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zilganersen
oligonucleotideGFAP (ASO)Second-generation 2'-MOE/DNA chimeric ASO targeting GFAP mRNA, intrathecalAlexander disease (AxD), pediatric and adult patients
Species
MonkeyMouse
Longest study
39 wk
Genotox
Conducted Conducted
Carcinogenicity
Not conducted Not conducted
Repro
Conducted Conducted
First dose
Partial / alternative Partly stated

Speciesopen answer page →

Species
Mouse (SC and ICV, juvenile) and juvenile monkey (intrathecal); mouse surrogate ASO arm
“The nonclinical package submitted to the NDA included general toxicology studies of up to 26 and 39 weeks' duration in mouse (subcutaneous [SC]) and monkey (intrathecal lumbar [ITL]), respectively, as well as a 13-week ICV toxicity study in mouse;”
✓ VerifiedFDA integrated review, p. 74Source ↗
Why that species
Single mismatch to monkey GFAP mRNA gave no knockdown in monkey; mouse surrogate used to probe on-target GFAP reduction
“No meaningful changes in GFAP mRNA levels were observed in brain or spinal cord tissues, likely due to the single mismatch between zilganersen and monkey GFAP mRNA.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Surrogate molecule
Yes: mouse-specific surrogate ASO (ISIS 713812) dosed ICV in parallel juvenile mouse arm
“A parallel group administered the mouse surrogate ASO (ISIS 713812; 0.1 mg ICV) demonstrated locomotor hypoactivity and reductions in bone mineral content in males;”
✓ VerifiedFDA integrated review, p. 75Source ↗
Species: general tox
Mouse (SC and ICV) and juvenile monkey (intrathecal lumbar)
“The nonclinical package submitted to the NDA included general toxicology studies of up to 26 and 39 weeks' duration in mouse (subcutaneous [SC]) and monkey (intrathecal lumbar [ITL]), respectively, as well as a 13-week ICV toxicity study in mouse;”
✓ VerifiedFDA integrated review, p. 74Source ↗
Species: DART
Mouse (combined fertility and developmental toxicity study)
“The Applicant has completed a combined fertility and developmental toxicology study in the mouse model.”
✓ VerifiedFDA integrated review, p. 162Source ↗
Species: carcinogenicity
None conducted; 6-month Tg.rasH2 mouse and 2-year rat required as PMRs
“5053-1: Conduct a 6-month carcinogenicity study of zilganersen in Tg.rasH2 mice to assess tumorigenic potential. 5053-2: Conduct a 2-year carcinogenicity study of zilganersen in rats to assess tumorigenic potential.”
✓ VerifiedFDA integrated review, p. 142Source ↗
Surrogate used in
Yes: mouse surrogate ASO ISIS 713812 (ICV) in juvenile mouse toxicity study
“A parallel group administered the mouse surrogate ASO (ISIS 713812; 0.1 mg ICV) demonstrated locomotor hypoactivity and reductions in bone mineral content in males;”
✓ VerifiedFDA integrated review, p. 75Source ↗

Study lengthopen answer page →

Longest pivotal study
39 weeks
“The nonclinical package submitted to the NDA included general toxicology studies of up to 26 and 39 weeks' duration in mouse (subcutaneous [SC]) and monkey (intrathecal lumbar [ITL]), respectively”
✓ VerifiedFDA integrated review, p. 74Source ↗
Pivotal GLP studies
Juvenile monkey 9-month ITL Q4W; juvenile mouse 13-week ICV Q6W; juvenile mouse 26-week SC Q2W
“In nonclinical toxicology studies, zilganersen was administered via ICV injection in juvenile C57BL/B6Ncrl mouse (13 weeks; 0, 0.05, 0.1, or 0.2 mg every 6 weeks) and via ITL injection in juvenile monkey (9 months; 0, 3, 8, or 25 mg Q4W).”
✓ VerifiedFDA integrated review, p. 74Source ↗
Route in tox
Intrathecal lumbar (monkey), intracerebroventricular and subcutaneous (mouse)
“In nonclinical toxicology studies, zilganersen was administered via ICV injection in juvenile C57BL/B6Ncrl mouse”
✓ VerifiedFDA integrated review, p. 74Source ↗

