SpeciesAcceptedBeyond the letter
No relevant animal model; no GLP formal toxicology studies, only safety observations in a syngeneic mouse surrogate model
Why: scFv recognises only human CD19; no relevant animal model · No relevant species
“Toxicology Similar as the pharmacology evaluation, also the non-clinical safety evaluation of KTE-X19 has been severely limited due to the lack of a relevant animal model. Therefore, no GLP-compliant formal toxicology studies were performed.”
✓ VerifiedEMA assessment report, p. 35Source ↗ “There were no nonclinical deficiencies identified in this submission and no outstanding requests for additional nonclinical data.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗ Efficacy modelAcceptedBeyond the letter
In vivo pharmacology with surrogate anti-murine CD19 CAR T cells in syngeneic immunocompetent lymphoma mice
Why: Surrogate model overcomes xenogeneic limitations; human-cell xenograft testing would add no significant value · No relevant species · Pharmacology or kinetics
“Since both models do have clear, although differing, limitations with regard to the translation of the non-clinical pharmacology data to human, additional non-clinical in vivo pharmacology data (e.g. testing of KTE-X19 in immunocompromised animals transplanted with human CD19+ tumour cells) would not add significant value”
✓ VerifiedEMA assessment report, p. 35Source ↗ “in immunocompetent mice is an acceptable approach that overcomes some of the limitations of the in vivo testing of KTE-X19 in immunocompromised animals (e.g. unspecific xenogeneic immune responses of KTE-X19 in mice, lack of complex interactions of the CAR T cells with other components of the immune system).”
✓ VerifiedEMA assessment report, p. 35Source ↗ CarcinogenicityAcceptedBeyond the letter
No genotoxicity or tumorigenicity studies despite gamma-retroviral vector integration risk
Why: Product characteristics, safety profile and indication · Other reason
“Traditional in vitro and in vivo genotoxicity and carcinogenicity/tumorigenicity assessments of KTE-X19 were not conducted which is acceptable based on the product characteristics, safety profile and indication.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗ DARTAcceptedBeyond the letter
No reproductive and developmental toxicity studies
Why: Type of product, target antigen expression pattern and lack of a relevant animal model · No relevant species · Low-risk modality
“The lack of non-clinical reproductive and developmental toxicity studies is acceptable based on the type of product, the expression pattern of the target antigen and the lack of a relevant animal model.”
✓ VerifiedEMA assessment report, p. 36Source ↗