Study lengthAcceptedBeyond the letter
No 3-month monkey study; exposure could not be maintained with repeated dosing
Why: Exposure could not be maintained with repeated dosing; longer studies would not provide meaningful information · Pharmacology or kinetics
“A 3-month repeat-dose toxicity study of epcoritamab in cynomolgus monkeys was waived for phase 3 trials and registration of epcoritamab across the ICH regions (FDA, EMEA, and PMDA) based on the inability to maintain sufficient exposures to epcoritamab with repeated dosing.”
✓ VerifiedFDA multi-discipline review, p. 53Source ↗ “We also agree that longer-duration repeat-dose toxicity studies in cynomolgus monkeys would not provide meaningful information and are not warranted.”
✓ VerifiedFDA multi-discipline review, p. 56Source ↗ DARTAcceptedBeyond the letter
Embryo-fetal development study waived; weight-of-evidence risk assessment instead
Why: High immunogenicity in monkeys; weight of evidence from mechanism of action and other B-cell targeting agents · Weight of evidence · Class precedent · Pharmacology or kinetics
“An EFD toxicity study of epcoritamab in cynomolgus monkeys was waived for phase 3 trials and registration of epcoritamab across ICH regions (FDA, EMEA, and PMDA) given the high potential for immunogenicity of epcoritamab in cynomolgus monkeys. A risk assessment-based on a weight of evidence approach was conducted considering the mechanism of action of epcoritamab and relevant information from other B-cell targeting agents (Module 2.6.6).”
✓ VerifiedFDA multi-discipline review, p. 57Source ↗ “Based on the above information, an EFD study can be waived.”
✓ VerifiedEMA assessment report, p. 37Source ↗