Skipped studiesopen answer page →

Genotoxicity
Conducted: Ames, in vitro chromosomal aberration, mouse micronucleus; all negative
“Zilganersen was negative in the Ames, in vitro chromosomal aberration, and mouse bone marrow micronucleus assays.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Carcinogenicity
Not conducted pre-approval; Tg.rasH2 mouse and 2-year rat studies required as PMRs
“No new studies were provided. The Division agreed these studies can be completed as post-marketing requirements (PMRs) given the benefit:risk and unmet medical need.”
✓ VerifiedFDA integrated review, p. 162Source ↗
Reproductive & developmental
Combined fertility/EFD in mouse (SC), no adverse effects; rabbit EFD and PPND deferred to PMRs
“No adverse fertility or embryofetal developmental effects were observed in mouse administered zilganersen subcutaneously at doses of 0, 10, 30, or 60 mg/kg once every 2 weeks.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Safety pharmacology
Incorporated into 9-month monkey study (no findings); in vitro hERG minimal; auditory startle in juvenile mice
“No zilganersen-related safety pharmacology findings were identified in the 9-month monkey study”
✓ VerifiedFDA integrated review, p. 75Source ↗
Genotox: Ames
Negative
“Zilganersen was negative in the Ames, in vitro chromosomal aberration, and mouse bone marrow micronucleus assays.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Genotox: in vitro mammalian
In vitro chromosomal aberration: negative
“Zilganersen was negative in the Ames, in vitro chromosomal aberration, and mouse bone marrow micronucleus assays.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Genotox: in vivo
Mouse bone marrow micronucleus: negative
“Zilganersen was negative in the Ames, in vitro chromosomal aberration, and mouse bone marrow micronucleus assays.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Carcinogenicity model
Not conducted
“Long-term studies to assess the carcinogenic potential of zilganersen have not been conducted.”
✓ VerifiedFDA integrated review, p. 169Source ↗
Carcinogenicity timing
6-month Tg.rasH2 mouse and 2-year rat: postmarketing requirements
“5053-1: Conduct a 6-month carcinogenicity study of zilganersen in Tg.rasH2 mice to assess tumorigenic potential. 5053-2: Conduct a 2-year carcinogenicity study of zilganersen in rats to assess tumorigenic potential.”
✓ VerifiedFDA integrated review, p. 142Source ↗
hERG / QT
Minimal hERG inhibition (IC50 >150 µM); no safety pharmacology findings in 9-month monkey study
“No zilganersen-related safety pharmacology findings were identified in the 9-month monkey study, and hERG inhibition in HEK-293 (human embryonic kidney-293) cells was minimal (IC50>150µM).”
✓ VerifiedFDA integrated review, p. 75Source ↗

First doseopen answer page →

First-in-human starting dose
Starting-dose rationale not stated; FDA capped clinical IT dose at 25 mg (~1/10 mouse/monkey NOAEL), later 50 mg Q12W
“The FDA placed protocol ION373-CS1 on hold for IT doses of ION373 exceeding 25 mg, which is approximately 1/10th the NOAELs in mouse and monkey”
✓ VerifiedFDA integrated review, p. 133Source ↗
NOAEL / key findings
NOAEL 25 mg monkey ITL, 0.2 mg mouse ICV; transient patellar reflex loss, neuronal vacuolation at high dose; CSF-volume margins 5-17x
“The NOAEL in the 9-month ITL study in juvenile monkey was 25 mg.”
✓ VerifiedFDA integrated review, p. 75Source ↗

Risksopen answer page →

Immune & cytokine safety
Low-severity proinflammatory findings (liver mononuclear infiltrates, vacuolated macrophages) in 26-week SC mouse study
“revealed findings consistent with ASO uptake, accumulation, and a proinflammatory response, including basophilic granules in Kupffer cells, mononuclear cell infiltration in the liver, and vacuolated/granular macrophages in multiple tissues”
✓ VerifiedFDA integrated review, p. 75Source ↗
Biodistribution & persistence
SC dosing: dose-dependent maternal/paternal liver accumulation; very low to undetectable in placenta and fetal liver
“Zilganersen concentrations increased in a dose-dependent manner in maternal and paternal liver, but were very low to undetectable in placenta and fetal liver.”
✓ VerifiedFDA integrated review, p. 75Source ↗
Modality-specific risk
Intrathecal CNS toxicity (reflex loss, neuronal vacuolation), on-target GFAP knockdown neurobehavior, developmental GFAP role
“In the 9-month ITL study in juvenile monkey, transient patellar reflex losses, occasionally accompanied by foot grip impairment, were observed at mid dose and high dose, along with neuronal vacuolation in the brain at high dose”
✓ VerifiedFDA integrated review, p. 75Source ↗
Anti-drug antibodies: animals
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.
Anti-drug antibodies: patients
28.1% (9/32) ADA positive, all treatment-induced (2 transient, 7 persistent); neutralizing not assessed
“Neutralizing ADA assays were not performed. Incidence 28.1% of zilganersen-treated subjects (9/32) were overall ADA positive over the DB and OL and LTE periods. All ADA were treatment-induced; 2 were transient and 7 were persistent.”
✓ VerifiedFDA integrated review, p. 29Source ↗
Label warnings
  • Aseptic Meningitis
US prescribing information, Warnings and PrecautionsDailyMed ↗

