−Removed: Overview of Ocular Therapeutix
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-based formulation technology.
−Removed: Core to our strategy is (i) to continue to build upon our experience commercializing ophthalmology products that can be administered primarily in the surgical and/or office settings and (ii) to continue to develop a clinical pipeline of innovative ophthalmology products that address large areas of unmet need.
−Removed: We currently have two FDA-approved products in commercialization in the United States:
−Removed: DEXTENZA, an intracanalicular insert for the treatment of both post-surgical ocular inflammation and pain and ocular itching associated with allergic conjunctivitis, and ReSure Sealant, an ophthalmic device designed to prevent wound leaks in corneal incisions following cataract surgery.
−Removed: We also have product candidates in preclinical and clinical development designed to utilize our proprietary, bioresorbable hydrogel technology to treat retinal diseases including wet age-related macular degeneration, or wet AMD;
−Removed: glaucoma and ocular hypertension;
−Removed: and ocular surface diseases and conditions including dry eye disease.
−Removed: We incorporate therapeutic agents that have previously received regulatory approval from the U.S.
−Removed: Food and Drug Administration, or FDA, including small molecules and proteins, into our proprietary bioresorbable hydrogel-based formulation technology in our internal drug development activities, with the goal of providing local programmed release to tailor the duration and amount of drug to be delivered 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 intravitreal implants, suprachoroidal implants, intracameral implants and intracanalicular inserts.
−Removed: Commercial Portfolio
−Removed: Post-Surgical Ocular Inflammation and Pain
−Removed: Ocular Itching Associated with Allergic Conjunctivitis
−Removed: DEXTENZA (dexamethasone ophthalmic insert) 0.4 mg for intracanalicular use for the Treatment of Post-Surgical Ocular Inflammation and Pain
−Removed: 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.
−Removed: The FDA approved a new drug application, or NDA, for DEXTENZA for the treatment of post-surgical ocular pain in November 2018 and approved a supplemental new drug application, or sNDA, for DEXTENZA for the treatment of post-surgical ocular inflammation in June 2019.
−Removed: In July 2019, we commercially launched DEXTENZA in the United States.
−Removed: DEXTENZA is the first FDA-approved, physician-administered intracanalicular insert delivering dexamethasone to treat post-surgical ocular inflammation and pain for up to 30 days with a single administration.
−Removed: In October 2021, the FDA approved an sNDA for DEXTENZA to include the treatment of ocular itching associated with allergic conjunctivitis as an additional indication.
−Removed: With the approval, DEXTENZA is the first FDA-approved, physician-administered intracanalicular insert for the delivery of a preservative-free drug for the treatment of ocular itching associated with allergic conjunctivitis with a single administration for up to 30 days.
−Removed: DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis also represents our first indication approved to be administered in a physician’s office during a routine, non-surgical appointment.
−Removed: In the first quarter of 2022, we are commercially launching DEXTENZA in the United States for the treatment of ocular itching associated with allergic conjunctivitis.
−Removed: Prevention of Wound Leaks Following Cataract Surgery
−Removed: ReSure Sealant
−Removed: 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.
−Removed: 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: As of the fourth quarter of 2021, we have suspended the production of ReSure in order to focus our manufacturing resources to support the commercialization of DEXTENZA.
−Removed: We have received only limited revenues from ReSure Sealant to date.
−Removed: Clinical Portfolio
−Removed: Our clinical portfolio is comprised of our development efforts in our retinal disease program, glaucoma program and ocular surface disease programs.
−Removed: Retinal Disease Program
−Removed: OTX-TKI (axitinib intravitreal implant)
−Removed: 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 and designed for a duration of six months or longer.
−Removed: We are conducting a Phase 1 clinical trial of OTX-TKI in Australia and a Phase 1 clinical trial in the United States.
−Removed: The U.S.-based Phase 1 clinical trial is fully enrolled, and we expect to report interim, six-month data in the second half of 2022.
−Removed: At the Angiogenesis, Exudation, and Degeneration 2022 Meeting held in February 2022, we presented interim data from the ongoing Phase 1 clinical trial of OTX-TKI for the treatment of wet AMD conducted in Australia.
−Removed: In subjects with subretinal and/or intraretinal fluid due to wet AMD, OTX-TKI was observed to be generally well tolerated with a favorable safety profile to date.
−Removed: This data also showed a preliminary signal of biological activity as observed by a clinically-meaningful decrease in intraretinal and/or subretinal fluid.
−Removed: Extended duration of activity was observed with over 60% of subjects across all cohorts and with over 80% of subjects in cohort 3a (600μg) with a duration of activity of six months or more that we believe could represent a compelling drug product profile.
−Removed: Glaucoma Program
−Removed: OTX-TIC (travoprost intracameral implant)
−Removed: 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.
−Removed: In the fourth quarter of 2021, we initiated a randomized, double-masked, active-controlled Phase 2 clinical trial in which we plan to enroll approximately 105 subjects with open-angle glaucoma at 15-20 sites between three arms of approximately 35 subjects each to evaluate two formulations of OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension in patients compared to DURYSTA™.
−Removed: We expect to dose the first patient in the first quarter of 2022.
−Removed: At Glaucoma 360 in February 2022, we presented interim data from a Phase 1 clinical trial evaluating OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension.
−Removed: This data highlighted the product candidate’s ability to cause a clinically meaningful decrease in intraocular pressure for six months or longer while preserving corneal health.
−Removed: We believe these results are comparable to the decrease in intraocular pressure seen with topical travoprost, the current standard of care, and represent OTX-TIC’s potential for a unique and differentiated drug product profile.
−Removed: OTX-TIC was observed to be generally well tolerated with a favorable safety profile to date and endothelial cell counts, pachymetry assessments, and slit lamp examinations in subjects indicated no changes from baseline.
−Removed: Ocular Surface Disease Programs
−Removed: Dry Eye Disease
−Removed: OTX-CSI (cyclosporine intracanalicular insert)
−Removed: 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.
−Removed: 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.
−Removed: We announced topline results from a Phase 2 clinical trial evaluating two different formulations of OTX-CSI for the chronic treatment of dry eye disease in October 2021.
−Removed: The study did not show separation between the subjects receiving OTX-CSI (two formulations) and the subjects receiving the vehicle (both formulations).
−Removed: Overall, the OTX-CSI insert (both formulations) was observed to be generally well tolerated with a favorable safety profile to date.
−Removed: We are currently developing an appropriate clinical-regulatory development and manufacturing plan.
−Removed: This plan will include additional formulation work for the OTX-CSI insert to allow improved retention and the development of an appropriate vehicle comparator.
−Removed: OTX-DED (dexamethasone intracanalicular insert)
−Removed: 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.
−Removed: 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.
−Removed: We announced the topline results for a Phase 2 clinical trial evaluating OTX-DED for the short-term treatment of the signs and symptoms of dry eye disease in December 2021.
−Removed: The clinical trial achieved its pre-specified primary endpoint.
−Removed: While the clinical trial was not powered to show statistical significance, the topline results demonstrated a statistically significant change of bulbar conjunctival hyperemia from baseline to day 15 compared to vehicle hydrogel using a central reading photographic assessment in the modified ITT population.
−Removed: Both formulations of OTX-DED were observed to have a favorable safety profile and to be generally well tolerated.
−Removed: We are currently developing an appropriate clinical-regulatory development and manufacturing plan.
−Removed: This plan will include additional formulation work for the OTX-DED insert and the development of an appropriate vehicle comparator.
−Removed: AffaMed License Agreement
−Removed: 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 ;
−Removed: South Korea ;
−Removed: and the ASEAN markets ( Brunei , Cambodia , Indonesia , Laos , Malaysia , Myanmar , the Philippines , Singapore , Thailand and Vietnam ).
−Removed: Under the terms of the agreement, we received an upfront payment of $12 million and became 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.
−Removed: In the fourth quarter of 2021, we received a $1 million milestone payment;
−Removed: we expect to recognize a clinical support payment of another $2 million in the first quarter of 2022 in connection with dosing the first patient in a Phase 2 clinical trial evaluating OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension.
−Removed: Royalties are tiered and will range from the low teens to low twenty percent range.
−Removed: 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.
−Removed: In January 2022, AffaMed announced that it had dosed its first patient in a real-world study conducted in China evaluating the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain post-cataract surgery.
−Removed: We retain the right to develop and commercialize DEXTENZA and OTX-TIC in all other global markets.
−Removed: Additional Potential Areas for Growth
−Removed: 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: In June 2021, we entered into an agreement with Mosaic Biosciences, Inc., or Mosaic, to identify new targets and discover novel therapeutic agents aimed at the treatment of dry age-related macular degeneration, or dAMD.
−Removed: Market Background
−Removed: 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.
−Removed: Bioresorbable materials gradually break down in the body into non-toxic, water soluble compounds that are cleared by normal biological processes.
−Removed: PEG is used in many pharmaceutical products and is widely considered to be safe and biocompatible.
−Removed: 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, intracameral implant, and intravitreal implant product candidates;
−Removed: our suprachoroidal formulations;
−Removed: and ReSure Sealant.
−Removed: 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: Product Pipeline
−Removed: The following table summarizes the status of our key product development programs and DEXTENZA, our primary marketed product.
−Removed: 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 that remain outstanding other than 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 .
−Removed: Our strategy is to build an ophthalmology-focused biopharmaceutical company that capitalizes on the gaps that we believe increasingly exist in the ophthalmology sector between single product companies and large, multi-product pharmaceutical companies.
−Removed: Core to our strategy is (i) to continue to build upon our experience in commercializing ophthalmology products that can be administered primarily in the surgical and/or office settings and (ii) to continue to develop a clinical pipeline of innovative ophthalmology products that address large areas of unmet need.
+Added: Our mission is to build an ophthalmology-focused biopharmaceutical company that capitalizes on the gaps that we believe increasingly exist in the ophthalmology sector between single product companies and large, multi-product pharmaceutical companies.
+Added: Our current products and product candidates in clinical development incorporate therapeutic agents that have previously received regulatory approval from the U.S.
+Added: Food and Drug Administration, or FDA, including small molecules, into our proprietary bioresorbable hydrogel-based formulation technology in our internal drug development activities, with the goal of providing local programmed release to tailor the duration and amount of drug to be delivered to the eye.
+Added: We believe that our local programmed-release drug delivery technology has the potential to enable the treatment of 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, intracameral implants and intracanalicular inserts.
+Added: We are currently commercializing DEXTENZA, an intracanalicular insert for the treatment of both post-surgical ocular inflammation and pain and ocular itching associated with allergic conjunctivitis, in the United States.
+Added: We also have product candidates in preclinical and clinical development:
+Added: ● OTX-TKI, an axitinib intravitreal implant being developed for the treatment of wet age-related macular degeneration, or wet AMD, diabetic retinopathy and other retinal diseases;
+Added: ● OTX-TIC, a travoprost intracameral implant being developed for the reduction of intraocular pressure, or IOP, in patients with primary open-angle glaucoma or ocular hypertension;
+Added: ● OTX-DED, a dexamethasone intracanalicular insert being developed for the short-term treatment of the signs and symptoms of dry eye disease;
+Added: ● OTX-CSI, a cyclosporine intracanalicular insert being developed for the chronic treatment of dry eye disease;
+Added: ● A complement inhibitor program in preclinical development for the treatment of dry age-related macular degeneration, or dry AMD;
+Added: ● A gene delivery program in preclinical development using our hydrogel technology to control the release of vectors such as adeno-associated virus , or AAV, to ocular tissues for the treatment of inherited and acquired ocular diseases, including dry or wet AMD.
+Added: We currently focus on some of the largest markets in ophthalmology.
+Added: According to the Market Scope 2022-2023 reports, our product candidates seek to address select indications within segments of ophthalmology that, in the aggregate, account for approximately $25 billion in global annual sales.
+Added: The following table summarizes the status of DEXTENZA, our primary marketed product, and our key product candidates and development programs.
+Added: We hold worldwide exclusive commercial rights to the core technology underlying all of our product candidates in development and have not granted commercial rights to any marketing
+Added: partners other than 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 .
+Added: PIPELINE AT A GLANCE
+Added: Our mission is to build an ophthalmology-focused biopharmaceutical company that capitalizes on the gaps that we believe increasingly exist in the ophthalmology sector between single product companies and large, multi-product pharmaceutical companies.
+Added: Our strategy is to continue to build upon our experience in commercializing ophthalmology products that can be administered primarily in the surgical and/or office settings and to continue to develop a clinical pipeline of innovative ophthalmology products that address large areas of unmet need.
The key tactics of our strategy are:
−Removed: ● Expand commercialization of DEXTENZA for the treatment of ocular inflammation and pain following ophthalmic surgery and ocular itching associated with allergic conjunctivitis.
−Removed: We are reorganizing our established commercial sales effort into two business units in the United States:
−Removed: the surgical business unit, which will focus primarily on ambulatory surgery centers, or ASCs, that generate the largest volume of cataract surgeries, for the treatment of ocular inflammation and pain;
−Removed: and the office business unit, which will focus on the offices of ophthalmologists and optometrists and the promotion of DEXTENZA for both the treatment of inflammation and pain and ocular itching associated with allergic conjunctivitis.
−Removed: We expect to grow our salesforce in both the surgical and office settings not only to increase the active number of accounts but to also penetrate each of those account types more deeply.
+Added: ● Grow DEXTENZA revenues primarily through sales for the treatment of ocular inflammation and pain following ophthalmic surgery.
● Advance our clinical development programs.
−Removed: We have deep experience in developing innovative ophthalmology products from discovery through regulatory approval while minimizing the development risks often associated with new chemical entities.
−Removed: Our current development pipeline includes:
−Removed: We are conducting an Australian based Phase 1 clinical trial and a U.S.-based Phase 1 clinical trial to treat wet AMD by addressing the limitations of durability associated with the existing standard of care.
−Removed: If we obtain favorable results, we intend to advance the program into a Phase 2 clinical trial in the United States.
−Removed: We have initiated a U.S.-based Phase 2 clinical trial for the treatment of open-angle glaucoma or ocular hypertension.
−Removed: If we obtain favorable data from this clinical trial, we intend to advance the program into a Phase 3 clinical trial.
−Removed: We have completed a Phase 2 clinical trial for the treatment of chronic dry eye disease.
−Removed: We continue to evaluate the data from this trial including, among other things, retention rates of the OTX-CSI inserts, or how long the inserts were observed to remain in the canaliculus, as well as the duration of the vehicle hydrogel inserts.
−Removed: We have completed a Phase 2 clinical trial for the treatment of the short-term signs and symptoms of dry eye disease.
−Removed: We continue to evaluate the data from this trial including, among other things, the duration of the vehicle hydrogel inserts.
−Removed: ● Leverage our commercial infrastructure with additional ophthalmology products for both the surgical and office settings.
−Removed: We have an active business development effort to identify and assess opportunities to partner, in-license or potentially acquire ophthalmology products that we believe could complement our existing product offerings.
+Added: be prepared to initiate a pivotal clinical trial as early as the third quarter of 2023, subject to ongoing discussions with the FDA and obtaining the necessary financing to fund the trial, which could be provided through a strategic alliance.
+Added: o Diabetic Retinopathy:
+Added: be positioned to initiate a pivotal clinical trial as early as the first quarter of 2024 subject to favorable interim results from our ongoing Phase 1 clinical trial, discussions with the FDA and obtaining the necessary financing to fund the trial.
+Added: continue to enroll our U.S.-based Phase 2 clinical trial for the treatment of open-angle glaucoma or ocular hypertension and plan to provide topline data from the trial in the fourth quarter of 2023.
+Added: ● Dry Eye Disease – OTX-DED and OTX-CSI:
+Added: initiate a small trial of OTX-DED in the first half of 2023 to identify a proper placebo control for any future trials of these product candidates.
+Added: ● Leverage our commercial infrastructure for additional ophthalmology products for both the surgical and office settings.
● Continue to develop experience and expertise with buy-and-bill products.
−Removed: Key to our success is the ability to effectively commercialize buy and bill products in both the surgical and office settings.
−Removed: We intend to continue to develop expertise in the selling and reimbursement of these types of products.
−Removed: Buy and bill refers to the process by which an ASC, hospital outpatient department, or HOPD, or physician’s office acquires medication that the provider then administers in its respective site of care.
−Removed: The “buy” part refers to the provider being responsible for ordering and purchasing the drug.
−Removed: The “bill” part refers to the provider directly billing third-party payors for reimbursement, typically Medicare or commercial payors.
−Removed: ● Apply our local programmed-release hydrogel-based technology to create additional proprietary solutions for ophthalmic diseases and conditions.
−Removed: 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.
−Removed: From time to time, we are also in discussions with other ophthalmic companies
−Removed: 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: DEXTENZA and all of our product candidates are designed to be medical-benefit “buy-and-bill” products with associated procedure codes.
+Added: Products with these characteristics are designed to be attractive not only to physicians, optometrists and patients but also to the sites of care that participate in utilization.
+Added: ● Apply our local programmed-release hydrogel-based formulation technology to create additional proprietary solutions for additional ophthalmic diseases and conditions.
● Address rest-of-world commercial opportunities through licensing and collaboration agreements.
−Removed: Similar to the collaboration that we have established with AffaMed, we will continue to consider arrangements with other companies to address market opportunities outside of the United States.
−Removed: Eye disease can be caused by many factors and can affect both the front and back of the eye.
−Removed: 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.
−Removed: The tissue surrounding the eye also serves important functions.
−Removed: There is a natural opening, called a punctum, located in the inner portion of each upper and lower eyelid near the nose.
−Removed: The puncta open into nasolacrimal ducts, which collect and drain tears.
−Removed: The conjunctiva is the membrane covering the inside of the eyelids and the white part of the eye, known as the sclera.
−Removed: It helps to protect the eye from microbes and to lubricate the eye.
−Removed: 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.
−Removed: The back of the eye contains the retina, which is the light sensing layer of tissue;
−Removed: the vitreous humor, which is a transparent gel that fills the vitreous chamber between the lens and the retina;
−Removed: and the optic nerve, which transmits visual information from the retina to the brain.
−Removed: Intravitreal injections or oral pills have typically been used to deliver medications to the back of the eye.
−Removed: Cross Section of Eye
−Removed: Tear Drainage System
−Removed: We currently focus on some of the largest markets in ophthalmology.
−Removed: According to the Market Scope 2021 reports, our product candidates seek to address select indications within segments of ophthalmology that, in the aggregate, account for more than $20 billion in global annual sales.
−Removed: Retinal Diseases
−Removed: One of the principal retinal diseases is wet AMD, a serious disease of the central portion of the retina, known as the macula, an oval-shaped pigmented area 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 is treatment with drugs that target VEGF, one of several proteins involved in neovascularization.
−Removed: Wet AMD is the most common cause of visual impairment among elderly patients in developed countries.
−Removed: According to the Market Scope 2021 Retinal Pharmaceuticals Market Report, there are approximately 8.8 million people in the United States who suffer from vision-threatening retinal diseases.
−Removed: This population is expected to grow at a 2.2% compound annual growth rate through 2026.
−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.
−Removed: The global market for retinal disease was approximately $14.1 billion in 2021 and is estimated to grow at approximately 6% per year through 2026 according to Market Scope.
−Removed: market accounted for just over 50% of the global market or $7.6 billion in 2021.
−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: Eylea, marketed in the United States by Regeneron;
−Removed: Lucentis, marketed in the United States by Genentech;
−Removed: and bevacizumab, an anti-VEGF therapy approved for the treatment of certain cancers, used off-label in ophthalmology.
−Removed: 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.
−Removed: According to the World Health Organization, glaucoma is the second leading cause of blindness in the world.
−Removed: Ocular hypertension is characterized by elevated levels of IOP without any optic nerve damage.
−Removed: Patients with ocular hypertension are at high risk of developing glaucoma.
−Removed: According to Market Scope, it is estimated that there were 111.1 million people globally in 2021 with primary open-angle glaucoma or ocular hypertension.
−Removed: In the United States, it is estimated there were 4.3 million and 3.5 million who had primary open-angle glaucoma or ocular hypertension, respectively.
−Removed: Both groups are estimated to grow by 2.3% annually through 2026.
−Removed: The primary goal of glaucoma treatment is to slow the progression of this chronic disease by reducing IOP, 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.
−Removed: In a healthy eye, fluid is continuously produced and drained to maintain pressure equilibrium and provide nutrients to the ocular tissue.
−Removed: Excess fluid production or insufficient drainage of fluid in the front of the eye or a combination of these problems causes increased IOP.
−Removed: The increased IOP associated with uncontrolled glaucoma results in degeneration of the optic nerve in the back of the eye and loss of peripheral vision.
−Removed: Once glaucoma develops, it is a chronic condition that requires life-long treatment.
−Removed: Prostaglandins are the most commonly used class of medications to treat patients with glaucoma and are administered via daily eye drops as the current standard of care.
−Removed: 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, or PGA, formulated with our programmed release hydrogel to lower IOP for several months with a single insert.
