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Nulibry

fosdenopterin
small moleculecPMP replacement (MoCD type A)Intravenous synthetic cPMP substrate replacement therapyMolybdenum cofactor deficiency type A, to reduce mortality
Species
RatDog
Longest study
39 wk
Genotox
Conducted Conducted
Carcinogenicity
Not conducted Not conducted
Repro
Not conducted Not conducted
First dose
Partial / alternative Partly stated

Speciesopen answer page →

Species
Rat and dog (juvenile)
“Repeat-dose toxicity studies in juvenile rats for 13 and 26 weeks and in juvenile dogs for 39 weeks (Table 15).”
✓ VerifiedFDA integrated review, p. 56Source ↗
Why that species
MoCo synthesis highly conserved and cPMP identical across species
“The MoCo-synthesis is considered highly conserved between species, and cPMP is considered identical between species. Thus, rat and dog are considered relevant species for toxicity studies.”
✓ VerifiedEMA assessment report, p. 27Source ↗
Surrogate molecule
No surrogate; the clinical compound was tested
“In the 39-week toxicity study in juvenile dogs in which fosdenopterin HBr (coded ALXN1101) was administered at 1, 3, 5, and 10 mg/kg/day once daily, no adverse effects were observed.”
✓ VerifiedFDA integrated review, p. 173Source ↗
Species: general tox
Juvenile rat (13- and 26-week) and juvenile dog (39-week)
“Repeat-dose toxicity studies in juvenile rats for 13 and 26 weeks and in juvenile dogs for 39 weeks (Table 15).”
✓ VerifiedFDA integrated review, p. 56Source ↗
Species: DART
Rabbit (EFD) and mouse (pre/postnatal development)
“fosdenopterin to pregnant rabbits once daily during the period of organogenesis (GD 7 to GD 20) at doses up to 200 mg/kg/day (approximately 89 times the human exposure at the MRHD, based on AUC) did not result in adverse developmental effects. In a pre- and postnatal development study, subcutaneous administration of fosdenopterin to pregnant mice”
✓ VerifiedUS prescribing informationSource ↗
Species: carcinogenicity
Not conducted; single-species study required postmarketing
“Carcinogenicity studies with fosdenopterin have not been conducted. A carcinogenicity study in a single species will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
Surrogate used in
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.

Study lengthopen answer page →

Longest pivotal study
39 (juvenile dog)
“Repeat-dose toxicity studies in juvenile rats for 13 and 26 weeks and in juvenile dogs for 39 weeks (Table 15).”
✓ VerifiedFDA integrated review, p. 56Source ↗
Pivotal GLP studies
13- and 26-week juvenile rat and 39-week juvenile dog studies
“Repeat-dose toxicity studies in juvenile rats for 13 and 26 weeks and in juvenile dogs for 39 weeks (Table 15).”
✓ VerifiedFDA integrated review, p. 56Source ↗
Route in tox
Subcutaneous in neonatal phase, then intravenous bolus
“Animals were dosed subcutaneously from PND 7 to PND 20, and then by intravenous bolus from PND 21 onwards.”
✓ VerifiedFDA integrated review, p. 173Source ↗

