as indicated by a minimum threshold of signs of corneal staining, were qualified for enrollment in the treatment phase of the trial.
−Removed: Qualified patients were then randomized to receive either DEXTENZA or a placebo vehicle control intracanalicular insert.
−Removed: Primary efficacy measures included corneal and conjunctival staining, tear osmolarity, tear film break-up time, presence of the insert, ease of product use and
−Removed: visualization, and resorption of the insert following therapy.
−Removed: We reported topline results for this clinical trial in December 2015.
−Removed: In this exploratory Phase 2 clinical trial, patients were selected for a minimum threshold of signs of corneal staining and were randomized to either treatment with DEXTENZA or a placebo vehicle insert.
−Removed: Patients were stratified into groups based on the level of National Eye Institute aggregate corneal fluorescein staining score improvement and were then randomized into the treatment or placebo vehicle insert group per a pre-determined randomization list to maintain masking.
−Removed: DEXTENZA treated patients showed clinically meaningful benefits compared to patients receiving a placebo vehicle control intracanalicular insert, with improvement in total and inferior corneal staining as well as conjunctival staining.
−Removed: Total corneal staining at day 30 following randomization was significantly decreased from baseline in the DEXTENZA group (-3.14) compared to placebo (-1.10) (p=0.018).
−Removed: Inferior staining showed clinically significant differences in the change from baseline in the DEXTENZA treatment group compared to the placebo group (-0.44 and -0.45 at day 15 and day 30, respectively).
−Removed: Corneal staining is a primary endpoint that has been used in recent Phase 3 dry eye clinical trials for dry eye disease conducted by other ophthalmology companies.
−Removed: Supportive analyses of lissamine green staining also demonstrated a clinically significant change in favor of DEXTENZA, where total staining was more than 1 point improved for the DEXTENZA group compared to the placebo group.
−Removed: This clinical trial was designed to evaluate a range of objective and subjective measures (signs and symptoms, respectively) for DEXTENZA and was intended to explore which measures would be appropriate to include in the design of future clinical trials of DEXTENZA or other molecules in a sustained-release product as a potential therapy for dry eye disease.
−Removed: Our long term strategy for the treatment of dry eye may be to use DEXTENZA as a mode of therapy to reduce inflammation in patients with acute dry eye conditions and pursue the development of an intracanalicular insert containing an immunosuppressant drug such as cyclosporine to treat dry eye disease.
−Removed: There was one serious adverse event in the DEXTENZA treatment group, myocardial infarction, that was not deemed to be treatment related.
−Removed: There were 17 adverse events in the DEXTENZA group and 11 adverse events in the vehicle control group.
−Removed: Eight patients in the DEXTENZA group reported 12 ocular related adverse events, and 4 patients in the vehicle control group reported 5 ocular related adverse events.
−Removed: Four patients in the DEXTENZA group reported 5 non-ocular related adverse events, and 5 subjects in the vehicle control group reported 6 non-ocular related adverse events.
−Removed: The most frequently reported ocular treatment related ocular adverse event was increased lacrimation, which was reported in 4 patients in the DEXTENZA group and 1 subject in the vehicle control group.
−Removed: Three patients, all from the DEXTENZA group, had a mild reduction in best corrected visual acuity, of which 2 were considered treatment related and 1 of these was not resolved during the trial.
+Added: Third Phase 3 Clinical Trial
+Added: In the third quarter of 2019, we began dosing patients in a 96-subject, pivotal Phase 3 clinical trial evaluating DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis.
+Added: This Phase 3 clinical trial was a U.S.-based, multi-center, 1:1 randomized, double-masked, placebo-controlled trial designed to evaluate the safety and efficacy of DEXTENZA versus a punctum plug using the CAC Model.
+Added: The trial was designed to assess the effect of DEXTENZA compared with a placebo on allergic reactions using a series of successive allergen challenges over a 30-day period.
+Added: The primary efficacy endpoint for this trial was ocular itching (subject-reported 5-point scale (0 to 4)) on day 8 at 3 minutes, 5 minutes and 7 minutes post-challenge and included subjects with seasonal and perennial allergens.
+Added: DEXTENZA-treated subjects demonstrated a statistically significant (p-value < 0.0001) difference in mean ocular itching scores, compared to vehicle-treated subjects, at all three pre-specified time points (see the figure below).
+Added: An assessment of the secondary endpoint of ocular itching at all other visits (day 7, day 8 (morning), day 8 (afternoon at 10 minutes following exposure), day 14, and day 15 (morning and afternoon)) also showed that DEXTENZA-treated subjects reported lower itching scores than vehicle-treated subjects at 3 minutes, 5 minutes, 7 minutes and 10 minutes post-exposure to the allergen challenge (p-value <0.05 for all 21 time points except day 7 at 3 minutes).
+Added: Primary Efficacy Endpoint Ocular Mean Itching Scores at Day 8 (PM)
+Added: *Statistically significant;
+Added: Least Squared Means;
+Added: Bars represent Standard Error
+Added: In the trial, DEXTENZA was generally observed to have a favorable safety profile and be well-tolerated.
+Added: No serious adverse events were observed.
+Added: No subjects required rescue medication and no subjects experienced elevated IOP.
+Added: There were 8 ocular treatment-emergent adverse events in this trial (2 in the DEXTENZA group and 6 in the vehicle group).
+Added: Overview of clinical trial data
+Added: Data received from the third Phase 3 clinical trial evaluating DEXTENZA for ocular itching associated with allergic conjunctivitis was generally consistent with our observations in our prior Phase 2 and Phase 3a clinical trials using a similar repeat CAC Model as reflected in the two figures below.
+Added: For all analyses we have conducted, the subject is the unit of analysis.
+Added: For the Phase 2 clinical trial, the data shown is for the prespecified primary endpoint of ocular itching at day 15 using the Intent-to-Treat (ITT) population and utilizing the last observation carried forward (LOCF) methodology to impute missing data.
+Added: For the Phase 3 trials, the data shown is for the prespecified primary endpoint of ocular itching at day 8 using the ITT population and imputing missing data using the Markov Chain Monte Carlo (MCMC) multiple imputation method.
+Added: The two figures below reflect the Phase 3 data using the MCMC method with different bases for imputation.
+Added: In the first figure, the basis for imputation for the MCMC method is at the individual eye level.
+Added: In the second figure, the basis for imputation for the MCMC method is at the subject level (average of the two eyes).
+Added: Both methods may be appropriate and, in this case, yield similar conclusions.
+Added: In certain data we have previously disclosed, we have presented analyses using the MCMC method with the individual eye as the basis for imputation.
+Added: However, the statistical analysis plan for each of the three Phase 3 trials specifies that the basis for imputation for the MCMC method should be the subject level.
+Added: Multiple other methods of imputation were also performed in some of the Phase 3 studies—including LOCF, baseline observation carried forward (BOCF), worse case observation (WCO), and observation only with no imputation—with similar clinical conclusions.
+Added: Primary Efficacy Endpoint – Eye Level Imputation
+Added: Mean Ocular Itching Scores Across All Studies
+Added: * Statistically Significant;
+Added: ITT + LOCF (Phase 2) & ITT + MCMC (Phase 3)
+Added: Primary Efficacy Endpoint – Subject Level Imputation
+Added: Mean Ocular Itching Scores Across All Studies
+Added: * Statistically Significant;
+Added: ITT + LOCF (Phase 2) & ITT + MCMC (Phase 3)
Regulatory Pathway
−Removed: We are not currently pursuing DEXTENZA for the treatment of episodic dry eye disease but have identified clinical and regulatory pathways for the program’s potential advancement.
−Removed: If we were to advance the program, we would expect to initiate a Phase 2 clinical trial to evaluate DEXTENZA for the treatment of flares due to dry eye, which we refer to as episodic dry eye disease.
−Removed: We would then be required to successfully complete two well-controlled Phase 3 clinical trials conducted under an IND to obtain marketing approval from the FDA.
−Removed: If we were to obtain favorable results from these two pivotal clinical trials, we would expect to submit an sNDA under Section 505(b)(2) of the FDCA.
−Removed: See “—Government Regulation—Section 505(b)(2) NDAs”
−Removed: for additional information.
−Removed: Clinical Trial for DEXTENZA in Pediatric Subjects
−Removed: We are also planning to evaluate DEXTENZA in pediatric subjects that are 0 to 3 years of age undergoing cataract surgery beginning in the second half of 2020.
−Removed: The planned pediatric trial is a post-approval commitment to the FDA.
−Removed: Travoprost Intracanalicular Insert (OTX-TP)
−Removed: Our OTX-TP product candidate incorporates the PGA travoprost as an active pharmaceutical ingredient in our proprietary intracanalicular insert.
−Removed: We are developing OTX-TP for the treatment of glaucoma and ocular hypertension.
−Removed: We have completed Phase 2a and Phase 2b clinical trials of OTX-TP, and we reported topline efficacy results of a Phase 3 trial in May 2019.
−Removed: Travoprost is a synthetic PGA that reduces IOP by enhancing the clearance and drainage of ocular fluid.
−Removed: We selected travoprost as the active pharmaceutical ingredient for OTX-TP because it:
−Removed: is approved by the FDA for the treatment of glaucoma and ocular hypertension;
−Removed: has relevant patent protection that expired in December 2014;
−Removed: is a highly potent PGA molecule;
+Added: In the fourth quarter of 2020, w e submitted an sNDA for DEXTENZA under Section 505(b)(2) of the FDCA (See “—Government Regulation—Section 505(b)(2) NDAs” for additional information) to include the treatment of ocular itching associated with allergic conjunctivitis as an additional approved indication.
+Added: The FDA has accepted our sNDA for filing and has established a target action date under PDUFA of October 18, 2021.
+Added: We believe that the totality of the efficacy and safety data across the Phase 2 trial and the three Phase 3 trials (n = 323 subjects), as well as the safety data associated with the prior approval of DEXTENZA for the treatment of inflammation and pain following ophthalmic surgery, represent a strong data package in support of the sNDA.
+Added: If our sNDA is approved, we expect to launch DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis in the first half of 2022.
+Added: Post-Surgical Ocular Inflammation and Pain
+Added: DEXTENZA (dexamethasone intracanalicular insert)
+Added: DEXTENZA incorporates the FDA-approved corticosteroid dexamethasone as a preservative-free active pharmaceutical ingredient into a hydrogel, drug-eluting intracanalicular insert.
+Added: Following FDA approval, we commercially launched DEXTENZA for the treatment of post-surgical inflammation and pain in July 2019.
+Added: We selected dexamethasone as the active pharmaceutical ingredient for DEXTENZA because it:
+Added: ● is approved by the FDA and has a long history of ophthalmic use;
+Added: ● is available on a generic basis;
+Added: ● is highly potent and is typically prescribed for prevention of ocular inflammation and pain following ocular surgery;
● is available from multiple qualified suppliers;
● has physical properties that are well suited for incorporation within our hydrogel technology.
−Removed: We have designed OTX-TP to deliver therapeutic levels of travoprost for up to three months.
−Removed: We have tested versions of OTX-TP that are capable of local programmed-release over a one-month, a two-month and a three-month period.
−Removed: The retention time of our intracanalicular inserts varies from patient-to-patient due to various physiological and anatomical factors to which the intracanalicular inserts may be subjected.
−Removed: We have conducted a series of non-significant risk, or NSR, investigational device exemption, or IDE, studies with improved product designs and placement procedures with the goal of achieving higher retention rates.
−Removed: We have achieved successive improvements in retention, with as high as a 92% retention rate at day 90 in one of these NSR studies.
−Removed: Our completed pilot studies evaluated one-month and two-month versions of OTX-TP.
−Removed: In our Phase 2a clinical trial, we evaluated two-month and three-month versions of OTX-TP.
−Removed: In our Phase 2b clinical trial, we evaluated an improved three-month version of OTX-TP.
−Removed: In our pilot studies, the OTX-TP inserts we evaluated were violet to provide a visual assessment of insert position.
−Removed: In our subsequent Phase 2 clinical trials, we switched to a fluorescent yellow color to improve visibility and are using this same fluorescent marker in our Phase 2b clinical trial.
−Removed: In addition to the PEG-based hydrogel, OTX-TP contains bioresorbable microparticles which contain encapsulated travoprost.
−Removed: We designed OTX-TP to deliver travoprost at therapeutic levels for the duration of therapy as the microparticles degrade.
−Removed: We provide OTX-TP in a sterile, single use package without any added preservatives.
−Removed: Overview of OTX-TP Clinical Development
−Removed: We are conducting clinical development of OTX-TP for glaucoma and ocular hypertension.
−Removed: Because OTX-TP incorporates an active pharmaceutical ingredient already approved by the FDA for the treatment of glaucoma and ocular hypertension, we did not need to conduct Phase 1 clinical trials for this product candidate.
−Removed: However, we did conduct two pilot studies to assess safety and to obtain initial efficacy data.
−Removed: The following summarizes our clinical development to date for OTX-TP.
−Removed: In 2012, we conducted two pilot studies evaluating the safety and efficacy of two versions of OTX-TP for the treatment of glaucoma and ocular hypertension over a 30 to 60 day period.
−Removed: In 2014, we completed a Phase 2a clinical trial of two versions of OTX-TP for the treatment of glaucoma and ocular hypertension to evaluate reduction in IOP over a 60 to 90 day period.
−Removed: This completed trial provided important information regarding the effects in patients of the drug delivery rates for our inserts that informed the design of the OTX-TP insert that we used in our Phase 2b clinical trial for this indication.
−Removed: In the November 2014, we initiated a Phase 2b clinical trial of OTX-TP for the treatment of glaucoma and ocular hypertension to evaluate reduction in IOP over a 60 to 90 day period.
−Removed: We reported topline efficacy results from this trial in October 2015.
−Removed: There were no hyperemia-related adverse events noted in any of the patients treated with OTX-TP.
−Removed: Further, there have been no serious adverse events observed to date in the Phase 2b trial.
−Removed: Adverse events noted include punctal stenosis, punctal trauma and canaliculitis.
−Removed: We have conducted NSR studies on additional modified intracanalicular insert design.
−Removed: We met with the FDA in the second quarter of 2016 to discuss alternative Phase 3 clinical trial designs and to formulate our plans for our Phase 3 program.
−Removed: Based on feedback we received from the FDA, we initiated a Phase 3 clinical trial in September 2016.
−Removed: We reported topline efficacy results from this trial in May 2019.
−Removed: No serious adverse events have been reported in connection with this trial.
−Removed: Adverse events observed include dacryocanaliculitis and lacrimal structure disorder.
−Removed: The trial design for the initial Phase 3 clinical trial includes an OTX-TP treatment arm and a placebo-controlled comparator arm using a non-drug-eluting insert.
−Removed: No timolol comparator or validation arm will be required in the study design and no eye drops, placebo or active, are being administered in either arm.
−Removed: We expect that the FDA will require that OTX-TP show both a statistically superior reduction of IOP, when compared to the placebo, as a primary efficacy endpoint, and a clinically meaningful reduction of IOP in the absolute.
−Removed: The primary efficacy endpoint will be evaluated at 2 weeks, 6 weeks and 12 weeks at 8:00 a.m., 10:00 a.m.
−Removed: and 4:00 p.m.
−Removed: at each of the three timepoints.
−Removed: Clinical Trials for Glaucoma and Ocular Hypertension
−Removed: Completed Singapore Pilot Study
−Removed: In 2012, we completed a prospective, single arm, open-label pilot study evaluating the initial safety and efficacy of the one-month version of OTX-TP for the treatment of glaucoma and ocular hypertension.
−Removed: We conducted this trial in 17 patients, and in 26 eyes, at two sites in Singapore.
−Removed: We enrolled patients in this trial who were at least 21 years of age with a documented diagnosis of ocular hypertension or open-angle glaucoma, baseline IOP within a specified range and a specified minimum level of visual acuity in each eye.
−Removed: The trial protocol provided that if the participant’s IOP was high despite treatment with OTX-TP, rescue medication would be made available to the patient.
−Removed: For patients who were currently under treatment for ocular hypertension or glaucoma, we required a drug washout period for these medications between screening and first visit.
−Removed: We evaluated patients at days 3, 10, 20 and 30 following insertion of the insert and made the following assessments:
−Removed: mean IOP at 8:00 a.m.
−Removed: at each evaluation date as measured in millimeters of mercury, or mmHg;
−Removed: mean IOP at 10:00 a.m.
−Removed: and 4:00 p.m.
−Removed: at days 10, 20 and 30;
−Removed: change in mean IOP from baseline at each time point measured;
−Removed: retention of the insert in the canaliculus at days 10, 20 and 30.
−Removed: We assessed IOP at multiple time points on each evaluation date because IOP naturally varies over the course of the day.
−Removed: For patients who are affected bilaterally, if both eyes met all eligibility criteria, both eyes were treated, but only the eye with the higher mean IOP at baseline was included in the efficacy analysis.
−Removed: On day 10, 100% of the inserts were visualized, on day 20, 88% of the inserts were visualized, and on day 30, 79% of the inserts were visualized.
−Removed: We observed a clinically meaningful reduction in mean IOP over the 30 day trial period.
−Removed: For eyes that retained the insert, from a mean baseline IOP of 27.2 mmHg, the mean IOP during treatment was maintained at or below 22 mmHg at each evaluation date and time point.
−Removed: The mean reduction in IOP from baseline ranged from 5.3 mmHg (20%) to 8.2 mmHg (30%) across all evaluation dates and time points.
−Removed: In studies conducted by third parties, a sustained 5.0 mmHg reduction in IOP reduced risk of disease progression by approximately 50%.
−Removed: The results for change in mean IOP from baseline at 8:00 a.m.
−Removed: on each evaluation date are set forth in the graph below.
−Removed: In this trial, there were no serious adverse events or unanticipated adverse events.
−Removed: There was only one adverse event, bilateral epiphora, or excess tearing of both eyes, which was transient in nature and completely resolved after insert removal.
−Removed: There were no significant changes in hyperemia scores from baseline through day 30.
−Removed: There were no notable observations of clinical relevance among the slit lamp biomicroscopy assessments.
−Removed: Completed South Africa Pilot Study
−Removed: In 2012, we completed a prospective, single arm, open-label pilot study evaluating the initial safety and efficacy of the two-month version of OTX-TP for the treatment of glaucoma and ocular hypertension.
−Removed: We conducted this trial in 20 patients, and in 36 eyes, at two sites in South Africa.
−Removed: Enrollment criteria were comparable to our Phase 1 Singapore trial described above, except that the minimum patient age was 18.
−Removed: We evaluated patients at days 3, 15, 30, 45 and 60 following insertion of the insert and made the same assessments with respect to mean IOP, change in mean IOP from baseline and retention of the insert in the canaliculus at each evaluation date following day 3 as in our Phase 1 Singapore trial described above.
−Removed: On day 15, 97% of the inserts were retained, on day 30, 92% of the inserts were visualized, on day 45, 78% of the inserts were retained, and on day 60, 59% of the inserts were retained.
−Removed: Because of the limitations of the visualization of the violet color through pigmented eyelids, it is possible that intracanalicular inserts identified as not being retained were in fact retained but not visible, particularly given the sustained reduction in IOP through day 60 described below.
−Removed: We have since eliminated the violet colorant in favor of a fluorescent PEG hydrogel, resulting in greatly improved visualization.
−Removed: We observed a clinically meaningful reduction in mean IOP over the 60 day trial period.
−Removed: For eyes that retained the insert, from a mean baseline IOP of 28.7 mmHg, the mean IOP during treatment was maintained at or below 22.0 mmHg beginning on day 15 and at all subsequent evaluation dates.
−Removed: The mean reduction in IOP from baseline ranged from 5.0 mmHg (18%) to 7.1 mmHg (25%) across all evaluation dates and time points.
−Removed: The results for change in mean IOP from baseline at 8:00 a.m.
−Removed: on each evaluation date are set forth in the graph below for patients who retained the insert on such date.
−Removed: There were only two cases in which IOP remained high even though the insert was confirmed to be present.
−Removed: In each of these cases, the investigator prescribed rescue medication at the end of the visit.
−Removed: It is possible that this elevated IOP was the result of the participants not responding to travoprost.
−Removed: In this trial, there were no serious adverse events or unanticipated adverse events.
−Removed: The most common adverse event was inflammatory reaction, which was noted in three patients.
−Removed: All adverse events were transient in nature and completely resolved by the end of the trial.
−Removed: There were no significant changes in hyperemia scores from baseline through day 60.
−Removed: There were no notable observations of clinical relevance among the slit lamp biomicroscopy assessments.
−Removed: Completed South Africa Phase 2a Clinical Trial
−Removed: In May 2014, we completed a prospective, randomized, multi-arm, active-controlled, multicenter, double masked Phase 2 clinical trial evaluating the safety and efficacy of two versions of OTX-TP for the treatment of glaucoma and ocular hypertension.
−Removed: The OTX-TPa version was intended to release travoprost over a two-month period, and the OTX-TPb version was intended to release travoprost at a slower rate over a three-month period.
−Removed: Based on in vitro testing, the OTX-TPa version had an average daily drug delivery rate of 3.5 micrograms per day and the OTX-TPb version had an average daily drug delivery rate of 2.8 micrograms per day.
−Removed: We conducted this trial in 41 patients at four sites in South Africa.
−Removed: In this trial, we randomized 11 patients for treatment with OTX-TPa and placebo eye drops, 17 patients for treatment with OTX-TPb and placebo eye drops and 13 patients for treatment with a placebo vehicle control intracanalicular insert without active drug and timolol eye drops.
−Removed: One patient randomized into the timolol group was excluded from the trial because the investigator was unable to insert the insert.
−Removed: We randomized more patients in the OTX-TPb group than in the OTX-TPa group because we ceased enrolling patients in the OTX-TPa group during the trial based on an amendment to our trial protocol intended to facilitate the completion of the trial and to allow us to evaluate a larger number of patients being treated with a three-month version of the insert.
−Removed: Timolol is the most commonly prescribed non-PGA drug for the treatment of glaucoma and has been used as a comparator drug in pivotal clinical trials for other approval glaucoma products.
−Removed: The primary efficacy endpoints in this trial are differences between treatment groups in:
−Removed: mean change in IOP from baseline on each evaluation date and at each time point;
−Removed: mean percent change in IOP from baseline on each evaluation date and at each time point;
−Removed: mean IOP on each evaluation date and at each time point.
−Removed: We designed our Phase 2a clinical trial to assess clinically meaningful response to treatment, and did not power the trial to measure any efficacy endpoints with statistical significance.
−Removed: We also evaluated retention of the insert as a secondary endpoint.
−Removed: We enrolled patients in this trial who were at least 18 years of age with a documented diagnosis of ocular hypertension or open-angle glaucoma, baseline IOP within a specified range and a specified minimum level of visual acuity in each eye.
−Removed: We excluded patients from this trial if, among other reasons, they had a history of inadequate response to treatment with prostaglandins or beta-blockers.
−Removed: For patients who were currently under treatment for ocular hypertension or glaucoma, we required a drug washout period for these medications between screening and first visit.
−Removed: We evaluated patients at days 3, 15, 30, 45, 60, 75 and 90 following insertion of the insert and made the following assessments:
−Removed: mean IOP at 8:00 a.m.
−Removed: at each evaluation date;
−Removed: mean IOP at 12:00 p.m.
−Removed: and 4:00 p.m.
−Removed: at days 30, 60 and 90;
−Removed: change in mean IOP from baseline at each time point measured;
−Removed: retention of the insert in the canaliculus at each evaluation date.
−Removed: For patients who are affected bilaterally, if both eyes met all eligibility criteria, both eyes were treated, but only the eye with the higher mean IOP at baseline was included in the primary efficacy analysis.
−Removed: We evaluated safety in all patients at each study visit with an assessment of general eye conditions, including visual acuity, along with any adverse events.
−Removed: In the timolol group, for eyes that retained the insert, from a mean baseline IOP of 26.1 mmHg, the mean IOP during treatment was maintained at or below 21.4 mmHg beginning on day 15 and at all subsequent evaluation dates and time points.
−Removed: The mean reduction in IOP from baseline ranged from 3.2 mmHg (13%) to 6.4 mmHg (25%) across all evaluation dates and time points through day 75.
−Removed: In the OTX-TPa group, for eyes that retained the insert, from a mean baseline IOP of 25.8 mmHg, the mean IOP during treatment was maintained at or below 21.0 mmHg beginning on day 15 and at all subsequent evaluation dates and time points through day 75.