−Removed: The global market for glaucoma was estimated by Market Scope at $4.8 billion in 2021 with the U.S.
−Removed: market representing $1.9 billion.
−Removed: The global market is estimated to grow at 6.6% annually to approximately $6.6 billion in 2026 while the U.S.
−Removed: market is expected to grow 7.1% annually to approximately $2.7 billion in 2026.
−Removed: The market for drugs administered by eye drops for the treatment of glaucoma consists of both branded and generic products.
−Removed: Branded products have maintained premium pricing and significant market share.
−Removed: These products include Lumigan ® (bimatoprost) marketed by Allergan, Travatan Z (travoprost) marketed by Novartis and Tapros marketed by Santen.
−Removed: The relevant patents covering travoprost expired in December 2014.
−Removed: Commonly used generic drugs include latanoprost and timolol.
−Removed: Ocular Surface Diseases
−Removed: Dry Eye Disease
−Removed: 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.
−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: There are approximately 17.6 million patients diagnosed with dry eye disease in the United States, according to the Market Scope 2021 Dry Eye Products Market Report.
−Removed: Approximately 9.1 million of those patients are diagnosed with moderate to severe dry eye while the remaining 8.5 million patients are diagnosed with mild dry eye disease.
−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 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 consists of Restasis, for increasing tear production, marketed by Allergan;
−Removed: Cequa™ 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: 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, patients have reported significant issues with stinging and burning when using several of the current treatments.
−Removed: The global market for dry ocular surface disease, which we refer to as dry eye disease, was estimated by Market Scope at $5.9 billion in 2021 with the U.S.
−Removed: market representing $2.2 billion.
−Removed: Within the prescription category, Restasis ® recorded sales in 2021 of approximately $1.2 billion in the United States while Xiidra ® recorded estimated sales of $0.3 billion in the United States.
−Removed: With the approval by the FDA of Viatris’ generic to Allergan’s Restasis, 2022 Restasis revenues are anticipated to be lower.
−Removed: Allergic Conjunctivitis
−Removed: 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.
−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: 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.
−Removed: According to IMS Health data, approximately 4.9 million anti-allergy eye drop prescriptions were filled in the United States in 2021, resulting in sales of approximately $270.6 million.
−Removed: The market to treat allergic conjunctivitis consists of antihistamines, mast-cell stabilizers and steroid eye drops and 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: 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 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 4.5 million ocular surgeries were performed in the United States in 2021, of which approximately 4.4 million are estimated to have been cataract surgeries.
−Removed: In 2022, Market Scope estimates 5.1 million cataract surgeries are to be performed.
−Removed: We currently focus our sales efforts for DEXTENZA for the treatment of inflammation and pain on patients covered by Medicare Part B which accounts for roughly 50% of all cataract surgeries or approximately 2 million surgeries annually.
−Removed: At the current wholesale acquisition price of $555 per insert, we estimate that there is a near-term addressable market of approximately $1 billion per year in the surgical space.
−Removed: According to IMS Health data, approximately 19.8 million prescriptions were filled in the United States in 2021 for anti-inflammatory drugs administered by prescription eye drops for ocular diseases and conditions, resulting in sales of approximately $4.9 billion.
−Removed: These prescriptions consisted of approximately 8.4 million prescriptions and $662.4 million in sales for single-agent corticosteroids, 3.2 million prescriptions and $312.6 million in sales for NSAIDs, 4.4 million prescriptions and $358.6 million in sales for corticosteroid and antibiotic combination products and approximately 4.0 million prescriptions and $3.5 billion in sales for dry eye disease products.
−Removed: The Use of Eye Drops and its Limitations
+Added: Limitations of Current Drug Delivery in Ophthalmology
Eye drops are widely used to deliver medications directly to the ocular surface and to intraocular tissue in the front of the eye.
2 unchanged sentences
● Lack of patient compliance .
−Removed: Eye drops require frequent administration.
−Removed: For example, steroids for ophthalmic use require administration as frequently as four to six times daily and require tapered dosing over the course of the therapy.
−Removed: As a result, patient compliance with required dosing regimens frequently suffers.
−Removed: According to a published third-party study, more than 50% of glaucoma patients are not compliant with their prostaglandin therapy and do not refill prescriptions as required or do not follow the prescribed regimen within six months of initiating therapy.
+Added: Eye drops require frequent administration, and, as a result, patient compliance with required dosing regimens frequently suffers.
Poor patient compliance can lead to diminished efficacy and disease progression.
● Difficulty in administration .
−Removed: Eye drops are difficult to administer for many patients, in particularly the elderly, due to physical or mental conditions such as arthritis or dementia.
−Removed: Difficulty in self-administering eye drops may lead to bacterial contamination in the bottle resulting from incorrect usage, limited accuracy
−Removed: administering the drops directly into the eye and the potential washout of drops from the eye.
+Added: Eye drops are difficult to administer for many patients, particularly among the elderly, due to physical or mental conditions such as arthritis or dementia.
We believe that this also may play a large role in lack of patient compliance and resulting diminished efficacy of treatment.
12 unchanged sentences
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: Challenges of Back-of-the-Eye Injections
+Added: Back-of-the-Eye Injections
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.
1 unchanged sentence
Intravitreal injections are used to administer medications to treat a variety of chronic conditions;
−Removed: wet AMD, DME and RVO are among the most common conditions treated with intravitreal anti-VEGF drugs.
+Added: wet AMD, diabetic retinopathy, diabetic retinal edema, or DME, and retinal vein
+Added: occlusion, or RVO, are among the most common conditions treated with intravitreal anti-VEGF drugs.
Anti-VEGF drugs and steroids help to reduce fluid leakage associated with these disorders.
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: We refer to the number of injections a patient has over a given time period as the treatment burden of the particular treatment.
The actual injection at the time of administration is uncomfortable for patients and can be a deterrent in terms of compliance.
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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.
−Removed: 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: 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.
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.
The Ocular Therapeutix Approach
−Removed: Our Hydrogel Technology Platform
−Removed: 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 bioresorbable hydrogel technology is based on the use of a proprietary form of PEG.
+Added: Our Hydrogel-Based Formulation Technology
+Added: We apply our expertise with an established bioresorbable hydrogel-based formulation 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.
+Added: Our bioresorbable hydrogel-based formulation 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.
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Because the body has an abundance of water at a constant temperature and pH level, hydrolysis provides a predictable and reproducible degradation rate.
−Removed: Our technology enables us to make hydrogels that can bioresorb over days, weeks or several months.
−Removed: The figure below depicts the formation and bioresorption of the hydrogel for ReSure Sealant.
−Removed: Intracanalicular Inserts
−Removed: A punctum is a natural opening located in the inner portion of the eyelid near the nose.
−Removed: 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’ lacrimal glands.
−Removed: Tears produced in the lacrimal glands sweep across the eye surface and drain through the puncta to the nasal cavity.
−Removed: The section of the nasolacrimal duct immediately beyond the puncta is called the vertical canaliculus.
−Removed: Intracanalicular inserts that do not contain an active drug are commonly used for treatment of dry eye disease by physically blocking tear drainage.
−Removed: Because intracanalicular inserts stay in contact with the tear film, they are well suited for local programmed-release of drug to the eye.
−Removed: Intracanalicular insert shown positioned in the vertical canaliculus
−Removed: Our intracanalicular inserts utilize our proprietary hydrogel technology and are embedded with an active drug.
−Removed: Following insertion through the punctum, our inserts swell in tear fluid to fill the vertical canaliculus, which secures the
−Removed: inserts in place.
−Removed: We design our inserts to release drug in a programmed fashion, tailored to each disease state, back through the punctum to the surface of the eye.
−Removed: Over time the inserts liquefy and are cleared through the nasolacrimal duct.
−Removed: If necessary due to excessive tearing, discomfort or improper placement, a healthcare professional can remove an intracanalicular insert by a process of pushing the soft insert back through the punctum.
−Removed: Our inserts allow incorporation of a variety of drugs with a controllable range of delivery durations and delivery rates.
−Removed: For acute conditions, such as post-surgical ocular inflammation and pain and ocular itching associated with allergic conjunctivitis, we have designed our intracanalicular inserts to provide a local programmed-release of therapeutic levels of drug for the duration of treatment.
−Removed: For chronic diseases, such as glaucoma, we have designed our intracanalicular inserts for repeat administration with extended dosing periods.
−Removed: We are concentrating our initial development efforts on intracanalicular inserts incorporating active pharmaceutical ingredients that are approved by the FDA for the targeted indication and that satisfy other specific selection criteria that we have developed.
−Removed: We manufacture our intracanalicular inserts from dried PEG-based hydrogel formed into tiny rods that hold an active pharmaceutical ingredient in a preservative-free formulation.
−Removed: We embed the active pharmaceutical ingredient in the pre-hydrogel liquid formulation, which then solidifies to form a hydrogel containing the drug within.
−Removed: The relative size of one of our intracanalicular inserts is shown in the figure below.
−Removed: 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 canaliculus, to secure it in place.
−Removed: 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.
−Removed: 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.
−Removed: Because intracanalicular inserts stay in contact with the tear film, other companies have pursued the development of intracanalicular punctum plugs containing active drugs for local programmed release to the ocular surface.
−Removed: However, these earlier product designs had significant limitations with respect to drug capacity, drug release kinetics and patient comfort and used non-degradable punctum plugs with a clear silicone hard rubber shell containing only a core with active drug.
−Removed: These plugs typically extended outside of the punctal opening and secured themselves in place with an external cap.
−Removed: The external cap was in constant contact with the surface of the eye, which may cause irritation and discomfort in some cases.
−Removed: In addition, some prior designs resorted to plugging both the upper and lower puncta, which could cause excessive tearing and patient discomfort.
−Removed: These designs did not incorporate a visualization agent to allow the patient and physician to assess the presence of the plug.
−Removed: In contrast to these prior approaches, we have designed our intracanalicular inserts to:
−Removed: ● incorporate the active pharmaceutical ingredient throughout the insert rather than just in a core to allow for higher drug capacity and better control over drug release;
−Removed: ● be bioresorbable so that removal is not required for acute conditions and required infrequently for chronic conditions;
−Removed: ● be soft and to fit beneath the punctal opening for patient comfort;
−Removed: ● include a fluorescent label to allow the healthcare professional and patient to visualize and assess the presence of the insert.
−Removed: We select the active pharmaceutical ingredients for our local programmed-release drug delivery product candidates, including our intracanalicular inserts, based on criteria we have developed through our extensive experience with hydrogel insert systems.
+Added: Our technology enables us to make hydrogels that can bioresorb over days, weeks or months.
+Added: We select the active pharmaceutical ingredients for our local programmed-release drug delivery product candidates based on criteria we have developed through our extensive experience with hydrogel-based technologies.
We consider the following selection criteria:
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● expiration of relevant patent protection prior to or within our anticipated development timeline;
−Removed: ● high potency to minimize required drug load in the intracanalicular insert;
+Added: ● high potency to minimize required drug load in the intracanalicular insert, intracameral implant or intravitreal implant;
● availability from a qualified supplier;
● compatibility with our drug delivery system.
−Removed: 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:
+Added: We believe our current and future intracanalicular insert, intracameral implant and intravitreal implant products and 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 .
−Removed: Our inserts and implants are placed by a healthcare professional and are designed to provide local programmed-release of drug to the ocular surface.
+Added: Our inserts and implants are placed by a healthcare professional and are designed to provide local programmed-release of drug to the ocular surface, intracameral space or intravitreal space.
Because patients are not responsible for self-administration of the drug and the inserts and implants dissipate over time and do not require removal for acute conditions or frequent removal for chronic conditions, we believe our inserts and implants address the problem of patient compliance.
● Ease of administration .
−Removed: We have designed our inserts and implants to provide the entire course of medication with a single administration by a healthcare professional for acute conditions or for several months for chronic conditions.
−Removed: We believe this avoids the need for frequent administration and the potential complications that could result if doses are missed.
+Added: We have designed our inserts and implants to provide the entire course of medication with a single administration by a healthcare professional for acute conditions or for months for chronic conditions.
+Added: We believe this avoids the need for frequent administration, reducing the patient’s treatment burden and the likelihood of potential complications that could result if doses are missed.
● Local programmed-release of drug .
−Removed: 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.
+Added: 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, as well as current standard of care injections for the back of the eye.
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.
5 unchanged sentences
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.
+Added: Intracanalicular Inserts
+Added: Our intracanalicular inserts, including DEXTENZA, OTX-DED, and OTX-CSI, are designed to be inserted into the patient’s punctum by a healthcare professional and to release drug to the surface of the eye to address diseases including ocular inflammation and pain following ophthalmic surgery, ocular itching associated with allergic conjunctivitis, and dry eye disease.
+Added: Our intracanalicular inserts utilize our proprietary hydrogel-based formulation technology and are embedded with an active drug.
+Added: Following insertion through the punctum, our inserts swell in tear fluid to fill the vertical canaliculus, which secures the inserts in place.
+Added: Over time, the inserts liquefy and are cleared through the nasolacrimal duct.
+Added: If necessary due to excessive tearing, discomfort or improper placement, a healthcare professional can remove an intracanalicular insert by a process of pushing the soft insert back through the punctum.
Intracameral Implants
−Removed: We are engaged in the clinical development of our hydrogel administered via intracameral injection to address retinal diseases.
+Added: We are engaged in the clinical development of our hydrogel administered via intracameral injection to address glaucoma.
Intracameral implants refer to biodegradable or bioresorbable implants placed into the anterior chamber or front of the eye for the treatment of ocular conditions.
2 unchanged sentences
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.
−Removed: OTX-TIC implant
−Removed: Injection needle
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 intravitreal implant product candidates consist of a PEG-based hydrogel suspension, which contains embedded micronized particles of active drug.
−Removed: 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.
−Removed: Our initial intravitreal implant development efforts are focused on the use of our programmed-release hydrogel in combination with anti-angiogenic compounds or small molecule drugs, such as TKIs, for the treatment of retinal diseases, including wet AMD, RVO and DME.
−Removed: 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.
−Removed: 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.
−Removed: We believe TKIs are well suited for use with our platform given their 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 timeframes at therapeutic levels without causing local and systemic toxicity due to low drug solubility and notably short half-lives in solution.
−Removed: We believe our local drug delivery technology gives us potential advantages in this regard.
−Removed: 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 cleared from the eye through hydrolysis over time.
−Removed: We design our hydrogels to control the hydrogel biodegradation rate and, as a result, the timing of TKI and anti-VEGF compound release.
−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: Development Pipeline and Marketed Products
−Removed: The following table summarizes important information about our key product development programs and our marketed products, DEXTENZA and ReSure Sealant.
−Removed: We hold worldwide commercial rights to DEXTENZA, ReSure
−Removed: Sealant and each of our product candidates other than rights we have licensed to AffaMed for the development and commercialization of DEXTENZA and OTX-TIC in specified Asian markets .
−Removed: (Active Pharmaceutical
−Removed: Product / Program
−Removed: Early-Stage Clinical Product
−Removed: Intravitreal implant (Axitinib)
−Removed: Australian Phase 1 clinical trial ongoing.
−Removed: United States Phase 1 trial initiated in July 2021.
−Removed: Plan to initiate a Phase 2 clinical trial in the United States, pending the receipt and review of topline data from the Phase 1 clinical trial in the United States, which is expected in the second half of 2022.
−Removed: Open-angle glaucoma or ocular hypertension
−Removed: Intracameral implant (Travoprost)
−Removed: Phase 2 clinical trial in the United States initiated in Q4 2021;
−Removed: first patient dosed expected Q1 2022.
−Removed: Chronic treatment of dry eye disease
−Removed: Intracanalicular insert (Cyclosporine)
−Removed: Phase 2 topline data reported in October 2021;
−Removed: evaluating additional data to inform the future of this program.
−Removed: Short-term treatment of signs and symptoms of dry eye disease
−Removed: Intracanalicular insert (Dexamethasone)
−Removed: Phase 2 topline data reported in December 2021;
−Removed: evaluating additional data to inform the future of this program.
−Removed: Approved Product
−Removed: Post-surgical ocular inflammation and pain
−Removed: Intracanalicular insert (Dexamethasone)
−Removed: Product commercially launched in the United States in July 2019.
−Removed: Allergic conjunctivitis
−Removed: Intracanalicular insert (Dexamethasone)
−Removed: Product commercially launching in the United States in first quarter of 2022.
−Removed: ReSure Sealant
−Removed: Cataract incision closure
−Removed: Ocular sealant
−Removed: Product commercially launched in the United States in February 2014.
+Added: Our intravitreal implant product candidates, such as OTX-TKI, consist of a PEG-based hydrogel suspension, which contains embedded micronized particles of active drug.
+Added: We design the intravitreal implant to be injected and retained in the vitreous humor to provide local programmed-release intravitreal delivery of anti-VEGF compounds.
+Added: Clinical Portfolio
+Added: Retinal Diseases
+Added: Age-related macular degeneration, or AMD, and diabetic retinopathy are the most common retinal diseases, affecting approximately 207.6 million and 141.2 million, respectively, worldwide, according to the Market Scope 2022 Retinal Pharmaceuticals Report.
+Added: In the United States, Market Scope estimates that there are approximately 17.9 million suffering from some form of AMD.
+Added: Wet Aged-Related Macular Degeneration (Wet AMD)
+Added: Wet AMD is a serious disease of the central portion of the retina, known as the macula, an oval-shaped pigmented area 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 most common cause of visual impairment among elderly patients in developed countries.
+Added: According to the Market Scope 2022 Retinal Pharmaceuticals Market Report, there are approximately 1.6 million people in the United States who suffer from wet AMD.
+Added: This population is expected to grow at a 3.0% compound annual growth rate through 2027.
+Added: Diabetic Retinopathy (DR)
+Added: DR is a progressive condition in which chronically elevated levels of blood glucose and depleted levels of oxygen damage the tiny blood vessels in the retina.
+Added: DR is among the most common microvascular complications of diabetes, making diabetes the leading cause of new cases of blindness in adults.
+Added: DR can take time to develop.
+Added: Nonproliferative DR, sometimes called background retinopathy, is usually mild and may go unnoticed.
+Added: Proliferative DR is the most serious stage of the disease and develops when areas of the retina are starved for nourishment and oxygen, triggering the proliferation of new blood vessels via secretions of vascular endothelial growth factor (VEGF).
+Added: The current standard of care for DR at the nonproliferative stage is watchful waiting, with the use of anti-VEGFs when the disease has progressed to the proliferative stage.
+Added: It is estimated that there were 8.4 million cases of DR in the United States in 2022 according to Market Scope, of which 3.3 million cases were moderate to severe non-proliferative DR, growing at an approximately 2% compound annual growth rate through 2027.
+Added: Overall, there are an estimated 141.2 million cases of DR globally, growing at a compound annual growth rate of 3%.
+Added: The global market for retinal disease inclusive of wet AMD and DR was approximately $15.9 billion in 2022 and is estimated to grow at approximately 6% per year through 2027 according to Market Scope.
+Added: market accounted for just over 50% of the global market or $8.5 billion in 2022 and is expected to grow at approximately 7% through 2027.
+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 bevacizumab, an anti-VEGF therapy approved for the treatment of certain cancers, used off-label in ophthalmology.
+Added: A new anti-VEGF, Vabysmo, launched by Genentech in 2022, has penetrated the market rapidly and is expected to gain significant market share in the future.
Retinal Disease Programs
OTX-TKI (axitinib intravitreal implant)
−Removed: 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.
−Removed: Our 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.
−Removed: In addition, our preclinical studies demonstrated a sustained pharmacodynamic effect in vivo of over six months with a small molecule TKI.
+Added: Our product candidate OTX-TKI is a preformed, bioresorbable hydrogel fiber implant incorporating axitinib, a small molecule TKI with anti-angiogenic properties delivered by intravitreal injection and designed for a duration of six months or longer.
+Added: We are conducting a Phase 1 clinical trial in Australia and a Phase 1 clinical trial in the United States to evaluate OTX-TKI for the treatment of wet AMD.
+Added: Our initial implants have delivered anti-VEGF compounds in vitro over a targeted nine to twelve month period, which we believe could make it possible to reduce patients’ treatment burden by reducing the frequency of the current monthly or bi-monthly intravitreal injection regimen for wet AMD.
+Added: We are also conducting a Phase 1 clinical trial in the United States to evaluate OTX-TKI for the treatment of DR.
We believe axitinib is well suited for use with our platform given its high potency, multi-target capability, and compatibility with a hydrogel vehicle.
1 unchanged sentence
We believe our local programmed-release drug delivery technology gives us potential advantages in this regard.
−Removed: In Vitro and preclinical results
−Removed: We have conducted in vivo pharmacokinetic and pharmacodynamic studies with hydrogels loaded with axitinib injected intravitreally.
−Removed: Pharmacokinetic data showed retinal tissue drug concentrations in excess of 3,000 times the published concentration needed to inhibit VEGF after six months and pharmacodynamic results show sustained efficacy for six months.
