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Zynyz

retifanlimab
monoclonal antibodyPD-1Humanized IgG4-kappa anti-PD-1 monoclonal antibodyMetastatic or recurrent Merkel cell carcinoma; anal carcinoma
Species
Monkey
Longest study
13 wk
Genotox
Not conducted Not conducted
Carcinogenicity
Not conducted Not conducted
Repro
Not conducted Not conducted
First dose
Not conducted Not stated publicly

Speciesopen answer page →

Species
Cynomolgus monkey only
“In vitro studies showed retifanlimab bound to human and cynomolgus monkey PD-1 with nanomolar affinity (0.6 and 3.6 nM, respectively) and did not cross react with rodent or canine PD-1, supporting the use of cynomolgus monkeys as the single pharmacologically relevant species for toxicity assessment.”
✓ VerifiedFDA multi-discipline review, p. 29Source ↗
Why that species
Binds human and cynomolgus PD-1 with nanomolar affinity (0.6 and 3.6 nM); no rodent or canine PD-1 cross-reactivity
“In vitro studies showed retifanlimab bound to human and cynomolgus monkey PD-1 with nanomolar affinity (0.6 and 3.6 nM, respectively) and did not cross react with rodent or canine PD-1, supporting the use of cynomolgus monkeys as the single pharmacologically relevant species for toxicity assessment.”
✓ VerifiedFDA multi-discipline review, p. 29Source ↗
Surrogate molecule
No surrogate; the clinical antibody was tested in cynomolgus monkeys
“The Applicant evaluated the toxicity of retifanlimab in a 13-week GLP-compliant repeat-dose toxicology study in cynomolgus monkeys.”
✓ VerifiedFDA multi-discipline review, p. 29Source ↗
Species: general tox
Cynomolgus monkey
“The Applicant evaluated the toxicity of retifanlimab in a 13-week GLP-compliant repeat-dose toxicology study in cynomolgus monkeys.”
✓ VerifiedFDA multi-discipline review, p. 29Source ↗
Species: DART
Not conducted; not required for advanced cancer therapeutics (ICH S9)
“Standard fertility and early embryonic development, embryofetal development and pre- and postnatal development studies have not been conducted with retifanlimab as not required for advanced cancer therapeutics (ICH S9 2009).”
✓ VerifiedEMA assessment report, p. 48Source ↗
Species: carcinogenicity
Not conducted; not warranted
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Surrogate used in
No surrogate used; in vivo studies limited to cynomolgus monkeys with retifanlimab
“Retifanlimab cross reacts with PD-1 from cynomolgus and rhesus monkeys, but not with PD-1 from non￾primate species. Thus, in vivo studies were limited to cynomolgus monkeys with retifanlimab delivered by IV infusion.”
✓ VerifiedEMA assessment report, p. 29Source ↗

Study lengthopen answer page →

Longest pivotal study
13 weeks
“The Applicant evaluated the toxicity of retifanlimab in a 13-week GLP-compliant repeat-dose toxicology study in cynomolgus monkeys.”
✓ VerifiedFDA multi-discipline review, p. 29Source ↗
Pivotal GLP studies
GLP cynomolgus monkey 4-week (0-150 mg/kg, 10-week recovery) and 13-week (0-100 mg/kg) studies, weekly IV infusion
“Pivotal repeat-dose toxicity studies with retifanlimab in cynomolgus monkeys include a 4-week study (doses: 0, 10, 40, or 150 mg/kg) with a 10-week recovery period (T19-01-03) and a 13 week study (doses: 0, 5, 20, 100 mg/kg; T18 02-10).”
✓ VerifiedEMA assessment report, p. 46Source ↗
Route in tox
IV infusion
“In both studies, retifanlimab was administered once weekly by IV infusion (1 hour infusion in 4-week study, 30 minute infusion in 13-week study).”
✓ VerifiedEMA assessment report, p. 46Source ↗

