throbber

`
`DEPARTMENT OF HEALTH & HUMAN SERVICES
`
`
`
`
`
`
`Public Health Service
`
`Food and Drug Administration
`
`Rockville, MD 20857
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` NDA APPROVAL
`
`
`
`
`
`
`
`
`NDA 22-253
`NDA 22-254
`
`
`Schwarz Biosciences, Inc.
`Attention: Alan Blumberg
`Senior Director, US Regulatory Affairs
`P.O. Box 110167
`Research Triangle Park, NC 27709
`
`
`Dear Mr. Blumberg:
`
`Please refer to your new drug applications (NDAs) dated September 28, 2007, received
`September 28, 2007, submitted under section 505(b) of the Federal Food, Drug, and Cosmetic
`Act (FDCA), for Vimpat (lacosamide) Tablets, 50 mg, 100 mg, 150 mg, and 200 mg, and
`Vimpat (lacosamide) Injection, 200 mg per 20 ml.
`
`
`
`
`
`
`
`
`
`We acknowledge receipt of your additional submissions dated:
`
`
`November 26, 2007 March 20, 2008 April 30, 2008
`December 13, 2007 April 3, 2008
`May 9, 2008
`January 23, 2008
`April 9, 2008
`May 27, 2008
`February 13, 2008
`April 14, 2008
`June 11, 2008
`February 22, 2008
`April 18, 2008
`July 11, 2008 (2)
`
`These new drug applications provide for the use of Vimpat (lacosamide) as follows:
`
`• Vimpat (lacosamide) Tablets as adjunctive therapy in the treatment of partial-onset seizures
`
`in patients with epilepsy aged 17 years and older.
`
`July 17, 2008
`July 30, 2008
`August 1, 2008
`August 14, 2008
`August 27, 2008
`
`September 4, 2008
`September 23, 2008
`October 15, 2008
`October 21, 2008
`
`
`
`• Vimpat (lacosamide) Injection as adjunctive therapy in the treatment of partial-onset seizures
`
`in patients with epilepsy aged 17 years and older when oral administration is temporarily not
`feasible.
`
`
`We have completed our review of these applications, as amended. They are approved, effective
`on the date of this letter, for use as recommended in the enclosed agreed-upon labeling text.
`
`

`

`NDA 22-253
`NDA 22-254
`Page 2
`
`
`Your applications for Vimpat (lacosamide) Tablets and Injection (NDA 22-253, 22-254) were
`not referred to an FDA advisory committee because your products are members of the class of
`previously approved anti-epileptic drugs and the products did not pose unique concerns beyond
`those applicable to other members of this class.
`
`
`REQUIRED PEDIATRIC ASSESSMENTS
`
`Under the Pediatric Research Equity Act (PREA) (21 U.S.C. 355c), all applications for new
`active ingredients, new indications, new dosage forms, new dosing regimens, or new routes of
`administration are required to contain an assessment of the safety and effectiveness of the
`product for the claimed indication(s) in pediatric patients unless this requirement is waived,
`
`deferred, or inapplicable.
`
`We are waiving the pediatric study requirement for ages 0 to 1 month for these applications
`because necessary studies are impossible or highly impracticable because there are too few
`children with partial onset seizures in this age group to study.
`
`In addition, we are deferring submission of your pediatric studies in partial onset seizures for
`ages 1 month up to 17 years for this application because this product is ready for approval for use
`in adults and the pediatric studies have not been completed.
`
`Your deferred pediatric studies required by section 505B(a) of the FDCA are required
`postmarketing studies. The status of these postmarketing studies must be reported annually
`according to 21 CFR 314.81 and section 505B(a)(3)(B) of the FDCA. These required studies are
`
`listed below.
`
`
`
`1. Deferred pediatric studies under PREA for the adjunctive treatment of partial onset seizures
`in pediatric patients ages 1 month up to 17 years.
`
`
`
`Final Report Submission: July 2013
`
`
`Submit final study reports to these NDAs. For administrative purposes, all submissions related
`to these required pediatric postmarketing studies must be clearly designated “Required
`Pediatric Assessment.”
`
`
`RISK EVALUATION AND MITIGATION STRATEGY (REMS) REQUIREMENTS
`
`Title IX, Subtitle A, Section 901 of Food and Drug Administration Amendments Act of 2007
`(FDAAA) amends the FDCA to authorize FDA to require the submission of a Risk Evaluation
`and Mitigation Strategy (REMS) if FDA determines that such a strategy is necessary to ensure
`that the benefits of the drug outweigh the risks (section 505-1(a)). This provision took effect on
`March 25, 2008.
`
`In accordance with section 505-1 of the FDCA, as one element of a REMS, FDA may require the
`development of a Medication Guide as provided for under 21 CFR Part 208. Pursuant to 21 CFR
`Part 208, FDA has determined that Vimpat (lacosamide) poses a serious and significant public
`health concern requiring the distribution of a Medication Guide. The Medication Guide is
`
`