−Removed: Preclinical studies to date have demonstrated suppression of vascular leakage and favorable pharmacokinetics in the relevant ocular tissues.
−Removed: Phase 1 clinical development (Australia)
+Added: We have conducted two Phase 1 trials of OTX-TKI for the treatment of wet AMD, with different formulations of axitinib.
+Added: We currently intend to move forward into pivotal trials with our single 600 µg axitinib implant formulation of OTX-TKI for both the treatment of wet AMD and the treatment of diabetic retinopathy.
+Added: As we have previously disclosed, we are also developing a second formulation of OTX-TKI that could be used in future trials of retinal indications.
+Added: Currently, we do not believe any additional development work is required to advance to pivotal trials in either wet AMD or diabetic retinopathy.
+Added: Wet Age-Related Macular Degeneration (wet AMD)
+Added: Phase 1 Clinical Trial (Australia)
We are conducting an open-label, multi-center, proof-of-concept, dose-escalation Phase 1 clinical trial of OTX-TKI for the treatment of patients with wet AMD caused by excessive blood vessel growth in the back of the eye due to VEGF.
This Phase 1 clinical trial is designed to evaluate the safety, durability and tolerability of OTX-TKI.
−Removed: OTX-TKI is a preformed, 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.
The Phase 1 clinical trial was submitted to the Therapeutic Goods Administration, Australia’s regulatory authority for therapeutic goods, in July 2018 and is being conducted at multiple sites in Australia.
−Removed: In the Phase 1 clinical trial of OTX-TKI, we are evaluating biological activity by measuring central subfield thickness, or CSFT, using spectral domain optical coherence tomography, or OCT, and following visual acuity over time as measured by BCVA, or Best Corrected Visual Acuity.
−Removed: We have fully enrolled three cohorts to date:
+Added: Our Phase 1 clinical trial of OTX-TKI in Australia is comprised of four cohorts consisting of subjects with pre-existing intraretinal and/or subretinal fluid:
a lower dose cohort of 200 µg with six subjects;
a higher dose cohort of 400 µg with seven subjects;
−Removed: and a third cohort with two parallel arms, one arm of six subjects receiving a concomitant anti-VEGF injection with 400 µg of OTX-TKI and the other arm of six subjects receiving a 600 µg of OTX-TKI with no anti-VEGF injection.
−Removed: We are actively enrolling a fourth cohort with two parallel arms, one arm of six subjects receiving a 600 µg single implant of OTX-TKI and the other arm of six subjects receiving a 600 µg single implant of OTX-TKI with anti-VEGF injection.
+Added: a third cohort with two parallel arms, one arm of six subjects receiving a concomitant anti-VEGF injection with 400 µg of OTX-TKI and the other arm of six subjects receiving a 600 µg of OTX-TKI with no anti-VEGF injection;
+Added: and a fourth cohort with two parallel arms, one arm of six subjects receiving a 600 µg single implant of OTX-TKI and the other arm of six subjects receiving a 600 µg single implant of OTX-TKI with anti-VEGF injection.
+Added: In this trial, we are evaluating whether OTX-TKI can reduce existing fluid levels.
+Added: This trial’s enrollment is complete.
+Added: We plan to continue to follow subjects at least until their respective seventeen-month anniversaries of initial dosing, in accordance with the clinical trial protocol.
+Added: In the Phase 1 clinical trial of OTX-TKI, we are evaluating biological activity by measuring central subfield thickness, or CSFT, using spectral domain optical coherence tomography, or OCT, and following visual acuity over time as measured by Best Corrected Visual Acuity, or BCVA.
In February 2022, interim data as of January 11, 2022 from this Phase 1 clinical trial of OTX-TKI was presented at the Angiogenesis, Exudation and Degeneration Virtual Symposium.
−Removed: We believe that this data showed a preliminary signal of biological activity for OTX-TKI 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.
−Removed: Some subjects have shown a decrease in intraretinal or subretinal fluid by two months in cohorts 2 (400 µg) and 3a (600 µg).
+Added: In subjects with subretinal and/or intraretinal fluid
+Added: due to wet AMD, OTX-TKI was observed to be generally well tolerated.
+Added: No ocular serious adverse events were reported in treatment naïve or previously treated wet AMD subjects.
+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, 2, 3a and 3b.
+Added: This assessment indicated that there was no measurable systemic exposure to axitinib.
+Added: This interim data also showed a preliminary signal of biological activity as observed by a clinically meaningful decrease in intraretinal and/or subretinal fluid as measured by high resolution OCT that provides cross-sectional images of the anatomical structure of the retina.
+Added: Some subjects showed a decrease in intraretinal or subretinal fluid by two months in cohorts 2 (400 µg) and 3a (600 µg).
In cohort 3b (400 µg dose plus anti-VEGF induction injection of aflibercept), two subjects showed a decrease in intraretinal or subretinal fluid as early as a week after treatment.
−Removed: Extended duration of activity was observed over 60% of subjects across all cohorts over 80% of subjects in cohort 3a (600 µg) with a duration of activity of six months or longer.
+Added: We observed extended duration of activity of six months or more for over 60% of subjects across all cohorts and for over 80% of subjects in cohort 3a, in which we administered a 600 μg dose.
In addition, the OTX-TKI implants in cohort 1 (single implant) were observed to have biodegraded in all subjects within nine to 10.5 months of injection.
It has also been observed in the trial that the implants were able to be adequately monitored and that there was limited to no movement of the implant in the anterior segment of the eye.
−Removed: In the trial, OTX-TKI has been observed to have a favorable safety profile and be generally well-tolerated to date.
−Removed: There have been no ocular serious adverse events in treatment naïve and previously treated wet AMD subjects.
−Removed: 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, 2, 3a and 3b.
−Removed: This assessment indicates that there is no measurable systemic exposure to axitinib.
Phase 1 Clinical Trial (United States)
−Removed: In July 2021, we announced that we had dosed the first patient in a prospective, multi-center, randomized, controlled Phase 1 clinical trial in the United States under an exploratory investigational new drug, or eIND, application to evaluate a single implant 600 µg dose of OTX-TKI with an anti-VEGF injection in comparison with a 2 mg dose of
−Removed: The trial consists of approximately 20 subjects previously treated with standard of care anti-VEGF therapy in two arms:
−Removed: a fifteen-subject arm that will receive OTX-TKI in combination with an anti-VEGF injection and a five-subject arm that will receive aflibercept at eight week intervals.
+Added: In July 2021, we announced that we had dosed the first patient in a prospective, multi-center, randomized, controlled Phase 1 clinical trial in the United States under an exploratory investigational new drug, or eIND, application to evaluate a single implant 600 µg dose of OTX-TKI with an anti-VEGF injection in comparison with a 2 mg dose of aflibercept.
+Added: The population we are studying in this U.S.-based clinical trial is different than the population we are studying in our ongoing Phase 1 clinical trial of OTX-TKI in Australia.
+Added: In this trial, we are evaluating how long we are able to maintain subjects who have been previously treated with anti-VEGF therapy without the need for retreatment.
+Added: The trial enrolled a total of 21 subjects at six clinical sites, comprising two arms consisting of subjects previously treated with, and responsive to, standard of care anti-VEGF therapy:
+Added: a 16-subject arm receiving OTX-TKI in combination with a single anti-VEGF injection at month one and a five-subject arm receiving on-label aflibercept at eight-week intervals.
The trial is designed to assess the safety, durability and tolerability of OTX-TKI as well as to assess preliminary biological activity in subjects by measuring anatomical and functional changes.
−Removed: At a pre-investigational new drug, or pre-IND, application meeting in April 2021, we discussed with the FDA the possibility of transitioning from an eIND application to a traditional investigational new drug application.
−Removed: The population being studied in this U.S.-based clinical trial is different than the population being studied in our ongoing Phase 1 clinical trial of OTX-TKI in Australia.
−Removed: In this trial, we are including only subjects who have been previously treated with anti-VEGF therapy and evaluating how long we are able to maintain subjects without the need for retreatment.
−Removed: In the Australian trial, we studied subjects who had pre-existing intraretinal and/or subretinal fluid and evaluated whether a TKI could reduce existing fluid levels.
−Removed: The U.S.-based Phase 1 clinical trial is fully enrolled and we expect interim, six-month data in the second half of 2022.
+Added: This trial was fully enrolled as of February 2022.
+Added: In February 2023, we announced interim 10-month data from the ongoing Phase 1 clinical trial of OTX-TKI in the United States at the Angiogenesis, Exudation, and Degeneration 2023 Annual Meeting.
+Added: As of the December 12, 2022 cut-off date, the interim data showed that the single 600 µg OTX-TKI implant was generally well tolerated with no drug-related ocular or systemic serious adverse events, or SAEs, observed through 10 months.
+Added: One SAE of endophthalmitis was observed in the OTX-TKI arm which occurred following the aflibercept injection required by the clinical trial protocol at month one and was assessed by the investigator as related to the injection procedure.
+Added: There were no instances of elevated IOP, retinal detachment, retinal vasculitis, or implant migration into the anterior chamber observed in the OTX-TKI arm, and no subjects had dropped out of either arm as of the data cutoff.
+Added: The interim results showed subjects treated with a single OTX-TKI implant demonstrated stable and sustained BCVA (mean change from baseline of -0.3 letters) and CSFT (mean change from baseline of -1.3 µm) in the OTX-TKI arm at 10 months, which was comparable with the aflibercept arm (mean change from BCVA baseline of -0.8 letters;
+Added: mean change from CSFT baseline of -4.5 µm).
+Added: Up to Month 10, 73% of subjects remained rescue-free.
+Added: Overall, a 92% reduction in treatment burden (average percent decrease in injections over the period compared to a standard monthly injection regimen) was observed in OTX-TKI treated subjects for up to 10 months.
+Added: Four subjects were rescued in the OTX-TKI arm up to Month 10.
+Added: One subject, the subject who experienced endophthalmitis, was rescued twice.
+Added: None of these rescues met the preestablished rescue criteria set forth in the clinical trial protocol and were instead initiated at investigator discretion.
+Added: One additional subject, who met the established rescue criteria at such subject’s Month 10 visit, was rescued at the end of Month 10.
+Added: There was one subject randomized to the OTX-TKI arm who was inadvertently given aflibercept instead of sham injections at the subject’s month three and month five visits.
+Added: Since this subject was not treated according to protocol, the subject was excluded from the analysis of biological activity, which comprised 15 out of the 16 subjects in the OTX-TKI
+Added: arm and all five subjects in the aflibercept arm, but the subject was included in the safety analysis which comprised all 16 subjects in the OTX-TKI arm and all five subjects in the aflibercept arm.
+Added: Per protocol, we will continue to follow subjects in the Phase 1 trial at least until their respective one-year anniversaries of initial dosing.
Regulatory Pathway
−Removed: We expect to receive topline data from the Phase 1 clinical trial in the United States in the second half of 2022.
−Removed: If we receive positive data, 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.
−Removed: If our development efforts are successful, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
+Added: We are in active discussions with the FDA regarding the regulatory pathway for OTX-TKI for the treatment of wet AMD and potential future clinical trial requirements.
+Added: Subject to those discussions and obtaining the necessary financing, which could be provided through a strategic alliance, we aim to be prepared to initiate a pivotal clinical trial for the treatment of wet AMD in the third quarter of 2023.
+Added: If we were to obtain favorable results from two pivotal clinical trials, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
See “—Government Regulation—Section 505(b)(2) NDAs” for additional information.
+Added: Diabetic Retinopathy (DR)
+Added: Phase 1 Clinical Trial
+Added: Given our belief in the potential applicability of OTX-TKI to other retinal diseases, we initiated a Phase 1 U.S.-based clinical trial to evaluate OTX-TKI for the treatment of DR in the fourth quarter of 2022 and dosed our first patient in February 2023.
+Added: We are conducting the Phase 1 clinical trial initially under an eIND.
+Added: The trial is designed to include approximately 21 subjects with diabetic retinopathy secondary to type 1 or type 2 diabetes who had not had an anti-VEGF injection in the prior 12 months or DME in the prior six months, randomized 2:1 to either a single 600 µg implant of OTX-TKI or sham control across approximately 10 sites.
+Added: We anticipate disclosing topline results as early as the fourth quarter of 2023.
+Added: Regulatory Pathway
+Added: We are in active discussions with the FDA regarding the clinical development of OTX-TKI.
+Added: Assuming positive topline data results from the Phase 1 clinical trial, the finalization of the design of our clinical development program reflecting of our ongoing discussions with the FDA, and additional financing to fund the trials, we believe we could be in a position to initiate our first pivotal trial of OTX-TKI for the treatment of DR as early as the first quarter of 2024 and a second pivotal trial shortly thereafter.
+Added: If we were to obtain favorable results from these two pivotal clinical trials, 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: 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.
+Added: According to the World Health Organization, glaucoma is the second leading cause of blindness in the world.
+Added: Ocular hypertension is characterized by elevated levels of IOP without any optic nerve damage.
+Added: Patients with ocular hypertension are at high risk of developing glaucoma.
+Added: In a healthy eye, fluid is continuously produced and drained to maintain pressure equilibrium and provide nutrients to the ocular tissue.
+Added: Excess fluid production or insufficient drainage of fluid in the front of the eye or a combination of these problems causes increased IOP.
+Added: The increased IOP associated with uncontrolled glaucoma results in degeneration of the optic nerve in the back of the eye and loss of peripheral vision.
+Added: Once glaucoma develops, it is a chronic condition that requires life-long treatment.
+Added: According to Market Scope, it is estimated that there were 172.0 million people globally in 2023 with primary open-angle glaucoma or ocular hypertension.
+Added: In the United States, it is estimated there are 6.8 million and 3.7 million who had primary open-angle glaucoma or ocular hypertension, respectively.
+Added: Both groups are estimated to grow by 1.3% and 2.4% annually through 2026, respectively.
+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
+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.
+Added: Prostaglandins are the most commonly used class of medications to treat patients with glaucoma and are administered via daily eye drops as the current standard of care.
+Added: The ability of patients to use and place daily eye drops is challenging.
+Added: The product candidates 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 $4.3 billion in 2023 with the U.S.
+Added: market representing $1.6 billion.
+Added: The global market is estimated to grow at 5.1% annually to approximately $5.5 billion in 2028 while the U.S.
+Added: market is expected to grow 3.5% annually to approximately $1.9 billion in 2026.
+Added: The market for drugs administered by eye drops for the treatment of glaucoma consists of both branded and generic products.
+Added: Branded products have maintained premium pricing and significant market share.
+Added: These products include Lumigan (bimatoprost) marketed by Allergan, Travatan Z (travoprost) marketed by Novartis and Tapros marketed by Santen.
+Added: Commonly used generic drugs include latanoprost and timolol.
Glaucoma Program
OTX-TIC (travoprost intracameral implant)
−Removed: 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.
−Removed: 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 over four to six months with a single treatment.
−Removed: In Vitro and Preclinical results
−Removed: Preclinical studies to date have demonstrated clinically meaningful IOP lowering and good pharmacokinetics in the aqueous humor.
+Added: Our product candidate OTX-TIC is a bioresorbable hydrogel implant incorporating travoprost, an FDA-approved prostaglandin analog designed to lower elevated IOP, 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 with a single treatment.
Phase 1 clinical development
−Removed: We filed an IND for OTX-TIC in February 2018 and have completed 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 subjects with moderate to severe glaucoma or ocular hypertension.
−Removed: The clinical trial was designed to evaluate the safety, biological activity, durability and tolerability of OTX-TIC in subjects with controlled open-angle glaucoma or ocular hypertension.
+Added: We submitted an IND for OTX-TIC in February 2018 and have completed 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 subjects 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 in subjects with controlled open-angle glaucoma or ocular hypertension.
The clinical trial consisted of four patient cohorts:
5 unchanged sentences
as early as two days following injection.
−Removed: We believe these results are comparable to the decrease in
−Removed: IOP seen with topical travoprost, the current standard of care.
+Added: We believe these results were comparable to the decrease in IOP achieved with topical travoprost administered via daily eye drops, the current standard of care.
IOP lowering effects lasted more than six months in subjects in cohorts 1 and 2 and three to six months in subjects in cohorts 3 and 4.
5 unchanged sentences
Phase 2 Clinical Trial
−Removed: In November 2021, we filed an IND amendment for a randomized, double-masked, active-controlled Phase 2 clinical trial in which we plan to enroll approximately 105 subjects at 15-20 sites between three arms of approximately 35 subjects each to evaluate two formulations of OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension in subjects compared to DURYSTA.
−Removed: We initiated the Phase 2 clinical trial in the fourth quarter of 2021 and expect to dose the first subject in the first quarter of 2022.
−Removed: One arm 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 a second arm 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: We are conducting a U.S.-based Phase 2 prospective, multi-center, randomized, controlled clinical trial evaluating the safety, tolerability and efficacy of OTX-TIC for the treatment of patients with primary open-angle glaucoma or ocular hypertension.
+Added: The Phase 2 clinical trial was designed to include approximately 105 subjects at 15 to 20 sites
+Added: between three arms of approximately 35 subjects each to evaluate two formulations of OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension in subjects compared to DURYSTA.
The non-study eye of each subject will receive a topical prostaglandin daily.
−Removed: The goals of the study will be to assess safety, tolerability and efficacy.
−Removed: Efficacy will be measured by diurnal IOP mean change from baseline (8 a.m., 10 a.m.
+Added: The primary efficacy endpoint is measured by diurnal IOP mean change from baseline (8 a.m., 10 a.m.
and 4 p.m.) at two, six and 12 weeks.
The active comparator control arm will receive one injection of DURYSTA in one eye and a topical prostaglandin daily in the non-study eye.
+Added: We initiated the Phase 2 clinical trial in the fourth quarter of 2021 and dosed the first subject in the first quarter of 2022.
+Added: One arm in the Phase 2 clinical trial is receiving the same formulation used in cohort 2 of the Phase 1 clinical trial, containing a 26 µg dose of drug and utilizing a standard implant.
+Added: The second arm was receiving 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: Due to elevations in IOP observed approximately 12 weeks after enrollment in six subjects in the OTX-TIC 5 µg arm of the trial, we terminated enrollment in the 5 µg arm of the trial in the fourth quarter of 2022 and are continuing forward with the OTX-TIC 26 µg and DURYSTA arms of the trial.
+Added: We expect that the Phase 2 clinical trial will consist of approximately 86 patients:
+Added: approximately 35 patients in the OTX-TIC 26 µg treatment arm, 35 patients in the DURYSTA arm and approximately 16 patients that were previously enrolled in the OTX-TIC 5 µg treatment arm.
+Added: Enrollment is ongoing.
+Added: We plan to provide topline data from the trial in the fourth quarter of 2023.
Regulatory Pathway
−Removed: If our 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.
−Removed: 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 Food, Drug and Cosmetic Act, or FDCA.
+Added: If our Phase 2 clinical trial is successful and subject to obtaining the necessary financing, we would then be required to successfully complete two well-controlled pivotal 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.
See “—Government Regulation—Section 505(b)(2) NDAs.”
+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 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 17.8 million patients diagnosed with dry eye disease in the United States, according to the Market Scope 2022 Dry Eye Products Market Report.
+Added: Approximately 9.8 million of those patients are diagnosed with moderate to severe dry eye while the remaining 8.0 million patients are diagnosed with mild 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 $5.7 billion in 2022 with the U.S.
+Added: market representing $2.2 billion.
+Added: There are many products to treat dry eye on the market from over an estimated 150 companies, from both the pharmaceutical and OTC segments.
+Added: Within the prescription category, two of the better-known branded products are Xiidra® from Novartis and Restasis from Allergan.
+Added: In 2022, Xiidra recorded global sales of $487 million while Restasis recorded sales of $666 million.
+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 performed in the United States in 2022, an increase of approximately 3.3% over 2021.
+Added: Market Scope further estimates that approximately 4.6 million are estimated to have been cataract surgeries, an increase of 3.1% over 2021.
+Added: We currently focus our sales efforts for DEXTENZA for the treatment of inflammation and pain 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 $555 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 IQVIA, Inc.
+Added: data, approximately 20.4 million prescriptions were filled in the United States in 2022 for anti-inflammatory drugs administered by prescription eye drops for ocular diseases and conditions, resulting in sales of approximately $4.9 billion.
+Added: These prescriptions consisted of approximately 8.5 million prescriptions and $581.1 million in sales for single-agent corticosteroids, 3.2 million prescriptions and $285.5 million in sales for NSAIDs, 4.7 million prescriptions and $356.2 million in sales for corticosteroid and antibiotic combination products and approximately 4.4 million prescriptions and $3.7 billion in sales for dry eye disease products.
+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 an 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 IQVIA, Inc.
+Added: data, approximately 4.5 million anti-allergy eye drop prescriptions were filled in the United States in 2022, resulting in sales of approximately $255.5 million.
+Added: The market to treat allergic conjunctivitis
+Added: 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.
Ocular Surface Disease Programs
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.
−Removed: 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, allergic conjunctivitis and inflammation and pain following ophthalmic surgery.