Tox packageopen answer page →

Before first-in-human

First-in-human: where
United States and other countries: ION373-CS1, the single combined first clinical and pivotal trial in AxD patients
“Subjects outside the United States received the IT placebo injection throughout the trial.”
✓ VerifiedFDA integrated review, p. 40Source ↗
Repeat-dose tox before first-in-human
9-week mouse ICV toxicity study plus monkey study; initial clinical IT doses capped at 25 mg (~1/10 mouse and monkey NOAELs)
“The FDA placed protocol ION373-CS1 on hold for IT doses of ION373 exceeding 25 mg, which is approximately 1/10th the NOAELs in mouse and monkey, due to unexplained deaths in female mice in the 9-week ICV toxicity study.”
✓ VerifiedFDA integrated review, p. 133Source ↗
First-in-human starting dose
Starting-dose rationale not stated; FDA capped clinical IT dose at 25 mg (~1/10 mouse/monkey NOAEL), later 50 mg Q12W
“The FDA placed protocol ION373-CS1 on hold for IT doses of ION373 exceeding 25 mg, which is approximately 1/10th the NOAELs in mouse and monkey”
✓ VerifiedFDA integrated review, p. 133Source ↗

Longest repeat-dose systemic studies

Longest repeat-dose study and recovery
39-week juvenile monkey (intrathecal lumbar); recovery not stated
“The nonclinical package submitted to the NDA included general toxicology studies of up to 26 and 39 weeks' duration in mouse (subcutaneous [SC]) and monkey (intrathecal lumbar [ITL]), respectively”
✓ VerifiedFDA integrated review, p. 74Source ↗
Pivotal GLP studies
Juvenile monkey 9-month ITL Q4W; juvenile mouse 13-week ICV Q6W; juvenile mouse 26-week SC Q2W
“In nonclinical toxicology studies, zilganersen was administered via ICV injection in juvenile C57BL/B6Ncrl mouse (13 weeks; 0, 0.05, 0.1, or 0.2 mg every 6 weeks) and via ITL injection in juvenile monkey (9 months; 0, 3, 8, or 25 mg Q4W).”
✓ VerifiedFDA integrated review, p. 74Source ↗

DART package

Species: DART
Mouse (combined fertility and developmental toxicity study)
“The Applicant has completed a combined fertility and developmental toxicology study in the mouse model.”
✓ VerifiedFDA integrated review, p. 162Source ↗
Reproductive & developmental
Combined fertility/EFD in mouse (SC), no adverse effects; rabbit EFD and PPND deferred to PMRs
“No adverse fertility or embryofetal developmental effects were observed in mouse administered zilganersen subcutaneously at doses of 0, 10, 30, or 60 mg/kg once every 2 weeks.”
✓ VerifiedFDA integrated review, p. 75Source ↗
PPND / ePPND: when
PPND in mouse (zilganersen and mouse surrogate): postmarketing requirement
“5053-4: Conduct a pre- and postnatal development (PPND) study of zilganersen and the mouse surrogate (ISIS 713812) to evaluate maternal and offspring toxicity.”
✓ VerifiedFDA integrated review, p. 142Source ↗

Carcinogenicity

Species: carcinogenicity
None conducted; 6-month Tg.rasH2 mouse and 2-year rat required as PMRs
“5053-1: Conduct a 6-month carcinogenicity study of zilganersen in Tg.rasH2 mice to assess tumorigenic potential. 5053-2: Conduct a 2-year carcinogenicity study of zilganersen in rats to assess tumorigenic potential.”
✓ VerifiedFDA integrated review, p. 142Source ↗
Carcinogenicity model
Not conducted
“Long-term studies to assess the carcinogenic potential of zilganersen have not been conducted.”
✓ VerifiedFDA integrated review, p. 169Source ↗
Carcinogenicity timing
6-month Tg.rasH2 mouse and 2-year rat: postmarketing requirements
“5053-1: Conduct a 6-month carcinogenicity study of zilganersen in Tg.rasH2 mice to assess tumorigenic potential. 5053-2: Conduct a 2-year carcinogenicity study of zilganersen in rats to assess tumorigenic potential.”
✓ VerifiedFDA integrated review, p. 142Source ↗