`

`NDA 22-253
`NDA 22-254
`Page 3
`
`necessary for patients’ safe and effective use of Vimpat (lacosamide). FDA has determined that
`Vimpat (lacosamide) has serious risks of which patients should be made aware because
`information concerning the risks could affect patients' decisions to use Vimpat (lacosamide). In
`addition, patient labeling could help prevent serious adverse effects related to the use of these
`products. Vimpat (lacosamide) may increase the risk of suicidal thoughts or behavior in patients
`taking anti-epileptic drugs for any indication. Under 21 CFR 208, you are responsible for
`ensuring that the Medication Guide is available for distribution to patients who are dispensed
`Vimpat (lacosamide).
`
`Your proposed REMS, submitted on October 17, 2008, in an electronic communication, is
`approved. The REMS consists of the Medication Guide included with this letter and the
`timetable for submission of assessments of the REMS included in your October 17, 2008
`submission.
`
`Prominently identify submissions containing REMS assessments or proposed modifications of
`the REMS with the following wording in bold capital letters at the top of the first page of the
`submission:
`
`• NDA 22-253 & 22-254 REMS ASSESSMENT
`
`• NEW SUPPLEMENT FOR NDA 22-253 & 22-254
`
`PROPOSED REMS MODIFICATION
`< other supplement identification > [if included]
`<REMS ASSESSMENT> [if included]
`
`
`POSTMARKETING REQUIREMENTS UNDER 505(o)
`
`
`Title IX, Subtitle A, Section 901 of FDAAA amends the FDCA to authorize FDA to require
`holders of approved drug and biological product applications to conduct postmarketing studies
`and clinical trials for certain purposes, if FDA makes certain findings required by the statute
`(section 505(o)(3)(A), 21 U.S.C. 355(o)(3)(A)).
`
`We have determined that an analysis of spontaneous postmarketing adverse events reported
`under subsection 505(k)(1) of the FDCA will not be sufficient to assess the known serious risk of
`
`developmental neurotoxicity.
`
`Furthermore, the new pharmacovigilance system that FDA is required to establish under section
`505(k)(3) has not yet been established and is not sufficient to assess this serious risk.
`
`Therefore, based on appropriate scientific data, FDA has determined that you are required,
`
`pursuant to section 505(o)(3) of the FDCA, to conduct the following study:
`
`
`
`2. A nonclinical study in rats to examine the effects of Vimpat (lacosamide) on brain
`development during the prenatal and early postnatal periods using more sensitive techniques
`for assessing central nervous system structure and function than were employed in the
`standard pre- and postnatal development study. You should consider the use of multiple
`daily dosing as a means of achieving higher plasma drug exposures during pregnancy and to
`better mimic the human exposure pattern.
`
`