Skipped studiesopen answer page →

Genotoxicity
Not conducted; not warranted
“Genetic toxicology studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Carcinogenicity
Not conducted; not warranted
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Reproductive & developmental
Not conducted; weight-of-evidence reproductive risk assessment submitted instead
“Reproductive and developmental toxicology studies were not conducted with retifanlimab. Instead, the Applicant submitted a weight-of-evidence reproductive risk assessment for retifanlimab.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Safety pharmacology
Incorporated into 4-week GLP monkey study (CNS, cardiovascular, respiratory); no adverse effects up to 150 mg/kg
“No retifanlimab-related findings suggestive of adverse effects on the CNS, cardiovascular, or respiratory systems were noted at any dose level evaluated (10-150 mg/kg).”
✓ VerifiedEMA assessment report, p. 36Source ↗
Genotox: Ames
Not conducted (ICH S6)
“No genotoxicity or carcinogenicity studies with retifanlimab have not been conducted, according to ICH S6(R1) (2011) and ICH S9 (2009) guidelines.”
✓ VerifiedEMA assessment report, p. 50Source ↗
Genotox: in vitro mammalian
Not conducted (ICH S6)
“No genotoxicity or carcinogenicity studies with retifanlimab have not been conducted, according to ICH S6(R1) (2011) and ICH S9 (2009) guidelines.”
✓ VerifiedEMA assessment report, p. 50Source ↗
Genotox: in vivo
Not conducted (ICH S6)
“No genotoxicity or carcinogenicity studies with retifanlimab have not been conducted, according to ICH S6(R1) (2011) and ICH S9 (2009) guidelines.”
✓ VerifiedEMA assessment report, p. 50Source ↗
Carcinogenicity model
Not conducted; not warranted
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Carcinogenicity timing
Not required
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
hERG / QT
No hERG assay; no CNS, cardiovascular or respiratory effects in monkeys at 10-150 mg/kg
“No retifanlimab-related findings suggestive of adverse effects on the CNS, cardiovascular, or respiratory systems were noted at any dose level evaluated (10-150 mg/kg).”
✓ VerifiedEMA assessment report, p. 36Source ↗

First doseopen answer page →

First-in-human starting dose
Not stated in public reviews
Why it's blank

The public FDA and EMA reviews of Zynyz don't say how the first human dose was chosen. That rationale is in the IND, which is confidential, so it is missing for most approved products.

How it's usually set for monoclonal antibodies

ADCs with cytotoxic payloads follow the S9 rules (1/10 STD10 or 1/6 HNSTD of the ADC, scaled by body surface area). For immune agonists, a MABEL-based start dose should be considered instead.

“For example, for cytotoxic payloads, the starting clinical dose can be determined using either 1/10th the Severely Toxic Dose (STD) in 10% of animals (STD10) in rodents or 1/6th the Highest Non- Severely Toxic Dose (HNSTD) in non-rodents, for the ADC based on body surface area, depending on which is the most appropriate and/or sensitive species.”
✓ VerifiedICH 2018: ICH S9 Guideline: Nonclinical Evaluation for Anticancer…, p. 15Source ↗
This product's starting point

NOAEL / key findings: 13-week monkey NOAEL 100 mg/kg per dose, the highest dose evaluated (EMA assessment report, p. 47)

Full method, every step sourced →

NOAEL / key findings
13-week monkey NOAEL 100 mg/kg per dose, the highest dose evaluated
“Following administration for 13 weeks, the NOAEL was considered to be 100 mg/kg per dose, the highest dose evaluated (sex combined mean Cmax of 4.88 mg/mL and AUC of 237 h•mg/mL).”
✓ VerifiedEMA assessment report, p. 47Source ↗