Safety marginopen answer page →

Safety margin at NOAEL
Monkey NOAEL 5x, mouse 17x the proposed 50 mg dose (CSF-volume-normalized dose)
“Based on doses normalized to CSF volume, the NOAELs in mouse and monkey provide safety margins of 34 and 10, respectively, compared to the (b) (4) human dose of 25 mg, but of 17 and 5, respectively, compared to the proposed human dose of 50 mg.”
✓ VerifiedFDA integrated review, p. 75Source ↗
NOAEL / key findings
NOAEL 25 mg monkey ITL, 0.2 mg mouse ICV; transient patellar reflex loss, neuronal vacuolation at high dose; CSF-volume margins 5-17x
“The NOAEL in the 9-month ITL study in juvenile monkey was 25 mg.”
✓ VerifiedFDA integrated review, p. 75Source ↗

Efficacy evidenceopen answer page →

Efficacy evidence
Transgenic mice overexpressing human GFAP (AxD-like features reduced); species surrogate ASO in rat AxD model
“Specifically, administration of zilganersen reduced GFAP mRNA and AxD-like features in transgenic mice overexpressing human GFAP; additionally, a species surrogate ASO reduced brain GFAP mRNA and decreased GFAP protein in the CSF of a rat model of AxD.”
✓ VerifiedFDA integrated review, p. 13Source ↗
Why that model
No cross-reactivity to rodent or monkey GFAP mRNA, so human GFAP transgenic mice used
“Given the lack of cross-reactivity to rodent or monkey GFAP mRNA, pharmacologic effects of zilganersen in vivo were evaluated in”
✓ VerifiedFDA integrated review, p. 25Source ↗
Reviewer's view of the efficacy data
FDA: target engagement and mechanistic data confirmed biologic plausibility of the treatment benefit
“These target engagement and mechanistic data confirmed the biologic plausibility of the observed treatment benefit and that the drug is having its intended effect.”
✓ VerifiedFDA integrated review, p. 13Source ↗

Flexibilityopen answer page →

Flexibility accepted
CarcinogenicityAccepted with a conditionBeyond the letter
No carcinogenicity studies before approval; completion required as postmarketing requirements
Why: Benefit:risk and unmet medical need · Rare disease / unmet need
“Carcinogenicity No new studies were provided. The Division agreed these studies can be completed as post-marketing requirements (PMRs) given the benefit:risk and unmet medical need.”
✓ VerifiedFDA integrated review, p. 162Source ↗
DARTAccepted with a conditionBeyond the letter
Rabbit embryo-fetal and pre/postnatal development studies deferred to postmarketing
“An embryofetal development study in rabbit will be needed but may be conducted as a postmarketing requirement.”
✓ VerifiedFDA integrated review, p. 134Source ↗
“5053-4: Conduct a pre- and postnatal development (PPND) study of zilganersen and the mouse surrogate (ISIS 713812) to evaluate maternal and offspring toxicity.”
✓ VerifiedFDA integrated review, p. 142Source ↗
SpeciesVerdict not stated
No GFAP knockdown in monkey toxicity study due to a single sequence mismatch with monkey GFAP mRNA
“No meaningful changes in GFAP mRNA levels were observed in brain or spinal cord tissues, likely due to the single mismatch between zilganersen and monkey GFAP mRNA.”
✓ VerifiedFDA integrated review, p. 75Source ↗
First doseAccepted with a conditionBeyond the letter
Clinical intrathecal dose capped at 25 mg (about 1/10 of mouse and monkey NOAELs) after unexplained deaths in a mouse ICV study
Why: Additional nonclinical data allowed an increase to 50 mg every 12 weeks
“The FDA placed protocol ION373-CS1 on hold for IT doses of ION373 exceeding 25 mg, which is approximately 1/10th the NOAELs in mouse and monkey, due to unexplained deaths in female mice in the 9- week ICV toxicity study.”
✓ VerifiedFDA integrated review, p. 133Source ↗
“Following nonclinical data review, Ionis was permitted to increase the maximum dose and dosing frequency to 50 mg every 12 weeks for Study ION373-CS1.”
✓ VerifiedFDA integrated review, p. 133Source ↗
Impurity or metaboliteAccepted with a conditionBeyond the letter
13-week intrathecal toxicity study of leachables with local CNS concerns required postmarketing
“5053-5: Conduct a 13-week intrathecal toxicity study for detected leachables with local CNS toxicity concerns including butylated hydroxytoluene (BHT) (0.65 µg/day), boron (6.6 µg/day),”
✓ VerifiedFDA integrated review, p. 142Source ↗

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