Skipped studiesopen answer page →

Genotoxicity
Negative in the standard ICH S2(R1) battery, in vitro and in vivo
“Fosdenopterin was without genotoxic potential in vitro and in vivo in the standard battery of tests indicated in ICH S2(R1).”
✓ VerifiedEMA assessment report, p. 24Source ↗
Carcinogenicity
Not conducted; postmarketing requirement
“Carcinogenicity studies with fosdenopterin have not been conducted. A carcinogenicity study in a single species will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
Reproductive & developmental
Not conducted; postmarketing requirement
“Nonclinical reproductive and developmental toxicity studies with fosdenopterin have not been conducted. These studies will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
Safety pharmacology
No effects in vitro (hERG) or on cardiovascular, CNS or respiratory parameters in vivo; NOEL margins low
“No fosdenopterin-related effects were observed in vitro or on cardiovascular, CNS or respiratory parameters in vivo. Due to low maximum dose levels, margins at no-observed-effect-level (NOEL) are low to non-existing.”
✓ VerifiedEMA assessment report, p. 21Source ↗
Genotox: Ames
Negative (bacterial reverse mutation)
“Fosdenopterin was not genotoxic in a standard battery of in vitro (bacterial reverse mutation and human lymphocyte chromosomal aberration) and in vivo (rodent bone marrow micronucleus) assays.”
✓ VerifiedUS prescribing informationSource ↗
Genotox: in vitro mammalian
Human lymphocyte chromosomal aberration: negative
“Fosdenopterin was not genotoxic in a standard battery of in vitro (bacterial reverse mutation and human lymphocyte chromosomal aberration) and in vivo (rodent bone marrow micronucleus) assays.”
✓ VerifiedUS prescribing informationSource ↗
Genotox: in vivo
Rodent bone marrow micronucleus: negative
“Fosdenopterin was not genotoxic in a standard battery of in vitro (bacterial reverse mutation and human lymphocyte chromosomal aberration) and in vivo (rodent bone marrow micronucleus) assays.”
✓ VerifiedUS prescribing informationSource ↗
Carcinogenicity model
Not conducted; single-species carcinogenicity study as postmarketing requirement
“Carcinogenicity studies with fosdenopterin have not been conducted. A carcinogenicity study in a single species will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
Carcinogenicity timing
2-year mouse study planned as a postmarketing requirement; none before approval
“A two-year carcinogenicity study in mice is however planned as a post-marketing requirement from FDA.”
✓ VerifiedEMA assessment report, p. 27Source ↗
hERG / QT
No effect on hERG current up to 300 µM (automated screening assay)
“In an automated screening assay for a number of ion channels (study 190129.PSN), there were no effects of fosdenopterin on the hERG current at concentrations up to 300 µM.”
✓ VerifiedEMA assessment report, p. 26Source ↗

First doseopen answer page →

First-in-human starting dose
FIH single IV doses 0.075, 0.25 and 0.68 mg/kg in healthy subjects; starting-dose derivation not described
“A total of 24 subjects was randomized into three sequential cohorts (6 active: 2 placebo) and received a single IV infusion of fosdenopterin at doses of 0.075, 0.25, and 0.68 mg/kg.”
✓ VerifiedFDA integrated review, p. 93Source ↗
NOAEL / key findings
No adverse findings; minor dog changes non-adverse; NOAELs 5 mg/kg/day (rat) and 10 mg/kg/day (dog), highest doses tested
“These findings were without histopathological correlates and were considered non-adverse. NOAELs for fosdenopterin were 5 mg/kg/day (rats) and 10 mg/kg/day (dogs), the highest dose levels evaluated.”
✓ VerifiedEMA assessment report, p. 24Source ↗

Risksopen answer page →

Immune & cytokine safety
No antigenicity or immunotoxicity studies conducted
“No studies on antigenicity, immunotoxicity, dependence, or metabolites have been conducted.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Biodistribution & persistence
Extensive distribution; highest in kidney, bone epiphyseal line, skin, liver and esophagus
“In both the pigmented and nonpigmented rats, the highest concentrations of fosdenopterin were observed in the kidney, bone epiphyseal line, skin, liver, and esophagus.”
✓ VerifiedFDA integrated review, p. 84Source ↗
Modality-specific risk
Phototoxicity: skin reactions and ocular lesions in pigmented rats at >=4.4x MRHD
“A significant safety concern for phototoxicity with fosdenopterin was identified at doses ≥4.4× the maximum recommended human dose of 0.9 mg/kg/day (based on the human equivalent dose [HED]) in a standalone phototoxicity study in rats.”
✓ VerifiedFDA integrated review, p. 57Source ↗
Anti-drug antibodies: animals
No antigenicity studies conducted
“No studies on antigenicity, immunotoxicity, dependence, or metabolites have been conducted.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Anti-drug antibodies: patients
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Label warnings
  • Potential for Photosensitivity
Skin reactions
US prescribing information, Warnings and PrecautionsDailyMed ↗

Tox packageopen answer page →

Before first-in-human

First-in-human: where
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Repeat-dose tox before first-in-human
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
First-in-human starting dose
FIH single IV doses 0.075, 0.25 and 0.68 mg/kg in healthy subjects; starting-dose derivation not described
“A total of 24 subjects was randomized into three sequential cohorts (6 active: 2 placebo) and received a single IV infusion of fosdenopterin at doses of 0.075, 0.25, and 0.68 mg/kg.”
✓ VerifiedFDA integrated review, p. 93Source ↗

Longest repeat-dose systemic studies

Longest repeat-dose study and recovery
39-week (9-month) juvenile dog (IV) with 3-month recovery
“A 9-Month Intravenous Toxicity Study in Juvenile Beagle Dogs With a 3-Month Recovery Period”
✓ VerifiedFDA integrated review, p. 78Source ↗
Pivotal GLP studies
13- and 26-week juvenile rat and 39-week juvenile dog studies
“Repeat-dose toxicity studies in juvenile rats for 13 and 26 weeks and in juvenile dogs for 39 weeks (Table 15).”
✓ VerifiedFDA integrated review, p. 56Source ↗

DART package

Species: DART
Rabbit (EFD) and mouse (pre/postnatal development)
“fosdenopterin to pregnant rabbits once daily during the period of organogenesis (GD 7 to GD 20) at doses up to 200 mg/kg/day (approximately 89 times the human exposure at the MRHD, based on AUC) did not result in adverse developmental effects. In a pre- and postnatal development study, subcutaneous administration of fosdenopterin to pregnant mice”
✓ VerifiedUS prescribing informationSource ↗
Reproductive & developmental
Not conducted; postmarketing requirement
“Nonclinical reproductive and developmental toxicity studies with fosdenopterin have not been conducted. These studies will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
PPND / ePPND: when
PPND in mouse: postmarketing requirement, not required before approval
“Pre- and postnatal development (PPND) study in mice. • 104-Week carcinogenicity study in mice. • Thorough QT/QTc Study. We are not requiring these studies pre-approval so as not to further delay approval of Nulibry”
✓ VerifiedFDA integrated review, p. 150Source ↗

Carcinogenicity

Species: carcinogenicity
Not conducted; single-species study required postmarketing
“Carcinogenicity studies with fosdenopterin have not been conducted. A carcinogenicity study in a single species will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
Carcinogenicity model
Not conducted; single-species carcinogenicity study as postmarketing requirement
“Carcinogenicity studies with fosdenopterin have not been conducted. A carcinogenicity study in a single species will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
Carcinogenicity timing
2-year mouse study planned as a postmarketing requirement; none before approval
“A two-year carcinogenicity study in mice is however planned as a post-marketing requirement from FDA.”
✓ VerifiedEMA assessment report, p. 27Source ↗

Safety marginopen answer page →

Safety margin at NOAEL
No adverse effects up to 17.8x (juvenile rat) and 6.2x (juvenile dog) the MRHD, HED basis
“No adverse effects (AEs) were observed in rats or dogs at doses up to 17.8× and 6.2×, respectively, the maximum recommended human dose, when compared to the human equivalent dose (mg/kg/day), based on body surface area.”
✓ VerifiedFDA integrated review, p. 75Source ↗
NOAEL / key findings
No adverse findings; minor dog changes non-adverse; NOAELs 5 mg/kg/day (rat) and 10 mg/kg/day (dog), highest doses tested
“These findings were without histopathological correlates and were considered non-adverse. NOAELs for fosdenopterin were 5 mg/kg/day (rats) and 10 mg/kg/day (dogs), the highest dose levels evaluated.”
✓ VerifiedEMA assessment report, p. 24Source ↗