−Removed: Dry Eye Disease
+Added: Our initial development efforts are focused on the use of our extended-delivery hydrogel in combination with well-known and well-understood drugs (corticosteroids and cyclosporine) for the treatment of dry eye disease, allergic conjunctivitis and inflammation and pain following ophthalmic surgery.
+Added: Dry Eye Disease Program
+Added: OTX-DED (dexamethasone intracanalicular insert)
+Added: One of the causes of dry eye disease is inflammation.
+Added: Topical anti-inflammatory drugs are used as one of several therapies to treat dry eye disease and are administered by eye drops.
+Added: As the understanding of dry eye disease, specifically the inflammatory components of dry eye disease, has evolved, the use of corticosteroids has become common to offer short-term relief of signs and symptoms of the disease.
+Added: 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.
+Added: However, safety limitations associated with the prolonged 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: 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 includes a lower dose of the drug, is administered in the office setting as a smaller insert and is designed to release dexamethasone over a period of two to three weeks, compared with up to thirty days in the case of DEXTENZA.
+Added: Phase 2 clinical trial
+Added: We submitted an IND in November 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 a hydrogel implant in a total of 166 subjects with dry eye disease, with more than 50 subjects per arm.
+Added: The subjects were followed for approximately two months after randomization.
+Added: This trial was 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 subjects were required to have diagnosed dry eye disease in both eyes for at least six months, a Visual Analog Score, or VAS, eye dryness severity score of at least 30 and bulbar conjunctival hyperemia grade of at least 2 on the Cornea Contact Lens Research Unit (CCLRU) Grading scale.
+Added: The primary endpoint was mean change in bulbar conjunctival hyperemia from baseline measured at 15 days post treatment by central reading center photographic assessment.
+Added: Secondary endpoints included eye dryness symptoms using VAS, total CFS, or corneal total fluorescein staining, using the National Eye Institute scale and adverse events, both ocular and non-ocular.
+Added: We announced the topline Phase 2 clinical results in December 2021.
+Added: The clinical trial achieved its pre-specified primary endpoint.
+Added: Although the clinical trial was not powered to show statistical significance, the topline results demonstrated a statistically significant change of bulbar conjunctival hyperemia from baseline to day 15 compared to the vehicle hydrogel using a central reading photographic assessment in the modified ITT population.
+Added: Change from baseline using the CCLRU Grading scale (0-4) was -0.51 for the OTX-DED 0.2 mg group (n=55), -0.43 for the OTX-DED 0.3 mg group (n=56), and -0.21 for the vehicle hydrogel insert group (n=55).
+Added: These differences were statistically significant compared with the vehicle hydrogel for both the OTX-DED 0.2 mg group (p=.004) and the OTX-DED 0.3 mg group (p=.028).
+Added: Sensitivity analysis using different methods of imputation including last observation carry forward (LOCF), Markov Chain Monte Carlo (MCMC), and fully conditioned specifications (FCS) were consistent with the primary
+Added: Improvements from baseline were noted in the VAS dry eye symptoms for both OTX-DED 0.2 mg and OTX-DED 0.3 mg groups, but there was little separation between OTX-DED and the vehicle hydrogel insert.
+Added: Both formulations of OTX-DED were generally observed to have a favorable safety profile and be well tolerated.
+Added: There were no ocular serious adverse events observed.
+Added: The most common ocular adverse events for subjects treated with OTX-DED were epiphora (lacrimation increase) (8.1%) and elevated IOP (3.6%).
+Added: All other ocular adverse events occurred in less than 1% of subjects.
+Added: The most common non-ocular adverse event for subjects treated with OTX-DED was arthralgia (joint pain) which was seen in 1.8% of subjects.
+Added: All other non-ocular adverse events occurred in less than 1% of subjects.
+Added: Regulatory Pathway
+Added: Based on the data from the Phase 2 clinical trial, we intend to conduct a small trial in connection with our efforts to develop an appropriate placebo comparator that may be used in both the OTX-DED and OTX-CSI programs.
+Added: Specifically, we intend to evaluate the performance of OTX-DED versus placebo inserts, namely fast-dissolving, biodegradable collagen plugs, and no inserts at all, to explain the placebo performance seen in the Phase 2 clinical trials evaluating both OTX-DED and OTX-CSI in which the vehicle hydrogel placebo insert or placebo comparator vehicle remained in the canaliculus longer than anticipated, performing more like an active comparator than a placebo.
+Added: We currently expect to begin this trial in the first half of 2023.
+Added: If we determine to advance the program, we believe we could advance the program to pivotal trials subject to a discussion with the FDA.
+Added: 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.
OTX-CSI (cyclosporine intracanalicular insert)
3 unchanged sentences
Phase 1 clinical development
−Removed: 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: We submitted 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.
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.
−Removed: The study was designed to evaluate the safety,
−Removed: 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: 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.
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.
4 unchanged sentences
One of five subjects (20%) had a greater than 10 mm increase from baseline in Schirmer’s score at Week 12.
−Removed: Subjects saw an improvement in signs of dry eye disease as measured by CFS, or 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).
−Removed: Further, subjects saw an improvement in symptoms of dry eye disease as measured by the Visual Analog Score, or 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: Subjects saw an improvement in signs of dry eye disease as measured by CFS (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).
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.
1 unchanged sentence
In September 2020, we dosed the first subjects in a U.S.-based, randomized, double-masked, multi-center, vehicle-controlled 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.
−Removed: The Phase 2 clinical trial evaluated 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 (12 week study period, with an additional 4-week safety follow-up).
+Added: The Phase 2 clinical trial evaluated two different formulations of OTX-CSI compared with a hydrogel vehicle insert in approximately 140 subjects who were followed for a period of 16 weeks (12-week study period, with an additional 4-week safety follow-up).
Included subjects must have been diagnosed with dry eye disease in both eyes for a period of greater than six months and have a VAS eye dryness severity score of greater than 30.
13 unchanged sentences
Overall, the OTX-CSI insert (both formulations) was generally observed to have a favorable safety profile and be well tolerated.
−Removed: There were no ocular serious adverse events.
+Added: There were no ocular serious adverse events observed.
No subjects dropped out of the trial due to an adverse event.
2 unchanged sentences
The most common non-ocular event was COVID-19 and was seen in 3% of subjects.
−Removed: We continue to evaluate the data from the Phase 2 clinical trial for additional information that may inform the future development of this program.
−Removed: This data includes, among other things, retention rates of the OTX-CSI inserts, or how long the inserts were observed to remain in the canaliculus, as well as the duration of the vehicle hydrogel inserts.
Regulatory Pathway
−Removed: If we determined to advance the program, we believe we would need to complete another Phase 2 clinical trial.
−Removed: If this Phase 2 clinical trial were 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.
−Removed: If our development efforts are successful, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
−Removed: See “—Government Regulation—Section 505(b)(2) NDAs” for additional information.
−Removed: OTX-DED (dexamethasone intracanalicular insert)
−Removed: One of the causes of dry eye disease is inflammation.
−Removed: 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 common to offer short-term relief of signs and symptoms of the disease.
−Removed: 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: However, safety limitations associated with the use of corticosteroids for dry eye disease have limited widespread adoption.
−Removed: We believe that OTX-DED has potential as a short-term treatment of the signs and symptoms of dry eye disease caused by inflammation.
−Removed: OTX-DED incorporates the FDA-approved corticosteroid dexamethasone, its preservative-free active pharmaceutical ingredient, into a hydrogel, drug-eluting intracanalicular insert.
−Removed: 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.
−Removed: Phase 2 clinical trial
−Removed: We filed an IND in November 2020 for OTX-DED.
−Removed: 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 subjects per arm.
−Removed: The subjects were followed for approximately two months after randomization.
−Removed: 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.
−Removed: Included subjects were 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 on the Cornea Contact Lens Research Unit (CCLRU) Grading scale.
−Removed: The primary endpoint is mean change in bulbar conjunctival hyperemia from baseline measured at 15 days post treatment by central reading center photographic assessment.
−Removed: Secondary endpoints include eye dryness symptoms using VAS, total CFS using the National Eye Institute scale and adverse events, both ocular and non-ocular.
−Removed: We announced the topline Phase 2 clinical results in December 2021.
−Removed: The clinical trial achieved its pre-specified primary endpoint.
−Removed: Although the clinical trial was not powered to show statistical significance, the topline results demonstrated a statistically significant change of bulbar conjunctival hyperemia from baseline to day 15 compared to vehicle hydrogel using a central reading photographic assessment in the modified ITT population.
−Removed: Change from baseline using the CCLRU Grading scale (0-4) was -0.51 for the OTX-DED 0.2 mg group (n=55), -0.43 for the OTX-DED 0.3 mg group (n=56), and -0.21 for the vehicle hydrogel insert group (n=55).
−Removed: These differences were statistically significant compared with the vehicle hydrogel for both the OTX-DED 0.2 mg group (p=.004) and the OTX-DED 0.3 mg group (p=.028).
−Removed: Sensitivity analysis using different methods of imputation including last observation carry forward (LOCF), Markov Chain Monte Carlo (MCMC), and fully conditioned specifications (FCS) were consistent with the primary analysis.
−Removed: Improvements from baseline were noted in the VAS dry eye symptoms for both OTX-DED 0.2 mg and OTX-DED 0.3 mg groups, but there was little separation between OTX-DED and the vehicle hydrogel insert.
−Removed: Other secondary endpoints are being evaluated.
−Removed: Both formulations of OTX-DED were generally observed to have a favorable safety profile and be well tolerated.
−Removed: There were no ocular serious adverse events.
−Removed: The most common ocular adverse events for subjects treated with OTX-DED were epiphora (lacrimation increase) (8.1%) and elevated IOP (3.6%).
−Removed: All other ocular adverse events occurred in less than 1% of subjects.
−Removed: The most common non-ocular adverse event for subjects treated with OTX-DED was arthralgia
−Removed: (joint pain) which was seen in 1.8% of subjects.
−Removed: All other non-ocular adverse events occurred in less than 1% of subjects.
−Removed: We continue to evaluate the data from the Phase 2 clinical trial for additional information that may inform the future development of this program.
−Removed: This data includes, among other things, the duration of the vehicle hydrogel inserts.
−Removed: Regulatory Pathway
−Removed: If we determined to advance the program, we believe we would need to complete another Phase 2 clinical trial.
−Removed: If this Phase 2 clinical trial were 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: We are continuing formulation work to extend the durability of the OTX-CSI insert and select the most appropriate formulations to move forward.
+Added: If we determine to advance the program, we believe we could advance the program to pivotal trials subject to discussions with the FDA.
+Added: We would then be required to successfully complete two well-controlled pivotal clinical trials conducted under an IND to obtain marketing approval from the FDA.
If our development efforts are successful, we expect that we would submit an NDA under Section 505(b)(2) of the FDCA.
See “—Government Regulation—Section 505(b)(2) NDAs” for additional information.
−Removed: Allergic Conjunctivitis
−Removed: DEXTENZA (dexamethasone ophthalmic insert) for the Treatment of Ocular Itching Associated with Allergic Conjunctivitis
−Removed: In October 2021, the FDA approved our sNDA, for DEXTENZA to include the treatment of ocular itching associated with allergic conjunctivitis as an additional indication.
−Removed: With the approval, DEXTENZA became the first, FDA-approved, physician-administered intracanalicular insert capable of delivering a preservative-free drug for the treatment of ocular itching associated with allergic conjunctivitis with a single administration for up to 30 days.
−Removed: DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis also represents our first indication approved to be administered in a physician’s office during a routine, non-surgical appointment.
−Removed: We are launching DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis in the first quarter of 2022 utilizing a small, dedicated and highly focused sales force of four KAMs, or key account managers and two FRMs, or field reimbursement managers that will call exclusively on the offices of ophthalmologists and optometrists.
−Removed: We believe that many of the specialists who treat patients for post-surgical inflammation and pain also treat patients suffering from allergic conjunctivitis.
−Removed: 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.
−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 due to potential patient abuse to treat this symptomatic condition, have limited its widespread adoption.
−Removed: These elevations 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: 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.
−Removed: Phase 3 Clinical Program
−Removed: The approval of DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis was based on three randomized, multicenter, double-masked, parallel group, vehicle-controlled studies in subjects with a positive history of ocular allergies and positive skin test reaction to perennial and seasonal allergens (n=255).
−Removed: Our first Phase 3 clinical trial assessed both ocular itching and conjunctival redness associated with allergic conjunctivitis.
−Removed: Our second and third Phase 3 clinical trials focused on the ocular itching indication only.
−Removed: In all three trials, DEXTENZA demonstrated lower mean ocular itching scores compared with the vehicle group at all time points throughout the study duration of up to 30 days.
−Removed: In two of the three studies, a higher proportion of subjects had statistically significant reductions in ocular itching on Day 8, at three minutes, five minutes and seven minutes post-
−Removed: challenge in the DEXTENZA group compared to the vehicle group.
−Removed: Data for the primary endpoint, ocular itching at Day 8, is shown below for all three studies (scale 0-4):
−Removed: Reduction in Ocular Itching
−Removed: Clinical Trial 1
−Removed: Clinical Trial 2
−Removed: Clinical Trial 3
−Removed: Least Square Means
−Removed: Least Square Means
−Removed: Least Square Means
−Removed: -0.7 (-1.2, -0.3)
−Removed: -0.2 (-0.7, 0.3)
−Removed: -0.9 (-1.2, -0.4)
−Removed: -0.7 (-1.2, -0.3)
−Removed: -0.2 (-0.8, 0.3)
−Removed: -1.0 (-1.4, -0.6)
−Removed: -0.8 (-1.2, -0.4)
−Removed: -0.3 (-0.8, 0.3)
−Removed: -1.0 (-1.4, -0.6)
−Removed: DEXTENZA was observed to have a favorable safety profile and be generally well-tolerated in the allergic conjunctivitis as well as the ocular inflammation and pain clinical populations.
−Removed: The most common ocular adverse events seen in the pooled analysis of the allergic conjunctivitis studies were:
−Removed: increased intraocular pressure (3%), increased lacrimation (1%), eye discharge (1%) and reduced visual acuity (1%).
−Removed: The most common non-ocular adverse reaction that occurred in subjects treated with DEXTENZA for allergic conjunctivitis was headache (1%).
−Removed: First Phase 3 Clinical Trial
−Removed: We initiated our first planned Phase 3 clinical trials in June 2015, and we reported topline efficacy results in October 2015.
−Removed: This first Phase 3 clinical trial was a prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked trial.
−Removed: A total of 73 subjects 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 CAC Model.
−Removed: We evaluated subjects 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.
−Removed: In this Phase 3 clinical trial, we placed the intracanalicular inserts 48 to 72 hours after exposure to the allergen.
−Removed: In our completed Phase 2 clinical trial, we obtained better efficacy results with this design protocol as noted in the description of the Phase 2 efficacy results above.
−Removed: The primary efficacy measures for this trial were ocular itching graded by the subject and conjunctival redness graded by the trial investigator, in each case 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 measured on 7 days post-insertion of the intracanalicular insert for all three time points measured for both ocular itching and conjunctival redness and differences of at least 1.0 unit for the majority of the three time points measured on 7 days post-insertion of the intracanalicular insert for both ocular itching and conjunctival redness.
−Removed: 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 conjunctivitis.
−Removed: Most commercially available prescription medications for the treatment of allergic conjunctivitis have an ocular itching indication only.
−Removed: As described below, ocular itching was the only primary efficacy endpoint in the second Phase 3 trial of DEXTENZA for the treatment of allergic conjunctivitis, with conjunctival redness being moved to a secondary efficacy endpoint.
−Removed: We enrolled subjects in this trial who were 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 subjects 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 subjects at each study visit with an assessment of general eye conditions, including visual acuity and IOP, along with any adverse events.
−Removed: In this trial, there was a statistically significant mean difference (p<0.0001) between the DEXTENZA treatment group and the placebo vehicle group for ocular itching at all three time points measured on 7 days post-placement of the intracanalicular insert.
−Removed: DEXTENZA also met the primary efficacy endpoint for ocular itching.
−Removed: The DEXTENZA treatment group achieved a mean difference compared to the vehicle group of greater than 0.5 units on a five point scale on 7 days post-insertion at each time point and greater than 1.0 unit at a majority of the time points on 7 days post-insertion for ocular itching.
−Removed: There was a statistically significant mean difference (p=0.01 or less) between the
−Removed: DEXTENZA treatment group and the placebo vehicle group for conjunctival redness at all three time points measured on 7 days post-placement of the intracanalicular insert.
−Removed: However, the DEXTENZA group did not achieve the pre-specified primary efficacy endpoints on 7 days post-insertion with respect to conjunctival redness.
−Removed: There were no serious adverse events reported in this trial.
−Removed: There were a variety of adverse events in both the DEXTENZA group and the vehicle control group, with three subjects in the DEXTENZA treatment group with a total of three ocular adverse events and one non-ocular adverse event and four subjects in the vehicle control group with a total of six ocular adverse events and one non-ocular adverse events.
−Removed: The most common ocular adverse event was increased lacrimation, which was experienced by one subject in the DEXTENZA group and two subjects in the vehicle control group.
−Removed: Other treatment-related ocular adverse events included increased IOP in the DEXTENZA group, and blepharospasm in the vehicle control group.
−Removed: Second Phase 3 Clinical Trial
−Removed: We initiated our second Phase 3 clinical trial of DEXTENZA for the treatment of allergic conjunctivitis in November 2015, and we reported topline efficacy results in June 2016.
−Removed: This second Phase 3 clinical trial was a prospective, randomized, parallel-arm, vehicle-controlled, multicenter, double-masked trial.
−Removed: A total of 72 subjects 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 CAC Model.
−Removed: Subjects 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.
−Removed: In this Phase 3 clinical trial, we placed the intracanalicular inserts 48 to 72 hours after exposure to the allergen.
−Removed: The single primary efficacy measure for this trial was ocular itching graded by the subject 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 and day 28 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 subjects 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 subjects 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 subjects at each study visit with an assessment of general eye conditions, including visual acuity and IOP, along with any adverse events.
−Removed: 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.
−Removed: 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.
−Removed: The trial also assessed conjunctival redness as a secondary endpoint.
−Removed: The differences in the mean scores in conjunctival redness between the DEXTENZA treatment group and the placebo group 7 days following insertion of the inserts at 7, 15 and 20 minutes were -0.35, -0.39 and -0.42, respectively.
−Removed: There were no serious adverse events reported in this trial.
−Removed: There were a variety of adverse events in both the DEXTENZA group and the vehicle control group, with six subjects in the DEXTENZA treatment group with a total of six ocular and one non-ocular adverse events and 11 subjects in the vehicle control group with a total of nine ocular and eight non-ocular adverse events.
−Removed: The lower rate of ocular adverse events in the DEXTENZA group could potentially
−Removed: be due to the presence of an anti-inflammatory active pharmaceutical ingredient.
−Removed: Ocular adverse events reported more than one subject in either treatment group included increased IOP, which was experienced by two subjects in the DEXTENZA group, as well as dacryostenosis acquired and dacryocanaliculitis, each experienced by two subjects in the vehicle control group.
−Removed: Both cases of IOP increased were considered treatment related, as were both cases of dacryocanaliculitis and a single case of dacryostenosis.
−Removed: All other ocular adverse events were reported by single subjects in either the DEXTENZA or vehicle control group, with most in the PV group considered treatment related.
−Removed: Third Phase 3 Clinical Trial
−Removed: In the third quarter of 2019, we began dosing subjects in a 96-subject, pivotal Phase 3 clinical trial evaluating DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis and we reported topline efficacy results in April 2020.
−Removed: 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.
−Removed: 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.
−Removed: 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.
−Removed: 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).
−Removed: 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).
−Removed: In the trial, DEXTENZA was generally observed to have a favorable safety profile and be well-tolerated.
−Removed: No serious adverse events were observed.
−Removed: No subjects required rescue medication and no subjects experienced elevated IOP.
−Removed: There were 8 ocular treatment-emergent adverse events in this trial (2 in the DEXTENZA group and 6 in the vehicle group).
+Added: Additional Potential Areas for Growth
+Added: We continue to leverage the potential of our hydrogel platform to explore areas for growth with a focus on formulating, developing and commercializing innovative therapies for diseases and conditions of the eye.
+Added: Complement Inhibitor .
+Added: In June 2021, we entered into an agreement with Mosaic Biosciences, Inc., or Mosaic, to identify new targets and discover novel therapeutic agents aimed at the treatment of dry AMD.
+Added: Dry AMD can progress to an advanced condition known as geographic atrophy, or GA.
+Added: Vision loss from GA is typically more gradual than it is from wet AMD.
+Added: In its 2022 Retinal Pharmaceuticals Market Report, Market Scope estimated that there are 1.6 million people with GA in the United States and more than 13 million globally, both growing at an estimated compound annual growth rate of 3%.
+Added: Our collaboration with Mosaic has yielded lead compounds that Mosaic has humanized and is now optimizing for our preclinical complement inhibitor program.