Risksopen answer page →

Immune & cytokine safety
No cytokine production by human PBMCs with soluble or immobilized antibody at 10-100 µg/mL
“Upon exposure of PBMCs to retifanlimab concentrations of 10 µg/mL and 100 µg/mL (ie, 10-200 times higher than the positive control antibody OKT3), no cytokine production was observed with all three conditions of retifanlimab presentation.”
✓ VerifiedEMA assessment report, p. 33Source ↗
Biodistribution & persistence
Human TCR staining limited to lymphocytes in expected tissues
“Staining was observed in expected tissues and was limited to lymphocytes.”
✓ VerifiedFDA multi-discipline review, p. 41Source ↗
Modality-specific risk
Potential for severely enhanced immune responses to infection with PD-1 blockade
“Based on data from the literature and its mechanism of action, there may be a potential for severely enhanced immune responses to infection following treatment with retifanlimab.”
✓ VerifiedFDA multi-discipline review, p. 30Source ↗
Anti-drug antibodies: animals
13-week monkey study: ADA in 10/30 animals; reduced exposure in 8/10, 3/10, 1/10 at 5, 20, 100 mg/kg
“Anti-drug antibodies (ADA) were detected in 10/30 animals. After repeat administration, changes in INCMGA00012 exposure (serum) were measured in 8/10, 3/10, and 1/10 animals in 5, 20, and 100 mg/kg dosing groups, respectively.”
✓ VerifiedFDA multi-discipline review, p. 37Source ↗
Anti-drug antibodies: patients
MCC: treatment-emergent ADA 2.8% (3/106); neutralizing in 2 of 3
“The incidence of retifanlimab treatment-emergent ADAs was 2.8% (3/106) using a bridging enzyme‑linked immunosorbent assay following a median exposure time of 312 days. Neutralizing antibodies were detected in 2 of 3 patients with treatment-emergent ADAs.”
✓ VerifiedUS prescribing informationSource ↗
Label warnings
  • Severe and Fatal Immune-Mediated Adverse Reactions
  • Infusion-Related Reactions
  • Complications of Allogeneic HSCT
  • Embryo-Fetal Toxicity
Immune-mediated reactionsHypersensitivity & infusion reactionsEmbryo-fetal toxicity
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
Not stated in public reviews
Why it's blank

The public FDA and EMA reviews of Zynyz don't say how the first human dose was chosen. That rationale is in the IND, which is confidential, so it is missing for most approved products.

How it's usually set for monoclonal antibodies

ADCs with cytotoxic payloads follow the S9 rules (1/10 STD10 or 1/6 HNSTD of the ADC, scaled by body surface area). For immune agonists, a MABEL-based start dose should be considered instead.

“For example, for cytotoxic payloads, the starting clinical dose can be determined using either 1/10th the Severely Toxic Dose (STD) in 10% of animals (STD10) in rodents or 1/6th the Highest Non- Severely Toxic Dose (HNSTD) in non-rodents, for the ADC based on body surface area, depending on which is the most appropriate and/or sensitive species.”
✓ VerifiedICH 2018: ICH S9 Guideline: Nonclinical Evaluation for Anticancer…, p. 15Source ↗
This product's starting point

NOAEL / key findings: 13-week monkey NOAEL 100 mg/kg per dose, the highest dose evaluated (EMA assessment report, p. 47)

Full method, every step sourced →

Longest repeat-dose systemic studies

Longest repeat-dose study and recovery
13-week GLP cynomolgus monkey (IV, once weekly); no recovery phase
“T18-02-10 (GLP) Cynomolgus monkeys/ 5M 5F 0, 5, 20, 100 mg/kg IV 30 min. infusion 13 weeks, no recovery”
✓ VerifiedEMA assessment report, p. 47Source ↗
Pivotal GLP studies
GLP cynomolgus monkey 4-week (0-150 mg/kg, 10-week recovery) and 13-week (0-100 mg/kg) studies, weekly IV infusion
“Pivotal repeat-dose toxicity studies with retifanlimab in cynomolgus monkeys include a 4-week study (doses: 0, 10, 40, or 150 mg/kg) with a 10-week recovery period (T19-01-03) and a 13 week study (doses: 0, 5, 20, 100 mg/kg; T18 02-10).”
✓ VerifiedEMA assessment report, p. 46Source ↗