−Removed: The OTX-TPa formulation, originally intended to deliver drug over a two-month period, exceeded our expectations, delivering drug for 75 days.
−Removed: The mean reduction in IOP from baseline ranged from 3.2 mmHg (14%) to 6.0 mmHg (24%) across all evaluation dates and time points through day 75.
−Removed: In OTX-TPb group, for eyes that retained the insert, from a mean baseline IOP of 26.4 mmHg, the mean IOP during treatment was maintained at or below 22.2 mmHg beginning on day 15 and at all subsequent evaluation dates and time points.
−Removed: The mean reduction in IOP from baseline ranged from 2.0 mmHg (9%) to 5.4 mmHg (20%) across all evaluation dates and time points.
−Removed: The results for change in mean IOP for patients in the OTX-TPa group, for patients in the OTX-TPb group and for patients in the timolol group from baseline at 8:00 a.m.
−Removed: on each applicable evaluation date are set forth in the graph below, in each case for patients who retained the insert on such date.
−Removed: We believe that the lower average daily drug delivery rate in the OTX-TPb group may have resulted in less reduction of mean IOP in this group as compared to the OTX-TPa group.
−Removed: As discussed below, we evaluated an improved three-month version of OTX-TP in our Phase 2b clinical trial.
−Removed: In this trial, there were no serious adverse events.
−Removed: The most common adverse event was inflammatory reaction, which was noted in five patients.
−Removed: All adverse events were transient in nature and resolved by the end of the trial.
−Removed: There were no significant changes in hyperemia scores from baseline through day 90.
−Removed: There were no notable observations of clinical relevance among the slit lamp biomicroscopy assessments.
−Removed: Completed U.S.
−Removed: Phase 2b Clinical Trial
−Removed: In November 2014, we initiated a prospective, randomized, parallel-arm, active-controlled, multicenter, double-masked Phase 2b clinical trial to evaluate the safety and efficacy of OTX-TP for the treatment of glaucoma and ocular hypertension after submitting an IND to the FDA for this indication.
−Removed: We treated 73 patients at 11 sites in the United States pursuant to our effective IND.
−Removed: We randomized patients in a 1:1 ratio to receive either OTX-TP and placebo eye drops or a placebo vehicle control intracanalicular insert without active drug and eye drops containing timolol.
−Removed: Patients were instructed to use the placebo drops or timolol drops twice daily for the duration of the trial.
−Removed: Based on the results of our completed Phase 2a clinical trial, we designed the OTX-TP insert for use in our Phase 2b clinical trial to deliver drug over a 90 day period at the same daily rate as the OTX-TPa insert used in the Phase 2a clinical trial.
−Removed: To achieve this, we modified the design of the OTX-TP insert to enlarge it in order to enable the insert to carry a greater amount of drug.
−Removed: These structural changes were previously evaluated in NSR studies that we describe below.
−Removed: The primary efficacy endpoint in this trial was the difference between treatment groups in the mean change in IOP from baseline at day 60 following insertion of the intracanalicular insert, calculated by averaging the change from baseline across the three time points at the assessment date, which is known as diurnal IOP.
−Removed: The secondary efficacy endpoints in this trial were the difference between treatment groups in the mean change from baseline in average diurnal IOP at day 90, the difference between treatment groups in the mean change from baseline in IOP at each individual time point at day 60 and day 90, the difference between treatment groups in the mean change in average diurnal IOP and IOP at each individual time point at day 60 and day 90, and the difference between treatment groups in the mean percent change from baseline in average diurnal IOP and IOP at each individual time point at day 60 and 90.
−Removed: We designed our Phase 2b clinical trial to assess clinically meaningful response to treatment, and did not power the trial to measure any efficacy endpoints with statistical significance.
−Removed: We enrolled patients in this trial who are at least 18 years of age with a documented diagnosis of ocular hypertension or open-angle glaucoma, baseline IOP within a specified range and a specified minimum level of visual acuity in each eye.
−Removed: We excluded patients from this trial if, among other reasons, they had a history of inadequate
−Removed: response to treatment with prostaglandins or beta-blockers.
−Removed: For patients under treatment for ocular hypertension or glaucoma, we required a drug washout period for these medications between screening and first visit.
−Removed: We also evaluated the effect of a four week versus a five week washout duration on the change in 8:00 a.m.
−Removed: IOP in both groups.
−Removed: We evaluated patients at days 3, 15, 30, 45, 60, 75 and 90 (with insertion of the insert on day 1) and made the following assessments:
−Removed: mean IOP and change in mean IOP from baseline at 8:00 a.m.
−Removed: at days 3, 15, 45 and 75;
−Removed: mean IOP and change in mean IOP from baseline at 8:00 a.m., 12:00 p.m.
−Removed: and 4:00 p.m.
−Removed: at days 30, 60 and 90.
−Removed: We also collected data on intracanalicular insert presence along with visualization of the insert by both the study patient and the investigator.
−Removed: The patients were instructed to assess insert presence on a daily basis and report the absence of an insert immediately.
−Removed: This data has provided a method for us to assess the accuracy of patient self-examination for insert presence, and we expect that this will maximize the consistency of dosing.
−Removed: We evaluated safety in all patients at each study visit with an assessment of general eye conditions, including visual acuity, along with any adverse events.
−Removed: In this trial, the mean change from baseline IOP at 8:00 a.m.
−Removed: on day 30, 60, and 90 in the OTX-TP group was a decrease of 4.5, 4.7, and 5.1 mm Hg, respectively.
−Removed: In this trial, on day 60, the OTX-TP group experienced a mean diurnal IOP lowering effect of 3.3 mmHg compared to baseline, versus mean diurnal IOP lowering of 5.9 mmHg compared to baseline for the timolol group.
−Removed: On day 90, the OTX-TP group experienced a mean diurnal IOP lowering effect of 3.6 mmHg compared to baseline, versus mean diurnal IOP lowering of 6.3 mmHg compared to baseline for the timolol group.
−Removed: On day 60, the OTX-TP group experienced a mean IOP lowering effect compared to baseline of 4.7 mmHg at 8:00 a.m., 2.3 mmHg at 12:00 p.m.
−Removed: and 2.8 mmHg at 4:00 p.m., versus mean IOP lowering compared to baseline of 6.4 mmHg at 8:00 a.m., 6.1 mmHg at 12:00 p.m.
−Removed: and 5.6 mmHg at 4:00 p.m.
−Removed: for the timolol group.
−Removed: On day 90, the OTX-TP group experienced a mean IOP lowering effect compared to baseline of 5.1 mmHg at 8:00 a.m., 2.5 mmHg at 12:00 p.m.
−Removed: and 3.0 mmHg at 4:00 p.m., versus a mean IOP lowering effect compared to baseline of 7.2 mmHg at 8:00 a.m., 6.1 mmHg at 12:00 p.m.
−Removed: and 5.5 mmHg at 4:00 p.m.
−Removed: for the timolol group.
−Removed: The mean IOP in the OTX-TP treatment group on day 60 was 21.73 mmHG at 8:00 a.m., 22.27 mmHg at 12:00 p.m.
−Removed: and 21.42 mmHg at 4:00 p.m.
−Removed: In the timolol group, the mean IOP on day 60 was 20.74 mmHg at 8:00 a.m., 19.05 mmHg at 12:00 p.m.
−Removed: and 18.85 mmHg at 4:00 p.m.
−Removed: The mean IOP in the OTX-TP treatment group on day 90 was 21.33 mmHg at 8:00 a.m., 22.09 mmHg at 12:00 p.m.
−Removed: and 21.18 mmHg at 4:00 p.m.
−Removed: In the timolol group, the mean IOP on day 90 was 19.87 mmHg at 8:00 a.m., 19.08 mmHg at 12:00 p.m.
−Removed: and 18.95 mmHg at 4:00 p.m.
−Removed: The mean diurnal IOP in the OTX-TP treatment group on day 60 was 21.81 mmHg.
−Removed: The mean diurnal IOP in the timolol treatment group on day 60 was 19.54 mmHg.
−Removed: The mean diurnal IOP in the OTX-TP treatment group on day 90 was 21.53 mmHg.
−Removed: The mean diurnal IOP in the timolol treatment group on day 90 was 19.3 mmHg.
−Removed: This Phase 2b glaucoma clinical trial was designed to evaluate the non-inferiority of OTX-TP compared to timolol and to inform the further clinical development for OTX-TP.
−Removed: This trial was not powered to show statistical significance between treatment groups.
−Removed: The OTX-TP treatment group included placebo eye drops that may have reduced the efficacy measures for OTX-TP, by washing out drug eluted from the insert from the ocular surface, whereas the timolol group included a placebo insert that may have improved the efficacy of timolol through occlusion of the punctum thereby prolonging its retention on the ocular surface.
−Removed: Several peer-reviewed medical journals have reported studies in which an additional IOP lowering effect of 1.32 to 1.80 mmHg was observed in patients taking timolol eye drops in combination with a non-drug eluting punctum plug compared to those patients only taking timolol eye drops.
−Removed: These include studies
−Removed: reported in September 2011 in Clinical and Experimental Optometry , February 1989 in the American Journal of Ophthalmology and August 1996 in Acta Ophthalmologica Scandinavica .
−Removed: The expected design for our Phase 3 clinical trials of OTX-TP for the treatment of glaucoma and ocular hypertension is addressed below under “—Regulatory Pathway”.
−Removed: In the timolol group, the mean IOP at day 30, 60 and 90 at all time points ranged from 18.9 mmHg to 20.7 mmHg.
−Removed: The mean reduction in IOP from baseline at day 30, 60 and 90 at all time points ranged from 5.3 mmHg to 7.3mmHg.
−Removed: In the OTX-TP group, the mean IOP at day 30, 60 and 90 at all time points ranged from 21.0 mmHg to 22.3 mmHg.
−Removed: The mean reduction in IOP from baseline at day 30, 60 and 90 at all time points ranged from 2.3 mmHg to 5.2 mmHg.
−Removed: In our completed South Africa Phase 2a clinical trial in which OTX-TP intracanalicular inserts were inserted in 36 eyes in 20 patients with no placebo eye drops used, on day 30 we observed a reduction in IOP of 6.1 mmHg at 8:00 a.m., 5.1 mmHg at 12:00 p.m.
−Removed: and 5.6 mmHg at 4:00 p.m.
−Removed: following insertion of the intracanalicular insert.
−Removed: In this trial, on day 60 we observed a reduction in IOP of 6.7 mmHg at 8:00 a.m., 5.1 mmHg at 12:00 p.m.
−Removed: and 4.3 mmHg at 4:00 p.m.
−Removed: following insertion of the intracanalicular insert.
−Removed: The diurnal averages of the reduction in the IOP were 5.6 mmHg at day 30 and 5.4 mmHg at day 60 in this trial.
−Removed: We believe that the higher IOP reduction observed in this trial may be due in part to the lack of placebo eye drops.
−Removed: We performed additional post-hoc analyses that were not pre-specified in the trial protocol for the Phase 2b glaucoma clinical trial to provide further insight on the performance of OTX-TP.
−Removed: Although post-hoc analyses performed using an unlocked clinical trial database can result in the introduction of bias, we believe that these analyses provide important information regarding our OTX-TP product candidate and are helpful in determining the study population and inclusion and exclusion criteria for future clinical trials.
−Removed: When we excluded patients on more than one glaucoma medication and used the baseline of five weeks of washout for comparisons of the OTX-TP group and the timolol group, the differences in mean reduction in IOP between the OTX-TP treatment group and the timolol group at the 8:00 a.m.
−Removed: time point on day 30, 60 and 90 narrowed to an average of 1.1 mmHg from an average of 2.2 mmHg based on the pre-specified criteria.
−Removed: These results are shown in the table below:
−Removed: 8:00 am Results for Intraocular Pressure (mmHg)
−Removed: Post-hoc analysis
−Removed: Intent to Treat
−Removed: Baseline of 5 weeks,
−Removed: single drug only
−Removed: In this trial, inserts were found to be retained in 91% of patients at day 60, 88% of patients at day 75 and 48% of patients at day 90, reflecting the corresponding absorption and clearance of the inserts with the duration of drug release.
−Removed: In this trial, there were no serious adverse events.
−Removed: Adverse events noted to date including punctal stenosis, punctal trauma and canaliculitis.
−Removed: The most common adverse event was inflammatory reaction of the lacrimal punctum and/or canaliculus, which was noted in five patients.
−Removed: These adverse events were transient in nature and resolved by the end of the trial.
−Removed: There were no significant changes in hyperemia scores from baseline through day 90 and there were no hyperemia related adverse events.
−Removed: There were no notable observations of clinical relevance among the slit lamp biomicroscopy assessments.
−Removed: Non-Significant Risk Retention Studies
−Removed: We conduct medical device NSR IDE studies on an ongoing basis for the purpose of refining our intracanalicular insert product and placement procedure.
−Removed: We conduct these NSR studies under FDA IDE regulations, although no specific FDA approval is required.
−Removed: We are able to conduct NSR studies because intracanalicular inserts without active drug are well established ophthalmic medical devices.
−Removed: The NSR study process allows us to make relatively quick evaluations of our intracanalicular insert design and placement procedure in human subjects.
−Removed: In a series of completed NSR studies, we have effected compositional and dimensional adjustments to our intracanalicular insert to optimize retention.
−Removed: We have also used these studies to evaluate intracanalicular insert placement, as well as removal and repeat placements and have seen a range of results in NSR studies to date, with the most recent study achieving a retention rate of approximately 85-90% at day 90.
−Removed: We are using an intracanalicular insert design in our Phase 3 clinical trials of OTX-TP for the treatment of glaucoma and ocular hypertension that is slightly smaller than the plug design used in the Phase 2b clinical trial.
−Removed: We also plan to use an intracanalicular insert design in these trials that has a rapidly dissolvable tip that enables greater ease of insertion of the insert.
−Removed: We believe that with the current level of retention with our intracanalicular insert design and given the ability of patients to assess the presence of the insert as a result of the fluorescent label, our current product design offers a potentially significant improvement over the current standard of care with patients receiving PGAs.
−Removed: The compliance rate with PGA eye drops has been shown to be only approximately 50% after six months of therapy due to the challenges of administration and side effects including hyperemia, or red eye.
−Removed: Completed U.S.
−Removed: Phase 3 Clinical Trial
−Removed: We initiated a randomized, double blind, placebo-controlled Phase 3 clinical trial in September 2016 based on feedback following discussions with the FDA in the second quarter of 2016, using a protocol design that focused on a comparison of the OTX-TP arm against a vehicle placebo arm.
−Removed: Patients were randomized in a 3:2 ratio to receive either OTX-TP or a placebo vehicle control intracanalicular insert without active drug.
−Removed: No timolol comparator or validation arm was required in the study design and no eye drops, placebo or active, were administered in either arm.
−Removed: In May 2019, we reported topline results of the Phase 3 clinical trial that was conducted at 49 sites and enrolled 554 subjects with open-angle glaucoma or ocular hypertension in the full analysis set, or FAS, population.
−Removed: The trial’s primary efficacy endpoint was an assessment of mean IOP at nine different time points:
−Removed: three diurnal time points (8:00 a.m., 10:00 a.m., and 4:00 p.m.) at each of 2, 6, and 12 weeks following insertion.
−Removed: The secondary endpoints included an evaluation of whether OTX-TP demonstrated a statistically superior mean reduction of IOP from baseline for OTX-TP treated-subjects compared with placebo insert-treated subjects (Table 1) at the same nine time points.
−Removed: Topline results show that the trial did not achieve its endpoint of statistically significant superiority in mean reduction of IOP compared with placebo at all nine time points.
−Removed: We enrolled patients in this trial who are at least 18 years of age with a documented diagnosis of ocular hypertension or open-angle glaucoma, baseline IOP within a specified range and a specified minimum level of visual acuity in each eye.
−Removed: We excluded patients from this trial if, among other reasons, they had a history of inadequate response to treatment with prostaglandins or beta-blockers.
−Removed: For patients under treatment for ocular hypertension or glaucoma, we required a drug washout period for these medications between screening and first visit.
−Removed: We evaluated patients at weeks 2, 4, 6, 8, 10 and 12 (with insertion of the insert on day 1) and made the following assessments:
−Removed: mean IOP at 8:00 a.m., 10:00 a.m.
−Removed: and 4:00 p.m.
−Removed: at weeks 2, 6, and 12;
−Removed: mean IOP at 8:00 a.m.
−Removed: at weeks 4, 8, and 10.
−Removed: We also collected data on intracanalicular insert presence along with visualization of the insert by both the study patient and the investigator.
−Removed: We evaluated safety in all patients at each study visit with an assessment of general eye conditions, including visual acuity, along with any adverse events.
−Removed: Topline results show that the trial did not achieve its endpoint of statistically significant superiority in mean reduction of IOP compared with placebo at all nine time points.
−Removed: OTX-TP treated subjects did have a greater reduction in IOP from baseline relative to placebo insert at all nine time points (Table 2), and these differences were statistically significant (p value < 0.05) for eight of the nine time points (Tables 2 and 3).
−Removed: The reductions from baseline
−Removed: for OTX-TP treated subjects in this trial ranged from 3.27-5.72 millimeters of mercury (mm Hg) across the nine time points with higher levels of intraocular pressure reduction seen at the earlier time points in this trial (Table 3) .
−Removed: Baseline Values
−Removed: OTX-TP (mm Hg)
−Removed: Placebo (mm Hg)
−Removed: Mean Intraocular Pressure Values
−Removed: FAS Population (OTX-TP=343 subjects, Placebo=211 subjects)
−Removed: Least Squares (LS) Means
−Removed: Reduction in Intraocular Pressure (Change from Baseline)
−Removed: Diurnal Time points
−Removed: FAS Population (OTX-TP=343 subjects, Placebo=211 subjects)
−Removed: Least Squares (LS) Means
−Removed: OTX-TP was generally well tolerated and no ocular serious adverse events were observed.
−Removed: The most common ocular adverse events seen in the study eye were dacryocanaliculitis (approximately 7.0% in OTX-TP vs.
−Removed: 3.0% in placebo) and lacrimal structure disorder (approximately 6.0% in OTX-TP vs.
−Removed: 4.0% in placebo).
−Removed: Regulatory Pathway
−Removed: In October 2019, we met with the FDA to discuss the topline data we reported from our completed Phase 3 trial.
−Removed: Our conversation with the FDA was productive and involved a discussion around the importance of compliance and how a product like OTX-TP could address the issue of non-compliance by delivering a prostaglandin analog formulated with our programmed release hydrogel to lower intraocular pressure for up to 12 weeks with a single insert.
−Removed: While the FDA did not feel that the data from this clinical trial met the standard of clinical meaningfulness in the population studied, there were constructive discussions about potential pathways forward in specific patient populations for whom drops are problematic.
−Removed: Based on feedback following discussions with the FDA in the fourth quarter of 2019, we do not intend to initiate the second Phase 3 clinical trial at this time without the assistance of a collaborative partner.
−Removed: We believe that if we were to find a partner for our OTX-TP program, we or such partner could decide to conduct additional Phase 2 clinical trials to address feedback from the FDA prior to another Phase 3 clinical trial.
−Removed: Given the potential use of OTX-TP as a chronic therapy, however, we have decided to continue an ongoing open-label, one-year safety extension study, generating six-month and one-year safety data for a limited number of subjects to support a potential future product registration.
−Removed: We anticipate data from this safety study including pharmacokinetic data later this year.
−Removed: If we were to obtain favorable results from future Phase 3 clinical trials, we would plan to submit an NDA to the FDA for marketing approval of OTX-TP for the treatment of glaucoma and ocular hypertension.
−Removed: We expect that we
−Removed: would submit this NDA under Section 505(b)(2) of the FDCA.
−Removed: See “—Governmental Regulation—Section 505(b)(2) NDAs”
−Removed: for additional information.
−Removed: Intracameral Glaucoma (OTX-TIC) Product Candidate
−Removed: We are conducting an open-label, proof-of-concept Phase 1 clinical trial of OTX-TIC that we initiated in the second quarter of 2018 for the treatment of patients with moderate to severe glaucoma and ocular hypertension.
−Removed: OTX-TIC (extended-delivery travoprost) is a bioresorbable hydrogel implant incorporating travoprost that is designed to be an intracameral injection into the anterior chamber of the eye with an initial target duration of drug release of four to six months.
−Removed: Preclinical studies to date have demonstrated clinically meaningful IOP lowering and good pharmacokinetics in the aqueous humor.
−Removed: We initiated a pilot clinical study outside the United States in the third quarter of 2017 to assess safety and obtain initial efficacy data, but did not enroll any patients in this clinical trial and determined to close this trial.
−Removed: We submitted an IND in the first quarter of 2018 and initiated a second Phase 1 trial in the United States in the second quarter of 2018.
−Removed: The study is a prospective, multi-center, open-label, dose escalation study to evaluate the safety, biological activity, durability and tolerability of OTX-TIC compared to topical travoprost (eye drops) in patients with open-angle glaucoma or ocular hypertension.
−Removed: We presented initial results from the first cohort, comprised of five patients, in this clinical trial at the Association of Research and Vision of Ophthalmology (ARVO) meeting in April 2019 and the American Society of Cataract and Refractive Surgery annual meeting in May 2019.
−Removed: This data demonstrated that, with a single implant, subjects were able to achieve IOP lowering for up to thirteen months at a level least as good as standard of care topical eye drop that was placed in each subject’s non-study eye.
−Removed: In addition, the hydrogel carrier, as designed, biodegraded in five to seven months.
−Removed: There were no clinically meaningful changes in corneal health as measured by endothelial cell evaluation and corneal pachymetry.
−Removed: Several subjects reported low grade inflammation and peripheral anterior synechiae that we believe may be addressable with modifications to the implants.
−Removed: At the Glaucoma 360 meeting in February of 2020, we presented results from the first two of four patient cohorts in the Phase 1 clinical trial.
−Removed: Data from the first two fully-enrolled cohorts (cohort 1 = 5 subjects, cohort 2 = 4 subjects) shows a clinically meaningful reduction from baseline in mean IOP values at the 8 a.m.
−Removed: timepoint in patients treated with a single insertion of OTX-TIC throughout the six-month study period.
−Removed: The data also shows that the mean IOP values at the 8 a.m.
−Removed: timepoint remained decreased from the baseline values beyond the study period and, in one patient, for up to eighteen months at the time of assessment.
−Removed: Mean IOP Change from Baseline at 8:00 a.m.
−Removed: Mean IOP Change from Baseline at 8:00 a.m.
−Removed: Overall, OTX-TIC was generally well-tolerated and observed to have a favorable safety profile, and no serious adverse events were reported.
−Removed: No changes in corneal health were noted as measured by slit lamp examination, corneal
−Removed: pachymetry and endothelial cell count evaluation.
−Removed: Eight ocular adverse events were reported, with the most frequent being iritis.
−Removed: The implant biodegraded consistently in approximately five to seven months.
−Removed: We continue to collect additional data from the first two cohorts and have begun enrollment in the third and fourth cohort to assess the impact of a faster degrading implant with the same therapeutic dose as administered in cohort one.
−Removed: We have also developed an additional formulation to test a smaller implant of OTX-TIC and expect to evaluate this formulation in a fourth cohort of this clinical trial in the future.
−Removed: We are currently collecting additional data from the first two cohorts and have begun enrolling a third cohort to assess the impact of a faster degrading implant with the same therapeutic dose as administered in cohort one.
−Removed: We have developed an additional formulation to test a smaller implant of OTX-TIC and expect to evaluate this formulation in a fourth cohort of this clinical trial in the future.
−Removed: Regulatory Pathway
−Removed: We anticipate that our ongoing Phase 1 clinical trial of OTX-TIC will provide important information to inform the design of later stage clinical trials of this product candidate.
−Removed: If our Phase 1 clinical trial were successful, we would expect to initiate a Phase 2 clinical trial to evaluate OTX-TIC for the treatment of open-angle glaucoma and ocular hypertension.
−Removed: We would then be required to successfully complete two well controlled Phase 3 clinical trials conducted under an IND to obtain marketing approval from the FDA.
−Removed: If we were to obtain favorable results from these two pivotal clinical trials, we would plan to submit an NDA to the FDA for marketing approval of OTX-TIC for such indication.
−Removed: We expect that we would submit this NDA under Section 505(b)(2) of the FDCA.
−Removed: See “—Government Regulation—Section 505(b)(2) NDAs.”
−Removed: Intravitreal Implants for the Treatment of Back-of-the-Eye Diseases
−Removed: We are engaged in a preclinical development program of our sustained-release hydrogel administered via intravitreal injection to address the large and growing markets for diseases and conditions of the back of the eye.
−Removed: Our current development efforts are focused on the use of our sustained-release hydrogel in combination with anti-angiogenic compounds, including anti-VEGF compounds, for the treatment of wet AMD.
−Removed: Our initial implants have delivered both small and large molecule anti-VEGF compounds in vitro over our targeted four to six month period, which we believe could make it possible to reduce the frequency of the current monthly or bi-monthly intravitreal injection regimen for wet AMD.
−Removed: In addition, our preclinical studies have demonstrated a sustained pharmacodynamic effect in vivo of up to six months with a small molecule tyrosine kinase inhibitor (TKI).
−Removed: The two strategies being pursued are as follows:
−Removed: We are evaluating an intravitreal implant, in collaboration with Regeneron, consisting of a PEG-based hydrogel matrix containing embedded micronized particles of aflibercept.
−Removed: Aflibercept is marketed by Regeneron under the brand name Eylea.
−Removed: We refer to the formulation we are developing with Regeneron as OTX-IVT.
−Removed: We designed the injection to be delivered to the vitreous chamber of the eye using a fine gauge needle.
−Removed: We entered into a strategic collaboration with Regeneron in October 2016 for the development and commercialization of protein-based anti-VEGF drugs, with the initial product candidate incorporating the drug aflibercept into our hydrogel.
−Removed: In December 2017, we delivered to Regeneron a proposed final formulation for the initial preclinical tolerability study.
−Removed: Regeneron initiated the preclinical study in early 2018.
−Removed: We and Regeneron have subsequently reached an understanding that the proposed formulation was not final and have ceased development of it.
−Removed: We are currently in discussions with Regeneron, in accordance with the terms of the Collaboration Agreement, regarding the development of an alternative formulation.
−Removed: We have selected the TKI, axitinib, referred to as OTX-TKI, and advanced the product candidate into an initial human clinical trial and dosed our first patient in Australia in February 2019.
−Removed: We have conducted preclinical work on this compound and have achieved local programmed-release and pharmacodynamic effect in vivo for six months .
−Removed: We believe this class of drugs is well suited for use with our platform given its high potency, multi-target capability, and compatibility with a hydrogel vehicle.
−Removed: In the absence of a sophisticated drug delivery system, these drugs have been difficult to deliver to the eye for acceptable time frames at
−Removed: therapeutic levels without causing local and systemic toxicity due to low drug solubility and very short half-lives in solution.
−Removed: We believe our local programmed-release drug delivery technology gives us potential advantages in this regard.
−Removed: By selecting a compound that is compatible with our hydrogel platform technology and that will have expiration of relevant patents within the timeline of our development program, we avoid the need to license the TKI molecule, thus retaining full worldwide rights to any products we develop.
−Removed: In Vitro and Preclinical results
−Removed: To date, in in vitro tests and preclinical studies, we have been able to incorporate antibody anti-VEGF drugs within our hydrogels, and our collaborators have been testing release rates and the integrity and activity of their compounds.
−Removed: We have achieved in vitro release over a four to six month duration.
−Removed: The released proteins have been stable, with no chemical or functional changes observed.
−Removed: Our hydrogel implants have shown initial tolerability and acceptable pharmacokinetics.
−Removed: We conducted an in vivo study to measure ocular tissue concentrations of bevacizumab after injection with and without our sustained-release hydrogel.
−Removed: The injection of a bevacizumab formulation without our hydrogel resulted in a first-order rate of drug clearance, as expected.
−Removed: In addition, bevacizumab concentrations decreased in the ocular tissues with distance from the intravitreal injection site.
−Removed: The injection of our hydrogel implant containing bevacizumab showed the same decrease of tissue concentration of bevacizumab in successively distant tissues.
−Removed: However, the injection of our hydrogel implant containing bevacizumab resulted in a sustained level of drug over the course of the 30 day study.
−Removed: Further, after injection of our hydrogel implant containing bevacizumab, we observed levels of drug in ocular tissues over the course of the study that were consistent with our in vitro release data.
−Removed: After two weeks, the drug concentrations of the implant exceeded those of bevacizumab injected without our hydrogel.
−Removed: More recently, we have conducted a pharmacodynamic study in a rabbit model, achieving activity against an intravitreal VEGF challenge injection after study duration of four months, compared to less than six weeks for a 1.25 mg (human dose) bevacizumab intravitreal injection.
−Removed: Tolerability of bevacizumab-loaded implants in rabbit eyes has been demonstrated through four months.
−Removed: In addition, there were no anti-drug antibodies detected in these rabbits, even though bevacizumab is a recombinant humanized monoclonal antibody and therefore might be expected to elicit an immune response in rabbits.
−Removed: This early feasibility study has provided us with initial encouraging data for our sustained-release hydrogel implant with bevacizumab and its potential capability of delivering active drug to ocular tissues in a local programmed-release fashion and informs the additional preclinical activities we plan to pursue.
−Removed: Although these results have been encouraging, we will need to further optimize our hydrogels for aflibercept in our collaboration with Regeneron.
−Removed: We believe we have demonstrated initial feasibility sufficient to support the continuing preclinical development of this program and, if we obtain additional favorable preclinical results, advancement into Phase 1 clinical trials.
−Removed: We have conducted in vivo pharmacokinetic and pharmacodynamic studies with hydrogels loaded with a small molecule anti-angiogenic TKI compound injected intravitreally.
−Removed: Pharmacokinetic data showed retinal tissue drug concentrations in excess of 3,000 times published IC50 after six months and pharmacodynamic results show sustained efficacy for six months.
−Removed: We also continue to conduct our own internal preclinical development program using TKIs.
−Removed: We also believe there are other opportunities for targets beyond VEGF-related targets to utilize our hydrogel for back-of-the-eye diseases, and we may pursue opportunities through internal research or in partnership with pharmaceutical companies.
−Removed: Intravitreal wet AMD (OTX-TKI) Product Candidate
−Removed: We are conducting an open-label, proof-of-concept Phase 1 clinical trial of OTX-TKI that was initiated in the second quarter of 2018 for the treatment of patients with neovascular age related macular degeneration (wet AMD).
−Removed: OTX-TKI (sustained-release tyrosine kinase inhibitor) is a bioresorbable hydrogel implant incorporating axitinib that is designed to be an intravitreal injection into the inferior hemisphere of the vitreous humor of the eye with an initial target duration of drug release for approximately 6-9 months.
−Removed: Preclinical studies to date have demonstrated suppression of vascular leakage and good pharmacokinetics in the relevant ocular tissues.
−Removed: The Phase 1 study was submitted to Therapeutic Goods Administration (TGA) in July 2018.
−Removed: The study is a prospective, multi-center study to evaluate the safety, biological activity, durability and tolerability of OTX-TKI.
−Removed: In the first quarter of 2019, we began dosing patients in a Phase 1 clinical trial in Australia.
−Removed: This clinical trial is a multi-center, open-label, does escalation study designed to evaluate the safety, durability, tolerability, and biological
−Removed: activty of OTX-TKI.
−Removed: We are evaluating biological activity by following visual acuity over time and measuring retinal thickness using standard optical coherence tomography.
−Removed: The independent Data Safety and Monitoring Committee met to review the safety from the first cohort of subjects in the Phase 1 clinical trial and recommended moving to a higher dose of OTX-TKI for the next cohort of subjects to be treated, as the first cohort of subjects reported no safety concerns.
−Removed: Two cohorts of six subjects each have been enrolled, a lower dose cohort of 200 μg and a higher dose cohort of 400 μg.
−Removed: In the first two fully enrolled cohorts, OTX-TKI was generally well tolerated and observed to have a favorable safety profile with no ocular serious adverse events noted.
−Removed: In the higher dose cohort, OTX-TKI showed a decrease in central subfield retinal thickness as measured by mean change in central subfield thickness values by decreases in intraretinal and/or subretinal fluid in some subjects.
−Removed: We plan to continue long-term evaluation of the first two cohorts.
−Removed: We plan to amend our current clinical trial protocol to enroll a third, higher-dose cohort.
−Removed: This Phase 1 clinical trial is not powered to measure any efficacy endpoints with statistical significance.
−Removed: Interim results from the Phase 1 trial were presented at the 40 th Annual Cowen Health Care Conference on March 3, 2020.
−Removed: Slides covering Mean Change in Central Subfield Thickness Values by Cohort, Individual Subject Durability Assessment and Safety Overview for Cohorts 1 & 2 are included below.
+Added: Embedded within our DEXTENZA intracanalicular insert are dexamethasone drug particles that gradually erode and release the drug in a programmed fashion until the drug is depleted.
+Added: As the dexamethasone drug particles erode and the hydrogel degrades by hydrolysis, the intracanalicular insert softens, liquefies and is cleared through the nasolacrimal duct.
+Added: We provide the DEXTENZA drug product in a preservative-free formulation in a sterile, single use package.
+Added: The standard regimen for dexamethasone eye drops following cataract surgery is an initial administration of four times daily for one week, with a gradual tapering in the number of eye drops over a four-week period.
+Added: Such a regimen is often confusing to patients as they must remember to taper the number of times per day they administer the steroid, while also taking multiple drops of other drugs, such as antibiotics and NSAIDs.
+Added: We believe that local programmed-release of drug to the eye may result in better control of ocular inflammation and pain as compared to prescription eye drops and that a low dose amount may provide enhanced safety by eliminating spikes in IOP associated with high-dose steroid eye drops.
+Added: Overview of Clinical Development for Post-Surgical Ocular Inflammation and Pain
+Added: In March and April 2015, we reported topline results from two Phase 3 clinical trials for the treatment of post-surgical ocular inflammation and pain.
+Added: In the first Phase 3 clinical trial, DEXTENZA met both primary efficacy endpoints, absence of pain at day 8 and absence of inflammatory cells at day 14, with statistical significance.
+Added: In the second Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint for absence of pain at day 8 with statistical significance but did not meet the primary efficacy endpoint for absence of inflammatory cells at day 14.
+Added: We met with the FDA in April 2015 to discuss the path forward for seeking marketing approval of DEXTENZA for the treatment of post-surgical ocular inflammation and pain.
+Added: In this pre-NDA clinical meeting, the FDA indicated that the existing data from our Phase 2 and two Phase 3 clinical trials are appropriate to support an NDA submission for DEXTENZA for a post-surgical ocular pain indication.
+Added: The FDA further indicated that we would need additional data from a third Phase 3 clinical trial for the inflammation endpoint to support the potential labeling expansion of DEXTENZA’s indications for use.
+Added: We initiated a third Phase 3 clinical trial for DEXTENZA for the treatment of post-surgical ocular inflammation and pain in October 2015.
+Added: In September 2015, we submitted to the FDA an NDA for DEXTENZA for the treatment of post-surgical ocular pain.
+Added: In July 2016, we received a complete response letter, or CRL, from the FDA regarding our NDA for DEXTENZA.
+Added: resubmitted our NDA for DEXTENZA for the treatment of post-surgical ocular pain in June 2018.
+Added: In November 2018, we received approval for the pain indication.
+Added: In June 2019, we received approval for the inflammation indication.
+Added: Completed Phase 3 Clinical Trials
+Added: In 2014, we initiated a pivotal clinical trial program that consisted of two prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked Phase 3 clinical trials evaluating the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain following cataract surgery.
+Added: We initiated the first of these Phase 3 clinical trials in February 2014 and the second trial in April 2014.
+Added: Patient enrollment was completed in September 2014, and the topline efficacy data from these clinical trials was reported in March and April 2015.
+Added: We initiated a third Phase 3 clinical trial in the October 2015.
+Added: Patient enrollment in the third Phase 3 clinical trial was completed in May 2016 and the topline efficacy data was reported in November 2016.
+Added: We enrolled 247 patients at 16 sites in the first Phase 3 clinical trial, 241 patients at 16 sites in the second Phase 3 clinical trial and 438 patients at 21 sites in the third Phase 3 clinical trial in the United States pursuant to our effective IND.
+Added: We randomized patients in a 2:1 ratio in the first two Phase 3 clinical trials and in a 1:1 ratio in the third Phase 3 clinical trial to receive either DEXTENZA or a placebo vehicle control intracanalicular insert without active drug.
+Added: We evaluated patients at days 2, 4, 8, 14, 30 and 60 following surgery in the first two Phase 3 trials and at days 2, 4, 8, 14, and 30 in the third Phase 3 clinical trial.
+Added: The two primary efficacy measures in these trials were absence of inflammatory cells in the anterior chamber of the study eye when measured with a slit lamp biomicroscope and absence of pain in the study eye.
+Added: To meet the efficacy end point for absence of inflammatory cells, there needed to be a complete absence of inflammatory cells.
+Added: In these trials, absence of pain was based on a patient reported score of zero on a scale from zero to ten of ocular pain assessment.
+Added: The first primary efficacy endpoint for these trials was the difference in the proportion of patients in each treatment group with absence of inflammatory cells in the anterior chamber of the study eye at day 14 following surgery.
+Added: Pivotal clinical trials for other ophthalmic steroid drugs approved by the FDA for marketing in the United States also have evaluated this endpoint at day 14.
+Added: The second primary efficacy endpoint for these trials was the difference in the proportion of patients in each treatment group with absence of pain in the study eye at day 8 following surgery.
+Added: For clarification of the endpoints, the day of surgery and insertion of DEXTENZA or the placebo is considered to be day 1.
+Added: We evaluated as secondary efficacy measures the level of flare, an indicator of inflammation in the anterior chamber of the study eye at each evaluation date until day 30 and absence of inflammatory cells in the anterior chamber of the study eye and absence of pain in the study eye at each evaluation date other than the day used for the primary efficacy measure until day 30.
+Added: The secondary analyses on primary endpoints were intended to be exploratory assessments that can be used to support the results from the primary endpoints.
+Added: We enrolled patients in these two trials who were at least 18 years of age undergoing unilateral clear corneal cataract surgery.
+Added: We excluded patients from these trials if, among other reasons, they had intraocular inflammation or ocular pain in the study eye at screening or had glaucoma or ocular hypertension.
+Added: We evaluated safety in all patients at each study visit with an assessment of general eye conditions, including visual acuity and IOP, along with any adverse events.
+Added: In the first Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint with statistical significance for the absence of cells in the anterior chamber compared to the vehicle control at day 14.
+Added: 33.1% of DEXTENZA treated patients showed an absence of inflammatory cells in the anterior chamber of the study eye on day 14 following drug product insertion, compared to 14.5% of those receiving placebo vehicle control intracanalicular inserts (p=0.0018).
+Added: DEXTENZA also met the primary efficacy endpoint with statistical significance for absence of pain compared to the vehicle control at day 8.
+Added: 80.4% of patients receiving DEXTENZA reported absence of pain in the study eye on day 8 following insertion of the drug product, compared to 43.4% of those receiving placebo vehicle control intracanalicular inserts (p< 0.0001).
+Added: In the second Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint for absence of pain at day 8 with statistical significance but did not meet the primary efficacy endpoint for absence of inflammatory cells at day 14.
+Added: In the second Phase 3 clinical trial, 77.5% of patients receiving DEXTENZA reported an absence of pain in the study eye on day 8 following insertion of the drug product, compared to 58.8% of those receiving placebo vehicle control intracanalicular inserts, a difference which was statistically significant (p=0.0025).
+Added: However, 39.4% of DEXTENZA
+Added: treated patients showed an absence of inflammatory cells in the anterior chamber of the study eye on day 14 following drug product insertion, compared to 31.3% of those receiving placebo vehicle control intracanalicular inserts, a difference which was not statistically significant (p=0.2182).
+Added: In the third Phase 3 clinical trial, DEXTENZA met the primary efficacy endpoint with statistical significance for the absence of cells in the anterior chamber compared to the vehicle control at day 14.
+Added: 52.1% of DEXTENZA treated patients showed an absence of inflammatory cells in the anterior chamber of the study eye on day 14 following drug product insertion compared to 31.2% of those receiving placebo vehicle control intracanalicular inserts (p< 0.0001).
+Added: DEXTENZA also met the primary efficacy endpoint with statistical significance for absence of pain compared to the vehicle control at day 8.
+Added: 79.3% of patients receiving DEXTENZA reported absence of pain in the study eye on day 8 following insertion of the drug product, compared to 61.3% of those receiving placebo vehicle control intracanalicular inserts (p< 0.0001).
+Added: Secondary analyses on primary endpoints for the three Phase 3 clinical trials were also completed.
+Added: In the first Phase 3 clinical trial, statistically significant differences were seen for absence of pain at all time points (days 2, 4, 8, 14, 30 and 60) in the DEXTENZA treatment group compared to the vehicle control group.
+Added: Statistically significant differences were seen for the absence of inflammatory cells at day 30 in the DEXTENZA treatment group compared to the vehicle control group, and there were no statistically significant differences seen at the other time points.
+Added: Statistically significant differences between the DEXTENZA treatment group and the vehicle control group were seen for flare at days 8, 14 and 30.
+Added: In the second Phase 3 clinical trial, statistically significant differences were seen for absence of pain at days 2, 4, 14 and 30 in the DEXTENZA treatment group compared to the vehicle control group.
+Added: A similar proportion of patients in the DEXTENZA treatment group and the vehicle control group were observed to have an absence of inflammatory cells at days 2, 4, 8, and 30.
+Added: A statistically significant difference between treatment groups was not seen for the absence of inflammatory cells until the day 60 visit, at which time a greater proportion of patients in the DEXTENZA treatment group compared to the vehicle control group were observed to have an absence of inflammatory cells at day 60 (p=0.0012).
+Added: Statistically significant differences between the DEXTENZA treatment group and the vehicle control group were seen for flare at days 14, 30 and 60.
+Added: In the third Phase 3 clinical trial, statistically significant differences were seen for absence of pain at all time points (days 2,4, 14, and 30) in the DEXTENZA treatment group compared to the vehicle control group.
+Added: Statistically significant differences were seen for the absence of inflammatory cells at days 4, 8, and 30 but not seen at day 2.
+Added: Statistically significant differences between the DEXTENZA treatment group and the vehicle control group were seen for flare at all measured time points (days 2, 4, 8, 14, and 30).
+Added: There were no ocular or treatment-related serious adverse events in the DEXTENZA treatment group in either of the first two completed Phase 3 clinical trials.
+Added: There was one ocular serious adverse event in the vehicle control group in the first two completed Phase 3 clinical trials:
+Added: hypopyon, or inflammatory cells in the anterior chamber.
+Added: There were two patients with three serious adverse events in the DEXTENZA treatment group in the first Phase 3 clinical trial (1.2% incidence), compared with two patients with four serious adverse events in the vehicle control group (2.4% incidence).
+Added: There were two serious adverse events in the DEXTENZA treatment group in the second Phase 3 clinical trial (1.3% incidence), compared with three serious adverse events in the vehicle control group (3.8% incidence).
+Added: There were three serious adverse events in the DEXTENZA treatment group in the third Phase 3 clinical trial (1.4% incidence), compared with two serious adverse events in the vehicle control group (0.9% incidence).
+Added: One serious adverse event in the DEXTENZA group was ocular in nature (retinal detachment) .
+Added: None of the serious adverse events in either group were deemed to be treatment-related.
+Added: Patients were randomized in a 2:1 ratio in the first two Phase 3 clinical trials and in a 1:1 ratio in the third Phase 3 clinical trial between the treatment group and the vehicle control group.
+Added: In the first Phase 3 clinical trial, 98 adverse events were noted in the DEXTENZA group and 59 adverse events were noted in the vehicle control group.
+Added: In the second Phase 3 clinical trial, 74 adverse events were noted in the DEXTENZA group and 47 adverse events were noted in the vehicle control group.
+Added: In the third Phase 3 clinical trial, 91 adverse events were noted in the DEXTENZA group and 109 adverse events were noted in the vehicle control group.
+Added: All adverse events were either resolved or considered chronic/stable at the time of subject exit from the study.
+Added: We expect to be able to use the safety data from these Phase 3 trials to support our other DEXTENZA clinical development programs, including for allergic conjunctivitis.
+Added: Investigator-Initiated Trials
+Added: We have received proposals for, and plan to support, several investigator-initiated trials evaluating DEXTENZA in different clinical situations.
+Added: To date, third-party clinical investigators have initiated over 25 trials to study the use of DEXTENZA in cataract surgery and other potential indications.
+Added: Seven of the trials have completed enrollment, the remaining trials are actively enrolling and treated patients are being followed.
Regulatory Pathway
−Removed: In the second quarter of 2018 we initiated a Phase 1 clinical trial for the treatment of patients with neovascular age-related macular degeneration (wet AMD) in Australia.
−Removed: If successful, we would plan for one Phase 2 clinical trial and two Phase 3 clinical trials for the treatment of patients with neovascular age-related macular degeneration (wet AMD).
−Removed: If successful, we would plan to submit an NDA under Section 505(b)(2) of the FDCA.
−Removed: See “—Government Regulation—Section 505(b)(2) NDAs”
−Removed: for additional information.
+Added: In November 2018, we received FDA approval for DEXTENZA for the pain indication.
+Added: In January 2019, we submitted a sNDA for DEXTENZA for the treatment of post-surgical ocular inflammation.
+Added: In June 2019, we received FDA approval for DEXTENZA for the inflammation indication.
+Added: Although we conducted our Phase 3 clinical trials of DEXTENZA in patients who have undergone cataract surgery, these trials were intended to support, and DEXTENZA ultimately received, a label for patients who have undergone any ocular surgery.
+Added: Post-Approval Studies
+Added: In September 2020, we announced that we had dosed the first pediatric patients in a Phase 3 clinical trial evaluating DEXTENZA for the treatment of post-surgical ocular inflammation and pain in children following cataract surgery.
+Added: This planned clinical trial is a post-approval requirement of the FDA in accordance with the Pediatric Research Equity Act of 2003, in connection with the FDA’s prior approval of DEXTENZA for the treatment of inflammation and pain following ophthalmic surgery in adults.
+Added: The Phase 3 clinical trial is a U.S.-based, randomized, multicenter clinical trial in which we intend to enroll approximately 60 subjects.
+Added: It is designed to evaluate the safety and biological activity of DEXTENZA compared to an active control, prednisolone acetate suspension eye drops, for the treatment of inflammation and pain following ocular surgery for pediatric cataract in children between zero and three years of age.
+Added: The primary endpoint is the absence of pain at day eight post-treatment as measured by a FLACC (Face, Legs, Activity, Cry, Consolability) score of zero.
+Added: Foreign Approvals
+Added: Outside the United States, we continue to assess whether to seek regulatory approval for DEXTENZA in markets such as the European Union, Australia and Japan based on the market opportunity, particularly pricing, and the requirements for marketing approval.
+Added: Given our prioritization of the clinical development of our sustained-release product candidates and our planned commercialization efforts for our initial intracanalicular insert product candidates in the United States, we will need to engage a third parties to assist us in the approval process.
+Added: We have entered into a license agreement and collaboration with AffaMed for the development and commercialization of DEXTENZA, along with OTX-TIC, in specified Asian markets.
+Added: From time to time, we may consider additional arrangements with other companies to address markets outside of the United States.
+Added: If we or our collaborators obtain regulatory approval to market and sell DEXTENZA in international markets, we expect to utilize a variety of types of collaboration, distribution and other marketing arrangements with one or more third parties to commercialize DEXTENZA.
+Added: See “—Government Regulation—Review and Approval of Medical Devices in the European Union” for additional information.
ReSure Sealant
4 unchanged sentences
We commercially launched ReSure Sealant in the United States in February 2014.
+Added: ReSure Sealant provides a novel means of definitive wound closure in situations in which the surgeon observes a wound leak at the conclusion of surgery and/or would otherwise use sutures.
+Added: We believe ReSure Sealant offers important benefits over sutures, including superior wound closure, a better safety profile and less follow-up.
+Added: The market opportunity for a surgical sealant following cataract surgery may be modest because sutures are used in a minority of cataract surgeries and, currently, there is no direct reimbursement for ReSure Sealant.
+Added: While ReSure Sealant remains commercially available in the United States, there is no sales support and only limited commercial support for this product at this time.
+Added: As a result, we do not expect to generate meaningful levels of revenue from the sale of ReSure Sealant.
Product Design
5 unchanged sentences
The surgeon applies the sealant to the corneal incision as a liquid using a soft foam-tipped applicator.
−Removed: The sealant forms a conformal coating that adheres to the ocular tissue through mechanical interlocking of the hydrogel with
−Removed: the tissue surfaces.
+Added: The sealant forms a conformal coating that adheres to the ocular tissue through mechanical interlocking of the hydrogel with the tissue surfaces.
The blue color fades within a few hours following surgery.
26 unchanged sentences
During the pre-randomization intraoperative evaluation, the surgeons assessed whether there was any leakage based on a standard test called a Seidel test in conjunction with an application of force near the incision using a standardized tool and technique.
−Removed: The surgeon slowly applied force using the standardized tool that we provided until a leak was observed or until a pre-specified maximum force of one ounce of force was reached.
−Removed: In the assessments
−Removed: conducted during the operation, approximately 50% of leaks occurred spontaneously without application of force and 76% of leaks occurred with the application of 0.25 ounces of force or less.
+Added: The surgeon slowly applied force using the standardized tool that we provided until a
+Added: leak was observed or until a pre-specified maximum force of one ounce of force was reached.
+Added: In the assessments conducted during the operation, approximately 50% of leaks occurred spontaneously without application of force and 76% of leaks occurred with the application of 0.25 ounces of force or less.
Based on assessments conducted immediately following surgery, using the same standardized leak testing tool and technique, eyes receiving sutures leaked more frequently than eyes sealed with ReSure Sealant by a statistically significant margin of more than 8 to 1 (p<0.0001).
8 unchanged sentences
No ReSure Sealant treated subjects were outside of normal limits at the day 28 assessment.
−Removed: In this trial, surgeons rated ReSure Sealant as “easy”
−Removed: or “very easy”
−Removed: to use for 94.1% of patients treated with ReSure Sealant.
+Added: In this trial, surgeons rated ReSure Sealant as “easy” or “very easy” to use for 94.1% of patients treated with ReSure Sealant.
Post-Approval Studies
ReSure Sealant is classified in the United States as a class III medical device subject to the rules and regulation of premarket approval by the FDA.
−Removed: Following our submission of a PMA application to the FDA for review and during the review process, the FDA completed compliance audits of our manufacturing facility and several of our pivotal clinical
+Added: Following our submission of a PMA application to the FDA for review and during the
+Added: review process, the FDA completed compliance audits of our manufacturing facility and several of our pivotal clinical trial sites.
Before granting approval of the PMA application, the FDA sought input from the Ophthalmic Devices Advisory Committee, a panel of physicians charged with reviewing results from our pivotal clinical trial.
The FDA approved our PMA application for ReSure Sealant in January 2014.
−Removed: The FDA included two post-approval studies as a condition of the PMA application approval.
−Removed: The first post-approval study, identified as the Clinical PAS, is to confirm that ReSure Sealant can be used safely by physicians in a standard cataract surgery practice and to confirm the incidence in eyes treated with ReSure Sealant of the most prevalent adverse ocular events identified in our pivotal study of ReSure Sealant in eyes treated with ReSure Sealant.
−Removed: The FDA has approved the protocol for the Clinical PAS, and we initiated enrollment in December 2014.
−Removed: Enrollment was completed in December 2015 with 626 patients in 22 sites.
−Removed: We submitted the final study report to the FDA in June 2016, and the FDA has subsequently confirmed the Clinical PAS has been completed.
−Removed: The second post-approval study, identified as the Device Exposure Registry Study, is intended to link to the Medicare database to ascertain if patients are diagnosed or treated for endophthalmitis within 30 days following cataract surgery and application of ReSure Sealant.
−Removed: We initiated enrollment in this study in December 2016 and submitted our first progress report to FDA in January 2017.
−Removed: The Device Exposure Registry Study is required to include at least 4,857 patients.
−Removed: Due to difficulties in establishing an acceptable way to link ReSure Sealant to the Medicare database and lack of investigator interest, we have been unable to enroll trial sites and patients, collect patient data and report study data to the FDA.
−Removed: We have provided regular periodic reports to the FDA on the progress of this post-approval study.
−Removed: We received a warning letter from the FDA in October 2018 relating to our compliance with data collection and information reporting obligations in the Device Exposure Registry Study.
−Removed: The FDA warning letter refers to a lack of progress with the enrollment and related data collection and information reporting obligations for a required post-approval trial.
−Removed: Failure by us to conduct the required post-approval trial for ReSure Sealant to the FDA’s satisfaction may result in withdrawal of the FDA’s approval of ReSure Sealant or other regulatory action.
−Removed: In November 2018, we appealed this warning letter.
−Removed: In December 2018, the FDA rejected our appeal.
−Removed: A teleconference was held with the FDA in January 2019 resulting in tentative agreement on a proposed retrospective registry study of endophthalmitis rates to satisfy the Device Exposure Registry Study requirements.
−Removed: In a letter dated June 7, 2019 from the FDA, the agency acknowledged receipt of a letter dated March 29, 2019 from us in which we proposed conducting the proposed retrospective analysis of the IRIS Registry, comparing endophthalmitis rates from sites that purchased ReSure versus those sites that did not purchase ReSure.
−Removed: If the rates are no different, the FDA has indicated that it will consider the post-approval requirement to have been fulfilled.
−Removed: If there is a statistically significant increase in endophthalmitis rates at sites purchasing ReSure compared with those not purchasing ReSure, a prospective study will be required.
−Removed: The FDA has indicated it will consider our response to the warning letter adequate once it approves the study protocol for the retrospective analysis of the IRIS Registry and the outline of the prospective study.
−Removed: We submitted the protocol for the agreed upon retrospective study and the prospective study outline, as required per the terms of the warning letter in December 2019.
−Removed: We received feedback from the FDA in February 2020 and responded to the FDA in March 2020.
−Removed: We expect a response from the FDA in the middle of 2020.
−Removed: ReSure Sealant currently remains commercially available in the United States, though there is no sales support provided to the product at this time.
−Removed: We have received only limited revenues from ReSure Sealant to date and anticipate receiving only limited revenues from the program in 2020.
+Added: The FDA required two post-approval studies as a condition for approval of our premarket approval, or PMA, application for ReSure Sealant.
+Added: The first post-approval study, identified as the Clinical PAS, was to confirm that ReSure Sealant can be used safely by physicians in a standard cataract surgery practice and to confirm the incidence of the most prevalent adverse ocular events identified in our pivotal study in eyes treated with ReSure Sealant.
+Added: We submitted the final study report to the FDA in June 2016 and the FDA has confirmed the Clinical PAS has been completed.
+Added: The second post-approval study, which we refer to as the Device Exposure Registry Study, was a retrospective analysis of the IRIS Registry, comparing endophthalmitis rates from sites that purchased ReSure Sealant versus those sites that did not.
+Added: We completed the retrospective study in accordance with our agreement with the FDA and submitted the final study report for the Device Exposure Registry Study to the FDA in January 2021.
+Added: We anticipate that the FDA will review the report within 90 days of our submission and notify us as to whether our obligation to conduct the post-approval study has been satisfied.
+Added: Failure by us to conduct the required post-approval trial for ReSure Sealant to the FDA’s satisfaction may result in withdrawal of the FDA’s approval of ReSure Sealant or other regulatory action.
Foreign Approvals
3 unchanged sentences
If we obtain regulatory approval to market and sell ReSure Sealant in international markets, we expect to utilize a variety of types of collaboration, distribution and other marketing arrangements with one or more third parties to commercialize ReSure Sealant.
−Removed: See “—Government Regulation—Review and Approval of Medical Devices in the European Union”
−Removed: for additional information.
−Removed: Commercial Strategy
−Removed: Our goals for ReSure Sealant are to provide a novel means of definitive wound closure in situations in which the surgeon would otherwise use sutures and to increase the number of procedures in which surgeons close the wound following cataract surgery, instead of leaving the wound to self-seal.
−Removed: The market opportunity for a surgical sealant following cataract surgery may be modest.
−Removed: However, we believe ReSure Sealant offers important benefits over sutures, including superior wound closure, a better safety profile and less follow-up.
−Removed: While ReSure Sealant remains commercially available in the United States, there is no current sales support provided to the product at this time.
+Added: See “—Government Regulation—Review and Approval of Medical Devices in the European Union” for additional information.
Sales, Marketing and Distribution
1 unchanged sentence
We generally expect to retain commercial rights in the United States to any of our local programmed-release drug delivery product candidates for front-of-the-eye diseases and conditions for which we may receive marketing approvals and which we believe we can successfully commercialize.
−Removed: We commercially launched ReSure Sealant in the United States in February 2014.
−Removed: We initially sold ReSure Sealant through a network of independent distributors across the United States.
−Removed: While ReSure Sealant remains commercially available in the United States, there is no sales support provided to the product at this time.
−Removed: However, with the approval of DEXTENZA, we expect to be able to sell ReSure Sealant with DEXTENZA with the current sales force if we choose to do so in the future.
−Removed: Although we do not actively promote ReSure Sealant in terms of territory sales representatives, we continue to sell it in the United States, and will resume a promotional presence for ReSure Sealant in the ophthalmic marketplace at industry conventions, such as the American Society of Cataract and Refractive Surgery and the American Academy of Ophthalmology, among others.
−Removed: With the approval of DEXTENZA in November of 2018 for ocular pain, and in June 2019 for ocular inflammation, we have built a highly targeted, key account sales force that focuses on the ambulatory surgical centers responsible for the largest volumes of cataract surgery.
−Removed: Following our receipt of FDA approval on November 30, 2018, we submitted an application for a C-code for transitional pass-through payment status.
−Removed: On May 29, 2019, we received formal notification from the Centers for Medicare and Medicaid Services, or CMS, that it had approved transitional pass-through payment status and established a new reimbursement code for DEXTENZA.
−Removed: The code, C9048, became effective on July 1, 2019.
−Removed: On December 28, 2018, we submitted an application for a J-Code for permanent payment status.
−Removed: In July 2019, we subsequently received a specific and permanent J-Code, J1096, that became effective October 1, 2019.
−Removed: A J-Code is a permanent code used to report drugs that ordinarily cannot be self-administered.
−Removed: With the effectiveness of our permanent J-Code as of October 1, 2019, our C-code is no longer in effect.
−Removed: J-Codes are familiar to both medical practices and their billing staffs, as well as Medicare (Part B and Part C) and commercial insurers.
−Removed: As a result, J-Codes allow for a simpler and more convenient reimbursement process.
−Removed: In connection with our July 1, 2019 commercial launch of DEXTENZA, we have built our own highly targeted, key account manager, or KAM, sales force that focuses on the ambulatory surgical centers, or ASCs, responsible for the largest volumes of cataract surgery.
−Removed: Since the commercial launch of DEXTENZA, we have expanded our field sales team by 50% to a total of 30 KAMs.
−Removed: DEXTENZA is now available through a network of distributors.
−Removed: Our initial commercial efforts are focused on the two million cataract procedures performed annually under Medicare Part B.
−Removed: If we receive approval to market any of our product candidates in the United States, we plan to then evaluate the regulatory approval requirements and commercial potential for any such product candidate in Europe, Japan and other selected geographies.
+Added: In general, if we receive approval to market any of our product candidates in the United States, we plan to then evaluate the regulatory approval requirements and commercial potential for any such product candidate in Europe, Japan and other selected geographies.
If we decide to commercialize our products outside of the United States, we expect to utilize a variety of types of collaboration, distribution and other marketing arrangements with one or more third parties to commercialize any product of ours that receives marketing approval.
−Removed: These may include independent distributors, pharmaceutical companies or our own direct sales organization.
−Removed: We have entered into a strategic collaboration with Regeneron for the commercialization of our intravitreal implant for the delivery of protein-based anti-VEGF drugs for the treatment of back-of-the-eye diseases, including wet AMD.
−Removed: In December 2017, we delivered to Regeneron a proposed final formulation for the initial preclinical tolerability study.
−Removed: Regeneron initiated the preclinical study in early 2018.
−Removed: We and Regeneron have subsequently reached an understanding that the proposed formulation was not final and have ceased development of it.
−Removed: We are currently in
−Removed: discussions with Regeneron, in accordance with the terms of the Collaboration Agreement, regarding the development of an alternative formulation.
+Added: ReSure Sealant
+Added: We commercially launched ReSure Sealant in the United States in February 2014.
+Added: While ReSure Sealant remains commercially available in the United States, there is no sales support and only modest commercial support for this product at this time.
+Added: We may decide to actively promote ReSure Sealant in the future with the current sales force that supports DEXTENZA.
+Added: We sell DEXTENZA in the United States to a network of specialty distributors, who then resell DEXTENZA to ASCs and hospital outpatient departments, or HOPDs.
+Added: In connection with our commercial launch of DEXTENZA, we have built a highly targeted, key account sales force that focuses on the ASCs responsible for the largest volumes of cataract surgery in the United States and their affiliates, with an initial emphasis on the approximately two million cataract procedures performed annually under Medicare Part B.
+Added: We expect to grow our salesforce in 2021 to increase our active number of accounts and penetrate each account more deeply.
+Added: Our current field sales team consists of approximately 30 key account managers, or KAMs;
+Added: nine Field Reimbursement Managers, or FRMs;
+Added: and three Regional Directors, or RDs.
+Added: We intend to add up to six KAMs and up to two FRMs, and we may add one RD, during the course of 2021.
+Added: We have entered into a license agreement and collaboration with AffaMed for the development and commercialization of DEXTENZA, along with OTX-TIC, in specified Asian markets.
+Added: If our sNDA to include the treatment of ocular itching associated with allergic conjunctivitis as an additional approved indication for DEXTENZA is approved, we expect to launch DEXTENZA for that indication in the first half of 2022.
+Added: We expect initially to support the launch of DEXTENZA for this indication with our existing field force given the high degree of overlap between surgeons performing cataract surgery and those that treat severe allergic conjunctivitis.
+Added: Following launch, we will consider the potential need for additional resources that may be required to support continued commercialization.
Manufacturing
3 unchanged sentences
We plan to maintain our existing manufacturing space of approximately 20,000 square feet and extended the operating lease until June 2023.
−Removed: We have a one-time option to terminate the manufacturing space lease on July 2021, upon the delivery to the landlord on or before July 2020 a termination notice and the payment to the landlord of a termination fee.
We purchase active pharmaceutical ingredient drug substance from independent suppliers on a purchase order basis for incorporation into our drug product candidates.
14 unchanged sentences
We rely on patent protection, trade secrets, know-how, continuing technological innovation and in-licensing opportunities to develop and maintain our proprietary position.
−Removed: We have in-licensed a significant portion of our patent rights from Incept.
+Added: We actively protect our innovations by seeking patents and other forms of intellectual property to cover our inventions.
+Added: We also seek to in-license and acquire intellectual property to provide additional protection.
+Added: As a result, we have patents and/or patent applications pending for all of our commercial products and product candidates, as well as trade secrets to protect proprietary manufacturing processes.
+Added: Several patents and applications have been in-licensed from Incept.
The license from Incept is limited to the fields of human ophthalmic diseases and conditions, acute post-surgical pain and ear, nose and/or throat diseases or conditions.
−Removed: As of March 2, 2020, we have licensed from Incept a total of 20 U.S.
+Added: As of February 26, 2021, we have licensed from Incept a total of 16 U.S.
patents, 8 U.S.
patent applications and foreign counterparts of some of these patents and patent applications.
−Removed: Our license from Incept includes the following:
−Removed: Intracanalicular Insert and Intracameral Implant Product Candidates
−Removed: We have six U.S.
−Removed: patents that cover our intracanalicular insert and intracameral implant product candidates.
−Removed: Two patents which have issued in the U.S.
−Removed: and Japan, and are pending in the European Union and elsewhere, which are expected to expire in 2030 and cover compositions and methods of use of intracanalicular inserts.
−Removed: These patents are licensed exclusively to us in the field of ophthalmology.
−Removed: patents which are expected to expire in 2020 and cover the hydrogel composition of the intracanalicular inserts and methods of making and using hydrogel implants.
−Removed: These patents are licensed exclusively to us in the field of ophthalmology.
−Removed: patent which is expected to expire in 2024 that covers the process of making the hydrogel composition of OTX-TP and OTX-MP and are non-exclusively
−Removed: licensed to us.
−Removed: A pending U.S.
−Removed: patent application that covers the hydrogel composition of DEXTENZA that, if granted, is expected to expire in 2027.
+Added: The following is a summary of patents and patent applications that cover our commercial products and potentially cover our product candidates:
+Added: OTX-TKI (axitinib intravitreal implant) for Wet AMD, DME and RVO
+Added: We have licenses to several U.S.
+Added: patents and patent applications with the potential to cover this product candidate:
+Added: patents and issued patents in Australia, the European Union and Japan covering certain drug-release features of the hydrogel implant in combination with its hydrogel composition, all of which are expected to expire in 2027;
+Added: two granted U.S.
+Added: patents which are expected to expire in 2033 and 2034;
+Added: and issued patents in Australia, Canada, China, Hong Kong, the European Union, India, Japan and South Korea covering the process of making the hydrogel implant with its drug release features and the resultant compositions that are expected to expire in 2032.
+Added: We own a pending patent application in the United States with the potential to cover this product candidate that, if granted, is expected to expire in 2041.
+Added: OTX-TIC (travoprost intracameral implant) for glaucoma or ocular hypertension
+Added: We have licenses to a pending U.S.
+Added: application and foreign patent applications pending in Australia, Brazil, Canada, China, the European Union, Israel, India, Japan and Korea that potentially cover this product candidates that, if granted, are expected to expire in 2037.
+Added: We own a pending patent application in the United States and under the Patent Cooperation Treaty, or PCT, with the potential to cover this product candidate that, if granted, is expected to expire in 2042.
+Added: OTX-CSI (cyclosporine intracanalicular insert) for dry eye disease
+Added: We have licenses to three U.S.
+Added: patents, patents which have issued in Australia, Canada, China and Japan, and pending applications in the European Union and India that potentially cover this product candidate, all of which are expected to expire in 2030 and cover compositions and methods of use of this product candidate.
+Added: We own a pending patent application in the United States with the potential to cover this product candidate that, if granted, is expected to expire in 2041.
+Added: OTX-DED (dexamethasone intracanalicular insert) for episodic dry eye disease
+Added: We have licenses to three U.S.
+Added: patents, patents which have issued in Australia, Canada, China and Japan, and pending applications in the European Union and India that potentially cover this product candidate, all of which are expected to expire in 2030 and cover compositions and methods of use of this product candidate.
+Added: We own a pending patent application in the United States with the potential to cover this product candidate that, if granted, is expected to expire in 2041.
+Added: DEXTENZA ® (dexamethasone ophthalmic insert) 0.4 mg
+Added: We have licenses to three U.S.
+Added: patents, patents which have issued in Australia, Canada, China and Japan, and pending applications in the European Union and India, that cover this product, all of which are expected to expire in 2030 and cover compositions and methods of use of this product candidate.
+Added: We also recently acquired a U.S.
+Added: patent application with the potential to cover this product that, if granted, is expected to expire in 2036.
+Added: DEXTENZA ® (dexamethasone ophthalmic insert) 0.4 mg for allergic conjunctivitis
+Added: We have licenses to three U.S.
+Added: patents, patents which have issued in Australia, Canada, China and Japan, and pending applications in the European Union and India, that potentially cover this product candidate, all of which are expected to expire in 2030 and cover compositions and methods of use of this product candidate.
+Added: We own a pending patent application in the United States with the potential to cover this product candidate that, if granted, is expected to expire in 2041.
ReSure® Sealant
−Removed: We have two U.S.
+Added: We have licenses to two U.S.
patents that cover ReSure Sealant.
−Removed: patent which is expected to expire in 2024 and which covers the process of making and using hydrogel compositions.
−Removed: patent which is expected to expire in 2032 and which covers certain features of the ReSure Sealant package.
−Removed: Intravitreal Injection
−Removed: We have two U.S.
−Removed: patents that cover intravitreal injection product candidates.
−Removed: patent that is expected to expire in 2027 and patent applications which are pending in the European Union covering certain drug-release features of the hydrogel implant in combination with its hydrogel composition and other proprietary technology relating to intravitreal injections, and which, if granted, are expected to expire in 2027.
−Removed: A granted U.S.
−Removed: patent which is expected to expire in 2033 and pending patent applications in the European Union, Japan, U.S.
−Removed: and certain other jurisdictions covering the process of making the hydrogel implant with its drug release features and the resultant compositions and other proprietary technology that, if granted are expected to expire in 2032.
−Removed: We have pending patent applications in the United States, European Union, and Japan directed to a drug delivery vehicle and other proprietary technology that, if granted, are expected to expire in 2040.
+Added: patent is expected to expire in 2024 and covers the process of making and using hydrogel compositions.
+Added: Our second U.S.
+Added: patent is expected to expire in 2032 and covers certain features of the ReSure Sealant package.
+Added: The existence of patent applications does not guarantee that a patent will issue, or that any patent that does issue will cover the product or product candidate.
+Added: Issued patents are subject to validity and infringement challenges by third parties with uncertain chances of success.
The term of individual patents depends upon the legal term for patents in the countries in which they are granted.
In most countries, including the United States, the patent term is generally 20 years from the earliest claimed filing date of a non-provisional patent application in the applicable country.
−Removed: In the United States, a patent’s term may, in certain cases, be lengthened by patent term adjustment, which compensates a patentee for administrative delays by the United States Patent and Trademark Office in examining and granting a patent, or may be shortened if a patent is terminally disclaimed over a commonly owned patent or a patent naming a common inventor and having an earlier expiration date.
+Added: In the United States, a patent’s term may, in certain cases, be lengthened by patent term adjustment, which compensates a patentee for administrative delays by the United States Patent and Trademark Office in examining and granting a patent, or may be shortened if a patent is terminally disclaimed over a commonly owned patent or a patent naming a common inventor and having an earlier expiration date.
The Drug Price Competition and Patent Term Restoration Act of 1984, or the Hatch-Waxman Act, permits a patent term extension of up to five years beyond the expiration date of a U.S.
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The expiration dates referred to above are without regard to potential patent term extension or other market exclusivity that may be available to us.
+Added: For patent applications covering our products and developmental candidates, we typically file patent applications under the PCT which provides for the filing of a single application that preserves the right to file in national patent offices in other countries up to 30 months from the first priority date.
We may rely, in some circumstances, on trade secrets to protect our technology.
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The Second Amended Agreement will expire on the later of (i) the expiration or disclaimer by us of the last valid claim of an issued and unexpired patent included in the Licensed IP or (ii) the final unappealable rejection or abandonment of the last pending patent application arising under the Licensed IP.
−Removed: Either party may terminate the Second Amended Agreement in the event of the other party’s insolvency, bankruptcy or comparable proceedings, or if the other party materially breaches the agreement and does not cure such breach during a specified cure period.
−Removed: Regeneron Collaboration
−Removed: In October 2016, we entered into the Collaboration Agreement with Regeneron for the development and commercialization of products using our sustained-release hydrogel in combination with Regeneron’s large molecule VEGF-targeting compounds to address conditions of the eye.
−Removed: Under the terms of the Collaboration Agreement, we and Regeneron have agreed to conduct a joint research program with the aim of developing an extended-delivery formulation of aflibercept that is suitable for advancement into clinical development.
−Removed: We have granted Regeneron the Option to enter into an exclusive, worldwide license, with the right to sublicense, under our intellectual property to develop and commercialize the Licensed Products.
−Removed: The Option is exclusive until 12 months after Regeneron has received a product candidate in accordance with a collaboration plan, subject to certain conditions, and non-exclusive for an additional six months following the end of the exclusive period.
−Removed: The field of this license is limited to Licensed Products delivered by local administration to or around the eye for diagnostic, therapeutic or prophylactic purposes relating to ophthalmic diseases or conditions.
−Removed: The Collaboration Agreement does not cover the development of any products that deliver small molecule drugs, including TKIs, or deliver large molecule drugs other than those that target certain specified VEGF proteins or their receptors.
−Removed: Under the terms of the Collaboration Agreement, Regeneron is responsible for funding an initial preclinical tolerability study.
−Removed: If the Option is exercised, Regeneron is to use commercially reasonable efforts to conduct further preclinical development and an initial clinical trial under a collaboration plan.
−Removed: We are obligated to reimburse Regeneron for certain development costs incurred by Regeneron under the collaboration plan during the period through the completion of the initial clinical trial, subject to a cap of $25 million, which cap may be increased by up to $5 million under certain circumstances.
−Removed: We are also responsible for paying our own costs associated with the activities conducted by us under the collaboration plan.
−Removed: If Regeneron elects to proceed with further development following the completion of the collaboration plan, it will be solely responsible for conducting and funding, and is to use commercially reasonable efforts with respect to, further development and commercialization of product candidates.