`

`NDA 22-253
`NDA 22-254
`Page 4
`
`
`The timetable you have submitted on October 28, 2008 states that you will conduct this study
`according to the following schedule:
`
`
`Within 6 months of approval
`Protocol Submission:
`
`Final Report Submission: Within 30 months of approval
`
`
`Submit protocols to your IND 57,939 with a cross-reference letter to these new drug applications
`(NDA) 22-253 and 22-254. Submit final reports to your NDAs 22-253 and 22-254. Please use
`the following designators to label prominently all submissions, including supplements, relating
`to this postmarketing study as appropriate:
`
`• Required Postmarketing Protocol under 505(o)
`• Required Postmarketing Final Report under 505(o)
`• Required Postmarketing Correspondence under 505(o)
`
`Section 505(o)(3)(E)(ii) of the FDCA requires you to report periodically on the status of any
`study or clinical trial required under this section. This section also requires you to periodically
`report to FDA on the status of any study or clinical trial otherwise undertaken to investigate a
`safety issue. Section 506B of the FDCA, as well as 21 CFR 314.81(b)(2)(vii) requires you to
`report annually on the status of any postmarketing commitments or required studies or clinical
`trials.
`
`FDA will consider the submission of your annual report under section 506B and 21 CFR
`314.81(b)(2)(vii) to satisfy the periodic reporting requirement under section 505(o)(3)(E)(ii)
`
` provided that you include the elements listed in 505(o) and 21 CFR 314.81(b)(2)(vii). We
`remind you that to comply with 505(o), your annual report must also include a report on the
`status of any study or clinical trial otherwise undertaken to investigate a safety issue. Failure to
`submit an annual report for studies or clinical trials required under 505(o) on the date required
`will be considered a violation of FDCA section 505(o)(3)(E)(ii) and could result in enforcement
`action.
`
`
`POSTMARKETING COMMITMENTS
`
`We acknowledge your written commitment to conduct the following postmarketing study as
`described in your submission dated October 28, 2008, as outlined below:
`
`
`
`3. In vitro data to determine which enzymes may be involved in the metabolism of Vimpat
`
`(lacosamide) in addition to CYP2C19.
`
`
`Final Report Submission: within 18 months of approval
`
` (b) (4)
` Submit nonclinical and chemistry, manufacturing, and
`Submit the protocol to your IND
`.
`controls protocols and all study final reports to these NDAs. In addition, under 21 CFR
`314.81(b)(2)(vii) and 314.81(b)(2)(viii), you should include a status summary of each
`commitment in your annual report to these NDAs. The status summary should include expected
`summary completion and final report submission dates, any changes in plans since the last
`annual report, and, for clinical studies, number of patients entered into each study.
`
`

`

`NDA 22-253
`NDA 22-254
`Page 5
`
`All submissions, including supplements, relating to these postmarketing study commitments
`should be prominently labeled:
`
`• Postmarketing Study Commitment Protocol
`
`
`• Postmarketing Study Commitment Final Report
`
`• Postmarketing Study Commitment Correspondence
`
`
`
`HIGHLIGHTS WAIVER
`
`
`We are waiving the requirements of 21 CFR 201.57(d)(8) regarding the length of Highlights of
`prescribing information. This waiver applies to all future supplements containing revised
`labeling unless we notify you otherwise.
`
`CONTENT OF LABELING
`
`
`
`As soon as possible, but no later than 14 days from the date of this letter, please submit the
`content of labeling [21 CFR 314.50(l)] in structured product labeling (SPL) format as described
`at http://www.fda.gov/oc/datacouncil/spl.html that is identical to the enclosed labeling (text for
`the package insert and Medication Guide). Upon receipt, we will transmit that version to the
`
`National Library of Medicine for public dissemination. For administrative purposes, please
`designate this submission, “SPL for approved NDA 22-253 and NDA 22-254.”
`
`
`CARTON AND IMMEDIATE CONTAINER LABELS
`
`
`
`Submit final printed carton and container labels as soon as they are available, but no more than
`30 days after they are printed. Please submit these labels electronically according to the
`guidance for industry titled Providing Regulatory Submissions in Electronic Format – Human
`Pharmaceutical Product Applications and Related Submissions Using the eCTD Specifications
`(October 2005). Alternatively, you may submit 12 paper copies, with 6 of the copies individually
`mounted on heavy-weight paper or similar material. For administrative purposes, designate this
`submission “Final Printed Carton and Container Labels for approved NDA 22-253 and
`NDA 22-254” Approval of this submission by FDA is not required before the labeling is used.
`
`In addition, we note your agreement on October 28, 2008 to address and make the following
`changes into your carton and immediate container labels:
`
`General
`(b) (4)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`NDA 22-253
`NDA 22—253
`NDA 22-254
`NDA 22—254
`Page 6
`Page 6
`
`
`(b) (4)
`
`
`
`
`
`
`
`
`
`
`
`
`
`(b) (4)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`(b) (4)
`
`