DART package

Species: DART
Not conducted; not required for advanced cancer therapeutics (ICH S9)
“Standard fertility and early embryonic development, embryofetal development and pre- and postnatal development studies have not been conducted with retifanlimab as not required for advanced cancer therapeutics (ICH S9 2009).”
✓ VerifiedEMA assessment report, p. 48Source ↗
Reproductive & developmental
Not conducted; weight-of-evidence reproductive risk assessment submitted instead
“Reproductive and developmental toxicology studies were not conducted with retifanlimab. Instead, the Applicant submitted a weight-of-evidence reproductive risk assessment for retifanlimab.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
PPND / ePPND: when
Not conducted: not required for advanced cancer therapeutics (ICH S9)
“Standard fertility and early embryonic development, embryofetal development and pre- and postnatal development studies have not been conducted with retifanlimab as not required for advanced cancer therapeutics (ICH S9 2009).”
✓ VerifiedEMA assessment report, p. 48Source ↗

Carcinogenicity

Species: carcinogenicity
Not conducted; not warranted
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Carcinogenicity model
Not conducted; not warranted
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Carcinogenicity timing
Not required
“Carcinogenicity studies were not warranted.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗

Safety marginopen answer page →

Safety margin at NOAEL
Monkey top dose 150 mg/kg corresponds to 26-fold the proposed MRHD exposure
“Across the studies, animals were given weekly doses ranging between 1 and 150 mg/kg (150 mg/kg corresponds to 26-fold the proposed MRHD exposure) administered via IV infusion.”
✓ VerifiedEMA assessment report, p. 50Source ↗
NOAEL / key findings
13-week monkey NOAEL 100 mg/kg per dose, the highest dose evaluated
“Following administration for 13 weeks, the NOAEL was considered to be 100 mg/kg per dose, the highest dose evaluated (sex combined mean Cmax of 4.88 mg/mL and AUC of 237 h•mg/mL).”
✓ VerifiedEMA assessment report, p. 47Source ↗

Efficacy evidenceopen answer page →

Efficacy evidence
Retifanlimab binding to peripheral T cells (flow cytometry) in cynomolgus monkey studies
“These studies in monkeys included the evaluation of a pharmacodynamic endpoint – retifanlimab binding to peripheral T cells by flow cytometry”
✓ VerifiedEMA assessment report, p. 29Source ↗
Why that model
No cross-reactivity with non-primate PD-1, so in vivo studies limited to cynomolgus monkeys
“Retifanlimab cross reacts with PD-1 from cynomolgus and rhesus monkeys, but not with PD-1 from non￾primate species. Thus, in vivo studies were limited to cynomolgus monkeys with retifanlimab delivered by IV infusion.”
✓ VerifiedEMA assessment report, p. 29Source ↗
Reviewer's view of the efficacy data
EMA: no in vivo proof-of-concept models presented; not considered needed given experience with PD-1 inhibitors
“No in vivo models were presented to demonstrate proof of concept. These are not considered needed based on the experience with PD-1 inhibitors.”
✓ VerifiedEMA assessment report, p. 49Source ↗

Flexibilityopen answer page →

Flexibility accepted
DARTAccepted
No animal reproductive or developmental toxicity studies; weight-of-evidence assessment instead
Why: Weight-of-evidence approach per ICH S6(R1) and ICH S9 · Within the guideline · Weight of evidence
“Embryo-fetal developmental toxicology studies were not conducted with retifanlimab. Rather, consistent with the alternative approach to providing information on the potential for reproductive toxicity described in ICH S6(R1) and ICH S9, the Applicant provided a weight-of-evidence assessment of the potential reproductive toxicity of retifanlimab.”
✓ VerifiedFDA multi-discipline review, p. 29Source ↗
“The lack of carcinogenicity, genotoxicity, reproductive and developmental studies were adequately justified.”
✓ VerifiedEMA assessment report, p. 51Source ↗
Efficacy modelAcceptedBeyond the letter
No in vivo proof-of-concept models; mode of action supported in vitro only
Why: Not needed given experience with PD-1 inhibitors · Class precedent
“The mode of action of retifanlimab was supported by in vitro studies. No in vivo models were presented to demonstrate proof of concept.”
✓ VerifiedEMA assessment report, p. 49Source ↗
“These are not considered needed based on the experience with PD-1 inhibitors.”
✓ VerifiedEMA assessment report, p. 49Source ↗

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