+Added: We believe that product candidates with these compounds have the potential for targeted dosing of every three to four months.
+Added: Companies actively pursuing treatments for GA through the inhibition of the complement system include Apellis Pharmaceuticals, Inc.
+Added: and Iveric bio, Inc.
+Added: Apellis’ Syfovre received marketing approval from the FDA in February of 2023.
+Added: In February 2023, Iveric Bio, Inc.
+Added: also announced that the FDA had accepted the company’s NDA for avacincaptad pegol for filing and established a PDUFA target action date in August 2023.
+Added: We are aware that several other companies are actively developing product candidates for the treatment of GA, including Annexon Biosciences, Inc.
+Added: Novartis Ionis (in collaboration with Roche/Genentech), AstraZeneca, The Janssen Pharmaceutical Companies of Johnson & Johnson (after acquisition from Hemera Biosciences), Alkeus Pharmaceuticals, Inc., Lineage Cell Therapeutics, Inc.
+Added: (in collaboration with Roche/Genentech), and Regenerative Patch Technologies, LLC.
+Added: Gene Delivery Program.
+Added: We have a preclinical program using our hydrogel technology to control the release of vectors such as AAV to ocular tissues for the treatment of inherited and acquired ocular diseases, including dry or wet AMD.
+Added: We believe that our hydrogel formulation technology may be uniquely suited to deliver a gene therapy safely, effectively and efficiently with a longer duration of effect.
+Added: Companies actively pursuing gene therapy to address ocular diseases and conditions of the eye include Adverum Biotechnologies, GenSight, REGENXBIO, and Spark Therapeutics.
+Added: Commercial Portfolio
Post-Surgical Ocular Inflammation and Pain
3 unchanged sentences
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 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;
+Added: We selected dexamethasone as the active pharmaceutical ingredient for DEXTENZA because it is approved by the FDA and has a long history of ophthalmic use;
is available on a generic basis;
1 unchanged sentence
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
−Removed: the hydrogel degrades by hydrolysis, the intracanalicular insert softens, liquefies and is cleared through the nasolacrimal duct.
+Added: and has physical properties that are well suited for incorporation within our hydrogel technology.
+Added: The dexamethasone drug particles embedded within our DEXTENZA intracanalicular insert 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.
We provide the DEXTENZA drug product in a preservative-free formulation in a sterile, single use package.
2 unchanged sentences
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.
−Removed: Overview of Clinical Development for Post-Surgical Ocular Inflammation and Pain
−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: 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 complete response letter, or CRL, from the FDA regarding our NDA for DEXTENZA.
−Removed: We resubmitted our NDA for DEXTENZA for the treatment of post-surgical ocular pain in June 2018 and received approval for the pain indication in November 2018.
−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 the third Phase 3 clinical trial, DEXTENZA met both primary efficacy endpoints, absence of pain at day 8 and absence of inflammatory cells at day 14.
−Removed: In January 2019, we submitted an sNDA for the treatment of post-surgical inflammation based, in part, on the results from the third Phase 3 clinical trial.
−Removed: In June 2019, we received approval for the inflammation indication.
Investigator-Initiated Trials
−Removed: We have received proposals for, and plan to support, several investigator-initiated trials evaluating DEXTENZA in different clinical situations.
+Added: We have received proposals for, and are supporting, several investigator-initiated trials evaluating DEXTENZA in different clinical situations.
To date, third-party clinical investigators have initiated over 45 trials to study the use of DEXTENZA in cataract surgery, other ophthalmic surgeries and other potential indications.
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Enrollment is ongoing.
−Removed: We intend to discuss with the FDA whether this Phase 3 clinical trial evaluating DEXTENZA for the treatment of post-surgical ocular inflammation and pain in children following cataract surgery may also satisfy the post-approval requirement for a pediatric trial as it relates to indication ocular itching associated with allergic conjunctivitis.
+Added: The FDA has agreed that this Phase 3 clinical trial evaluating DEXTENZA for the treatment of post-surgical ocular inflammation and pain in children following cataract surgery may also satisfy the post-approval requirement for a pediatric trial as it relates to indication ocular itching associated with allergic conjunctivitis.
Foreign Approvals
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.
−Removed: Given our prioritization of the clinical development of our sustained-release
−Removed: 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: 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 third parties to assist us in the approval process.
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.
In January 2022, AffaMed dosed its first subject in a study conducted in China evaluating the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain post-cataract surgery.
+Added: This prospective, single-arm, real-world trial is designed to assess the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain following cataract surgery in approximately 120 patients at the Bo’ao Super Hospital.
+Added: The trial’s primary efficacy endpoint is the absence of anterior chamber cells in the study eye at Day 14, and the key secondary endpoint is the absence of pain in the study eye at Day 8.
+Added: In April 2022, AffaMed announced that DEXTENZA has been approved in Macau, China for the treatment of ocular inflammation and pain following ophthalmic surgery.
+Added: We do not expect that DEXTENZA sales in Macau will result in material revenues to us.
We retain the right to develop and commercialize DEXTENZA in all other global markets.
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See “—Government Regulation—Review and Approval of Medical Devices in the European Union” for additional information.
+Added: Allergic Conjunctivitis
+Added: DEXTENZA (dexamethasone ophthalmic insert) for the Treatment of Ocular Itching Associated with Allergic Conjunctivitis
+Added: In October 2021, the FDA approved our sNDA, for DEXTENZA to include the treatment of ocular itching associated with allergic conjunctivitis as an additional indication.
+Added: With the approval, DEXTENZA became the first, FDA-approved, physician-administered intracanalicular insert capable of delivering a preservative-free drug for the treatment of ocular itching associated with allergic conjunctivitis with a single administration for up to 30 days.
+Added: DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis also represents our first indication approved to be administered in a physician’s office during a routine, non-surgical appointment.
+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
+Added: antihistamine 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 can 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: 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.
+Added: We believe that many of the specialists who treat patients for post-surgical inflammation and pain also treat patients suffering from allergic conjunctivitis.
+Added: We commercially launched DEXTENZA for the treatment of ocular itching associated with allergic conjunctivitis in the first quarter of 2022 utilizing a small, dedicated and highly focused sales force of four key account managers and two field reimbursement managers that called exclusively on the offices of ophthalmologists and optometrists.
+Added: In the fourth quarter of 2022, we redeployed this small sales force to join the DEXTENZA sales force focused on the ophthalmic surgery market, specifically cataract surgery, in ambulatory surgery centers, or ASCs, and hospital outpatient departments, or HOPDs.
+Added: We believe that cataract surgeries represent a larger, near-term market opportunity and a faster return-on-investment.
+Added: Prevention of Wound Leaks Following Cataract Surgery
ReSure Sealant
ReSure Sealant is a topical liquid hydrogel that creates a temporary, adherent, soft and lubricious sealant to prevent post-surgical leakage from clear corneal incisions that are made during cataract surgery.
−Removed: The main components of ReSure hydrogel are water and PEG.
−Removed: ReSure hydrogel is completely synthetic, with no animal or human derived components.
−Removed: The FDA granted marketing approval for ReSure Sealant in January 2014.
−Removed: We commercially launched ReSure Sealant in the United States in February 2014.
−Removed: 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.
−Removed: We believe ReSure Sealant offers important benefits over sutures, including superior wound closure, a better safety profile and less follow-up.
−Removed: 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 separate reimbursement for ReSure Sealant—meaning ReSure Sealant is only reimbursed as part of a bundled payment for the associated surgery.
−Removed: While ReSure Sealant remains commercially available in the United States, we are not providing any sales support and only modest commercial support for this product at this time.
−Removed: As of the fourth quarter of 2021, we have suspended manufacturing ReSure in order to focus our manufacturing resources to support the further commercialization of DEXTENZA.
−Removed: As a result, we do not expect to generate meaningful levels of revenue from the sale of ReSure Sealant.
−Removed: Product Design
−Removed: A surgeon forms ReSure Sealant hydrogel by combining three components:
−Removed: PEG, a cross-linker and a diluent buffer solution.
−Removed: The cross-linker interacts with the PEG molecules to form a molecular network that comprises the hydrogel.
−Removed: The components are mixed to initiate the cross-linking reaction to form a biocompatible, resorbable hydrogel.
−Removed: The hydrogel is approximately 90% water and is blue in color to help the surgeon visualize the sealant during application.
−Removed: 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 the tissue surfaces.
−Removed: The blue color fades within a few hours following surgery.
−Removed: The soft, pliable hydrogel remains on the corneal surface during the critical wound healing period of one to three days and provides a barrier to fluid leakage.
−Removed: ReSure Sealant softens over time, detaches and is sloughed off in the tears as a liquid or extremely soft gel pieces.
−Removed: ReSure Sealant is designed to completely liquefy over a five to seven day duration.
−Removed: Complete epithelial healing takes place over this time period, providing long-term wound closure.
−Removed: We provide ReSure Sealant in a sterile, single patient use package.
−Removed: The package contains a tray with two elongated mixing wells.
−Removed: Each well contains dried deposits of reactants, separated within the well.
−Removed: The package also contains one plastic dropper bottle filled with diluent solution and two applicators.
−Removed: The device is stored at room temperature for easy access.
−Removed: Post-Approval Studies
−Removed: 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: Before granting approval of the premarket approval, or PMA, application, the FDA
−Removed: sought input from the Ophthalmic Devices Advisory Committee, a panel of physicians charged with reviewing results from our pivotal clinical trial.
−Removed: The FDA approved our PMA application for ReSure Sealant in January 2014.
−Removed: The FDA required two post-approval studies as a condition for approval of our 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, 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.
−Removed: 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.
−Removed: In April 2021, the FDA confirmed that the Device Exposure Registry Study had been completed and that we had fulfilled our post-approval study requirements.
+Added: The FDA granted marketing approval for ReSure Sealant in January 2014 and we commercially launched ReSure Sealant in the United States in February 2014.
+Added: We have received only limited revenues from ReSure Sealant to date as the product is only used in a minority of cataract surgeries and, currently, there is no direct separate reimbursement for the product—meaning ReSure Sealant is only reimbursed as part of a bundled payment for the associated surgery.
+Added: As of the fourth quarter of 2021, we suspended the production of ReSure Sealant in order to focus our manufacturing resources on the commercialization of DEXTENZA.
+Added: Currently, ReSure Sealant is not commercially available in the United States.
+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, Taiwan, Hong Kong, Macau, South Korea, and the countries of the Association of Southeast Asian Nations.
+Added: Under the terms of the agreement, we received an upfront payment of $12 million and became 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: In the fourth quarter of 2021, we received a $1 million milestone payment upon the approval by the FDA of an sNDA for DEXTENZA to include the treatment of ocular itching associat ed with allergic conjunctivitis as an additional indication ;
+Added: in the second quarter of 2022, we received a $2 million clinical support payment in connection with dosing the first subject in a Phase 2 clinical trial evaluating OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension.
+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 IOP 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.
+Added: In January 2022, AffaMed announced that it had dosed its first patient in a real-world setting study conducted in China evaluating the safety and efficacy of DEXTENZA ® (0.4mg dexamethasone ophthalmic insert) for the treatment of ocular inflammation and pain post-cataract surgery.
+Added: This prospective, single-arm, real-world trial is designed to assess the safety and efficacy of DEXTENZA for the treatment of ocular inflammation and pain following cataract surgery in approximately 120 patients at the Bo’ao Super Hospital.
+Added: The trial’s primary efficacy endpoint is the absence of anterior
+Added: chamber cells in the study eye at Day 14, and the key secondary endpoint is the absence of pain in the study eye at Day 8.
+Added: In April 2022, AffaMed announced that DEXTENZA has been approved in Macau, China for the treatment of ocular inflammation and pain following ophthalmic surgery.
+Added: We do not expect that DEXTENZA sales in Macau will result in material revenues to us.
Sales, Marketing and Distribution
−Removed: We plan to prioritize our commercialization efforts in the United States.
We generally expect to retain commercial rights in the United States to any of our product candidates for which we may receive marketing approvals and which we believe we can successfully commercialize.
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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: 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.
−Removed: In connection with the commercialization 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.
−Removed: We expect to grow our salesforce in 2022 to increase our active number of accounts and penetrate each account more deeply.
−Removed: Our current field sales team consists of approximately 35 KAMs, nine FRMs and four Regional Directors, or RDs, all of whom are focused on selling DEXTENZA for the treatment of ocular inflammation and pain to surgical sites, primarily ASCs.
−Removed: We intend to hire at least five additional KAMs who will also be focused on surgical sites.
−Removed: With the approval of DEXTENZA for the indication of ocular itching associated with allergic conjunctivitis, we are launching a commercial effort in the first quarter of 2022 and intend to hire four KAMs and two FRMs dedicated to selling DEXTENZA to the offices of ophthalmologists and optometrists, where the vast majority of prescriptions for allergies are written.
−Removed: 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.
−Removed: ReSure Sealant
−Removed: We commercially launched ReSure Sealant in the United States in February 2014.
−Removed: While ReSure Sealant remains commercially available in the United States, we are not providing any sales support.
−Removed: As of the fourth quarter of 2021, we have suspended manufacturing ReSure in order to focus our manufacturing resources to support the further commercialization of DEXTENZA.
−Removed: As a result, we do not expect to generate meaningful levels of revenue from the sale of ReSure Sealant.
+Added: We sell DEXTENZA in the United States to a network of specialty distributors, who then resell DEXTENZA to ASCs and HOPDs.
+Added: We have built a highly targeted, key account sales force of KAMs, or key account managers, Regional Directors, and FRMs or field reimbursement managers that focus on the ASCs and their affiliates responsible for the largest volumes of cataract surgery in the United States, with an initial emphasis on the approximately two million cataract procedures performed annually under Medicare Part B.
+Added: With the approval of DEXTENZA for the indication of ocular itching associated with allergic conjunctivitis, we launched a commercial effort in the first half of 2022 with four KAMs and two FRMs dedicated to selling DEXTENZA to the offices of ophthalmologists and optometrists, where the vast majority of prescriptions for allergies are written.
+Added: As of the fourth quarter of 2022, we redeployed the office-focused personnel back to the ocular surgical market, calling on ASCs and HOPDs.
+Added: In the third quarter of 2022, we implemented an off-invoice discount program whereby providers receive the discounted price immediately upon purchase, rather than having to wait until the end of the quarter for a rebate payment.
Manufacturing
1 unchanged sentence
In June 2016, we entered into a new lease agreement for approximately 71,000 square feet of a facility in Bedford, Massachusetts that primarily houses our research and development functions but may include additional manufacturing space in the future.
−Removed: We are currently evaluating a long-term master facilities plan to accommodate our manufacturing needs in the future.
We purchase active pharmaceutical ingredient drug substance from independent suppliers on a purchase order basis for incorporation into our drug product candidates.
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This structure enables us to efficiently transfer research stage product concepts into manufacturing.
−Removed: We have designed our manufacturing facility and processes to provide flexibility for the manufacture of different product candidates.
+Added: We have designed our
+Added: manufacturing facility and processes to provide flexibility for the manufacture of different product candidates.
We outsource sterilization services for our products.
3 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 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.
−Removed: The number of U.S.
−Removed: patents and applications owned by us may increase, on a product-by-product basis or in the aggregate, if we, for example, file additional patent applications and/or obtain patent grants from patent applications.
−Removed: The number of patents and applications owned by us may decrease, on a product-by-product basis or in the aggregate, if we, for example, voluntarily abandon patents or patent applications, allow patent applications to expire, or have patents invalidated.
−Removed: As of February 19, 2022, patents and/or patent applications pending owned by us, are 49 pending applications:
+Added: We have issued 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: As of March 1, 2023, patents and/or patent applications pending owned by us, are 95 pending applications:
5 pending provisional applications, 11 pending U.S.
patent applications, 11 pending World Intellectual Property Organization applications and 68 foreign applications.
−Removed: patents and applications, and foreign counterparts, have been in-licensed from Incept, and we may in-license additional U.S.
−Removed: patents and applications, and foreign counterparts.
−Removed: As of February 19, 2022, there have been 33 granted of which 15 are U.S.
−Removed: patents and there are 45 patent applications pending of which 7 are U.S.
−Removed: applications that are in-licensed from Incept.
−Removed: 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.
+Added: Certain of our U.S.
+Added: patents and applications, and foreign counterparts, are Company owned and other U.S.
+Added: patents and applications, and foreign counterparts have been in-licensed from Incept.
The following is a summary of patents and patent applications that cover our commercial products and potentially cover our product candidates:
OTX-TKI (axitinib intravitreal implant) for Wet AMD, DME and RVO
−Removed: We have licenses to several U.S.
−Removed: patents and patent applications, and certain foreign counterparts, with the potential to cover this product candidate, expected to expire between 2027 and 2032.
−Removed: We own pending patent applications in the United States with the potential to cover this product candidate that, if granted, are expected to expire in 2041.
+Added: We own issued patents in the U.S.
+Added: that cover this product candidate, with current expiration dates in 2041.
+Added: Additional U.S.
+Added: and foreign patent applications are pending.
OTX-TIC (travoprost intracameral implant) for open-angle glaucoma or ocular hypertension
−Removed: We have licenses to a pending U.S.
−Removed: application and certain foreign patent applications pending that potentially cover this product candidates that, if granted, are expected to expire in 2037.
−Removed: We own 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, are expected to expire in 2042.
+Added: We have licenses to pending U.S.
+Added: applications and certain foreign patent applications pending that potentially cover this product candidate that, if granted, are expected to expire in 2037.
+Added: We own pending patent applications in the U.S., and certain foreign counterparts, with the potential to cover this product candidate that, if granted, are expected to expire in 2041.
OTX-CSI (cyclosporine intracanalicular insert) for dry eye disease
We have licenses to U.S.
−Removed: patents and patent applications, and certain foreign counterparts, that potentially cover this product candidate, and which are expected to expire in 2030, relating to methods of use of this product candidate.
−Removed: 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: patents, and certain foreign counterparts, that cover this product candidate, with current expiration dates in 2030.
+Added: We own issued patents and pending patent applications in the U.S.
+Added: that cover this product candidate with current expiration dates in 2037 and in 2041, and corresponding foreign patent applications that, if granted, are expected to expire in 2041.
OTX-DED (dexamethasone intracanalicular insert) for episodic dry eye disease
We have licenses to U.S.
−Removed: patents and pending applications, and certain foreign counterparts, which are expected to expire in 2030 and relate to compositions and methods of use of this product candidate.
−Removed: 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: patents, and certain foreign counterparts, with current expiration dates in 2030.
+Added: We own an issued patent that expires in 2037 that covers this product candidate and a pending patent application in the U.S., and certain foreign counterparts, with the potential to cover this product candidate that, if granted, are expected to expire in 2041.
DEXTENZA (dexamethasone ophthalmic insert) 0.4 mg
We have licenses to U.S.
−Removed: patents and pending applications, and certain foreign counterparts, which are expected to expire in 2030 and potentially cover compositions and methods of use of this product candidate.
+Added: patents, and certain foreign counterparts, with current expiration dates in 2030 that cover this product.
We also own a U.S.
−Removed: patent application with the potential to cover this product that, if granted, is expected to expire in 2036.
+Added: patent that covers this product with a current expiration date in 2037.
DEXTENZA (dexamethasone ophthalmic insert) 0.4 mg for allergic conjunctivitis
We have licenses to U.S.
−Removed: patents, and certain foreign counterparts, which are expected to expire in 2030 and potentially cover compositions and methods of use of this product candidate.
−Removed: 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: patents, and certain foreign counterparts, with current expiration dates in 2030 that cover this product.
+Added: We also own a U.S.
+Added: patent that covers this product with a current expiration date in 2037 and a pending patent application in the U.S., and certain foreign counterparts, with the potential to cover this product candidate that, if granted, is expected to expire in 2041.
ReSure Sealant
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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
−Removed: 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.
19 unchanged sentences
We will solely own, without a license to Incept, all intellectual property rights conceived solely by one or more individuals from our company, or the Company Individuals, after the Effective Date, subject to exceptions specified therein.
−Removed: Subject to certain exceptions specified in the Second Amended Agreement, Incept will own and license to the us (i) all intellectual property rights included in the Original License, or the Original IP, in the Ophthalmic Field of Use and the Additional Field of Use, (ii) intellectual property rights in the field of drug delivery conceived solely by the Company Individuals on or before the Effective Date, or Incept IP, and (iii) intellectual property rights in the field of
−Removed: drug delivery conceived by one or more Company Individuals jointly with one or more individuals from Incept, including Dr.
+Added: Subject to certain exceptions specified in the Second Amended Agreement, Incept will own and license to the us (i) all intellectual property rights included in the Original License, or the Original IP, in the Ophthalmic Field of Use and the Additional Field of Use, (ii) intellectual property rights in the field of drug delivery conceived solely by the Company Individuals on or before the Effective Date, or Incept IP, and (iii) intellectual property rights in the field of drug delivery conceived by one or more Company Individuals jointly with one or more individuals from Incept, including Dr.