`

`NDA 22-253
`NDA 22-254
`Page 7
`
`
`(b) (4)
`
`
`
`
`
`
`
`
`Marketing the products with FPL that is not identical to the approved labeling text including the
`changes noted above may render the product misbranded and an unapproved new drug.
`
`CONTROLLED SUBSTANCE CLASS
`
`
` We have recommended that this product be scheduled under the Controlled Substances Act. We
`
`remind you of the following statement that appears on the Form FDA 356h, “If this application
`applies to a drug product that FDA has proposed for scheduling under the Controlled Substances
`Act, I agree not to market the product until the Drug Enforcement Administration makes a final
`scheduling decision.” Once a final scheduling decision is made, your label must be amended to
`
`reflect the schedule.
`
`
`EXPIRATION DATE (Injection)
`
`
`We grant the proposed 36 month drug product expiry, when stored at controlled room
`
`temperature, for lacosamide 200 mg/20 mL injection packaged in 20 mL type I colorless glass
`vials with a grey rubber stopper coated with a
`and aluminum overseal.
`
`PROMOTIONAL MATERIALS
`
`
`You may request advisory comments on proposed introductory advertising and promotional
`labeling. To do so, submit, in triplicate, a cover letter requesting advisory comments, the
`proposed materials in draft or mock-up form with annotated references, and the package insert(s)
`to:
`
`
`Food and Drug Administration
`Center for Drug Evaluation and Research
`Division of Drug Marketing, Advertising, and Communications
`5901-B Ammendale Road
`Beltsville, MD 20705-1266
`
`
`As required under 21 CFR 314.81(b)(3)(i), you must submit final promotional materials, and the
`package insert(s), at the time of initial dissemination or publication, accompanied by a Form
`
`FDA 2253. For instruction on completing the Form FDA 2253, see page 2 of the Form. For
`more information about submission of promotional materials to the Division of Drug Marketing,
`Advertising, and Communications (DDMAC), see www.fda.gov/cder/ddmac.
`
` LETTERS TO HEALTH CARE PROFESSIONALS
`
`If you issue a letter communicating important safety related information about this drug product
`(i.e., a “Dear Health Care Professional” letter), we request that you submit an electronic copy of
`the letter to both this NDA and to the following address:
`
`
`
`
`(b) (4)
`
`

`

`NDA 22-253
`NDA 22-254
`Page 8
`
`
`
`MedWatch
`
`Food and Drug Administration
`
`Suite 12B05
`
`5600 Fishers Lane
`
`Rockville, MD 20857
`
`
`REPORTING REQUIREMENTS
`
`
`We remind you that you must comply with reporting requirements for an approved NDA (21
`CFR 314.80 and 314.81).
`
`MEDWATCH-TO-MANUFACTURER PROGRAM
`
`
`The MedWatch-to-Manufacturer Program provides manufacturers with copies of serious adverse
`event reports that are received directly by the FDA. New molecular entities and important new
`biologics qualify for inclusion for three years after approval. Your firm is eligible to receive
`copies of reports for this product. To participate in the program, please see the enrollment
`instructions and program description details at www.fda.gov/medwatch/report/mmp.htm.
`
`
`If you have any questions, call Jacqueline H. Ware, Pharm.D., Supervisory Regulatory Project
`Manager, at (301) 796-1160.
`
`
`
`
`Sincerely,
`
`{See appended electronic signature page}
`
`Ellis F. Unger, M.D.
`Deputy Director (Acting)
`Office of Drug Evaluation I
`Center for Drug Evaluation and Research
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Enclosures (FDA Approved Labeling Text, Medication Guide, and REMS document)
`
`
`
`
`
`
`
`
`
`
`

`

`---------------------------------------------------------------------------------------------------------------------
`This is a representation of an electronic record that was signed electronically and
`this page is the manifestation of the electronic signature.
`---------------------------------------------------------------------------------------------------------------------
`/s/
`
`---------------------
`Ellis Unger
`
`10/28/2008 08:00:13 PM
`
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket