throbber
8027.4
`
`Lilly Research Laboratories
`A Division of Eli Lilly and Company
`
`Lilly Corpo,ale Center
`Indianapolis. Indiana 46285
`(317) 276-2C00
`
`November 18, 1998
`
`Food and Drug Administration
`Center for Drug Evaluation and Research
`Division of Oncologic Drug Products, HF])- 150
`Ann: Ms. Linda McCollum, CSO
`1451 Rockville Pike
`Rockville, Maryland 20852-1448
`
`INID # 40,061 - LY231514
`End-of-Phase 2 Meeting Minutes
`Compound LY231514 (MTA, Multitargeted Antifolate)
`
`Serial No.: 137
`
`Enclosed are Lilly's minutes for the End-of-Phase 2 meetings held on September 23
`(Biopharmaceutics) and September 25 (Clinical) 1998 to discuss LY23 1514 with members
`of the Division of Oncologic Drug Products. We sincerely appreciate the willingness of
`the Division members to meet with us and to offer advice regarding the development of
`this investigational drug.
`
`We respectfUlly request a copy of the Division's meeting minutes when they are available.
`
`Please call Mr. John Worzalla at (317) 276-5052 or me at (317) 277-3799 if there are any
`questions. Thank you for your continued cooperation and assistance.
`
`Sincerely,
`
`ELI LILLY AN) COMPANY
`
`Gregory It Brophy, Ph.D.
`Director
`U.S. Regulatory Affairs
`
`CONFIDENTIAL
`ELAP00008700
`
`TX 392
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`DEPARTMENT OF HEALTH AND HUMAN SERVICES
`PUBLIC HEALTH SERVICE
`FOOD AND DRUG ADMINISTRATION
`INVESTIGATIONAL NEW DRUG APPLICATION (IND)
`(7171.5 21, CODE OFFEDER4L REeL/LA 77CN$ (GAF) PART 312)
`I. NAME OF SPONSOR
`
`ELI LILLY AND COMPANY
`a ADDRESS (Nimter. Sbor, Cl,. Ste and Zip code)
`Lilly Corporate Center
`Indianapolis, IN 46285
`
`8027.5
`
`Eçka
`SeeOMBsc,watonps.is,se.
`
`TZtthat
`invegaSn is in elIect (21 Cm 12.4Q).
`2. DATE OF SuBMISSION
`November18, 1998
`
`4. TELEPHONE NUMBER
`(&tia%,e Code)
`
`(317) 276-2000
`
`5. NAME(S) OF DRUG (ir,cludeallavnllablonames made, Gened Chen*al, code)
`
`6. IND NUMBER (YusOaSSfl&
`
`Compound LY231 514 Disodiuni (MTA)
`
`IND 40,061
`
`7. INDICATION(S) (Cowmdbythissuzwm'sskn)
`
`Cancer
`
`8. PHASE(S) OF CLINICAL INVESTIGATION TO BE CONDUCTED: U PHASE I U PHASE 2 U PHASES U OTHER
`
`(Specif)
`9. LIST NUMBERS OF ALL INVESTIGATIONAL NEW DRUG APPLICATIONS (21 CFR Part 312), NEW DRUG OR AN11BIO11C APPLICATIONS
`(21 CRR Part 314), DRUG MASTER FILES I21 CFR Part 314.420), AND PRODUCT LICENSE APPLICATIONS (21 CFR Pair 601) REFERRED
`TO IN THIS APPLICATION.
`
`-
`
`NA
`
`10. MiD submission should be consecutively numbered. The Initial IND should be numbered
`"Serial number 000. The next submission (e.g., amendmen4 repor4 or con'espondence)
`should be numbered seziai Number OO1. Subiequent submission should be
`numbered consecutively in the order in which they are submitted.