−Removed: Under the terms of the Collaboration Agreement, Regeneron has agreed to pay us $10 million upon exercise of the Option.
−Removed: We are also eligible to receive up to $145 million per Licensed Product upon the achievement of specified development and regulatory milestones, $100 million per Licensed Product upon first commercial sale of such Licensed Product and up to $50 million based on the achievement of specified sales milestones for all Licensed Products.
−Removed: In addition, we are entitled to tiered, escalating royalties, in a range from a high-single digit to a low-to-mid teen percentage of net sales of Licensed Products, which royalties are subject to potential reductions in certain circumstances, subject to a minimum royalty.
−Removed: If Regeneron has not exercised the Option during the designated option period, the Collaboration Agreement will expire.
−Removed: If Regeneron exercises the Option, the Collaboration Agreement will expire on a Licensed Product-by-Licensed Product and country-by-by country basis upon the expiration of the later of 10 years from the date of first commercial sale in such country or the expiration of all patent rights covering the Licensed Product in such country.
−Removed: Following expiration, Regeneron will have a fully paid-up, non-exclusive license to continue to develop and commercialize Licensed Products.
−Removed: The Collaboration Agreement may be terminated by Regeneron at any time after exercise of the Option upon 60 days’
−Removed: prior written notice.
−Removed: Either party may, subject to a cure period, terminate the Collaboration Agreement in the event of the other party’s uncured material breach, in addition to other specified termination rights.
−Removed: In December 2017, we delivered to Regeneron the final formulation for Regeneron’s initial preclinical tolerability study.
−Removed: Regeneron initiated the preclinical study in early 2018.
−Removed: We and Regeneron have subsequently reached an understanding that the proposed formulation was not final and have ceased development of it.
−Removed: We are currently in
−Removed: discussions with Regeneron, in accordance with the terms of the Collaboration Agreement, regarding the development of an alternative formulation.
+Added: Either party may terminate the Second Amended Agreement in the event of the other party’s insolvency, bankruptcy or comparable proceedings, or if the other party materially breaches the agreement and does not cure such breach during a specified cure period.
+Added: AffaMed License Agreement
+Added: On October 29, 2020, we entered into a license agreement, or the License Agreement, with AffaMed for the development and commercialization of DEXTENZA regarding ocular inflammation and pain following cataract surgery and allergic conjunctivitis, or collectively, the DEXTENZA Field, and for OTX-TIC, or collectively with DEXTENZA, the AffaMed Licensed Products, regarding open-angle glaucoma and ocular hypertension, or collectively, the TIC Field and, with the DEXTENZA Field, each a Field, in each case in mainland China, Taiwan, Hong Kong, Macau, South Korea, and the countries of the Association of Southeast Asian Nations, or collectively, the Territories.
+Added: We retain development and commercialization rights for the AffaMed Licensed Products in the rest of the world.
+Added: Under the License Agreement, we granted AffaMed (i) a non-exclusive, royalty-free, non-sublicensable license under certain of our intellectual property rights and know-how to use the AffaMed Licensed Products in connection with specified activities in accordance with a development plan agreed between the parties and (ii) an exclusive, royalty-bearing, sublicensable, non-transferable (subject to specified exceptions), license under certain of our intellectual property rights and know-how to commercialize the AffaMed Licensed Products in the applicable Field in the Territories.
+Added: We have further agreed not to, and to cause its affiliates or agents not to, develop or commercialize in the Territories (i) the AffaMed Licensed Products outside of the applicable Fields and (ii) any other product containing the same active pharmaceutical ingredients as the AffaMed Licensed Products and administered into the anterior chamber of the eye, in each case without AffaMed’s prior written consent.
+Added: AffaMed has agreed not to, and to cause its affiliates or agents not to, engage in the development, manufacture, or commercialization of any competing product in the Territories.
+Added: Under the terms of the License Agreement, we received upfront payments totaling $12 million in the fourth quarter of 2020.
+Added: We are also eligible to receive up to an additional $91 million in aggregate, inclusive of a low-seven-figure clinical support payment, upon the achievement of certain development and commercial milestones.
+Added: There can be no guarantee, however, that any of these milestones will be achieved.
+Added: We are also entitled to receive tiered, escalating royalties on the net sales of the AffaMed Licensed Products ranging from a low-teen to low-twenties percentage.
+Added: Royalties under the License Agreement are payable on an AffaMed Licensed Product-by-AffaMed Licensed Product and jurisdiction-by-jurisdiction basis and are subject to potential reductions in specified circumstances, subject to a specified floor.
+Added: Pursuant to the terms of the License Agreement, we are generally responsible for expenses related to the development of the AffaMed Licensed Products in the applicable Fields in the Territories, provided that AffaMed (i) reimburse us a low-teen percentage of expenses incurred in connection with certain clinical trials conducted by us and designed to support marketing approval of the AffaMed Licensed Product by FDA or the European Medicines Agency, or the Global Studies;
+Added: (ii) is solely responsible for expenses incurred in connection with territory-specific clinical trials that it conducts in furtherance of the development plan agreed between the parties in the applicable Fields in the Territories, or the Local Studies;
+Added: and (iii) reimburse us in full for expenses incurred in connection with obtaining and maintaining regulatory approvals of the AffaMed Licensed Products in the applicable Fields in the Territories.
+Added: In the event AffaMed declines to participate in a Global Study or to conduct a Local Study in any jurisdiction in which we determine to conduct such a study, we are relieved of our obligation to provide AffaMed clinical data from such study, other than safety data, unless AffaMed subsequently reimburses us in the amounts described above plus a prespecified premium.
+Added: AffaMed is further obligated, at its sole cost and expense, to use commercially reasonable efforts to commercialize the AffaMed Licensed Products in the applicable Fields in the Territories.
+Added: The License Agreement contemplates that the parties negotiate and enter into a future agreement requiring us to use commercially reasonable efforts to manufacture
+Added: and supply finished drug products in sufficient quantity for clinical development and commercialization of the AffaMed Licensed Products in the applicable Fields in the Territories.
+Added: In accordance with its terms, the License Agreement expires upon the expiration of the last royalty term for the last AffaMed Licensed Product in any applicable Field in the Territories.
+Added: Either party may, subject to specified cure periods, terminate the License Agreement in the event of the other party’s uncured breach.
+Added: Either party may also terminate the License Agreement under specified circumstances relating to the other party’s insolvency.
+Added: During an established period following a change of control of us or our entry into a global licensing agreement that includes the Territories with a third party, we have the option to terminate the License Agreement, subject to a specified notice period and the repayment of any costs and expenses incurred by AffaMed in connection with the License Agreement, including upfront and milestone payments AffaMed has previously paid to us, at a prespecified premium.
+Added: AffaMed has the right to terminate the License Agreement at any time following the completion of a Phase 3 clinical trial to evaluate OTX-TIC.
The biotechnology and pharmaceutical industries are characterized by rapidly advancing technologies, intense competition and a strong emphasis on proprietary products.
−Removed: While we believe that our technologies, knowledge, experience and scientific resources provide us with competitive advantages, we face potential competition from many different sources, including major pharmaceutical, specialty pharmaceutical and biotechnology companies, academic institutions and governmental agencies and public and private research institutions.
−Removed: Any product candidates that we successfully develop and commercialize will compete with existing therapies and new therapies that may become available in the future.
−Removed: Our potential competitors include large pharmaceutical and biotechnology companies, specialty pharmaceutical and generic drug companies, and compounding pharmacies.
+Added: While we believe that our technologies, knowledge, experience and scientific resources provide us with competitive advantages, potential competitors include large pharmaceutical and biotechnology companies, specialty pharmaceutical and generic drug companies, and compounding pharmacies.
Potential competitors also include academic institutions, government agencies and other public and private research organizations that conduct research, seek patent protection and establish collaborative arrangements for research, development, manufacturing and commercialization.
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The key competitive factors affecting the success of each of our product candidates, if approved for marketing, are likely to be efficacy, safety, method of administration, convenience, price, the level of generic competition and the availability of coverage and adequate reimbursement from government and other third-party payors.
−Removed: Our commercial opportunity could be reduced or eliminated if our competitors develop and commercialize products that are safer, more effective, have fewer or less severe side effects, are more convenient or are less expensive than any products that we may develop.
−Removed: Our competitors also may obtain FDA or other regulatory approval for their products more rapidly than we may obtain approval for ours, which could result in our competitors’
−Removed: establishing a strong market position before we are able to enter the market.
−Removed: In addition, our ability to compete may be affected in many cases by insurers or other third-party payors seeking to encourage the use of generic products.
−Removed: Our product candidates target markets that are already served by a variety of competing products based on a number of active pharmaceutical ingredients.
−Removed: Many of these existing products have achieved widespread acceptance among physicians, patients and payors for the treatment of ophthalmic diseases and conditions.
−Removed: In addition, many of these products are available on a generic basis, and our product candidates may not demonstrate sufficient additional clinical benefits to physicians, patients or payors to justify a higher price compared to generic products.
−Removed: In many cases, insurers or other third-party payors, particularly Medicare, seek to encourage the use of generic products.
−Removed: Given that we are developing products based on FDA-approved therapeutic agents, our product candidates, if approved, will face competition from generic, branded and compounded versions of existing drugs based on the same active pharmaceutical ingredients that are administered in a different manner, typically through eye drops.
Because the active pharmaceutical ingredients in our product candidates are available on a generic basis, or are soon to be available on a generic basis, competitors will be able to offer and sell products with the same active pharmaceutical ingredient as our products so long as these competitors do not infringe the patents that we license.
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Competitors of our Intracanalicular Insert Product Candidates
−Removed: Several competitors are developing sustained drug release products for the same ophthalmic indications as our intracanalicular insert product candidates, as set forth below.
+Added: Several competitors are developing sustained drug release products for the same ophthalmic indications as our retinal implants, intracameral implants, intracanalicular insert and wound sealant products and product candidates, as set forth below.
+Added: Competitors of our Retinal Implants
+Added: Our intravitreal implant for the treatment of wet AMD will compete with anti-VEGF compounds administered in their current formulation and prescribed for the treatment of wet AMD as these agents can in some instances deliver one to two months or more of therapeutic effect.
+Added: They include Lucentis, Eylea, Beovu and off-label use of the cancer therapy Avastin.
+Added: Multiple companies, although all in early stages of development, are exploring ways to deliver anti-VEGF products in a sustained-release fashion, including Clearside Biomedical, Inc., which is pursuing a TKI (axitinib) administered into the suprachoroidal space;
+Added: Eyepoint Pharmaceuticals, Inc., which is pursuing a sustained-release bioerodible device containing a TKI (vorolanib) using its Durasert™ technology;
+Added: Aerie Pharmaceuticals, which is
+Added: pursuing development of a 4-6 month TKI implant (axitinib) using its Print® manufacturing technology;
+Added: Graybug Vision, Inc.
+Added: which is pursuing a sustained-release microparticle depot TKI formulation (sunitinib) to extend therapeutic drug levels in ocular tissue for up to six months;
+Added: and Kodiak Sciences Inc., which is pursuing sustained release therapies based on its anti-VEGF biopolymer conjugate technology.
+Added: In addition, there are several companies pursuing gene therapy to treat retinal diseases including Adverum Biotechnologies, Inc.
+Added: and REGENXBIO Inc.
+Added: There also are a number of companies with products in development targeting the inhibition of the complement system to address retinal diseases, specifically geographic atrophy including Apellis Pharmaceuticals, IVERIC bio, Inc., Annexion Biosciences, Gyroscope Therapeutics, Genentech/Ionis and Janssen Pharmaceutical, among others.
+Added: Competitors of OTX-TIC
+Added: Allergan PLC, now owned by AbbVie, Inc., received approval in March 2020 of DURYSTA™, a biodegradable bimatoprost intracameral implant consisting of a PGA and a biodegradable polymer matrix for the reduction of IOP in patients with open-angle glaucoma or ocular hypertension.
+Added: Allergan purchased ForSight VISION5 who was conducting a Phase 2 clinical development of the Helios insert, a sustained-release ocular insert placed below the eyelid that delivers bimatoprost for the treatment of glaucoma.
+Added: Glaukos, Inc.
+Added: is in Phase 3 trials with its iDose technology to deliver travoprost for the treatment of glaucoma.
+Added: In addition, several other companies have announced their intention to develop products for treatment of glaucoma using sustained-release therapy, although each of these is at an early stage of development.
+Added: Mati Therapeutics has conducted a Phase 2 clinical development of an intracanalicular insert for the treatment of glaucoma.
+Added: Competitors of OTX-CSI and OTX-DED
+Added: A number of therapies are currently available for the treatment of DED in the United States.
+Added: The most commonly used treatments for DED in the United States are over-the-counter eye drops, often referred to as “artificial tears,” and three FDA-approved prescription eye drop therapies:
+Added: Restasis, Xiidra and Cequa.
+Added: Artificial tears are intended to supplement insufficient tear production or improve tear film instability, but are primarily saline-based and provide only temporary relief.
+Added: Restasis and Cequa, both calcineurin inhibitor immunosuppressants, and Xiidra, a LFA-1 antagonist, address chronic inflammation associated with DED.
+Added: Kala Pharmaceuticals received approval in 2020 and launched EYESUVIS™, (loteprednol etabonate ophthalmic suspension) 0.25% for the short term (up to two weeks) treatment of the signs and symptoms of dry eye disease.
+Added: Other treatment options include ointments, gels, warm compresses, omega-3 fatty acid supplements and a number of medical devices.
+Added: We are aware of many other companies developing therapies for DED, including Aerie Pharmaceuticals, Alcon, Aldeyra Therapeutics, Allergan, Aurinia Pharmaceuticals, Azura Ophthalmics, Bausch Health (Novaliq), HanAll BioPharma, Johnson & Johnson, Mitotech, Novartis, Oyster Point Pharma, Parion Sciences, ReGenTree, Silk Technologies, Sylentis, TearSolutions, and TopiVert Pharma.
Competitors of DEXTENZA
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Icon Biosciences Inc.
−Removed: was subsequently bought by pSvidia Corporation in March 2018 and, at the same time, the new entity was renamed Eyepoint Pharmaceuticals, Inc., or Eyepoint.
−Removed: In January 2019, Eyepoint announced that DEXYCU’s J-Code became effective and Eyepoint launched DEXYCU commercially in the first quarter of 2019.
−Removed: Competitors of OTX-TIC
−Removed: Allergan PLC, now owned by Abbvie, Inc., received approval in March 2020 of DURYSTA™, a biodegradable intracameral implant consisting of a PGA and a biodegradable polymer matrix for the reduction of IOP in patients with open-angle glaucoma or ocular hypertension.
−Removed: Allergan purchased ForSight VISION5 who was conducting a Phase 2 clinical development of the Helios insert, a sustained-release ocular insert placed below the eyelid that delivers bimatoprost for the treatment of glaucoma.
−Removed: In addition, several other companies have announced their intention to develop products for treatment of glaucoma using sustained-release therapy, although each of these is at an early stage of development.
−Removed: Mati Therapeutics has conducted a Phase 2 clinical development of an intracanalicular insert for the treatment of glaucoma.
−Removed: Competitors of our Intravitreal Implants
−Removed: Our intravitreal implant for the treatment of wet AMD will compete with anti-VEGF compounds administered in their current formulation and prescribed for the treatment of wet AMD as these agents can in some instances deliver one to two months or more of therapeutic effect.
−Removed: They include Lucentis, Eylea, Beovu and off-label use of the cancer therapy Avastin.
−Removed: Multiple companies, although all in early stages of development are exploring ways to deliver anti-VEGF products in a sustained-release fashion, including Graybug Vision, Inc.
−Removed: which is pursuing a sustained-release microparticle depot formulation to extend therapeutic drug levels in ocular tissue for up to six months.
+Added: was subsequently bought by pSvidia Corporation in March 2018 and, at the same time, the new entity was renamed Eyepoint.
+Added: Eyepoint launched DEXYCU commercially in the first quarter of 2019.
Competitors of ReSure Sealant
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Government Regulation
−Removed: Government authorities in the United States, at the federal, state and local level, and in other countries and jurisdictions, including the European Union, extensively regulate, among other things, the research, development, testing, manufacture, quality control, clearance, approval, pricing, sales, reimbursement, packaging, storage, recordkeeping, labeling, advertising, promotion, distribution, marketing, post-approval monitoring and reporting, and import and export of pharmaceutical products and medical devices.
+Added: Government authorities in the United States, at the federal, state and local level, and in other countries and jurisdictions, including the European Union, extensively regulate, among other things, the research, development,
+Added: testing, manufacture, quality control, clearance, approval, pricing, sales, reimbursement, packaging, storage, recordkeeping, labeling, advertising, promotion, distribution, marketing, post-approval monitoring and reporting, and import and export of pharmaceutical products and medical devices.
The processes for obtaining regulatory approvals in the United States and in foreign countries and jurisdictions, along with subsequent compliance with applicable statutes and regulations and other regulatory authorities, require the expenditure of substantial time and financial resources.
2 unchanged sentences
Drugs are also subject to other federal, state and local statutes and regulations.
−Removed: Biological products are licensed for marketing under
−Removed: the Public Health Service Act, or PHSA, and subject to regulation under the FDCA and related regulations, and other federal, state and local statutes and regulations.
+Added: Biological products are licensed for marketing under the Public Health Service Act, or PHSA, and subject to regulation under the FDCA and related regulations, and other federal, state and local statutes and regulations.
An applicant seeking approval to market and distribute a new drug or biological product in the United States must typically undertake the following:
−Removed: completion of preclinical laboratory tests, animal studies and formulation studies in compliance with the FDA’s good laboratory practice, or GLP, regulations;
+Added: ● completion of preclinical laboratory tests, animal studies and formulation studies in compliance with the FDA’s good laboratory practice, or GLP, regulations;
● submission to the FDA of an IND, which must take effect before human clinical trials may begin;
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● review by an FDA advisory committee, where appropriate or if applicable;
−Removed: satisfactory completion of one or more FDA inspections of the manufacturing facility or facilities at which the product, or components thereof, are produced to assess compliance with current Good Manufacturing Practices, or cGMP, requirements and to assure that the facilities, methods and controls are adequate to preserve the product’s identity, strength, quality and purity;
+Added: ● satisfactory completion of one or more FDA inspections of the manufacturing facility or facilities at which the product, or components thereof, are produced to assess compliance with current Good Manufacturing Practices, or cGMP, requirements and to assure that the facilities, methods and controls are adequate to preserve the product’s identity, strength, quality and purity;
● satisfactory completion of FDA audits of clinical trial sites to assure compliance with GCPs and the integrity of clinical data;
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In support of a request for an IND, applicants must submit a protocol for each clinical trial and any subsequent protocol amendments must be submitted to the FDA as part of the IND.
−Removed: In addition, the results of the preclinical tests, together with manufacturing information, analytical data, any available clinical data or literature and plans for clinical trials, among other things, are submitted to the FDA as part of an IND.
The FDA requires a 30-day waiting period after the filing of each IND before clinical trials may begin.
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An IRB must operate in compliance with FDA regulations.
−Removed: An IRB can suspend or terminate approval of a clinical trial at its institution, or an institution it represents, if the clinical trial is not being conducted in accordance with the IRB’s requirements or if the product candidate has been associated with unexpected serious harm to patients.
−Removed: The FDA’s primary objectives in reviewing an IND are to assure the safety and rights of patients and to help assure that the quality of the investigation will be adequate to permit an evaluation of the drug’s effectiveness and safety and of the biological product’s safety, purity and potency.
+Added: An IRB can suspend or terminate approval of a clinical trial at its institution, or an institution it represents, if the clinical trial is not being conducted in accordance with the IRB’s requirements or if the product candidate has been associated with unexpected serious harm to patients.
+Added: The FDA’s primary objectives in reviewing an IND are to assure the safety and rights of patients and to help assure that the quality of the investigation will be adequate to permit an evaluation of the drug’s effectiveness and safety and of the biological product’s safety, purity and potency.
The decision to terminate development of an investigational drug or biological product may be made by either a health authority body such as the FDA, an IRB or ethics committee, or by us for various reasons.
−Removed: Additionally, some trials are overseen by an independent group of qualified experts organized by the trial sponsor, known as a data safety monitoring board or committee.
+Added: Additionally, some trials are overseen by an independent group of qualified experts organized by the trial sponsor, known as a data safety monitoring board, or DSMB, or committee.
This group provides authorization for whether or not a trial may move forward at designated check points based on access that only the group maintains to available data from the study.
2 unchanged sentences
Information about clinical trials must be submitted within specific timeframes to the National Institutes of Health, or NIH, for public dissemination on its ClinicalTrials.gov website.
−Removed: Similar requirements for posting clinical trial information are present in the European Union (EudraCT) website:
−Removed: https://eudract.ema.europa.eu/ and other countries, as well.
Expanded Access to an Investigational Drug for Treatment Use
−Removed: Expanded access, sometimes called “compassionate use,”
−Removed: is the use of investigational new drug products outside of clinical trials to treat patients with serious or immediately life-threatening diseases or conditions when there are no comparable or satisfactory alternative treatment options.
+Added: Expanded access, sometimes called “compassionate use,” is the use of investigational new drug products outside of clinical trials to treat patients with serious or immediately life-threatening diseases or conditions when there are no comparable or satisfactory alternative treatment options.
The rules and regulations related to expanded access are intended to improve access to investigational drugs for patients who may benefit from investigational therapies.
−Removed: FDA regulations allow access to investigational drugs under an IND by the company or the treating physician for treatment
−Removed: purposes on a case-by-case basis for:
+Added: FDA regulations allow access to investigational drugs under an IND by the company or the treating physician for treatment purposes on a case-by-case basis for:
individual patients (single-patient IND applications for treatment in emergency settings and non-emergency settings);
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and the expanded use of the investigational drug for the requested treatment will not interfere initiation, conduct, or completion of clinical investigations that could support marketing approval of the product or otherwise compromise the potential development of the product.
−Removed: On December 13, 2016, the 21st Century Cures Act established (and the 2017 Food and Drug Administration Reauthorization Act later amended) a requirement that sponsors of one or more investigational drugs for the treatment of a serious disease(s) or condition(s) make publicly available their policy for evaluating and responding to requests for expanded access for individual patients.
−Removed: Although these requirements were rolled out over time, they have now come into full effect.
−Removed: This provision requires drug and biologic companies to make publicly available their policies for expanded access for individual patient access to products intended for serious diseases.
+Added: Drug and biologic companies are required to make publicly available their policies for expanded access for individual patient access to products intended for serious diseases.
Sponsors are required to make such policies publicly available upon the earlier of initiation of a Phase 2 or Phase 3 study;
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The GCP requirements encompass both ethical and data integrity standards for clinical trials.
−Removed: The FDA’s regulations are intended to help ensure the protection of human subjects enrolled in non-IND foreign clinical trials, as well as the quality and integrity of the resulting data.
+Added: The FDA’s regulations are intended to help ensure the protection of human subjects enrolled in non-IND foreign clinical trials, as well as the quality and integrity of the resulting data.
They further help ensure that non-IND foreign trials are conducted in a manner comparable to that required for IND trials.
3 unchanged sentences
The drug or biologic is administered to an expanded patient population, generally at geographically dispersed clinical trial sites, in well-controlled clinical trials to generate enough data to statistically evaluate the efficacy and safety of the product for approval, to establish the overall risk-benefit profile of the product, and to provide adequate information for the labeling of the product.
−Removed: Phase 3 clinical trials are commonly referred to as “pivotal”
−Removed: trials, which typically denotes a trial which presents the data that the FDA or other relevant regulatory agency will use to determine whether to approve a drug.
+Added: Phase 3 clinical trials are commonly referred to as “pivotal” trials, which typically denotes a trial which presents the data that the FDA or other relevant regulatory agency will use to determine whether to approve a drug.
Progress reports detailing the safety results of the clinical trials must be submitted at least annually to the FDA and more frequently if serious adverse events occur.
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and any clinically important increase in the case of a serious suspected adverse reaction over that listed in the protocol or investigator brochure.
−Removed: The FDA or the sponsor or the data monitoring committee may suspend or terminate a clinical trial at any time on various grounds, including a finding that the research subjects are being exposed to an unacceptable health risk.
The FDA will typically inspect one or more clinical sites to assure compliance with GCP and the integrity of the clinical data submitted.
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Additionally, appropriate packaging must be selected and tested and stability studies must be conducted to demonstrate that the drug candidate does not undergo unacceptable deterioration over its shelf life.
+Added: Pediatric Studies
+Added: Under the Pediatric Research Equity Act of 2003, an application or supplement thereto must contain data that are adequate to assess the safety and effectiveness of the drug product for the claimed indications in all relevant pediatric subpopulations, and to support dosing and administration for each pediatric subpopulation for which the product is safe and effective.
+Added: With enactment of the Food and Drug Safety and Innovation Act, or the FDASIA, in 2012, sponsors must also submit pediatric study plans prior to the assessment data.
+Added: Those plans must contain an outline of the proposed pediatric study or studies the applicant plans to conduct, including study objectives and design, any deferral or waiver requests, and other information required by regulation.
+Added: The applicant, the FDA, and the FDA’s internal review committee must then review the information submitted, consult with each other, and agree upon a final plan.
+Added: The FDA or the applicant may request an amendment to the plan at any time.
+Added: For drugs intended to treat a serious or life-threatening disease or condition, the FDA must, upon the request of an applicant, meet to discuss preparation of the initial pediatric study plan or to discuss deferral or waiver of pediatric assessments.
+Added: The FDA may, on its own initiative or at the request of the applicant, grant deferrals for submission of some or all pediatric data until after approval of the product for use in adults, or full or partial waivers from the pediatric data requirements.
+Added: Additional requirements and procedures relating to deferral requests and requests for extension of deferrals are contained in the Food and Drug Administration Safety and Innovation Act, or FDASIA.
+Added: The FDA maintains a list of diseases that are exempt from PREA requirements due to low prevalence of disease in the pediatric population.
+Added: Congress amended the FDA Reauthorization Act of 2017, or FDARA.
+Added: Previously, drugs that had been granted orphan drug designation were exempt from the requirements of the Pediatric Research Equity Act.
+Added: Under the amended section 505B, beginning on August 18, 2020, the submission of a pediatric assessment, waiver or deferral will be required for certain molecularly targeted cancer indications with the submission of an application or supplement to an application.
Review of an NDA or BLA by the FDA
In order to obtain approval to market a drug or biological product in the United States, a marketing application must be submitted to the FDA that provides data establishing the safety and effectiveness of the proposed drug product for the proposed indication, and the safety, purity and potency of the biological product for its intended indication.
−Removed: The application includes all relevant data available from pertinent preclinical and clinical trials, including negative or ambiguous results as well as positive findings, together with detailed information relating to the product’s chemistry, manufacturing, controls and proposed labeling, among other things.
+Added: The application includes all relevant data available from pertinent preclinical and clinical trials, including negative or ambiguous results as well as positive findings, together with detailed information relating to the product’s chemistry, manufacturing, controls and proposed labeling, among other things.
Data can come from company-sponsored clinical trials intended to test the safety and effectiveness of a use of a product, or from a number of alternative sources, including studies initiated by investigators.
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Certain exceptions and waivers are available for some of these fees, such as an exception from the application fee for product candidates with orphan designation and a waiver for certain small businesses.
−Removed: Following submission of an NDA or BLA, the FDA conducts a preliminary review of the application generally within 60 calendar days of its receipt and strives to inform the sponsor by the 74th day after the FDA’s receipt of the submission to determine whether the application is sufficiently complete to permit substantive review.
+Added: Following submission of an NDA or BLA, the FDA conducts a preliminary review of the application generally within 60 calendar days of its receipt and strives to inform the sponsor by the 74th day after the FDA’s receipt of the submission to determine whether the application is sufficiently complete to permit substantive review.
The FDA may request additional information rather than accept the application for filing.
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Once the submission is accepted for filing, the FDA begins an in-depth substantive review.
−Removed: FDA has agreed to specified performance goals in the review process of NDAs and BLAs.
−Removed: Under that agreement, 90% of applications seeking approval of New Molecular Entities, or NMEs, are meant to be reviewed within ten months from the date on which FDA accepts the application for filing, and 90% of applications for NMEs that have been designated for “priority review”
−Removed: are meant to be reviewed within six months of the filing date.
+Added: The FDA has agreed to specified performance goals in the review process of NDAs and BLAs.
+Added: Under that agreement, 90% of applications seeking approval of New Molecular Entities, or NMEs, are meant to be reviewed within ten months from the date on which FDA accepts the application for filing, and 90% of applications for NMEs that have been designated for “priority review” are meant to be reviewed within six months of the filing date.
For applications seeking approval of products that are not NMEs, the ten-month and six-month review periods run from the date that FDA receives the application.
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The FDA may refer an application for a novel product to an advisory committee or explain why such referral was not made.
−Removed: Typically, an advisory committee is a panel of independent experts, including clinicians and other scientific experts, that reviews, evaluates and provides a recommendation as to whether the application should be approved and under what conditions.
+Added: Typically, an advisory committee is a panel of independent experts, including clinicians and other scientific experts, that reviews, evaluates and provides a recommendation as to whether the application should be approved and
+Added: under what conditions.
The FDA is not bound by the recommendations of an advisory committee, but it considers such recommendations carefully when making decisions.
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The accelerated approval pathway is most often used in settings in which the course of a disease is long and an extended period of time is required to measure the intended clinical benefit of a drug, even if the effect on the surrogate or intermediate clinical endpoint occurs rapidly.
−Removed: The accelerated approval pathway is usually contingent on a sponsor’s agreement to conduct, in a diligent manner, additional post-approval confirmatory studies to verify and describe the
−Removed: drug’s clinical benefit.
+Added: The accelerated approval pathway is usually contingent on a sponsor’s agreement to conduct, in a diligent manner, additional post-approval confirmatory studies to verify and describe the drug’s clinical benefit.
As a result, a product candidate approved on this basis is subject to rigorous post-marketing compliance requirements, including the completion of Phase 4 or post-approval clinical trials to confirm the effect on the clinical endpoint.
1 unchanged sentence
All promotional materials for product candidates approved under accelerated regulations are subject to prior review by the FDA.
−Removed: The FDA’s Decision on an Application
−Removed: On the basis of the FDA’s evaluation of the application and accompanying information, including the results of the inspection of the manufacturing facilities, the FDA may issue an approval letter or a complete response letter.
+Added: The FDA’s Decision on an Application
+Added: On the basis of the FDA’s evaluation of the application and accompanying information, including the results of the inspection of the manufacturing facilities, the FDA may issue an approval letter or a complete response letter, or CRL.
An approval letter authorizes commercial marketing of the product with specific prescribing information for specific indications.
−Removed: A complete response letter generally outlines the deficiencies in the submission and may require substantial additional testing or information in order for the FDA to reconsider the application.
−Removed: If and when those deficiencies have been addressed to the FDA’s satisfaction in a resubmission of the application, the FDA will issue an approval letter.
+Added: A CRL generally outlines the deficiencies in the submission and may require substantial additional testing or information in order for the FDA to reconsider the application.
+Added: If and when those deficiencies have been addressed to the FDA’s satisfaction in a resubmission of the application, the FDA will issue an approval letter.
The FDA has committed to reviewing such resubmissions in two or six months depending on the type of information included.
Even with submission of this additional information, the FDA ultimately may decide that the application does not satisfy the regulatory criteria for approval.
−Removed: If the FDA approves a product, it may limit the approved indications for use for the product, require that contraindications, warnings or precautions be included in the product labeling, require that post‑approval studies, including Phase 4 clinical trials, be conducted to further assess the product candidate’s safety after approval, require testing and surveillance programs to monitor the product after commercialization, or impose other conditions, including distribution restrictions or other risk management mechanisms, including REMS, which can materially affect the potential market and profitability of the product.
+Added: If the FDA approves a product, it may limit the approved indications for use for the product, require that contraindications, warnings or precautions be included in the product labeling, require that post-approval studies, including Phase 4 clinical trials, be conducted to further assess the product candidate’s safety after approval, require testing and surveillance programs to monitor the product after commercialization, or impose other conditions, including distribution restrictions or other risk management mechanisms, including REMS, which can materially affect the potential market and profitability of the product.
The FDA may prevent or limit further marketing of a product based on the results of post-market studies or surveillance programs.
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A product may also be subject to official lot release, meaning that the manufacturer is required to perform certain tests on each lot of the product before it is released for distribution.
−Removed: If the product is subject to official release, the manufacturer must submit samples of each lot, together with a release protocol showing a summary of the history of manufacture of the lot and the results of all of the manufacturer’s tests performed on the lot, to the FDA.
+Added: If the product is subject to official release, the manufacturer must submit samples of each lot, together with a release protocol showing a summary of the history of manufacture of the lot and the results of all of the manufacturer’s tests performed on the lot, to the FDA.
The FDA may in addition perform certain confirmatory tests on lots of some products before releasing the lots for distribution.
1 unchanged sentence
Once an approval is granted, the FDA may withdraw the approval if compliance with regulatory requirements and standards is not maintained or if problems occur after the product reaches the market.
−Removed: Later discovery of previously
−Removed: unknown problems with a product, including adverse events of unanticipated severity or frequency, or with manufacturing processes, or failure to comply with regulatory requirements, may result in revisions to the approved labeling to add new safety information;
+Added: Later discovery of previously unknown problems with a product, including adverse events of unanticipated severity or frequency, or with manufacturing processes, or failure to comply with regulatory requirements, may result in revisions to the approved labeling to add new safety information;
imposition of post-market studies or clinical trials to assess new safety risks;
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The FDA is, however, authorized to approve an alternative type of NDA under Section 505(b)(2) of the FDCA.
−Removed: This type of application allows the applicant to rely, in part, on the FDA’s previous findings of safety and efficacy for a similar product, or published literature.
−Removed: Specifically, Section 505(b)(2) applies to NDAs for a drug for which the investigations made to show whether or not the drug is safe for use and effective in use and relied upon by the applicant for approval of the application “were not conducted by or for the applicant and for which the applicant has not obtained a right of reference or use from the person by or for whom the investigations were conducted.”
+Added: This type of application allows the applicant to rely, in part, on the FDA’s previous findings of safety and efficacy for a similar product, or published literature.
+Added: Specifically, Section 505(b)(2) applies to NDAs for a drug for which the investigations made to show whether or not the drug is safe for use and effective in use and relied upon by the applicant for approval of the application “were not conducted by or for the applicant and for which the applicant has not obtained a right of reference or use from the person by or for whom the investigations were conducted.”
Thus, Section 505(b)(2) authorizes the FDA to approve an NDA based on safety and effectiveness data that were not developed by the applicant.
NDAs filed under Section 505(b)(2) may provide an alternate and potentially more expeditious pathway to FDA approval for new or improved formulations or new uses of previously approved products.
−Removed: If the 505(b)(2) applicant can establish that reliance on the FDA’s previous approval is scientifically appropriate, the applicant may eliminate the need to conduct certain preclinical or clinical studies of the new product.
+Added: If the 505(b)(2) applicant can establish that reliance on the FDA’s previous approval is scientifically appropriate, the applicant may eliminate the need to conduct certain preclinical or clinical studies of the new product.
The FDA may also require companies to perform additional studies or measurements to support the change from the approved product.
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In 1984, with passage of the Hatch-Waxman Amendments to the FDCA, Congress authorized the FDA to approve generic drugs that are the same as drugs previously approved by the FDA under the NDA provisions of the statute.
−Removed: To obtain approval of a generic drug, an applicant must submit an abbreviated new drug application, or ANDA, to the agency.
−Removed: In support of such applications, a generic manufacturer may rely on the preclinical and clinical testing previously conducted for a drug product previously approved under an NDA, known as the reference listed drug, or RLD.
−Removed: Specifically, in order for an ANDA to be approved, the FDA must find that the generic version is identical to the RLD with respect to the active ingredients, the route of administration, the dosage form, and the strength of the drug.
−Removed: At the same time, the FDA must also determine that the generic drug is “bioequivalent”
−Removed: to the innovator drug.
−Removed: Under the statute, a generic drug is bioequivalent to an RLD if “the rate and extent of absorption of the drug do not show a significant difference from the rate and extent of absorption of the listed drug.”
−Removed: Upon approval of an ANDA, the FDA indicates whether the generic product is “therapeutically equivalent”
−Removed: to the RLD in its publication “Approved Drug Products with Therapeutic Equivalence Evaluations,”
−Removed: also referred to as the “Orange Book.”
−Removed: Physicians and pharmacists consider a therapeutic equivalent generic drug to be fully substitutable for the RLD.
−Removed: In addition, by operation of certain state laws and numerous health insurance programs, the FDA’s designation of therapeutic equivalence often results in substitution of the generic drug without the knowledge or consent of either the prescribing physician or patient.
+Added: Specifically, in order for an abbreviated new drug application, or ANDA, to be approved, the FDA must find that the generic version is identical to the reference listed drug, or RLD, with respect to the active ingredients, the route of administration, the dosage form, and the strength of the drug.
+Added: At the same time, the FDA must also determine that the generic drug is “bioequivalent” to the innovator drug.
+Added: Under the statute, a generic drug is bioequivalent to an RLD if “the rate and extent of absorption of the drug do not show a significant difference from the rate and extent of absorption of the listed drug.”
+Added: Upon approval of an ANDA, the FDA indicates whether the generic product is “therapeutically equivalent” to the RLD in its publication “Approved Drug Products with Therapeutic Equivalence Evaluations,” also referred to as the “Orange Book.” Physicians and pharmacists consider a therapeutic equivalent generic drug to be fully substitutable for the RLD.
+Added: In addition, by operation of certain state laws and numerous health insurance programs, the FDA’s designation of therapeutic equivalence often results in substitution of the generic drug without the knowledge or consent of either the prescribing physician or patient.
Under the Hatch-Waxman Amendments, the FDA may not approve an ANDA until any applicable period of non-patent exclusivity for the RLD has expired.
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The FDA typically makes decisions about awards of data exclusivity shortly before a product is approved.
−Removed: The FDA must establish a priority review track for certain generic drugs, requiring the FDA to review a drug application within eight months for a drug that has three or fewer approved drugs listed in the Orange Book and is no longer protected by any patent or regulatory exclusivities, or is on the FDA’s drug shortage list.
−Removed: The FDA is also authorized to expedite review of “competitor generic therapies”
−Removed: or drugs with inadequate generic competition, including holding meetings with or providing advice to the drug sponsor prior to submission of the application.
Hatch-Waxman Patent Certification and the 30-Month Stay
−Removed: Upon approval of an NDA or a supplement thereto, NDA sponsors are required to list with the FDA each patent with claims that cover the applicant’s product or an approved method of using the product.
+Added: Upon approval of an NDA or a supplement thereto, NDA sponsors are required to list with the FDA each patent with claims that cover the applicant’s product or an approved method of using the product.
Each of the patents listed by the NDA sponsor is published in the Orange Book.
When an ANDA applicant files its application to the FDA, the applicant is required to certify to the FDA concerning any patents listed for the reference product in the Orange Book, except for patents covering methods of use for which the ANDA applicant is not seeking approval.
−Removed: To the extent that the
−Removed: Section 505(b)(2) applicant is relying on studies conducted for an already approved product, the applicant is required to certify to the FDA concerning any patents listed for the approved product in the Orange Book to the same extent that an ANDA applicant would.
+Added: To the extent that the Section 505(b)(2) applicant is relying on studies conducted for an already approved product, the applicant is required to certify to the FDA concerning any patents listed for the approved product in the Orange Book to the same extent that an ANDA applicant would.
Specifically, the applicant must certify with respect to each patent that:
3 unchanged sentences
● the listed patent is invalid, unenforceable or will not be infringed by the new product.
−Removed: A certification that the new product will not infringe the already approved product’s listed patents or that such patents are invalid or unenforceable is called a Paragraph IV certification.
+Added: A certification that the new product will not infringe the already approved product’s listed patents or that such patents are invalid or unenforceable is called a Paragraph IV certification.
If the applicant does not challenge the listed patents or indicate that it is not seeking approval of a patented method of use, the ANDA application will not be approved until all the listed patents claiming the referenced product have expired.
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Additional guidance is expected to be finalized by FDA in the near term.
−Removed: Under the BPCIA, a manufacturer may submit an application for licensure of a biologic product that is “biosimilar to”
−Removed: or “interchangeable with”
−Removed: a previously approved biological product or “reference product.”
−Removed: In order for the FDA to approve a biosimilar product, it must find that there are no clinically meaningful differences between the reference product and proposed biosimilar product in terms of safety, purity, and potency.
+Added: Under the BPCIA, a manufacturer may submit an application for licensure of a biologic product that is “biosimilar to” or “interchangeable with” a previously approved biological product or “reference product.” In order for the FDA to approve a biosimilar product, it must find that there are no clinically meaningful differences between the reference product and proposed biosimilar product in terms of safety, purity, and potency.
For the FDA to approve a biosimilar product as interchangeable with a reference product, the agency must find that the biosimilar product can be expected to produce the same clinical results as the reference product, and for products administered multiple times that the biologic and the reference biologic may be switched after one has been previously administered without increasing safety risks or risks of diminished efficacy relative to exclusive use of the reference biologic.
1 unchanged sentence
The FDA may not approve a biosimilar product until 12 years from the date on which the reference product was approved.
−Removed: Even if a product is considered to be a reference product
−Removed: eligible for exclusivity, another company could market a competing version of that product if the FDA approves a full BLA for such product containing the sponsor’s own preclinical data and data from adequate and well-controlled clinical trials to demonstrate the safety, purity and potency of their product.
+Added: Even if a product is considered to be a reference product eligible for exclusivity, another company could market a competing version of that product if the FDA approves a full BLA for such product containing the sponsor’s own preclinical data and data from adequate and well-controlled clinical trials to demonstrate the safety, purity and potency of their product.
The BPCIA also created certain exclusivity periods for biosimilars approved as interchangeable products.
−Removed: At this juncture, it is unclear whether products deemed “interchangeable”
−Removed: by the FDA will, in fact, be readily substituted by pharmacies, which are governed by state pharmacy law.
−Removed: Pediatric Studies and Exclusivity
−Removed: Under the Pediatric Research Equity Act of 2003, an NDA or supplement thereto must contain data that are adequate to assess the safety and effectiveness of the drug product for the claimed indications in all relevant pediatric subpopulations, and to support dosing and administration for each pediatric subpopulation for which the product is safe and effective.
−Removed: With enactment of the Food and Drug Administration Safety and Innovation Act, or FDASIA, in 2012, sponsors must also submit pediatric study plans prior to the assessment data.
−Removed: Those plans must contain an outline of the proposed pediatric study or studies the applicant plans to conduct, including study objectives and design, any deferral or waiver requests, and other information required by regulation.
−Removed: The applicant, the FDA, and the FDA’s internal review committee must then review the information submitted, consult with each other, and agree upon a final plan.
−Removed: The FDA or the applicant may request an amendment to the plan at any time.
−Removed: Unless otherwise required by regulation, the pediatric data requirements do not apply to products with orphan designation.
−Removed: The FDA may, on its own initiative or at the request of the applicant, grant deferrals for submission of some or all pediatric data until after approval of the product for use in adults, or full or partial waivers from the pediatric data requirements.
−Removed: Additional requirements and procedures relating to deferral requests and requests for extension of deferrals are contained in FDASIA.
−Removed: In addition, products that have received orphan designation are exempt from the requirements of the Pediatric Research Equity Act.
+Added: At this juncture, it is unclear whether products deemed “interchangeable” by the FDA will, in fact, be readily substituted by pharmacies, which are governed by state pharmacy law.
+Added: Pediatric Exclusivity
Pediatric exclusivity is another type of non-patent marketing exclusivity in the United States and, if granted, provides for the attachment of an additional six months of marketing protection to the term of any existing regulatory exclusivity, including the non-patent exclusivity.
1 unchanged sentence
The data do not need to show the product to be effective in the pediatric population studied;
−Removed: rather, if the clinical trial is deemed to fairly respond to the FDA’s request, the additional protection is granted.
+Added: rather, if the clinical trial is deemed to fairly respond to the FDA’s request, the additional protection is granted.
If reports of requested pediatric studies are submitted to and accepted by the FDA within the statutory time limits, whatever statutory or regulatory periods of exclusivity or patent protection cover the product are extended by six months.
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The restoration period granted is typically one-half the time between the effective date of an IND and the submission date of an NDA, plus the time between the submission date of an NDA and the ultimate approval date.
−Removed: Patent term restoration cannot be used to extend the remaining term of a patent past a total of 14 years from the product’s approval date.
+Added: Patent term restoration cannot be used to extend the remaining term of a patent past a total of 14 years from the product’s approval date.
Only one patent applicable to an approved drug product is eligible for the extension, and the application for the extension must be submitted prior to the expiration of the patent in question.
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Under the FDCA, a medical device is defined as an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is, among other things:
−Removed: intended for use in the diagnosis
−Removed: of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, in man or other animals;
+Added: intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, in man or other animals;
or intended to affect the structure or any function of the body of man or other animals, and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of any of its primary intended purposes.
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Medical devices are classified into one of three classes on the basis of the controls deemed by the FDA to be necessary to reasonably ensure their safety and effectiveness.
−Removed: Class I devices are low risk devices for which reasonable assurance of safety and effectiveness can be provided by adherence to the FDA’s general controls for medical devices, which include applicable portions of the FDA’s Quality System Regulation, or QSR, facility registration and product listing, reporting of adverse medical events and malfunctions and appropriate, truthful and non-misleading labeling, advertising and promotional materials.
+Added: Class I devices are low risk devices for which reasonable assurance of safety and effectiveness can be provided by adherence to the FDA’s general controls for medical devices, which include applicable portions of the FDA’s Quality System Regulation, or QSR, facility registration and product listing, reporting of adverse medical events and malfunctions and appropriate, truthful and non-misleading labeling, advertising and promotional materials.
Many Class I devices are exempt from premarket regulation;
however, some Class I devices require premarket clearance by the FDA through the 510(k) premarket notification process.
−Removed: Class II devices are moderate risk devices and are subject to the FDA’s general controls, and any other special controls, such as performance standards, post-market surveillance, and FDA guidelines, deemed necessary by the FDA to provide reasonable assurance of the devices’
−Removed: safety and effectiveness.
+Added: Class II devices are moderate risk devices and are subject to the FDA’s general controls, and any other special controls, such as performance standards, post-market surveillance, and FDA guidelines, deemed necessary by the FDA to provide reasonable assurance of the devices’ safety and effectiveness.
Premarket review and clearance by the FDA for Class II devices are accomplished through the 510(k) premarket notification procedure, although some Class II devices are exempt from the 510(k) requirements.
Premarket notifications are subject to user fees, unless a specific exemption applies.
−Removed: Class III devices are deemed by the FDA to pose the greatest risk, such as those for which reasonable assurance of the device’s safety and effectiveness cannot be assured solely by the general controls and special controls described above and that are life-sustaining or life-supporting.
+Added: Class III devices are deemed by the FDA to pose the greatest risk, such as those for which reasonable assurance of the device’s safety and effectiveness cannot be assured solely by the general controls and special controls described above and that are life-sustaining or life-supporting.
A PMA application must provide valid scientific evidence, typically extensive preclinical and clinical trial data and information about the device and its components regarding, among other things, device design, manufacturing and labeling.
1 unchanged sentence
510(k) Premarket Notification
−Removed: To obtain 510(k) clearance, a manufacturer must submit a premarket notification demonstrating that the proposed device is “substantially equivalent”
−Removed: to a predicate device, which is a previously cleared 510(k) device or a pre-amendment device that was in commercial distribution before May 28, 1976, for which the FDA has not yet called for the submission of a PMA application.
−Removed: The FDA’s 510(k) clearance pathway usually takes from three to 12 months from the date the application is submitted and filed with the FDA, but it can take significantly longer and clearance is never assured.
+Added: To obtain 510(k) clearance, a manufacturer must submit a premarket notification demonstrating that the proposed device is “substantially equivalent” to a predicate device, which is a previously cleared 510(k) device or a pre-amendment device that was in commercial distribution before May 28, 1976, for which the FDA has not yet called for the submission of a PMA application.
+Added: The FDA’s 510(k) clearance pathway usually takes from three to 12 months from the date the application is submitted and filed with the FDA, but it can take significantly longer and clearance is never assured.
The FDA has issued guidance documents meant to expedite review of a 510(k) and facilitate interactions between applicants and the agency.
4 unchanged sentences
However, if the FDA concludes that a new device is not substantially equivalent to a predicate device, the new device will be classified in Class III and the manufacturer will be required to submit a PMA application to market the product.
−Removed: Devices of a new type that the FDA has not previously classified based on risk are automatically classified into Class III by operation of section 513(f)(1) of the
−Removed: FDCA, regardless of the level of risk they pose.
+Added: Devices of a new type that the FDA has not previously classified based on risk are automatically classified into Class III by operation of section 513(f)(1) of the FDCA, regardless of the level of risk they pose.
To avoid requiring PMA review of low- to moderate-risk devices classified in Class III by operation of law, Congress enacted section 513(f)(2) of the FDCA.
5 unchanged sentences
A Special 510(k) allows a manufacturer to declare conformance to design controls without providing new data.
−Removed: When the modification involves a change in material, the nature of the “new”
−Removed: material will determine whether a traditional or Special 510(k) is necessary.
+Added: When the modification involves a change in material, the nature of the “new” material will determine whether a traditional or Special 510(k) is necessary.
Any modification to a 510(k)-cleared product that would constitute a major change in its intended use or any change that could significantly affect the safety or effectiveness of the device may, in some circumstances, requires the submission of a PMA application, if the change raises complex or novel scientific issues or the product has a new intended use.
A manufacturer may be required to submit extensive pre-clinical and clinical data depending on the nature of the changes.
−Removed: The FDA requires every manufacturer to make the determination regarding the need for a new 510(k) submission in the first instance, but the FDA may review any manufacturer’s decision.
−Removed: If the FDA disagrees with the manufacturer’s determination and requires new 510(k) clearances or PMA application approvals for modifications to previously cleared products for which the manufacturer concluded that new clearances or approvals are unnecessary, the manufacturer may be required to cease marketing or distribution of the products or to recall the modified product until it obtains clearance or approval, and the manufacturer may be subject to significant regulatory fines or penalties.
+Added: The FDA requires every manufacturer to make the determination regarding the need for a new 510(k) submission in the first instance, but the FDA may review any manufacturer’s decision.
+Added: If the FDA disagrees with the manufacturer’s determination and requires new 510(k) clearances or PMA application approvals for modifications to previously cleared products for which the manufacturer concluded that new clearances or approvals are unnecessary, the manufacturer may be required to cease marketing or distribution of the products or to recall the modified product until it obtains clearance or approval, and the manufacturer may be subject to significant regulatory fines or penalties.
In addition, the FDA is currently evaluating the 510(k) process and may make substantial changes to industry requirements.
10 unchanged sentences
Even with additional trials, the FDA may not approve the PMA application.
−Removed: If the FDA’s evaluations of both the PMA application and the manufacturing facilities are favorable, the FDA will either issue an approval letter authorizing commercial marketing or an approvable letter that usually contains a number of conditions that must be met in order to secure final approval.
−Removed: If the FDA’s evaluations are not favorable, the FDA will deny approval of the PMA application or issue a not approvable letter.
−Removed: The PMA application process, including the gathering of clinical and nonclinical data and the submission to and review by the FDA, can take several years, and the process can be expensive and uncertain.
+Added: If the FDA’s evaluations of both the PMA application and the manufacturing facilities are favorable, the FDA will either issue an approval letter authorizing commercial marketing or an approvable letter that usually contains a number of conditions that must be met in order to secure final approval.
+Added: If the FDA’s evaluations are not favorable, the FDA will deny approval of the PMA application or issue a not approvable letter.
+Added: The PMA application process, including the
+Added: gathering of clinical and nonclinical data and the submission to and review by the FDA, can take several years, and the process can be expensive and uncertain.
Moreover, even if the FDA approves a PMA application, the FDA may approve the device with an indication that is narrower or more limited than originally sought.
The FDA can impose post-approval conditions that it believes necessary to ensure the safety and effectiveness of the device, including, among other things, restrictions on labeling, promotion, sale and distribution.
−Removed: After approval of a PMA application, a new PMA application or PMA application supplement may be required for a modification to the device, its labeling, or its manufacturing
+Added: After approval of a PMA application, a new PMA application or PMA application supplement may be required for a modification to the device, its labeling, or its manufacturing process.
PMA application supplements often require submission of the same type of information as an initial PMA application, except that the supplement is limited to information needed to support any changes from the device covered by the approved PMA application and may or may not require as extensive technical or clinical data or the convening of an advisory panel.
5 unchanged sentences
A clinical trial is typically required for a PMA application and, in a small percentage of cases, the FDA may require a clinical study in support of a 510(k) submission.
−Removed: A manufacturer that wishes to conduct a clinical study involving the device is subject to the FDA’s IDE regulation.
+Added: A manufacturer that wishes to conduct a clinical study involving the device is subject to the FDA’s IDE regulation.
The IDE regulation distinguishes between significant and non-significant risk device studies and the procedures for obtaining approval to begin the study differ accordingly.
8 unchanged sentences
The FDA typically grants IDE approval for a specified number of subjects to be enrolled at specified study centers.
−Removed: The clinical trial must be conducted in accordance with applicable regulations, including but not limited to the FDA’s IDE regulations and GCP.
+Added: The clinical trial must be conducted in accordance with applicable regulations, including but not limited to the FDA’s IDE regulations and GCP.
The investigators must obtain subject informed consent, rigorously follow the investigational plan and study protocol, control the disposition of investigational devices, and comply with all reporting and record keeping requirements.
A clinical trial may be suspended or terminated by the FDA, the IRB or the sponsor at any time for various reasons, including a belief that the risks to the study participants outweigh the benefits of participation in the trial.
−Removed: Approval of an IDE does not bind the FDA to accept the results of the trial as sufficient to prove the product’s safety and efficacy, even if the trial meets its intended success criteria.
+Added: Approval of an IDE does not bind the FDA to accept the results of the trial as sufficient to prove the product’s safety and efficacy, even if the trial meets its intended success criteria.
Post-Marketing Restrictions and Enforcement
3 unchanged sentences
● compliance with the QSR, which require manufacturers to follow stringent design, testing, control, documentation, record maintenance, including maintenance of complaint and related investigation files, and other quality assurance controls during the manufacturing process;
−Removed: unannounced routine or for-cause device inspections by the FDA, which may include our suppliers’
−Removed: facilities labeling regulations, which prohibit the promotion of products for uncleared or unapproved or “off-label”
−Removed: uses and impose other restrictions on labeling;
+Added: ● unannounced routine or for-cause device inspections by the FDA, which may include our suppliers’ facilities labeling regulations, which prohibit the promotion of products for uncleared or unapproved or “off-label” uses and impose other restrictions on labeling;
● post-approval restrictions or conditions, including requirements to conduct post-market surveillance studies to establish continued safety data or tracking products through the chain of distribution to the patient level.
−Removed: Under the FDA medical device reporting, or MDR, regulations, medical device manufacturers are required to report to the FDA information that a device has or may have caused or contributed to a death or serious injury or has malfunctioned in a way that would likely cause or contribute to death or serious injury if the malfunction of the device or
−Removed: a similar device of such manufacturer were to recur.
+Added: Under the FDA medical device reporting, or MDR, regulations, medical device manufacturers are required to report to the FDA information that a device has or may have caused or contributed to a death or serious injury or has malfunctioned in a way that would likely cause or contribute to death or serious injury if the malfunction of the device or a similar device of such manufacturer were to recur.
The decision to file an MDR involves a judgment by the manufacturer.
−Removed: If the FDA disagrees with the manufacturer’s determination, the FDA can take enforcement action.
+Added: If the FDA disagrees with the manufacturer’s determination, the FDA can take enforcement action.
Additionally, the FDA has the authority to require the recall of commercialized products in the event of material deficiencies or defects in design or manufacture.
18 unchanged sentences
● two or more separate products packaged together in a single package or as a unit and comprised of drug and device products;
−Removed: a drug or device packaged separately that according to its investigational plan or proposed labeling is intended for use only with an approved individually specified drug or device where both are required to achieve the intended use, indication, or effect and where upon approval of the proposed product the labeling of the approved product would need to be changed, e.g., to reflect a change in intended use, dosage form, strength, route of administration, or significant change in dose;
+Added: ● a drug or device packaged separately that according to its investigational plan or proposed labeling is intended for use only with an approved individually specified drug or device where both are required to achieve the intended use, indication, or effect and where upon approval of the proposed product the labeling of the
+Added: approved product would need to be changed, e.g., to reflect a change in intended use, dosage form, strength, route of administration, or significant change in dose;
● any investigational drug or device packaged separately that according to its proposed labeling is for use only with another individually specified investigational drug, device, or biological product where both are required to achieve the intended use, indication, or effect.
Under the FDCA, the FDA is charged with assigning a center with primary jurisdiction, or a lead center, for review of a combination product.
−Removed: That determination is based on the “primary mode of action”
−Removed: of the combination product.
+Added: That determination is based on the “primary mode of action” of the combination product.
Thus, if the primary mode of action of a device-drug combination product is attributable to the drug product, the FDA Center responsible for premarket review of the drug product would have primary jurisdiction for the combination product.
2 unchanged sentences
It is also responsible for developing guidance and regulations to clarify the regulation of combination products, and for assignment of the FDA center that has primary jurisdiction for review of combination products where the jurisdiction is unclear or in dispute.
−Removed: Review and Approval of Drug Products in the European Union
+Added: Review and Approval of Medical Products in the European Union
In order to market any product outside of the United States, a company must also comply with numerous and varying regulatory requirements of other countries and jurisdictions regarding quality, safety and efficacy and governing, among other things, clinical trials, marketing authorization, commercial sales and distribution of drug products.
8 unchanged sentences
Clinical trial application must be accompanied by an investigational medicinal product dossier with supporting information prescribed by the European Clinical Trials Directive and corresponding national laws of the member states and further detailed in applicable guidance documents.
−Removed: In April 2014, the EU adopted a new Clinical Trials Regulation, which is set to replace the current Clinical Trials Directive.
−Removed: The new Clinical Trials Regulation will be directly applicable to and binding in all 28 EU Member States without the need for any national implementing legislation.
+Added: In April 2014, the EU adopted a new Clinical Trials Regulation (EU) No 536/2014, which is set to replace the current Clinical Trials Directive 2001/20/EC.
+Added: The new Clinical Trials Regulation will become directly applicable to and binding in all 28 EU Member States without the need for any national implementing legislation.
+Added: It will overhaul the current system of approvals for clinical trials in the EU.
+Added: Specifically, the new legislation aims at simplifying and streamlining the approval of clinical trials in the EU.
Under the new coordinated procedure for the approval of clinical trials, the sponsor of a clinical trial will be required to submit a single application for approval of a clinical trial to a reporting EU Member State (RMS) through an EU Portal.
The submission procedure will be the same irrespective of whether the clinical trial is to be conducted in a single EU Member State or in more than one EU Member State.
−Removed: The Clinical Trials Regulation also aims to streamline and simplify the rules on safety reporting for clinical trials.
−Removed: As of January 1, 2020, the website of the European Commission reported that the implementation of the Clinical Trials Regulation was dependent on the development of a fully functional clinical trials portal and database, which would be confirmed by an independent audit, and that the new legislation would come into effect six months after the European Commission publishes a notice of this confirmation.
+Added: The Regulation was published on June 16, 2014 but has not yet become effective.
+Added: In January 2020, the website of the European Commission reported that the implementation of the Clinical Trials Regulation was dependent on the development of a fully functional clinical trials portal and database, which would be confirmed by an independent audit, and that the new legislation would come into effect six months after the European Commission publishes a notice of this confirmation.
The website indicated that the audit was expected to commence in December 2020.
+Added: In late 2020, the EMA indicated that it plans to focus on the findings of a system audit;
+Added: improving the usability, quality and stability of the clinical trial information system;
+Added: and knowledge transfer to prepare users and their organizations for the new clinical trial system.
+Added: The EMA has indicated that the system will go live in December 2021.
Marketing Authorization
12 unchanged sentences
The reference member state prepares a draft assessment report and drafts of the related materials within 210 days after receipt of a valid application.
−Removed: Within 90 days of receiving the reference member state’s assessment report and related materials, each concerned member state must decide whether to approve the assessment report and related materials.
+Added: Within 90 days of receiving the reference member state’s assessment report and related materials, each concerned member state must decide whether to approve the assessment report and related materials.
If a member state cannot approve the assessment report and related materials on the grounds of potential serious risk to public health, the disputed points are subject to a dispute resolution mechanism and may eventually be referred to the European Commission, whose decision is binding on all member states.
2 unchanged sentences
Regulation (EC) No 726/2004 repeats this entitlement for medicinal products authorized in accordance the centralized authorization procedure.
−Removed: Data exclusivity prevents applicants for authorization of generics of these innovative products from referencing the innovator’s data to assess a generic (abridged) application for a period of eight years.
−Removed: During an additional two-year period of market exclusivity, a generic marketing authorization application can be submitted and authorized, and the innovator’s data may be referenced, but no generic medicinal product can be placed on the EU market until the expiration of the market exclusivity.
+Added: Data exclusivity prevents applicants for authorization of generics of these innovative products from referencing the innovator’s data to assess a generic (abridged) application for a period of eight years.
+Added: During an additional two-year period of market exclusivity, a generic marketing authorization application can be submitted and authorized, and the innovator’s data may be referenced, but no generic medicinal product can be placed on the EU market until the expiration of the market exclusivity.
The overall ten-year period will be extended to a maximum of 11 years if, during the first eight years of those ten years, the marketing authorization holder obtains an authorization for one or more new therapeutic indications which, during the scientific evaluation prior to their authorization, are held to bring a significant clinical benefit in comparison with existing therapies.
10 unchanged sentences
These include:
−Removed: Compliance with the EU’s stringent pharmacovigilance or safety reporting rules must be ensured.
+Added: ● Compliance with the EU’s stringent pharmacovigilance or safety reporting rules must be ensured.
These rules can impose post-authorization studies and additional monitoring obligations.
−Removed: The manufacturing of authorized medicinal products , for which a separate manufacturer’s license is mandatory, must also be conducted in strict compliance with the applicable EU laws, regulations and guidance, including Directive 2001/83/EC, Directive 2003/94/EC, Regulation (EC) No 726/2004 and the European Commission Guidelines for Good Manufacturing Practice.
+Added: ● The manufacturing of authorized medicinal products, for which a separate manufacturer’s license is mandatory, must also be conducted in strict compliance with the applicable EU laws, regulations and guidance, including Directive 2001/83/EC, Directive 2003/94/EC, Regulation (EC) No 726/2004 and the European Commission Guidelines for Good Manufacturing Practice.
These requirements include compliance with EU cGMP standards when manufacturing medicinal products and active pharmaceutical ingredients, including the manufacture of active pharmaceutical ingredients outside of the EU with the intention to import the active pharmaceutical ingredients into the EU.
3 unchanged sentences
The European Union has adopted numerous directives and standards regulating, among other things, the design, manufacture, clinical trials, labeling, approval and adverse event reporting for medical devices.
−Removed: In the EU, medical devices must comply with the Essential Requirements in Annex I to the EU Medical Devices Directive (Council Directive 93/42/EEC), or the Essential Requirements.
+Added: In the European Union, or the EU, medical devices must comply with the Essential Requirements in Annex I to the currently applicable EU Medical Devices Directive (Council Directive 93/42/EEC), or the Essential Requirements.
Compliance with these requirements is a prerequisite to be able to affix the CE Mark of Conformity to medical devices, without which they cannot be marketed or sold in the European Economic Area, or EEA, comprised of the European Union member states plus Norway, Iceland, and Liechtenstein.
−Removed: Actual implementation of these directives, however, may vary on a country-by-country basis.
To demonstrate compliance with the Essential Requirements a manufacturer must undergo a conformity assessment procedure, which varies according to the type of medical device and its classification.
1 unchanged sentence
Notified Bodies are independent testing houses, laboratories, or product certifiers typically based within the European Union and authorized by the European member states to perform the required conformity assessment tasks, such as quality system audits and device compliance testing.
−Removed: The Notified Body would typically audit and examine the product’s Technical File and the quality system for the manufacture, design and final inspection of the product before issuing a CE Certificate of Conformity demonstrating compliance with the relevant Essential Requirements.
+Added: The Notified Body would typically audit and examine the product’s Technical File and the quality system for the manufacture, design and final inspection of the product before issuing a CE Certificate of Conformity demonstrating compliance with the relevant Essential Requirements.
Medical device manufacturers must carry out a clinical evaluation of their medical devices to demonstrate conformity with the relevant Essential Requirements.
−Removed: This clinical evaluation is part of the product’s Technical File.
−Removed: A clinical evaluation includes an assessment of whether a medical device’s performance is in accordance with its intended use, and that the known and foreseeable risks linked to the use of the device under normal conditions are minimized and acceptable when weighed against the benefits of its intended purpose.
+Added: This clinical evaluation is part of the product’s Technical File.
+Added: A clinical evaluation includes an assessment of whether a medical device’s performance is in accordance with its intended use, and that the known and foreseeable risks linked to the use of the device under normal conditions are minimized and acceptable when weighed against the benefits of its intended purpose.
The clinical evaluation conducted by the manufacturer must also address any clinical claims, the adequacy of the device labeling and information (particularly claims, contraindications, precautions and warnings) and the suitability of related Instructions for Use.
This assessment must be based on clinical data, which can be obtained from clinical studies conducted on the devices being assessed, scientific literature from similar devices whose equivalence with the assessed device can be demonstrated or both clinical studies and scientific literature.
−Removed: With respect to implantable devices or devices classified as Class III in the European Union, the manufacturer must conduct clinical studies to obtain the required clinical data, unless relying on existing clinical data from similar
−Removed: devices can be justified.
−Removed: As part of the conformity assessment process, depending on the type of devices, the Notified Body will review the manufacturer’s clinical evaluation process, assess the clinical evaluation data of a representative sample of the device’s subcategory or generic group, or assess all the clinical evaluation data, verify the manufacturer’s assessment of that data and assess the validity of the clinical evaluation report and the conclusions drawn by the manufacturer.
+Added: With respect to implantable devices or devices classified as Class III in the European Union, the manufacturer must conduct clinical studies to obtain the required clinical data, unless relying on existing clinical data from similar devices can be justified.
+Added: As part of the conformity assessment process, depending on the type of devices, the Notified Body will review the manufacturer’s clinical evaluation process, assess the clinical evaluation data of a representative sample of the device’s subcategory or generic group, or assess all the clinical evaluation data, verify the manufacturer’s assessment of that data and assess the validity of the clinical evaluation report and the conclusions drawn by the manufacturer.
Even after a manufacturer receives a CE Certificate of Conformity enabling the CE mark to be placed on it products and the right to sell the products in the EEA countries, a Notified Body or a competent authority may require post-marketing studies of the products.
Failure to comply with such requirements in a timely manner could result in the withdrawal of the CE Certificate of Conformity and the recall or withdrawal of the subject product from the European market.
−Removed: A manufacturer must inform the Notified Body that carried out the conformity assessment of the medical devices of any planned substantial changes to the devices which could affect compliance with the Essential Requirements or the devices’
−Removed: intended purpose.
−Removed: The Notified Body will then assess the changes and verify whether they affect the product’s conformity with the Essential Requirements or the conditions for the use of the devices.
+Added: A manufacturer must inform the Notified Body that carried out the conformity assessment of the medical devices of any planned substantial changes to the devices which could affect compliance with the Essential Requirements or the devices’ intended purpose.
+Added: The Notified Body will then assess the changes and verify whether they affect the product’s conformity with the Essential Requirements or the conditions for the use of the devices.
If the assessment is favorable, the Notified Body will issue a new CE Certificate of Conformity or an addendum to the existing CE Certificate of Conformity attesting compliance with the Essential Requirements.
10 unchanged sentences
FSCAs must be communicated by the manufacturer or its European Authorized Representative to its customers and to the end users of the device through Field Safety Notices.
−Removed: In September 2012, the European Commission adopted a proposal for a regulation which, if adopted, will change the way that most medical devices are regulated in the European Union, and may subject products to additional requirements.
+Added: The legal framework currently applicable for medical devices in the European Union will soon be amended by Medical Devices Regulation (Regulation (EU) 2017/745) adopted in 2017, which we refer to as the MDR and which
+Added: repeals and replaces the EU Medical Devices Directive.
+Added: Unlike directives, which must be implemented into the national laws of the European Economic Area, or EEA, member states, the MDR will be directly applicable (i.e., without the need for adoption of EEA member State laws implementing them) in all EEA member states and are intended to eliminate current differences in the regulation of medical devices among EEA member states.
+Added: The MDR, among other things, is intended to establish a uniform, transparent, predictable and sustainable regulatory framework across the EEA for medical and ensure a high level of safety and health.
+Added: Currently, the MDR is scheduled to become applicable on May 26, 2021.
+Added: Once applicable, the MDR will, among other things:
+Added: ● strengthen the rules on placing devices on the market and reinforce surveillance once they are available;
+Added: ● establish explicit provisions on manufacturers' responsibilities for the follow-up of the quality, performance and safety of devices placed on the market;
+Added: ● improve the traceability of medical devices throughout the supply chain to the end-user or patient through a unique identification number;
+Added: ● set up a central database to provide patients, healthcare professionals and the public with comprehensive information on products available in the EU;
+Added: ● strengthen rules for the assessment of certain high-risk devices, such as implants, which may have to undergo an additional check by experts before they are placed on the market.
Brexit and the Regulatory Framework in the United Kingdom
−Removed: On June 23, 2016, the electorate in the United Kingdom voted in favor of leaving the European Union, commonly referred to as Brexit.
−Removed: Following protracted negotiations, the United Kingdom left the European Union on January 31, 2020.
−Removed: Under the withdrawal agreement, there is a transitional period until December 31, 2020 (extendable up to two years).
−Removed: Discussions between the United Kingdom and the European Union have so far mainly focused on finalizing withdrawal issues and transition agreements but have been extremely difficult to date.
−Removed: To date, only an outline of a trade agreement has been reached.
−Removed: Much remains open but the Prime Minister has indicated that the United Kingdom will not seek to extend the transitional period beyond the end of 2020.
−Removed: If no trade agreement has been reached before the end of the transitional period, there may be significant market and economic disruption.
−Removed: The Prime Minister has also indicated that the UK will not accept high regulatory alignment with the EU.
−Removed: Since the regulatory framework for medical products in the United Kingdom covering quality, safety, and efficacy of medical products, clinical trials, marketing authorization, commercial sales, and distribution of medical products is
−Removed: derived from European Union directives and regulations, Brexit could materially impact the future regulatory regime that applies to products and the approval of product candidates in the United Kingdom.
−Removed: Any delay in obtaining, or an inability to obtain, any marketing approvals, as a result of Brexit or otherwise, may force us to restrict or delay efforts to seek regulatory approval in the United Kingdom and/or European Union for our product candidates, which could significantly and materially harm our business.
+Added: On June 23, 2016, the electorate in the United Kingdom voted in favor of leaving the EU, commonly referred to as Brexit.
+Added: Following protracted negotiations, the United Kingdom left the EU on January 31, 2020.
+Added: Under the withdrawal agreement, there is a transitional period until December 31, 2020 (extendable by up to two years).
+Added: On December 24, 2020, the United Kingdom and the European Union entered into a Trade and Cooperation Agreement.
+Added: The agreement sets out certain procedures for approval and recognition of medical products in each jurisdiction.
+Added: Since the regulatory framework for pharmaceutical products in the United Kingdom covering quality, safety and efficacy of pharmaceutical products, clinical trials, marketing authorization, commercial sales and distribution of pharmaceutical products is derived from EU directives and regulations, Brexit could materially impact the future regulatory regime which applies to products and the approval of product candidates in the UK, as the UK legislation now has the potential to diverge from EU legislation.
+Added: It remains to be seen how Brexit will impact regulatory requirements for product candidates and products in the UK in the long-term.
+Added: The MHRA has recently published detailed guidance for industry and organizations to follow from January 1, 2021 now the transition period is over, which will be updated as the UK’s regulatory position on medicinal products evolves over time.
+Added: Furthermore, while the Data Protection Act of 2018 in the United Kingdom that “implements” and complements the European Union’s General Data Protection Regulation, or GDPR, has achieved Royal Assent on May 23, 2018 and is now effective in the United Kingdom, it is still unclear whether transfer of data from the European Economic Area, or EEA, to the United Kingdom will remain lawful under GDPR.
+Added: The Trade and Cooperation Agreement provides for a transitional period during which the United Kingdom will be treated like an European Union member state in relation to processing and transfers of personal data for four months from January 1, 2021.
+Added: This may be extended by two further months.
+Added: After such period, the United Kingdom will be a “third country” under the GDPR unless the European Commission adopts an adequacy decision in respect of transfers of personal data to the United Kingdom.