Efficacy evidenceopen answer page →

Efficacy evidence
Knockout mouse model of MoCD Type A: reduced plasma and brain SSC, improved survival vs controls
“animal data from a knockout mouse model of MoCD Type A showing a reduction of plasma and brain SSC and improved mortality in treated mice compared to controls.”
✓ VerifiedFDA integrated review, p. 14Source ↗
Why that model
MoCo synthesis pathway highly conserved; cPMP identical between species
“The MoCo synthesis pathway is highly conserved, and cPMP is considered identical between species.”
✓ VerifiedEMA assessment report, p. 28Source ↗
Reviewer's view of the efficacy data
EMA: pharmacodynamic studies support cPMP replacement in MOCS1-/- knockout mice; treatment from PND1 prevented early death
“Overall, primary pharmacodynamic studies support that fosdenopterin can replace endogenous cPMP in a knock-out mouse model of MoCD (MOCS1-/-), showing phenotypes with similar characteristics and biochemical anomalies as human MoCD Type A. In these animals, fosdenopterin treatment from PND1 prevented early death.”
✓ VerifiedEMA assessment report, p. 28Source ↗

Flexibilityopen answer page →

Flexibility accepted
CarcinogenicityAccepted with a conditionBeyond the letter
No carcinogenicity study before approval; single-species study deferred to a postmarketing requirement
Why: Not required pre-approval to avoid delaying a drug with mortality benefit for a rare, serious disease without other treatments · Rare disease / unmet need · Serious disease
“Carcinogenicity studies with fosdenopterin have not been conducted. A carcinogenicity study in a single species will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
“We are not requiring these studies pre-approval so as not to further delay approval of Nulibry, a drug with a mortality benefit for a rare, serious, devastating disease without other treatment options.”
✓ VerifiedFDA integrated review, p. 150Source ↗
DARTAccepted with a conditionBeyond the letter
No reproductive or developmental toxicity studies before approval; deferred to postmarketing requirements
Why: Untreated patients do not survive into adolescence and adulthood; studies delayed until more clinical data · Rare disease / unmet need · Serious disease
“Nonclinical reproductive and developmental toxicity studies with fosdenopterin have not been conducted. These studies will be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 79Source ↗
“Because untreated patients with MoCD Type A do not survive into adolescence and adulthood, we agreed upon a delay of the nonclinical reproductive and developmental toxicity studies until additional clinical data on patients treated with Nulibry”
✓ VerifiedFDA integrated review, p. 150Source ↗
Safety pharmacologyVerdict not stated
Safety pharmacology margins at the no-observed-effect level low to non-existent due to low maximum dose levels
“No fosdenopterin-related effects were observed in vitro or on cardiovascular, CNS or respiratory parameters in vivo. Due to low maximum dose levels, margins at no-observed-effect-level (NOEL) are low to non-existing.”
✓ VerifiedEMA assessment report, p. 21Source ↗
Efficacy modelAcceptedBeyond the letter
No pharmacodynamic data in mice by the intended IV route of administration
Why: Limited volume feasible for IV administration to mice · Other reason
“The lack of data from the intended route of administration is considered acceptable based on the limited volume feasible for IV administration to mice.”
✓ VerifiedEMA assessment report, p. 21Source ↗
OtherAcceptedBeyond the letter
No in vivo metabolism or excretion studies
Why: No metabolites in vitro; synthetic replacement for endogenous cPMP eliminated like the endogenous molecule · Pharmacology or kinetics
“In vivo studies to address metabolism have not been conducted. This is considered acceptable since no metabolites are detected in vitro, and since fosdenopterin is a synthetic replacement for the endogenous molecule (cPMP) expected to be eliminated and excreted in an identical manner to that of the endogenous molecule.”
✓ VerifiedEMA assessment report, p. 27Source ↗

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