Sawhney, or the Incept Individuals, after the Effective Date.
21 unchanged sentences
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.
−Removed: 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
−Removed: 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: 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.
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.
2 unchanged sentences
In the fourth quarter of 2021, we received a $1 million milestone payment under the License Agreement from AffaMed;
−Removed: we expect to recognize a clinical support payment of another $2 million in the first quarter of 2022 in connection with dosing the first subject in a Phase 2 clinical trial evaluating OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension.
−Removed: There can be no guarantee, however, that any of these milestones will be achieved.
+Added: in the second quarter of 2022, we received a $2 million clinical support payment in connection with dosing the first subject in a Phase 2 clinical trial evaluating OTX-TIC for the treatment of open-angle glaucoma or ocular hypertension.
+Added: There can be no guarantee, however, that any of the remaining milestones will be achieved.
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.
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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.
−Removed: The License Agreement contemplates that the parties negotiate and enter into a future agreement requiring us to use commercially reasonable efforts to manufacture 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: 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.
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.
3 unchanged sentences
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.
+Added: Mosaic Biosciences Agreement
+Added: In June 2021, we entered into an agreement with Mosaic to identify new targets and discover novel therapeutic agents aimed at the treatment of dry AMD.
+Added: Our collaboration with Mosaic has yielded lead compounds that Mosaic has humanized and is now optimizing for our preclinical complement inhibitor program for the treatment of dry AMD.
+Added: We own all intellectual property created under this agreement.
The biotechnology and pharmaceutical industries are characterized by rapidly advancing technologies, intense competition and a strong emphasis on proprietary products.
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Many of our potential competitors have significantly greater financial resources and expertise in research and development, manufacturing, preclinical testing, conducting clinical trials, obtaining regulatory approvals and marketing approved products than we do.
−Removed: These competitors also
−Removed: compete with us in recruiting and retaining qualified scientific and management personnel and establishing clinical trial sites and patient registration for clinical trials, as well as in acquiring technologies complementary to, or necessary for, our programs.
+Added: These competitors also compete with us in recruiting and retaining qualified scientific and management personnel and establishing clinical trial sites and patient registration for clinical trials, as well as in acquiring technologies complementary to, or necessary for, our programs.
Smaller or early-stage companies may also prove to be significant competitors, particularly through collaborative arrangements with large and established companies.
3 unchanged sentences
As such, if a third party were able to design around the formulation and process patents that we license and create a different formulation using a different production process not covered by our licensed patents or patent applications, we would likely be unable to prevent that third party from manufacturing and marketing its product.
−Removed: Competitors of our Intracanalicular Insert Product Candidates
−Removed: 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.
Competitors of OTX-TKI
1 unchanged sentence
They include Lucentis, Eylea, Beovu, Vabysmo 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 Clearside Biomedical, Inc., which is pursuing a TKI (axitinib) administered into the suprachoroidal space;
+Added: Multiple companies, although all in early stages of development, are exploring ways to deliver anti-VEGF products in a sustained-release fashion, including Regeneron which is pursuing a high-dose version of Eyelea;
+Added: Clearside Biomedical, Inc., which is pursuing a TKI (axitinib) administered into the suprachoroidal space;
Eyepoint Pharmaceuticals, Inc., which is pursuing a sustained-release bioerodible device containing a TKI (vorolanib) using its Durasert technology;
−Removed: Aerie Pharmaceuticals, which is pursuing development of a 4-6 month TKI implant (axitinib) using its Print® manufacturing technology;
−Removed: Graybug Vision, Inc.
−Removed: 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: Aerie Pharmaceuticals, which is pursuing development of a four to six month TKI implant (axitinib) using its Print® manufacturing technology;
and Kodiak Sciences Inc., which is pursuing sustained release therapies based on its anti-VEGF biopolymer conjugate technology.
−Removed: Recently, Genentech received approval for Susvimo which utilizes the company’s port delivery system for delivery of ranibizumab.
+Added: In October 2021, Genentech received approval for Susvimo which utilizes the company’s port delivery system for delivery of ranibizumab but has recently launched a voluntary recall of the product due to manufacturing issues.
In addition, there are several companies pursuing gene therapy to treat retinal diseases including Adverum Biotechnologies, Inc.
1 unchanged sentence
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, Novartis (Gyroscope Therapeutics), Genentech/Ionis and Janssen Pharmaceuticals, among others.
+Added: Apellis recently received approval of SYFOVRE as the first approved treatment for geographic atrophy.
Competitors of OTX-TIC
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Allergan purchased ForSight VISION5 who was conducting a Phase 2 clinical trial with the Helios insert, a sustained-release ocular insert placed below the eyelid that delivers bimatoprost for the treatment of glaucoma.
−Removed: Glaukos, Inc.
−Removed: is in Phase 3 trials with its iDose technology to deliver travoprost for the treatment of glaucoma.
+Added: In February 2023, Glaukos, Inc.
+Added: submitted an NDA for its iDose technology to deliver travoprost for the treatment of glaucoma.
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.
2 unchanged sentences
A number of therapies are currently available for the treatment of dry eye disease in the United States.
−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,” and three FDA-approved prescription eye drop therapies:
+Added: 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,” and there are three FDA-approved prescription eye drop therapies:
Restasis, Xiidra and Cequa.
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Kala Pharmaceuticals received approval in 2020 and launched EYSUVIS, (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: EYSUVIS was sold to Alcon in July 2022.
Oyster Point Pharma received approval in 2021 for TYRVAYA (varenicline solution) Nasal Spray, a cholinergic agonist indicated for the treatment of the signs and symptoms of dry eye disease.
+Added: Oyster Point was purchased by Viatris in November 2022.
Other treatment options include ointments, gels, warm compresses, omega-3 fatty acid supplements and a number of medical devices.
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Eyepoint launched DEXYCU commercially in the first quarter of 2019.
−Removed: OMIDRIA ® , recently purchased by Rayner Surgical Group Limited, is a prescription medication used during cataract surgery.
+Added: OMIDRIA, purchased by Rayner Surgical Group Limited, is a prescription medication used during cataract surgery.
According to the OMIDRIA website, this product helps the black part in the center of your eye (pupil) stay open (dilated) during cataract surgery and decreases eye pain after surgery.
2 unchanged sentences
Outside the United States, Beaver Visitec is commercializing its product OcuSeal, which is designed to provide a protective hydrogel film barrier to stabilize ocular wounds.
−Removed: This product has received a CE Mark in Europe but is not approved for use in the United States.
+Added: This product has received a CE Mark in Europe but is not approved for
+Added: use in the United States.
Sutures are the primary alternative device for closing ophthalmic wounds.
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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.
−Removed: An applicant seeking approval to market and distribute a new drug or biological product in the United States must typically undertake the following:
+Added: A company, institution, or organization which takes responsibility for the initiation and management of a clinical development program for such products is referred to as a sponsor.
+Added: A sponsor seeking approval to market and distribute a new drug or biological product in the United States must typically undertake the following:
● completion of preclinical laboratory tests, animal studies and formulation studies in compliance with the FDA’s good laboratory practice, or GLP, regulations;
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Preclinical studies include laboratory evaluation of the purity and stability of the manufactured drug substance or active pharmaceutical ingredient and the formulated product, as well as in vitro and animal studies to assess the safety and activity of the investigational product for initial testing in humans and to establish a rationale for therapeutic use.
+Added: These studies are generally referred to as IND-enabling studies.
The conduct of preclinical studies is subject to federal regulations and requirements, including GLP regulations and standards and the United States Department of Agriculture’s Animal Welfare Act.
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Such authorization must be secured prior to interstate shipment and administration of any new drug or biologic that is not the subject of an approved NDA or BLA.
−Removed: 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.
+Added: In support of a request for an IND, sponsors must submit a protocol for each clinical trial and any subsequent protocol amendments must be submitted to the FDA as part of the IND.
The FDA requires a 30-day waiting period after the filing of each IND before clinical trials may begin.
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In addition to the foregoing IND requirements, an IRB representing each institution participating in the clinical trial must review and approve the plan for any clinical trial before it commences at that institution, and the IRB must conduct continuing review and reapprove the study at least annually.
−Removed: The IRB must review and approve, among other things, the study protocol and informed consent information to be provided to study subjects.
+Added: The IRB must review and approve, among other
+Added: things, the study protocol and informed consent information to be provided to study subjects.
An IRB must operate in compliance with FDA regulations.
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Although sponsors are also obligated to disclose the results of their clinical trials after completion, disclosure of the results can be delayed in some cases for up to two years after the date of completion of the trial.
−Removed: The NIH’s Final Rule on registration and reporting requirements for clinical trials became effective in 2017, and both NIH and the FDA have recently signaled the government’s willingness to begin enforcing those requirements against non-compliant clinical trial sponsors.
+Added: The NIH’s Final Rule on registration and reporting requirements for clinical trials became effective in 2017.
+Added: Although the FDA has historically not enforced these reporting requirements due to the Department of Health and Human Services (HHS) long delay in issuing final implementing regulations, the FDA has issued several Notices of Noncompliance to manufacturers since April 2021.
Expanded Access to an Investigational Drug for Treatment Use
28 unchanged sentences
Generally, pivotal trials are Phase 3 trials, but they may be Phase 2 trials if the design provides a well-controlled and reliable assessment of clinical benefit, particularly in an area of unmet medical need.
+Added: In December 2022, with the passage of Food and Drug Omnibus Reform Act, or FDORA, Congress began requiring sponsors to develop and submit a diversity action plan for each phase 3 clinical trial or any other “pivotal study” of a new drug or biological product.
+Added: These plans are meant to encourage the enrollment of more diverse patient populations in late-stage clinical trials of FDA-regulated products.
+Added: Specifically, actions plans must include the sponsor’s goals for enrollment, the underlying rationale for those goals, and an explanation of how the sponsor intends to meet them.
+Added: In addition to these requirements, the legislation directs the FDA to issue new guidance on diversity action plans.
In some cases, the FDA may approve an NDA or BLA for a product candidate but require the sponsor to conduct additional clinical trials to further assess the product candidate’s safety and effectiveness after approval.
1 unchanged sentence
These trials are used to gain additional experience from the treatment of a larger number of patients in the intended treatment group.
−Removed: In certain instances, the FDA may mandate the performance of Phase 4 clinical trials, such as to verify clinical benefit in the case of products approved under accelerated approval regulations.
+Added: In certain instances, the FDA may mandate the performance of Phase 4 clinical trials, such as to verify clinical
+Added: benefit in the case of products approved under accelerated approval regulations.
Failure to exhibit due diligence with regard to conducting mandatory Phase 4 clinical trials could result in withdrawal of FDA approval for products.
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and analyses and corresponding discussions that address the impact of implemented contingency measures (e.g., participant discontinuation from investigational product and/or study, alternative procedures used to collect critical safety and/or efficacy data) on the safety and efficacy results reported for the study, among other things.
−Removed: The FDA has indicated that it will continue to provide any necessary guidance to sponsors, clinical investigators, and research institutions as the public health emergency evolves.
+Added: On January 30, 2023, the Biden Administration announced that it will end the public health emergency declarations related to COVID-19 on May 11, 2023.
+Added: On January 31, 2023, the FDA indicated that it would soon issue a Federal Register notice describing how the termination of the public health emergency will impact the agency’s COVID-19 related guidance’s, including the clinical trial guidance and updates thereto.
+Added: At this point, it is unclear how, if at all, these developments will impact our efforts to develop and commercialize our product candidates.
Interactions with FDA During the Clinical Development Program
5 unchanged sentences
and any clinically important increase in the occurrence of a serious suspected adverse reaction over that listed in the protocol or investigator brochure.
−Removed: Phase 1, Phase 2 and Phase 3 clinical trials may not be completed successfully within any specified period, or
+Added: Phase 1, Phase 2 and Phase 3 clinical trials may not be completed successfully within any specified period, or at all.
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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Meetings at other times may also be requested.
−Removed: There are three types of meetings that occur between sponsors and the FDA.
+Added: There are four types of meetings that occur between sponsors and the FDA.
Type A meetings are those that are necessary for an otherwise stalled product development program to proceed or to address an important safety issue.
1 unchanged sentence
A Type C meeting is any meeting other than a Type A or Type B meeting regarding the development and review of a product, including for example meetings to facilitate early consultations on the use of a biomarker as a new surrogate endpoint that has never been previously used as the primary basis for product approval in the proposed context of use.
+Added: Finally, a Type D meeting is focused on a narrow set of issues, which should be limited to no more than two focused topics, and should not require input from more than three disciplines or Divisions.
These meetings provide an opportunity for the sponsor to share information about the data gathered to date with the FDA and for the FDA to provide advice on the next phase of development.
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Concurrently with clinical trials, sponsors usually complete additional animal safety studies, develop additional information about the chemistry and physical characteristics of the product candidate and finalize a process for manufacturing commercial quantities of the product candidate in accordance with cGMP requirements.
−Removed: The manufacturing process must be capable of consistently producing quality batches of the product candidate and, among other criteria, the sponsor must develop methods for testing the identity, strength, quality, and purity of the finished product.
+Added: manufacturing process must be capable of consistently producing quality batches of the product candidate and, among other criteria, the sponsor must develop methods for testing the identity, strength, quality, and purity of the finished product.
Additionally, appropriate packaging must be selected and tested and stability studies must be conducted to demonstrate that the product candidate does not undergo unacceptable deterioration over its shelf life.
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The FDA’s regulations also require, among other things, the investigation and correction of any deviations from cGMP and the imposition of reporting and documentation requirements upon the sponsor and any third-party manufacturers involved in producing the approved product.
+Added: The PREVENT Pandemics Act, which was enacted in December 2022, clarifies that foreign drug manufacturing establishments are subject to registration and listing requirements even if a drug or biologic undergoes further manufacture, preparation, propagation, compounding, or processing at a separate establishment outside the United States prior to being imported or offered for import into the United States.
Pediatric Studies
1 unchanged sentence
The sponsor must submit an initial Pediatric Study Plan, or PSP, within 60 days of an EOP2 meeting or as may be agreed between the sponsor and the FDA.
−Removed: Those plans must contain an outline of the
−Removed: proposed pediatric study or studies the applicant plans to conduct, including study objectives and design, age groups, relevant endpoints and statistical approach, or a justification for not including such detailed information, and any request for a deferral of pediatric assessments or a full or partial waiver of the requirement to provide data from pediatric studies along with supporting information.
+Added: Those plans must contain an outline of the proposed pediatric study or studies the sponsor plans to conduct, including study objectives and design, age groups, relevant endpoints and statistical approach, or a justification for not including such detailed information, and any request for a deferral of pediatric assessments or a full or partial waiver of the requirement to provide data from pediatric studies along with supporting information.
The sponsor and the FDA must reach agreement on a final plan.
A sponsor can submit amendments to an agreed-upon initial PSP at any time if changes to the pediatric plan need to be considered based on data collected from nonclinical studies, early phase clinical trials, and/or other clinical development programs.
−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.
+Added: The FDA may, on its own initiative or at the request of the sponsor, 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.
A deferral may be granted for several reasons, including a finding that the product or therapeutic candidate is ready for approval for use in adults before pediatric trials are complete or that additional safety or effectiveness data needs to be collected before the pediatric trials begin.
−Removed: The law now requires the FDA to send a PREA Non-Compliance letter to sponsors who have failed to submit their pediatric assessments required under PREA, have failed to seek or obtain a deferral or deferral extension or have failed to request approval for a required pediatric formulation.
+Added: Pursuant to the Food and Drug Administration Safety and Innovation Act of 2012, or FDASIA, the FDA must send a PREA Non-Compliance letter to sponsors who have failed to submit their pediatric assessments required under PREA, have failed to seek or obtain a deferral or deferral extension or have failed to request approval for a required pediatric formulation.
It further requires the FDA to publicly post the PREA Non-Compliance letter and sponsor’s response.
5 unchanged sentences
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.”
−Removed: Section 505(b)(2) thus authorizes the FDA to approve an NDA based on safety and effectiveness data that were not developed by the applicant.
+Added: This type of application allows the sponsor 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 sponsor for approval of the application “were not conducted by or for the sponsor and for which the sponsor has not obtained a right of reference or use from the person by or for whom the investigations were conducted.”
+Added: Section 505(b)(2) thus authorizes the FDA to approve an NDA based on safety and effectiveness data that were not developed by the sponsor.
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) sponsor can establish that reliance on the FDA’s previous approval is scientifically appropriate, the sponsor 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.
−Removed: The FDA may then approve the new drug candidate for all or some of the label indications for which the referenced product has been approved, as well as for any new indication sought by the Section 505(b)(2) applicant.
+Added: The FDA may then approve the new drug candidate for all or some of the label indications for which the referenced product has been approved, as well as for any new indication sought by the Section 505(b)(2) sponsor.
If we obtain favorable results in our clinical trials, we plan to submit NDAs for our product candidates under Section 505(b)(2).
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The fee required for the submission and review of an application under the Prescription Drug User Fee Act, or PDUFA, is substantial (for example, for FY2023 this application fee is approximately $3.25 million), and the sponsor of an approved application is also subject to an annual program fee, currently more than $394,000 per eligible prescription product.
−Removed: These fees are typically adjusted annually, and exemptions and waivers may be available
−Removed: under certain circumstances, such as where a waiver is necessary to protect the public health, where the fee would present a significant barrier to innovation, or where the applicant is a small business submitting its first human therapeutic application for review.
+Added: These fees are typically adjusted annually, and exemptions and waivers may be available under certain circumstances, such as where a waiver is necessary to protect the public health, where the fee would present a significant barrier to innovation, or where the sponsor is a small business submitting its first human therapeutic application for review.
The FDA conducts a preliminary review of all applications within 60 days of receipt and must inform the sponsor at that time or before whether an application is sufficiently complete to permit substantive review.
In pertinent part, FDA’s regulations state that an application “shall not be considered as filed until all pertinent information and data have been received” by the FDA.
−Removed: In the event that FDA determines that an application does not satisfy this standard, it will issue a Refuse to File, or RTF, determination to the applicant.
+Added: In the event that FDA determines that an application does not satisfy this standard, it will issue a Refuse to File, or RTF, determination to the sponsor.
Typically, an RTF will be based on administrative incompleteness, such as clear omission of information or sections of required information;
6 unchanged sentences
The FDA reviews the application to determine, among other things, whether the proposed product is safe and effective for its intended use, whether it has an acceptable purity profile and whether the product is being manufactured in accordance with cGMP.
−Removed: Under the goals and policies agreed to by the FDA under PDUFA, the FDA has ten months from the filing date in which to complete its initial review of a standard application that is a new molecular entity, and six months from the filing date for an application with “priority review.” The review process may be extended by the FDA for three additional months to consider new information or in the case of a clarification provided by the applicant to address an outstanding deficiency identified by the FDA following the original submission.
+Added: Under the goals and policies agreed to by the FDA under PDUFA, the FDA has ten months from the filing date in which to complete its initial review of a standard application that is a new molecular entity, and six months from
+Added: the filing date for an application with “priority review.” The review process may be extended by the FDA for three additional months to consider new information or in the case of a clarification provided by the sponsor to address an outstanding deficiency identified by the FDA following the original submission.
Despite these review goals, it is not uncommon for FDA review of an application to extend beyond the PDUFA target action date.
−Removed: In connection with its review of an application, the FDA will typically submit information requests to the applicant and set deadlines for responses thereto.
+Added: In connection with its review of an application, the FDA will typically submit information requests to the sponsor and set deadlines for responses thereto.
The FDA will also conduct a pre-approval inspection of the manufacturing facilities for the new product to determine whether the manufacturing processes and facilities comply with cGMPs.
1 unchanged sentence
The FDA also may inspect the sponsor and one or more clinical trial sites to assure compliance with IND and GCP requirements and the integrity of the clinical data submitted to the FDA.
−Removed: To ensure cGMP and GCP compliance by its employees and third-party contractors, an applicant may incur significant expenditure of time, money and effort in the areas of training, record keeping, production and quality control.
+Added: With passage of FDORA, Congress clarified FDA’s authority to conduct inspections by expressly permitting inspection of facilities involved in the preparation, conduct, or analysis of clinical and non-clinical studies submitted to FDA as well as other persons holding study records or involved in the study process.
+Added: To ensure cGMP and GCP compliance by its employees and third-party contractors, a sponsor may incur significant expenditure of time, money and effort in the areas of training, record keeping, production and quality control.
Additionally, the FDA may refer an application, including applications for novel product candidates which present difficult questions of safety or efficacy, to an advisory committee for review, evaluation and recommendation as to whether the application should be approved and under what conditions.
2 unchanged sentences
Data from clinical trials are not always conclusive, and the FDA or its advisory committee may interpret data differently than the sponsor interprets the same data.
−Removed: The FDA may also re-analyze the clinical trial data, which could result in extensive discussions between the FDA and the applicant during the review process.
+Added: The FDA may also re-analyze the clinical trial data, which could result in extensive discussions between the FDA and the sponsor during the review process.
The FDA also may require submission of a Risk Evaluation and Mitigation Strategy, or REMS, if it determines that a REMS is necessary to ensure that the benefits of the product outweigh its risks and to assure the safe use of the product.
3 unchanged sentences
Decisions on NDAs and BLAs
−Removed: The FDA reviews an applicant to determine, among other things, whether the product is safe and whether it is effective for its intended use(s), with the latter determination being made on the basis of substantial evidence.
+Added: The FDA reviews a sponsor to determine, among other things, whether the product is safe and whether it is effective for its intended use(s), with the latter determination being made on the basis of substantial evidence.
The term “substantial evidence” is defined under the FDCA as “evidence consisting of adequate and well-controlled investigations, including clinical investigations, by experts qualified by scientific training and experience to evaluate the effectiveness of the product involved, on the basis of which it could fairly and responsibly be concluded by such experts that the product will have the effect it purports or is represented to have under the conditions of use prescribed, recommended, or suggested in the labeling or proposed labeling thereof.”
2 unchanged sentences
This approach was subsequently endorsed by Congress in 1998 with legislation providing, in pertinent part, that “If FDA determines, based on relevant science, that data from one adequate and well-controlled clinical investigation and confirmatory evidence (obtained prior to or after such investigation) are sufficient to establish effectiveness, FDA may consider such data and evidence to constitute substantial evidence.” This modification to the law recognized the potential for FDA to find that one adequate and well controlled clinical investigation with confirmatory evidence, including supportive data outside of a controlled trial, is sufficient to establish effectiveness.
−Removed: In December 2019, FDA issued draft guidance further explaining the studies that are needed to establish substantial evidence of effectiveness.
+Added: In December 2019, FDA issued draft guidance further
+Added: explaining the studies that are needed to establish substantial evidence of effectiveness.
It has not yet finalized that guidance.
11 unchanged sentences
The CRL may require additional clinical or other data, additional pivotal Phase 3 clinical trial(s) and/or other significant and time- consuming requirements related to clinical trials, preclinical studies or manufacturing.
−Removed: If a CRL is issued, the applicant will have one year to respond to the deficiencies identified by the FDA, at which time the FDA can deem the application withdrawn or, in its discretion, grant the applicant an additional six-month extension to respond.
+Added: If a CRL is issued, the sponsor will have one year to respond to the deficiencies identified by the FDA, at which time the FDA can deem the application withdrawn or, in its discretion, grant the sponsor an additional six-month extension to respond.
The FDA has committed to reviewing resubmissions in response to an issued CRL in either two or six months depending on the type of information included.
1 unchanged sentence
The FDA has taken the position that a CRL is not final agency action making the determination subject to judicial review.
+Added: For those seeking to challenge FDA’s CRL decision, the FDA has indicated that sponsors may request a formal hearing on the CRL or file a request for reconsideration or a request for a formal dispute resolution.
An approval letter, on the other hand, authorizes commercial marketing of the product with specific prescribing information for specific indications.
18 unchanged sentences
All promotional materials for product candidates approved under accelerated regulations are subject to prior review by the FDA.
+Added: With passage of FDORA, Congress modified certain provisions governing accelerated approval of drug and biologic products.
+Added: Specifically, the new legislation authorized the FDA to:
+Added: require a sponsor to have its confirmatory clinical trial underway before accelerated approval is awarded, require a sponsor of a product granted accelerated approval to submit progress reports on its post-approval studies to FDA every six months until the study is completed;
+Added: and use expedited procedures to withdraw accelerated approval of an NDA or BLA after the confirmatory trial fails to verify the product’s clinical benefit.
+Added: Further, FDORA requires the FDA to publish on its website “the rationale for why a post-approval study is not appropriate or necessary” whenever it decides not to require such a study upon granting accelerated approval.
Post-Approval Regulation
7 unchanged sentences
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
−Removed: 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.
12 unchanged sentences
Products may be promoted only for the approved indications and in accordance with the provisions of the approved label.
−Removed: If a company is found to have promoted off-label uses, it may become subject to adverse public relations and administrative and judicial enforcement by the FDA, the Department of Justice, or the Office of the Inspector General of the Department of Health and Human Services, as well as state authorities.
+Added: If a company is found to have promoted off-label uses, it may become subject to adverse public relations and administrative and judicial enforcement by the FDA, the Department of Justice, or the Office of the Inspector General of the HHS, as well as state authorities.
This could subject a company to a range of penalties that could have a significant commercial impact, including civil and criminal fines and agreements that materially restrict the manner in which a company promotes or distributes drug products.
In September 2021, the FDA published final regulations which describe the types of evidence that the agency will consider in determining the intended use of a drug or biologic.
+Added: It may be permissible, under very specific, narrow conditions, for a manufacturer to engage in nonpromotional, non-misleading communication regarding off-label information, such as distributing scientific or medical journal information.
+Added: Moreover, with passage of the Pre-Approval Information Exchange Act, or PIE Act, in December 2022, sponsors of products that have not been approved may proactively communicate to payors certain information about products and product candidates in development to help expedite patient access upon product approval.
+Added: Previously, such communications were permitted under FDA guidance but the new legislation explicitly provides protection to sponsors who convey certain information about products and product candidates in development to payors, including unapproved uses of approved products.
In addition, the distribution of prescription pharmaceutical products is subject to a variety of federal and state laws, the most recent of which is still in the process of being phased into the U.S.
7 unchanged sentences
In 1984, with passage of the Hatch-Waxman Act, Congress established an abbreviated regulatory scheme authorizing the FDA to approve generic drugs that are shown to contain the same active ingredients as, and to be bioequivalent to, drugs previously approved by the FDA pursuant to NDAs and it also enacted Section 505(b)(2).
−Removed: To obtain approval of a generic drug, an applicant must submit an abbreviated new drug application, or ANDA, to the agency.
+Added: To obtain approval of a generic drug, a sponsor must submit an abbreviated new drug application, or ANDA, to the agency.
In support of such applications, a generic manufacturer may rely on the preclinical and clinical testing conducted for a drug product previously approved under an NDA, known as the reference listed drug, or RLD.
7 unchanged sentences
An active moiety is the molecule or ion responsible for the physiological or pharmacological action of the drug substance.
−Removed: In cases where such NCE exclusivity has been granted, a generic or follow-on drug application may not be filed with the FDA until the expiration of five years unless the submission is accompanied by a Paragraph IV certification, in which case the applicant may submit its application four years following the original product approval.
−Removed: The FDCA also provides for a period of three years of exclusivity if the NDA includes reports of one or more new clinical investigations, other than bioavailability or bioequivalence studies, that were conducted by or for the applicant and are essential to the approval of the application.
+Added: In cases where such NCE exclusivity has been granted, a generic or follow-on drug application may not be filed with the FDA until the expiration of five years unless the submission is accompanied by a Paragraph IV certification, in which case the sponsor may submit its application four years following the original product approval.
+Added: The FDCA also provides for a period of three years of exclusivity if the NDA includes reports of one or more new clinical investigations, other than bioavailability or bioequivalence studies, that were conducted by or for the sponsor and are essential to the approval of the application.
This three-year exclusivity period often protects changes to a previously approved drug product, such as new indications, dosage forms, route of administration or combination of ingredients.
3 unchanged sentences
Five-year and three-year exclusivity also will not delay the submission or approval of a traditional NDA filed under Section 505(b)(1) of the FDCA;
−Removed: however, an applicant submitting a traditional NDA would be required to conduct or obtain a right of reference to all of the preclinical studies and adequate and well-controlled clinical trials necessary to demonstrate safety and effectiveness.
−Removed: As part of the submission of an NDA or certain supplemental applications, 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: however, a sponsor submitting a traditional NDA would be required to conduct or obtain a right of reference to all of the preclinical studies and adequate and well-controlled clinical trials necessary to demonstrate safety and effectiveness.
+Added: As part of the submission of an NDA or certain supplemental applications, NDA sponsors are required to list with the FDA each patent with claims that cover the sponsor’s product or an approved method of using the product.
Upon approval of a new drug, each of the patents listed in the application for the drug is then published in the Orange Book.
The FDA’s regulations governing patient listings were largely codified into law with enactment of the Orange Book Modernization Act in January 2021.
−Removed: When an ANDA applicant files its application with the FDA, the applicant is required to certify to the FDA concerning any patents listed for the reference product in the Orange Book.
−Removed: Specifically, the ANDA applicant must certify that:
+Added: When an ANDA sponsor files its application with the FDA, the sponsor is required to certify to the FDA concerning any patents listed for the reference product in the Orange Book.
+Added: Specifically, the ANDA sponsor must certify that:
(i) the required patent information has not been filed;
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or (iv) the listed patent is invalid or will not be infringed by the new product.
−Removed: Moreover, to the extent that the Section 505(b)(2) NDA applicant is relying on studies conducted for an already approved product, the applicant also is required to certify to the FDA concerning any patents listed for the NDA-approved product in the Orange Book to the same extent that an ANDA applicant would.
−Removed: If the generic drug or follow-on drug applicant does not challenge the innovator’s listed patents, FDA will not approve the ANDA or 505(b)(2) application until all the listed patents claiming the referenced product have expired.
+Added: Moreover, to the extent that the Section 505(b)(2) NDA sponsor is relying on studies conducted for an already approved product, the sponsor also is required to certify to the FDA concerning any patents listed for the NDA-approved product in the Orange Book to the same extent that an ANDA sponsor would.
+Added: If the generic drug or follow-on drug sponsor does not challenge the innovator’s listed patents, FDA will not approve the ANDA or 505(b)(2) application until all the listed patents claiming the referenced product have expired.
A certification that the new generic 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.
−Removed: If the ANDA applicant has provided a Paragraph IV certification to the FDA, the applicant must also send notice of the Paragraph IV certification to the NDA owner and patent holders once the ANDA has been accepted for filing by the FDA.
−Removed: The NDA owner and patent holders may then initiate a patent infringement lawsuit in response to the notice of the Paragraph IV certification.
−Removed: The filing of a patent infringement lawsuit within 45 days after the receipt of a Paragraph IV certification automatically prevents the FDA from approving the ANDA or 505(b)(2) NDA until the earliest of 30 months after the receipt of the Paragraph IV
−Removed: notice, expiration of the patent and a decision in the infringement case that is favorable to the ANDA or 505(b)(2) NDA applicant.
+Added: If the ANDA sponsor has provided a Paragraph IV certification to the FDA, the sponsor must also send notice of the Paragraph IV certification to the NDA owner and patent holders once the ANDA has been accepted for filing by the FDA.
+Added: The NDA owner and patent holders
+Added: may then initiate a patent infringement lawsuit in response to the notice of the Paragraph IV certification.
+Added: The filing of a patent infringement lawsuit within 45 days after the receipt of a Paragraph IV certification automatically prevents the FDA from approving the ANDA or 505(b)(2) NDA until the earliest of 30 months after the receipt of the Paragraph IV notice, expiration of the patent and a decision in the infringement case that is favorable to the ANDA or 505(b)(2) NDA sponsor.
Regulatory Exclusivity Governing Biologics
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Under the BPCIA, a manufacturer may submit an application for a product that is “biosimilar to” a previously approved biological product, which the statute refers to as a “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 the proposed biosimilar product in terms of safety, purity and potency.
−Removed: The biosimilar applicant may demonstrate that its product is biosimilar to the reference product on the basis of data from analytical studies, animal studies and one or more clinical studies to demonstrate safety, purity and potency in one or more appropriate conditions of use for which the reference product is approved.
−Removed: In addition, the applicant must show that the biosimilar and reference products have the same mechanism of action for the conditions of use on the label, route of administration, dosage and strength, and the production facility must meet standards designed to assure product safety, purity and potency.
+Added: The biosimilar sponsor may demonstrate that its product is biosimilar to the reference product on the basis of data from analytical studies, animal studies and one or more clinical studies to demonstrate safety, purity and potency in one or more appropriate conditions of use for which the reference product is approved.
+Added: In addition, the sponsor must show that the biosimilar and reference products have the same mechanism of action for the conditions of use on the label, route of administration, dosage and strength, and the production facility must meet standards designed to assure product safety, purity and potency.
For the FDA to approve a biosimilar product as interchangeable with a reference product, the agency must find not only that the product is biosimilar to the reference product but also that it can be expected to produce the same clinical results as the reference product such that the two products may be switched without increasing safety risks or risks of diminished efficacy relative to exclusive use of the reference biologic.
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Following approval of the interchangeable biosimilar product, the FDA may not grant interchangeability status for any second biosimilar until one year after the first commercial marketing of the first interchangeable biosimilar product.
+Added: In December 2022, Congress clarified through FDORA that FDA may approve multiple first interchangeable biosimilar biological products so long as the products are all approved on the first day on which such a product is approved as interchangeable with the reference product.
A reference biological product is granted 12 years of exclusivity from the time of first licensure of the product, and the FDA will not accept an application for a biosimilar or interchangeable product based on the reference biological product until four years after the date of first licensure of the reference product.
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For drug products, the six-month exclusivity may be attached to the term of any existing patent or regulatory exclusivity, including the orphan exclusivity and regulatory exclusivities available under the Hatch-Waxman Act.
−Removed: For biologic products, the six month period may be attached to any existing regulatory exclusivities but not to any patent terms.
−Removed: The conditions for pediatric exclusivity include the FDA’s determination that information relating to the use of a new product in the pediatric population may produce health benefits in that population, the FDA making a written request for pediatric clinical trials, and the applicant agreeing to perform, and reporting on, the requested clinical trials within the statutory timeframe.
+Added: For biologic products, the six month period may be attached to any existing
+Added: regulatory exclusivities but not to any patent terms.
+Added: The conditions for pediatric exclusivity include the FDA’s determination that information relating to the use of a new product in the pediatric population may produce health benefits in that population, the FDA making a written request for pediatric clinical trials, and the sponsor agreeing to perform, and reporting on, the requested clinical trials within the statutory timeframe.
This six-month exclusivity may be granted if an NDA sponsor submits pediatric data that fairly respond to a written request from the FDA for such data.
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Although this is not a patent term extension, it effectively extends the regulatory period during which the FDA cannot approve another application.
−Removed: With regard to patents, the six-month pediatric exclusivity period will not attach to any patents for which an ANDA or 505(b)(2) applicant submitted a paragraph IV patent certification, unless the NDA sponsor or patent owner first obtains a court determination that the patent is valid and infringed by the proposed product.
+Added: With regard to patents, the six-month pediatric exclusivity period will not attach to any patents for which an ANDA or 505(b)(2) sponsor submitted a paragraph IV patent certification, unless the NDA sponsor or patent owner first obtains a court determination that the patent is valid and infringed by the proposed product.
Patent Term Restoration and Extension
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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’ 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
+Added: 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.
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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.
−Removed: The FDA has issued guidance documents meant to expedite review of a 510(k) and facilitate interactions between applicants and the agency.
+Added: The FDA has issued guidance documents meant to expedite review of a 510(k) and facilitate interactions between the sponsor and the FDA.
To demonstrate substantial equivalence, a manufacturer must show that the device has the same intended use as a predicate device and the same technological characteristics, or the same intended use and different technological characteristics and does not raise new questions of safety and effectiveness than the predicate device.
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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: If the FDA disagrees with the manufacturer’s determination and requires new 510(k) clearances or PMA application approvals for modifications to previously cleared
+Added: 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.
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An IDE application must be supported by appropriate data, such as animal and laboratory testing results, showing that it is safe to test the device in humans and that the testing protocol is scientifically sound.
−Removed: An IDE application is considered approved 30 days after it has been received by the FDA, unless the FDA otherwise informs the sponsor prior to 30 calendar days from the date of receipt, that the IDE is approved, approved with conditions, or disapproved.
+Added: An IDE application is
+Added: considered approved 30 days after it has been received by the FDA, unless the FDA otherwise informs the sponsor prior to 30 calendar days from the date of receipt, that the IDE is approved, approved with conditions, or disapproved.
The FDA typically grants IDE approval for a specified number of subjects to be enrolled at specified study centers.
The clinical trial must be conducted in accordance with applicable regulations, including but not limited to the FDA’s IDE regulations and GCP.
−Removed: The investigators must obtain subject informed consent, rigorously follow the investigational plan
−Removed: and study protocol, control the disposition of investigational devices, and comply with all reporting and record keeping requirements.
+Added: 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.
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HIPAA also imposes certain obligations on the business associates of covered entities that obtain protected health information in providing services to or on behalf of covered entities.
−Removed: HIPAA may apply to us in certain circumstances and may also apply to our business partners in ways that may impact our relationships with them.
+Added: HIPAA may apply to us in certain
+Added: circumstances and may also apply to our business partners in ways that may impact our relationships with them.
Our clinical trials are regulated by the Common Rule, which also includes specific privacy-related provisions.
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In addition to possible federal civil and criminal penalties for HIPAA violations, state attorneys general are authorized to file civil actions for damages or injunctions in federal courts to enforce HIPAA and seek attorney’s fees and costs associated with pursuing federal civil actions.
−Removed: In addition, state attorneys general
−Removed: (along with private plaintiffs) have brought civil actions seeking injunctions and damages resulting from alleged violations of HIPAA’s privacy and security rules.
+Added: In addition, state attorneys general (along with private plaintiffs) have brought civil actions seeking injunctions and damages resulting from alleged violations of HIPAA’s privacy and security rules.
State attorneys general also have authority to enforce state privacy and security laws.
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The CCPA went into effect on January 1, 2020 and requires covered companies to provide new disclosures to California consumers, provide such consumers new ways to opt-out of certain sales of personal information, and allow for a new cause of action for data breaches.
−Removed: Additionally, effective starting on January 1, 2023, the California Privacy Rights Act, or CPRA, will significantly modify the CCPA, including by expanding consumers’ rights with respect to certain sensitive personal information.
−Removed: The CPRA also creates a new state agency that will be vested with authority to implement and enforce the CCPA and the CPRA.
−Removed: The CCPA and CPRA could impact our business activities depending on how it is interpreted and exemplifies the vulnerability of our business to not only cyber threats but also the evolving regulatory environment related to personal data and individually identifiable health information.
−Removed: These provisions may apply to some of our business activities.
−Removed: In addition, other states, including Virginia and Colorado, already have passed state privacy laws and other states will likely be considering similar laws in the near future.
+Added: In November 2020, California voters passed a ballot initiative for the California Privacy Rights Act, or the CPRA, which went into effect on January 1, 2023, and significantly expanded the CCPA to incorporate additional GDPR-like provisions including requiring that the use, retention, and sharing of personal information of California residents be reasonably necessary and proportionate to the purposes of collection or processing, granting additional protections for sensitive personal information, and requiring greater disclosures related to notice to residents regarding retention of information.
+Added: The CPRA also created a new enforcement agency – the California Privacy Protection Agency – whose sole responsibility is to enforce the CPRA, which will further increase compliance risk.
+Added: The provisions in the CPRA may apply to some of our business activities.
+Added: In addition, other states, including Virginia, Colorado, Utah, and Connecticut, already have passed state privacy laws.
+Added: Virginia’s privacy law also went into effect on January 1, 2023, and the laws in the other three states will go into effect later in the year.
+Added: Other states will be considering these laws in the future, and Congress has also been debating passing a federal privacy law.
+Added: These laws may impact our business activities, including our identification of research subjects, relationships with business partners and ultimately the marketing and distribution of our products.
Because of the breadth of these laws and the narrowness of the statutory exceptions and regulatory safe harbors available under such laws, it is possible that some of our current or future business activities, including certain clinical research, sales and marketing practices and the provision of certain items and services to our customers, could be subject to challenge under one or more of such privacy and data security laws.
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Clinical Trial Approval
−Removed: Pursuant to the European Clinical Trials Directive, a system for the approval of clinical trials in the European Union has been implemented through national legislation of the member states.
−Removed: Under this system, an applicant must obtain approval from the competent national authority of a European Union member state in which the clinical trial is to be conducted.
−Removed: Furthermore, the applicant may only start a clinical trial after a competent ethics committee has issued a favorable opinion.
−Removed: 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 new Clinical Trials Regulation, (EU) No 536/2014, or the Clinical Trials Regulation, was adopted.
−Removed: The Clinical Trials Regulation aims to simplify and streamline the approval of clinical trials in the European Union.
−Removed: The main characteristics of the regulation include:
−Removed: a streamlined application procedure via a single entry point, the “EU portal”;
−Removed: a single set of documents to be prepared and submitted for the application as well as simplified reporting procedures for clinical trial sponsors;
−Removed: and a harmonized procedure for the assessment of applications for clinical trials, which is divided in two parts.
−Removed: Part I is assessed by the competent authorities of all European Union Member States in which an application for authorization of a clinical trial has been submitted (Member States concerned).
+Added: On January 31, 2022, the new Clinical Trials Regulation (EU) No 536/2014 became effective in the European Union and replaced the prior Clinical Trials Directive 2001/20/EC.
+Added: The new regulation aims at simplifying and streamlining the authorization, conduct and transparency of clinical trials in the European Union.
