Study lengthAcceptedBeyond the letter
Only a 5-week repeat-dose monkey study; no 13-week study
Why: No findings and neutralizing ADAs in the 5-week study; a 13-week study would not provide meaningful information · Weight of evidence
“Given the dearth of findings and the induction of neutralizing ADAs in the 5-week repeat-dose toxicity study in cynomolgus monkeys, a 13-week repeat-dose toxicity study would not provide meaningful information and is not warranted to support a BLA.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗ SpeciesCriticised but acceptedBeyond the letter
No pharmacodynamic activity in the monkey toxicity study (lower monkey BCMA affinity, few target cells, neutralizing ADAs)
Why: PD absence attributed to lower monkey BCMA affinity, few BCMA-expressing target cells and neutralizing ADAs · Pharmacology or kinetics
“Teclistamab was administered at dose levels expected to be pharmacologically active, but there was no evidence of pharmacodynamic (PD) activity or teclistamab-related adverse effects.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗ “Lack of teclistamab PD activity may be attributed to the lower binding affinity of teclistamab to cynomolgus monkey BCMA, the paucity of BCMA-expressing target cells in healthy cynomolgus monkeys, and the decreased teclistamab systemic exposure in animals affected by neutralizing ADAs.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗ DARTAccepted
No reproductive and developmental toxicity studies; weight-of-evidence assessment using BCMA biology and BCMA-deficient mice
Why: No BCMA expression in human reproductive organs, so on-target/off-tumor risk in these tissues relatively low · Weight of evidence · Within the guideline
“The Applicant’s Position: No reproductive and developmental toxicity studies were conducted for teclistamab. In accordance with ICH S5(R3) and S6(R1) and the US FDA Guidance for Oncology, a weight of evidence based on the intended patient population, BCMA target biology including data from genetically modified mice that lack BCMA,”
✓ VerifiedFDA multi-discipline review, p. 46Source ↗ “The FDA’s Assessment: We agree with the Applicant’s WOE-based approach for the assessment of reproductive and developmental toxicity. There is no BCMA gene or protein expression in human reproductive organs; therefore, the risk of on-target/off-tumor toxicity in these tissues is relatively low.”
✓ VerifiedFDA multi-discipline review, p. 46Source ↗ OtherVerdict not stated
Monkey toxicity study used IV dosing while the clinical route is subcutaneous
“This study evaluated the IV route of administration, whereas the clinical route of administration is subcutaneous (SC).”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