+Added: The United Kingdom has already determined that it considers all of the EU 27 and EEA member states to be adequate for the purposes of data protection, ensuring that data flows from the United Kingdom to the EU/EEA remain unaffected.
General Data Protection Regulation
The collection, use, disclosure, transfer, or other processing of personal data regarding individuals in the EU, including personal health data, is subject to the EU General Data Protection Regulation, or GDPR, which became effective on May 25, 2018.
−Removed: The GDPR is wide-ranging in scope and imposes numerous requirements on companies that process personal data, including requirements relating to processing health and other sensitive data, obtaining consent of the individuals to whom the personal data relates, providing information to individuals regarding data processing activities, implementing safeguards to protect the security and confidentiality of personal data, providing notification of data breaches, and taking certain measures when engaging third-party processors.
−Removed: The GDPR also imposes strict rules on the transfer of personal data to countries outside the EU , including the United States, and permits data protection authorities to impose large penalties for violations of the GDPR, including potential fines of up to €20 million or 4% of annual global revenues, whichever is greater.
+Added: The GDPR is wide-ranging in scope and imposes numerous requirements on companies that
+Added: process personal data, including requirements relating to processing health and other sensitive data, obtaining consent of the individuals to whom the personal data relates, providing information to individuals regarding data processing activities, implementing safeguards to protect the security and confidentiality of personal data, providing notification of data breaches, and taking certain measures when engaging third-party processors.
+Added: The GDPR also imposes strict rules on the transfer of personal data to countries outside the EU, including the United States, and permits data protection authorities to impose large penalties for violations of the GDPR, including potential fines of up to €20 million or 4% of annual global revenues, whichever is greater.
The GDPR also confers a private right of action on data subjects and consumer associations to lodge complaints with supervisory authorities, seek judicial remedies, and obtain compensation for damages resulting from violations of the GDPR.
9 unchanged sentences
In order to secure coverage and reimbursement for any product that might be approved for sale, a company may need to conduct expensive pharmacoeconomic studies in order to demonstrate the medical necessity and cost-effectiveness of the product, in addition to the costs required to obtain FDA or other comparable regulatory approvals.
−Removed: A payor’s decision to provide coverage for a product does not imply that an adequate reimbursement rate will be approved.
+Added: A payor’s decision to provide coverage for a product does not imply that an adequate reimbursement rate will be approved.
Third-party reimbursement may not be sufficient to maintain price levels high enough to realize an appropriate return on investment in product development.
−Removed: Section 1833(t)(6) of the Social Security Act provides for temporary additional payments or “transitional pass-through payments”
−Removed: for certain drugs and biological agents.
−Removed: As originally enacted by the Balanced Budget Refinement Act of 1999, this provision required Centers for Medicare & Medicaid Services, or CMS, to make additional payments to hospitals for current orphan drugs, as designated under section 526 of the FDCA;
+Added: Section 1833(t)(6) of the Social Security Act provides for temporary additional payments or “transitional pass-through payments” for certain drugs and biological agents.
+Added: As originally enacted by the Balanced Budget Refinement Act of 1999, this provision required Centers for Medicare and Medicaid Services, or CMS, to make additional payments to hospitals for current orphan drugs, as designated under section 526 of the FDCA;
current drugs and biological agents and brachytherapy sources used for the treatment of cancer;
and current radiopharmaceutical drugs and biological products.
−Removed: Transitional pass-through payments are also provided for certain new drugs, devices and biological agents that were not paid for as a hospital outpatient department service as of December 31, 1996, and whose cost is “not insignificant”
−Removed: in relation to the Outpatient Prospective Payment System payment for the procedures or services associated with the new drug, device, or biological.
+Added: Transitional pass-through payments are also provided for certain new drugs, devices and biological agents that were not paid for as a hospital outpatient department service as of December 31, 1996, and whose cost is “not insignificant” in relation to the Outpatient Prospective Payment System payment for the procedures or services associated with the new drug, device, or biological.
Under the statute, transitional pass-through payments can be made for at least two years but not more than three years.
−Removed: We applied for a transitional pass-through reimbursement status, or C-code, on November 30, 2018 for DEXTENZA from the Centers for Medicare and Medicaid Services, or CMS.
−Removed: In May 2019, we received formal notification from CMS that it had approved transitional pass-through payment status and established a new C-Code for DEXTENZA that subsequently became effective on July 1, 2019.
−Removed: We expected pricing for DEXTENZA while in pass-through status to be approximately $538 per surgery, and we expected pass-through status would remain in effect for up to three years from the effective date of the C-code, or July 1, 2019.
−Removed: We also submitted an application to the CMS for a J-Code for DEXTENZA on December 28, 2018, and received a specific and permanent J-Code in July 2019 which became effective on October 1, 2019.
−Removed: With the effectiveness of our permanent J-Code as of October 1, 2019, our C-code is no longer in effect.
+Added: We applied for a transitional pass-through reimbursement status on November 30, 2018 for DEXTENZA from CMS.
+Added: In May 2019, we received formal notification from CMS that it had approved transitional pass-through payment status and established an interim billing code, known as a C-Code, for DEXTENZA that subsequently became effective on July 1, 2019.
+Added: We also submitted an application to CMS for a J-Code for DEXTENZA in December 2018 and received a specific and permanent J-Code J1096 in July 2019 which became effective on October 1, 2019.
+Added: With the effectiveness of our permanent J-Code for DEXTENZA as of October 1, 2019, our C-code is no longer in effect.
+Added: J-Codes are familiar to both medical practices and their billing staffs, as well as Medicare (Part B and Part C) and commercial insurers.
+Added: As a result, J-Codes generally allow for a simpler and more convenient reimbursement process.
+Added: We expect pricing for DEXTENZA while in pass-through payment status to be approximately $538 per insert, and we expect pass-through status to remain in effect for up to three years from the effective date of the C-code, or July 1, 2019.
+Added: To date, four of seven Medicare Administrative Contractors, or MACs, have established physician fee schedules for the Category III Current Procedural Terminology, or CPT, procedure code 0356T currently in effect for the administration of drug-eluting intracanalicular inserts, including DEXTENZA:
+Added: Novitas Solutions, Inc., or Novitas;
+Added: First Coast Service Options, Inc., or First Coast;
+Added: National Government Services, Inc., or NGS;
+Added: and Wisconsin Physician Services, Inc, or WPS.
+Added: The professional fee for CPT code 0356T is now eligible for physician payment for each insertion, in accordance with the applicable MAC’s fee schedule.
+Added: Novitas covers Medicare patients in New Mexico, Texas, Colorado, Oklahoma, Arkansas, Louisiana, Mississippi, New Jersey, Pennsylvania, Delaware, Virginia and the District of Columbia.
+Added: First Coast covers Medicare patients in Florida, Puerto Rico, and the U.S.
+Added: Virgin Islands.
+Added: NGS covers Medicare patients in Illinois, Minnesota, Wisconsin, New York, Massachusetts, Connecticut, New Hampshire, Maine, Rhode Island, and Vermont.
+Added: Wisconsin Physician Services, Inc.
+Added: covers Medicare beneficiaries in Iowa, Kansas, Missouri, Nebraska, Indiana and Michigan.
+Added: Combined, Novitas, First Coast, NGS and WPS cover over 60% of all Medicare beneficiaries.
+Added: As of March 1, 2021, all seven MACs were reimbursing providers for intracanalicular insertions under CPT code 0356T despite only four of them having published physician fee schedules for the procedure.
+Added: On November 4, 2020, we announced that our application to the American Medical Association CPT Editorial Panel, or the Panel, for the creation of a Category I CPT procedure code had been granted.
+Added: Category I CPT codes normally have a standardized Medicare physician fee schedule.
+Added: As a result, they can improve coverage and payment across all payers for procedures performed in both the ASC and physician office settings.
+Added: The Panel has agreed to create a permanent Category I CPT procedure code, effective January 1, 2022, to replace CPT code 0356T currently in effect for the administration of drug-eluting intracanalicular inserts including DEXTENZA.
In the European Union, pricing and reimbursement schemes vary widely from country to country.
21 unchanged sentences
● analogous state and foreign laws and regulations, such as state anti-kickback and false claims laws, may apply to sales or marketing arrangements and claims involving healthcare items or services reimbursed by non-governmental third-party payors, including private insurers.
−Removed: Some state laws require pharmaceutical companies to comply with the pharmaceutical industry’s voluntary compliance guidelines and the relevant compliance guidance promulgated by the federal government in addition to requiring drug manufacturers to report information related to payments to physicians and other health care providers or marketing expenditures.
+Added: Some state laws require pharmaceutical companies to comply with the pharmaceutical industry’s voluntary compliance guidelines and the relevant compliance guidance promulgated by the federal government in addition to requiring drug manufacturers to report information related to payments to physicians and other health care providers or marketing expenditures.
State and foreign laws also govern the privacy and security of health information in some circumstances, many of which differ from each other in significant ways and often are not preempted by HIPAA, thus complicating compliance efforts.
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In March 2010, the United States Congress enacted the Patient Protection and Affordable Care Act, or ACA, which, among other things, includes changes to the coverage and payment for products under government health care programs.
−Removed: Among the provisions of ACA of importance to potential drug candidates are:
−Removed: an annual, nondeductible fee on any entity that manufactures or imports specified branded prescription drugs and biologic agents, apportioned among these entities according to their market share in certain government healthcare programs, although this fee would not apply to sales of certain products approved exclusively for orphan indications;
−Removed: expansion of eligibility criteria for Medicaid programs by, among other things, allowing states to offer Medicaid coverage to certain individuals with income at or below 133% of the federal poverty level, thereby potentially increasing a manufacturer’s Medicaid rebate liability;
−Removed: expanded manufacturers’
−Removed: rebate liability under the Medicaid Drug Rebate Program by increasing the minimum rebate for both branded and generic drugs and revising the definition of “average manufacturer price,”
−Removed: or AMP, for calculating and reporting Medicaid drug rebates on outpatient prescription drug prices and extending rebate liability to prescriptions for individuals enrolled in Medicare Advantage plans;
−Removed: addressed a new methodology by which rebates owed by manufacturers under the Medicaid Drug Rebate Program are calculated for drugs that are inhaled, infused, instilled, implanted or injected;
−Removed: expanded the types of entities eligible for the 340B drug discount program;
−Removed: established the Medicare Part D coverage gap discount program by requiring manufacturers to provide a 50% point-of-sale-discount off the negotiated price of applicable brand drugs to eligible beneficiaries during their coverage gap period as a condition for the manufacturers’
−Removed: outpatient drugs to be covered under Medicare Part D;
−Removed: a new Patient-Centered Outcomes Research Institute to oversee, identify priorities in, and conduct comparative clinical effectiveness research, along with funding for such research;
−Removed: the Independent Payment Advisory Board, or IPAB, which has authority to recommend certain changes to the Medicare program to reduce expenditures by the program that could result in reduced payments for prescription drugs.
−Removed: However, the IPAB implementation has been not been clearly defined.
−Removed: ACA provided that under certain circumstances, IPAB recommendations will become law unless Congress enacts legislation that will achieve the same or greater Medicare cost savings;
−Removed: established the Center for Medicare and Medicaid Innovation within CMS to test innovative payment and service delivery models to lower Medicare and Medicaid spending, potentially including prescription drug spending.
−Removed: Funding has been allocated to support the mission of the Center for Medicare and Medicaid Innovation from 2011 to 2019.
−Removed: Other legislative changes have been proposed and adopted in the United States since ACA was enacted.
−Removed: For example, in August 2011, the Budget Control Act of 2011, among other things, created measures for spending reductions by Congress.
−Removed: A Joint Select Committee on Deficit Reduction, tasked with recommending a targeted deficit reduction of at least $1.2 trillion for the years 2012 through 2021, was unable to reach required goals, thereby triggering the legislation’s automatic reduction to several government programs.
−Removed: This includes aggregate reductions of Medicare payments to providers of up to 2% per fiscal year, which went into effect in April 2013 and will remain in effect through 2024 unless additional Congressional action is taken.
−Removed: In January 2013, President Obama signed into law the American Taxpayer Relief Act of 2012, which, among other things, further reduced Medicare payments to several providers, including hospitals, imaging centers and cancer treatment centers, and increased the statute of limitations period for the government to recover overpayments to providers from three to five years.
+Added: In addition, other legislative changes have been proposed and adopted since the ACA was enacted.
+Added: In August 2011, the Budget Control Act of 2011, among other things, created measures for spending reductions by Congress.
+Added: A Joint Select Committee on Deficit Reduction, tasked with recommending a targeted deficit reduction of at least $1.2 trillion for the years 2013 through 2021, was unable to reach required goals, thereby triggering the legislation’s automatic reduction to several government programs.
+Added: These changes included aggregate reductions to Medicare payments to providers of up to 2% per fiscal year, which went into effect in April 2013 and will remain in effect through 2030 under the Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act.
+Added: The American Taxpayer Relief Act of 2012, among other things, reduced Medicare payments to several providers and increased the statute of limitations period for the government to recover overpayments to providers from three to five years.
These laws may result in additional reductions in Medicare and other healthcare funding and otherwise affect the prices we may obtain for any of our product candidates for which we may obtain regulatory approval or the frequency with which any such product candidate is prescribed or used.
−Removed: Since enactment of the ACA, there have been numerous legal challenges and Congressional actions to repeal and replace provisions of the law.
−Removed: For example, with enactment of the Tax Cuts and Jobs Act of 2017, which was signed by the President on December 22, 2017, Congress repealed the “individual mandate.”
−Removed: The repeal of this provision, which requires most Americans to carry a minimal level of health insurance, will become effective in 2019.
−Removed: According to the Congressional Budget Office, the repeal of the individual mandate will cause 13 million fewer Americans to be insured in 2027 and premiums in insurance markets may rise.
−Removed: Additionally, on January 22, 2018, President Trump signed a continuing resolution on appropriations for fiscal year 2018 that delayed the implementation of certain ACA-mandated fees, including the so-called “Cadillac”
−Removed: tax on certain high cost employer-sponsored insurance plans, the annual fee imposed on certain health insurance providers based on market share, and the medical device excise tax on non-exempt medical devices.
−Removed: Further, the Bipartisan Budget Act of 2018, among other things, amends the ACA, effective January 1, 2019, to increase from 50 percent to 70 percent the point-of-sale discount that is owed by pharmaceutical manufacturers who participate in Medicare Part D and to close the coverage gap in most Medicare drug plans, commonly referred to as the “donut hole”.
−Removed: The Trump Administration has also taken executive actions to undermine or delay implementation of the ACA.
−Removed: Since January 2017, President Trump has signed two Executive Orders designed to delay the implementation of certain provisions of the ACA or otherwise circumvent some of the requirements for health insurance mandated by the ACA.
−Removed: One Executive Order directs federal agencies with authorities and responsibilities under the ACA to waive, defer, grant exemptions from, or delay the implementation of any provision of the ACA that would impose a fiscal or regulatory burden on states, individuals, healthcare providers, health insurers, or manufacturers of pharmaceuticals or medical devices.
−Removed: The second Executive Order terminates the cost-sharing subsidies that reimburse insurers under the ACA.
−Removed: Several state Attorneys General filed suit to stop the administration from terminating the subsidies, but their request for a restraining order was denied by a federal judge in California on October 25, 2017.
−Removed: In addition, CMS has recently proposed regulations that would give states greater flexibility in setting benchmarks for insurers in the individual and small group marketplaces, which may have the effect of relaxing the essential health benefits required under the ACA for plans sold through such marketplaces.
−Removed: Further, on June 14, 2018, U.S.
−Removed: Court of Appeals for the Federal Circuit ruled that the federal government was not required to pay more than $12 billion in ACA risk corridor payments to third-party payors who argued were owed to them.
−Removed: The effects of this gap in reimbursement on third-party payors, the viability of the ACA marketplace, providers, and potentially our business, are not yet known.
−Removed: In addition, on December 14, 2018, a U.S.
+Added: Since enactment of the ACA, there have been, and continue to be, numerous legal challenges and Congressional actions to repeal and replace provisions of the law.
+Added: For example, with enactment of the Tax Cuts and Jobs Act of 2017, which was signed by President Trump on December 22, 2017, Congress repealed the “individual mandate.” The repeal of this provision, which requires most Americans to carry a minimal level of health insurance, became effective in 2019.
+Added: Further, on December 14, 2018, a U.S.
District Court judge in the Northern District of Texas ruled that the individual mandate portion of the ACA is an essential and inseverable feature of the ACA, and therefore because the mandate was repealed as part of the Tax Cuts and Jobs Act, the remaining provisions of the ACA are invalid as well.
−Removed: The Trump administration and CMS have both stated that the ruling will have no immediate effect, and on December 30, 2018 the same judge issued an order staying the judgment pending appeal.
−Removed: The Trump Administration recently represented to the Court of Appeals considering this judgment that it does not oppose the lower court’s ruling.
−Removed: On July 10, 2019, the Court of Appeals for the Fifth Circuit heard oral argument in this case.
−Removed: On December 18, 2019, that court affirmed the lower court’s ruling that the individual mandate portion of the ACA is unconstitutional and it remanded the case to the district court for reconsideration of the severability question and additional analysis of the provisions of the ACA.
−Removed: On January 21, 2020, the U.S.
−Removed: Supreme Court declined to review this decision on an expedited basis.
+Added: On December 18, 2019, the Court of Appeals for the Fifth Circuit affirmed the lower court’s ruling that the individual mandate portion of the ACA is unconstitutional and it remanded the case to the district court for reconsideration of the severability question and additional analysis of the provisions of the ACA.
+Added: Thereafter, the U.S.
+Added: Supreme Court agreed to hear this case.
+Added: Oral argument in the case took place on November 10, 2020.
+Added: On February 10, 2021, the Biden Administration withdrew DOJ’s support for this lawsuit.
+Added: A ruling by the U.S.
+Added: Supreme Court is expected sometime this year.
Litigation and legislation over the ACA are likely to continue, with unpredictable and uncertain results.
−Removed: Further , there have been several recent U.S.
−Removed: congressional inquiries and proposed federal and proposed and enacted state legislation designed to, among other things, bring more transparency to drug pricing, review the relationship between pricing and manufacturer patient programs, reduce the costs of drugs under Medicare and reform government program reimbursement methodologies for drug products.
−Removed: For example, there have been several recent U.S.
−Removed: congressional inquiries and proposed federal and proposed and enacted state legislation designed to, among other things, bring more transparency to drug pricing, review the relationship between pricing and manufacturer patient programs, reduce the costs of drugs under Medicare and reform government program reimbursement methodologies for drug products.
−Removed: At the federal level, Congress and the Trump administration have each indicated that it will continue to seek new legislative and/or administrative measures to control drug costs.
−Removed: For example, on May 11, 2018, the Administration issued a plan to lower drug prices.
−Removed: Under this blueprint for action, the Administration indicated that the Department of Health and Human Services (HHS) will:
−Removed: take steps to end the gaming of regulatory and patent processes by drug makers to unfairly protect monopolies;
−Removed: advance biosimilars and generics to boost price competition;
−Removed: evaluate the inclusion of prices in drug makers’
−Removed: ads to enhance price competition;
−Removed: speed access to and lower the cost of new drugs by clarifying policies for sharing information between insurers and drug makers;
−Removed: avoid excessive pricing by relying more on value-based pricing by expanding outcome-based payments in Medicare and Medicaid;
−Removed: work to give Part D plan sponsors more negotiation power with drug makers;
−Removed: examine which Medicare Part B drugs could be negotiated for a lower price by Part D plans, and improving the design of the Part B Competitive Acquisition Program;
−Removed: update Medicare’s drug-pricing dashboard to increase transparency;
−Removed: prohibit Part D contracts that include “gag rules”
−Removed: that prevent pharmacists from informing patients when they could pay less out-of-pocket by not using insurance;
−Removed: and require that Part D plan members be provided with an annual statement of plan payments, out-of-pocket spending, and drug price increases.
−Removed: In addition, on December 23, 2019, the Trump Administration published a proposed rulemaking that, if finalized, would allow states or certain other non-federal government entities to submit importation program proposals to FDA for review and approval.
−Removed: Applicants would be required to demonstrate their importation plans pose no additional risk to public health and safety and will result in significant cost savings for consumers.
−Removed: At the same time, FDA issued draft guidance that would allow manufacturers to import their own FDA-approved drugs that are authorized for sale in other countries (multi-market approved products).
+Added: The Trump Administration also took executive actions to undermine or delay implementation of the ACA, including directing federal agencies with authorities and responsibilities under the ACA to waive, defer, grant exemptions from, or delay the implementation of any provision of the ACA that would impose a fiscal or regulatory burden on states, individuals, healthcare providers, health insurers, or manufacturers of pharmaceuticals or medical devices.
+Added: On January 28, 2021, however, President Biden rescinded those orders and issued a new Executive Order which directs federal agencies to reconsider rules and other policies that limit Americans’ access to health care, and consider actions that will protect and strengthen that access.
+Added: Under this Order, federal agencies are directed to re-examine:
+Added: policies that undermine protections for people with pre-existing conditions, including complications related to COVID-19;
+Added: demonstrations and waivers under Medicaid and the ACA that may reduce coverage or undermine the programs, including work requirements;
+Added: policies that undermine the Health Insurance Marketplace or other markets for health insurance;
+Added: policies that make it more difficult to enroll in Medicaid and the ACA;
+Added: and policies that reduce affordability of coverage or financial assistance, including for dependents.
+Added: The costs of prescription pharmaceuticals have also been the subject of considerable discussion in the United States To date, there have been several recent U.S.
+Added: congressional inquiries, as well as proposed and enacted state and federal legislation designed to, among other things, bring more transparency to drug pricing, review the relationship between pricing and manufacturer patient programs, reduce the costs of drugs under Medicare and reform government program reimbursement methodologies for drug products.
+Added: To those ends, President Trump issued five executive orders intended to lower the costs of prescription drug products but it is unclear whether, and to what extent, these orders will remain in force under the Biden Administration.
+Added: Further, on September 24, 2020, the Trump Administration finalized a rulemaking allowing states or certain other non-federal government entities to submit importation program proposals to the FDA for review and approval.
+Added: Applicants are required to demonstrate that their importation plans pose no additional risk to public health and safety and will result in significant cost savings for consumers.
+Added: The FDA has issued draft guidance that would allow manufacturers to import their own FDA-approved drugs that are authorized for sale in other countries (multi-market approved products).
At the state level, individual states are increasingly aggressive in passing legislation and implementing regulations designed to control pharmaceutical and biological product pricing, including price or patient reimbursement constraints, discounts, restrictions on certain product access and marketing cost disclosure and transparency measures, and, in some cases, designed to encourage importation from other countries and bulk purchasing.
2 unchanged sentences
We expect that additional state and federal healthcare reform measures will be adopted in the future, any of which could limit the amounts that federal and state governments will pay for healthcare products and services, which could result in reduced demand for our product candidates or additional pricing pressures.
−Removed: As of March 2, 2020, we had 161 full-time employees.
−Removed: Of these full-time employees, 71 employees are primarily engaged in research and development activities.
+Added: Human Capital
+Added: As of December 31, 2020, we had 181 full-time employees.
+Added: The following table provides an overview of the distribution of those employees:
+Added: Research & Development
+Added: Sales & Marketing
+Added: Manufacturing
+Added: General & Administrative
+Added: Total Employees
+Added: We are committed to inclusion and diversity and believe that these are important elements of our culture that enables us to attract and retain a high quality workforce.
+Added: As of December 31, 2020, our workforce was composed of 48% female and 52% male, and 25% of the workforce was non-white.
+Added: The development, attraction and retention of employees is a critical success factor for us for the execution of our business strategy and succession planning.
+Added: To support the advancement of our employees, we offer training and development programs encouraging advancement from within and continue to fill our team with strong and experienced management talent.
+Added: We leverage both formal and informal programs to identify, foster, and retain top talent at both the corporate and operating unit level.
+Added: We provide employee wages and benefits that are competitive and consistent with the employee positions, skill levels, experience, knowledge and geographic location.
None of our employees are represented by labor unions or covered by collective bargaining agreements.
We consider our relationship with our employees to be good.
+Added: We value the health, safety and wellbeing of our employees and their families.
+Added: In response to the COVID-19 pandemic, we have implemented significant changes that we determined were in the best interest of our employees, as well as the communities in which we operate, and which comply with government regulations.
+Added: This includes allowing a number of our corporate employees to work remotely, as appropriate, while implementing significant safety measures designed to protect the health of all those entering our office.
Our Corporate Information
9 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.