+Added: Under the new coordinated procedure for the approval of clinical trials, the sponsor of a clinical trial to be conducted in more than one Member State of the European Union, or EU Member State, will only be required to submit a single application for approval.
+Added: The submission will be made through the Clinical Trials Information System, a new clinical trials portal overseen by the EMA and available to clinical trial sponsors, competent authorities of the EU Member States and the public.
+Added: Beyond streamlining the process, the new Regulation includes a single set of documents to be prepared and submitted for the application as well as simplified reporting procedures for clinical trial sponsors, and a harmonized procedure for the assessment of applications for clinical trials, which is divided in two parts.
+Added: Part I is assessed by the competent authorities of all EU Member States in which an application for authorization of a clinical trial has been submitted (Member States concerned).
Part II is assessed separately by each Member State concerned.
Strict deadlines have been established for the assessment of clinical trial applications.
−Removed: The role of the relevant ethics committees in the assessment procedure will continue to be governed by the national law of the concerned European Union Member State.
+Added: The role of the relevant ethics committees in the assessment procedure will continue to be governed by the national law of the concerned EU Member State.
However, overall related timelines will be defined by the Clinical Trials Regulation.
−Removed: The new Regulation came into application on January 31, 2022, following confirmation of full functionality of the Clinical Trials Information System through an independent audit by the European Commission in mid-2020.
−Removed: The Clinical Trials Regulation repealed the prior Clinical Trials Directive 2001/20/EC.
−Removed: According to the transitional provisions, if a clinical trial initiated prior to the effectiveness of the new Regulation continues for more than three years from the day on which the Clinical Trials Regulation becomes applicable, the Clinical Trials Regulation will at that time begin to apply to the clinical trial.
+Added: The new regulation did not change the preexisting requirement that a sponsor must obtain prior approval from the competent national authority of the EU Member State in which the clinical trial is to be conducted.
+Added: If the clinical trial is conducted in different EU Member States, the competent authorities in each of these EU Member States must provide their approval for the conduct of the clinical trial.
+Added: Furthermore, the sponsor may only start a clinical trial at a specific clinical site after the applicable ethics committee has issued a favorable opinion.
Parties conducting certain clinical trials must, as in the United States, post clinical trial information in the European Union at the EudraCT website:
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Marketing Authorization
−Removed: To obtain marketing approval of a drug under European Union regulatory systems, an applicant must submit a marketing authorization application, or MAA, either under a centralized or decentralized procedure.
+Added: To obtain marketing approval of a drug under European Union regulatory systems, a sponsor must submit a marketing authorization application, or MAA, either under a centralized or decentralized procedure.
The centralized procedure provides for the grant of a single marketing authorization by the European Commission that is valid for all European Union member states.
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The CHMP is also responsible for several post-authorization and maintenance activities, such as the assessment of modifications or extensions to an existing marketing authorization.
−Removed: Under the centralized procedure in the European Union, the maximum timeframe for the evaluation of an MAA is 210 days, excluding clock stops, when additional information or written or oral explanation is to be provided by the applicant in response to questions of the CHMP.
+Added: Under the centralized procedure in the European Union, the maximum timeframe for the evaluation of an MAA is 210 days, excluding clock stops, when additional information or written or oral explanation is to be provided by the sponsor in response to questions of the CHMP.
Accelerated evaluation might be granted by the CHMP in exceptional cases, when a medicinal product is of major interest from the point of view of public health and in particular from the viewpoint of therapeutic innovation.
In this circumstance, the EMA ensures that the opinion of the CHMP is given within 150 days.
−Removed: The decentralized procedure is available to applicants who wish to market a product in various European Union member states where such product has not received marketing approval in any European Union member states before.
−Removed: The decentralized procedure provides for approval by one or more other, or concerned, member states of an assessment of an application performed by one member state designated by the applicant, known as the reference member state.
−Removed: Under this procedure, an applicant submits an application based on identical dossiers and related materials, including a draft summary of product characteristics, and draft labeling and package leaflet, to the reference member state and concerned member states.
−Removed: The reference member state prepares a draft assessment report and drafts of the related materials within 210 days after receipt of a valid application.
+Added: The decentralized procedure is available to sponsors who wish to market a product in various European Union member states where such product has not received marketing approval in any European Union member states before.
+Added: The decentralized procedure provides for approval by one or more other, or concerned, member states of an assessment of an application performed by one member state designated by the sponsor, known as the reference member state.
+Added: Under this procedure, a sponsor submits an application based on identical dossiers and related materials, including a draft summary of product characteristics, and draft labeling and package leaflet, to the reference member state and concerned member states.
+Added: The reference member state prepares a draft assessment report and drafts of the related
+Added: materials within 210 days after receipt of a valid application.
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.
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Conditional Approval
−Removed: In particular circumstances, European Union legislation (Article 14–a Regulation (EC) No 726/2004 (as amended by Regulation (EU) 2019/5 and Regulation (EC) No 507/2006 on Conditional Marketing Authorizations for Medicinal Products for Human Use) enables applicants to obtain a conditional marketing authorization prior to obtaining the comprehensive clinical data required for an application for a full marketing authorization.
+Added: In particular circumstances, European Union legislation (Article 14–a Regulation (EC) No 726/2004 (as amended by Regulation (EU) 2019/5 and Regulation (EC) No 507/2006 on Conditional Marketing Authorizations for Medicinal Products for Human Use) enables sponsors to obtain a conditional marketing authorization prior to obtaining the comprehensive clinical data required for an application for a full marketing authorization.
Such conditional approvals may be granted for product candidates (including medicines designated as orphan medicinal products) if (1) the product candidate is intended for the treatment, prevention or medical diagnosis of seriously debilitating or life-threatening diseases;
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(3) a marketing authorization may be granted prior to submission of comprehensive clinical data provided that the benefit of the immediate availability on the market of the medicinal product concerned outweighs the risk inherent in the fact that additional data are still required;
−Removed: (4) the risk-benefit balance of the product candidate is positive, and (5) it is likely that the applicant will be in a position to provide the required comprehensive clinical trial data.
+Added: (4) the risk-benefit balance of the product candidate is positive, and (5) it is likely that the sponsor will be in a position to provide the required comprehensive clinical trial data.
A conditional marketing authorization may contain specific obligations to be fulfilled by the marketing authorization holder, including obligations with respect to the completion of ongoing or new studies and with respect to the collection of pharmacovigilance data.
Conditional marketing authorizations are valid for one year, and may be renewed annually, if the risk-benefit balance remains positive, and after an assessment of the need for additional or modified conditions or specific obligations.
−Removed: The timelines for the centralized procedure described above also apply with respect to the review by the CHMP of applications for a conditional marketing authorization.
+Added: The timelines for the centralized procedure described above also apply with respect to the review by the CHMP of applications for a conditional marketing authorization, but applicants can also request EMA to conduct an accelerated assessment, for instance in cases of unmet medical needs.
Periods of Authorization and Renewals
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● 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 European Union 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.
−Removed: These requirements include compliance with European Union cGMP standards when manufacturing medicinal products and active pharmaceutical ingredients, including the manufacture of active pharmaceutical ingredients outside of the European Union with the intention to import the active pharmaceutical ingredients into the European Union.
+Added: These requirements include compliance with European Union cGMP standards when manufacturing medicinal products and active pharmaceutical
+Added: ingredients, including the manufacture of active pharmaceutical ingredients outside of the European Union with the intention to import the active pharmaceutical ingredients into the European Union.
● The marketing and promotion of authorized drugs, including industry-sponsored continuing medical education and advertising directed toward the prescribers of drugs and/or the general public, are strictly regulated in the European Union notably under Directive 2001/83EC, as amended, and European Union Member State laws.
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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.
+Added: Data exclusivity prevents sponsors 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.
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 European Union market until the expiration of the market exclusivity.
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Pediatric Exclusivity
−Removed: If an applicant obtains a marketing authorization in all European Union Member States, or a marketing authorization granted in the centralized procedure by the European Commission, and the study results for the pediatric population are included in the product information, even when negative, the medicine is then eligible for an additional six-month period of qualifying patent protection through extension of the term of the Supplementary Protection Certificate, or SPC, or alternatively a one year extension of the regulatory market exclusivity from ten to eleven years, as selected by the marketing authorization holder.
+Added: If a sponsor obtains a marketing authorization in all European Union Member States, or a marketing authorization granted in the centralized procedure by the European Commission, and the study results for the pediatric population are included in the product information, even when negative, the medicine is then eligible for an additional six-month period of qualifying patent protection through extension of the term of the Supplementary Protection Certificate, or SPC, or alternatively a one year extension of the regulatory market exclusivity from ten to eleven years, as selected by the marketing authorization holder.
Patent Term Extensions
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In the European Union, manufacturers must comply with the European Union Medical Device Vigilance System.
−Removed: Under this system, incidents must be reported to the relevant authorities of the
−Removed: European Union countries, and manufacturers are required to take Field Safety Corrective Actions, or FSCAs, to reduce a risk of death or serious deterioration in the state of health associated with the use of a medical device that is already placed on the market.
+Added: Under this system, incidents must be reported to the relevant authorities of the European Union countries, and manufacturers are required to take Field Safety Corrective Actions, or FSCAs, to reduce a risk of death or serious deterioration in the state of health associated with the use of a medical device that is already placed on the market.
An incident is defined as any malfunction or deterioration in the characteristics and/or performance of a device, as well as any inadequacy in the labeling or the instructions for use which, directly or indirectly, might lead to or might have led to the death of a patient or user or of other persons or to a serious deterioration in their state of health.
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is no longer part of the single market.
−Removed: As of January 1, 2021, the Medicines and Healthcare products Regulatory Agency, or the MHRA, became responsible for supervising medicines and medical devices in Great Britain, comprising England, Scotland and Wales under domestic law whereas Northern Ireland continues to be subject to European Union rules under the Northern Ireland Protocol.
+Added: As of January 1, 2021, the Medicines
+Added: and Healthcare products Regulatory Agency, or the MHRA, became responsible for supervising medicines and medical devices in Great Britain, comprising England, Scotland and Wales under domestic law whereas Northern Ireland continues to be subject to European Union rules under the Northern Ireland Protocol.
The MHRA will rely on the Human Medicines Regulations 2012 (SI 2012/1916) (as amended), or the HMR, as the basis for regulating medicines.
The HMR has incorporated into the domestic law the body of European Union law instruments governing medicinal products that pre-existed prior to the U.K.’s withdrawal from the European Union.
+Added: The MHRA may rely on a decision taken by the European Commission on the approval of a new marketing authorization via the centralized procedure until December 31, 2023.
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.
−Removed: 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
−Removed: processing and transfers of personal data for four months from January 1, 2021.
+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.
This may be extended by two further months.
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and includes parallel obligations to those set forth by GDPR.
+Added: Additionally, in October 2022, President Biden signed an executive order to implement the EU-U.S.
+Added: Data Privacy Framework, which would serve as a replacement to the EU-U.S.
+Added: Privacy Shield.
+Added: The EC initiated the process to adopt an adequacy decision for the EU-U.S.
+Added: Data Privacy Framework in December 2022.
+Added: It is unclear if and when the framework will be finalized and whether it will be challenged in court.
+Added: The uncertainty around this issue may further impact our business operations in the EU.
Pharmaceutical Coverage, Pricing and Reimbursement
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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” 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, or OPPS, 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: DEXTENZA is scheduled to lose transitional pass-through status in July 2022.
−Removed: In November 2021, CMS, in its annual rulemaking, has indicated that DEXTENZA will be paid separately in the ASC and HOPD settings through 2022 despite its scheduled loss of pass-through status.
−Removed: CMS also indicated that DEXTENZA is eligible for separate payment in the ASC setting beyond 2022 because it meets the criteria set forth for non-opioid pain management drugs as a surgical supply provision.
−Removed: In addition, CMS, during the same rulemaking cycle, made a final recommendation on the fixed reimbursement amount for the procedure of inserting DEXTENZA, a Category I Current Procedural Terminology, or CPT, code 68841 to replace DEXTENZA’s current Category III CPT code 0365T, effective January 1, 2022.
−Removed: The physician fee for the insertion of DEXTENZA into the canaliculus will be $31.58 in the ASCs and HOPDs and $37.29 in the physician’s office for unilateral insertion as of January 1, 2022 under the new Category I code.
−Removed: Additionally, although CMS established these reimbursement amounts for 2022, CMS will review such determination as part of its annual rulemaking cycle.
−Removed: A specific and permanent J-Code for ophthalmic inserts containing dexamethasone including DEXTENZA is 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 generally allow for a simpler and more convenient reimbursement process.
−Removed: Separately, a CPT procedure code has been established for the administration of drug-eluting intracanalicular inserts to facilitate reimbursement for physicians for the procedure of inserting DEXTENZA into the canaliculus.
−Removed: We expect pricing for DEXTENZA while in pass-through payment status to be approximately $555 per insert.
+Added: J-Codes are part of the Healthcare Common Procedure Coding System (HCPCS) Level II set of procedure codes.
+Added: These codes are used by CMS and other managed care organizations to identify drugs that ordinarily cannot be self-administered by a patient.
+Added: Lacrimal ophthalmic inserts containing dexamethasone, such as DEXTENZA, have a specific and permanent J-Code, J1096, that allows for a simpler and more convenient reimbursement process versus miscellaneous J-codes.
+Added: Since its launch, DEXTENZA has been payable in ASCs and HOPDs separately from ophthalmic surgery via the transitional pass-through status under the J1096 J-Code.
+Added: However, the pass-through status for J1096 ended on December 31, 2022.
+Added: In November 2022, as part of the annual CMS rule-making cycle, the CY 2023 OPPS rule was finalized and provided that DEXTENZA would qualify under the criteria established for non-opioid pain management drugs as a surgical supply provision.
+Added: This provision allows for continued separate payment of DEXTENZA in the ASC setting for 2023 but does not require separate payment for DEXTENZA in the HOPD setting.
+Added: CPT codes are part of the HCPCS Level I set of procedure codes which consists of codes that are used to report medical services and procedures furnished by physicians.
+Added: These codes are also used by CMS and other managed care organizations.
+Added: Drug-eluting intracanalicular inserts, such as DEXTENZA, have a procedure-specific and permanent Category 1 CPT code, 68841, used to facilitate reimbursement for the administration of inserts into the canaliculus.
+Added: In 2022, the Medicare Physician Fee Schedule, or MPFS, for the insertion of DEXTENZA into the canaliculus was $31.58 in the ASCs and $37.29 in the physician’s office for unilateral insertion.
+Added: In November 2022, the CY 2023 MPFS rule was finalized resulting in a marginal increase in physician payments over 2022 to $32.53 in the ASCs and $38.29 in the physician’s office for unilateral insertion.
In the European Union, pricing and reimbursement schemes vary widely from country to country.
Some countries provide that drug products may be marketed only after a reimbursement price has been agreed.
−Removed: Some countries may require the completion of additional studies that compare the cost-effectiveness of a particular product candidate to currently available therapies.
+Added: Some countries may require the completion of additional studies that compare the cost-effectiveness of a particular product candidate to
+Added: currently available therapies.
For example, the European Union provides options for its member states to restrict the range of drug products for which their national health insurance systems provide reimbursement and to control the prices of medicinal products for human use.
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officials for the purpose of obtaining or retaining business or otherwise seeking favorable treatment;
−Removed: ● the federal transparency requirements under the ACA, known as the federal Physician Payments Sunshine Act, will require certain manufacturers of drugs, devices, biologics and medical supplies to report to CMS within the Department of Health and Human Services information related to payments and other transfers of value to physicians, other healthcare providers and teaching hospitals and physician ownership and investment interests held by physicians, other healthcare providers and their immediate family members;
+Added: ● the federal transparency requirements under the ACA, known as the federal Physician Payments Sunshine Act, will require certain manufacturers of drugs, devices, biologics and medical supplies to report to CMS within the HHS information related to payments and other transfers of value to physicians, other healthcare providers and teaching hospitals and physician ownership and investment interests held by physicians and their immediate family members;
● 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.
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In August 2011, the Budget Control Act of 2011, among other things, created measures for spending reductions by Congress.
−Removed: A Joint Select
−Removed: 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: 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.
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 2031.
−Removed: Pursuant to the Coronavirus Aid, Relief and Economic Security Act, or CARES Act, and subsequent legislation, these Medicare sequester reductions have been suspended through the end of March 2022.
−Removed: From April 2022 through June 2022 a 1% sequester cut will be in effect, with the full 2% cut resuming thereafter.
+Added: Pursuant to the Coronavirus Aid, Relief and Economic Security Act, or CARES Act, and subsequent legislation, these Medicare sequester reductions have been suspended and reduced through the end of June 2022, with the full 2% cut resuming thereafter.
+Added: Under current legislation, the actual reductions in Medicare payments may vary up to 4%.
Since enactment of the PPACA, there have been, and continue to be, numerous legal challenges and Congressional actions to repeal and replace provisions of the law.
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Further, on November 20, 2020, HHS finalized a regulation removing safe harbor protection for price reductions from pharmaceutical manufacturers to plan sponsors under Part D, either directly or through pharmacy benefit managers, unless the price reduction is required by law.
−Removed: The implementation of the rule has been delayed by the Biden administration from January 1, 2022 to January 1, 2023 in response to ongoing litigation.
−Removed: The rule also creates a new safe harbor for price reductions reflected at the point-of-sale, as well as a new safe
−Removed: harbor for certain fixed fee arrangements between pharmacy benefit managers and manufacturers, the implementation of which have also been delayed by the Biden administration until January 1, 2023.
+Added: The final rule would eliminate the current safe harbor for Medicare drug rebates and create new safe harbors for beneficiary point-of-sale discounts and pharmacy benefit manager, or PBM, service fees.
+Added: It originally was set to go into effect on January 1, 2022, but with passage of the Inflation Reduction Act, or IRA, has been delayed by Congress to January 1, 2032.
On July 9, 2021, President Biden signed Executive Order 14063, which focuses on, among other things, the price of pharmaceuticals.
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and (c) foster scientific innovation to promote better healthcare and improve health by supporting public and private research and making sure that market incentives promote discovery of valuable and accessible new treatments.
+Added: More recently, on August 16, 2022, the IRA was signed into law by President Biden.
+Added: The new legislation has implications for Medicare Part D, which is a program available to individuals who are entitled to Medicare Part A or enrolled in Medicare Part B to give them the option of paying a monthly premium for outpatient prescription drug coverage.
+Added: Among other things, the IRA requires manufacturers of certain drugs to engage in price negotiations with Medicare (beginning in 2026), with prices that can be negotiated subject to a cap;
+Added: imposes rebates under Medicare Part B and Medicare Part D to penalize price increases that outpace inflation (first due in 2023);
+Added: and replaces the Part D coverage gap discount program with a new discounting program (beginning in 2025).
+Added: The IRA permits the Secretary of the HHS to implement many of these provisions through guidance, as opposed to regulation, for the initial years.
+Added: Specifically, with respect to price negotiations, Congress authorized Medicare to negotiate lower prices for certain costly single-source drug and biologic products that do not have competing generics or biosimilars and are reimbursed under Medicare Part B and Part D.
+Added: CMS may negotiate prices for ten high-cost drugs paid for by Medicare Part D starting in 2026, followed by 15 Part D drugs in 2027, 15 Part B or Part D drugs in 2028, and 20 Part B or Part D drugs in 2029 and beyond.
+Added: This provision applies to drug products that have been approved for at least 9 years and biologics that have been licensed for 13 years, but it does not apply to drugs and biologics that have been approved for a single rare disease or condition.
+Added: Further, the legislation subjects drug manufacturers to civil monetary penalties and a potential excise tax for failing to comply with the legislation by offering a price that is not equal to or less than the negotiated “maximum fair price” under the law or for taking price increases that exceed inflation.
+Added: The legislation also requires manufacturers to pay rebates for drugs in Medicare Part D whose price increases exceed inflation.
+Added: The new law also caps
+Added: Medicare out-of-pocket drug costs at an estimated $4,000 a year in 2024 and, thereafter beginning in 2025, at $2,000 a year.
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.
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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.
−Removed: As of December 31, 2021, our workforce was composed of 47% female and 53% male, and 39% of the workforce was non-white.
+Added: As of December 31, 2022, our workforce was composed of approximately 47% female and 53% male, and approximately 18% of the workforce was non-white.
The development, attraction and retention of employees is a critical success factor for us for the execution of our business strategy and succession planning.
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We leverage both formal and informal programs to identify, foster, and retain top talent at both the corporate and operating unit level.
−Removed: We provide employee wages and benefits that are competitive and consistent with the employee positions, skill levels, experience, knowledge and geographic location.
+Added: We provide employee wages and benefits that we believe 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.
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We value the health, safety and wellbeing of our employees and their families.
−Removed: 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.
−Removed: 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.
+Added: As an example, in response to the COVID-19 pandemic, we implemented significant changes that we determined were in the best interest of our employees, which included allowing a number of our corporate employees to work remotely, as appropriate.
Our Corporate Information
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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.