`
`SERL NUMBER
`
`II. THIS SUBMISSION CONTAINS THE FOLLOtMNG:
`U INrTIAL INVES11GATIONAL NEW DRUG
`
`that apply)
`(Check
`APPLICATION (IND)
`
`U RESPONSE TO CLiNICAL HOLD
`
`PROTOCOL AMENDMENT(S):
`U NEW PROTOCOL
`U CHANGE IN PROTOCOL
`U NEW INVESTIGATOR
`
`AMENDMENT(S):
`INFORMATION
`U CHEMISTRYIMICROBIOLOGY
`U PHARMACOLOGWrO)OCOLOGY
`U CUNICAL
`
`ND SAFETY REPORT(S):
`U INITiAL WRITTEN REPORT
`U FOLLOW-UP TO A WRITTEN REPORT
`
`U ANNUAL REPORT
`U RESPONSE TO FDA REQUEST FOR INFORMATION
`U OTHER
`U REQUEST FOR REINSTATEMENT OF ND THAT
`IS WITHDRAWN,
`INACTIVATED, TERMINATED OR DISCONTINUED
`
`s=t-rr-
`
`..
`
`-c.;..?jr.Lesr t*e'U*
`
`rr::-',S,t'-rto7t.,.,..
`
`CHECK ONLY IF APPUCAE&E
`
`.---r-1%...
`
`.'*ta
`
`.
`
`GENERAL CORRESPONDENCE
`
`t''-
`
`(Spociv)
`
`z:: to
`
`.
`
`_%tt:2t?..
`-
`-
`- ---- fl_s
`
`_-
`
`.
`
`CDRJDBINDa'OGD RECEIPT STAMP
`
`FORFDAUSEONL'Y
`DDR RECEIPT STAMP
`
`.
`
`IND NUMBER ASSIGNED:
`
`DIViSION ASSIGNMENT:
`
`FORM FDA 1671 (1297)
`
`PREVIOUS EDmON IS OBSOLETE.
`
`CONFIDENTIAL
`ELAP000087O1
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`iz
`
`CONTENTS OF APPLICATION
`This application ccntuins the following items: (Check all that apply)
`
`O 1. Form FDA 1571(21 CFR 312.23(a)(1)J
`0 2. Table of Contents (21 CFR 312.23(a)(2)1
`O 3.
`Introductory statement (21 CFR 312.23(a)(3fl
`O 4. General Investigational plan £21 CFR 31223(a)(3))
`U 5. Investigators brochure [21 CFR 312.23(aX5)]
`O 6. Protocol(s) [21 CFR 312.23(a)(6)]
`O a. Study protocol(s) 121 CFR 312.23(a)(6fl
`O b.
`Investigator data (2ICFR 312.23(aX6)(iii)(b)J or completed Form(s) FDA 1572
`0 c. Facilities data [21 CER S12.23(a)(5)(iii)çb)3 or completed Form(s) FDA 1572
`C d.
`Institutional Review Board data £21 CFR 312.23(a)(exiii)(b)J or completed Form(s). FDA 1572
`U 7. Chemistry, manufacturing, and control data (21 CFR 3l2.23(aX7)]
`O
`Ci Environmental assessment or claim for exclusion (21 CER 312.23(a)(7)(W)(e)1
`O 8. Pharmacology and toxicology data 121 CFR 312.23(a)(8fl
`o 9. Previous human experIence [21 CFR 312.23(a)(9)J
`U 10. Additional information (21 CFR 312.23(a)(1O)1
`
`13, IS ANY PART OF THE CLINICAL STUDY TO BE CONDUCTED BYA CONTRACT RESEARCH ORGANIZATION? U YES Ci NO
`
`IF YES, WILL ANY SPONSOR OBLIGATIONS BE TRANSFERRED TO THE CONTRACT RESEARCH ORGANIZATION? U YES U NO
`
`NA
`
`IF YES, ATTACH A STATEMENT CONTAINING THE NAME AND ADDRESS OF THE CONTRACT RESEARCH ORGANIZATION
`IDENTIFICATION OF THE CLINICAL STUDY, AND A LISTING OF THE OBUGATIONS TRANSFERRED.
`
`14 NAME AND TITLE OF THE PERSON RESPONSIBLE FOR MONITORING THE CONDUCT AND PROGRESS OF THE CLINICAL
`INVESTIGATIONS
`
`Steven J. Nicol, M.D.
`
`IS. NAME(S) AND TITLE(S) OF THE PERSON(S) RESPONSIBLE FOR REVIEW AND EVALUATION OF INFORMATION RELEVANT TO THE
`SAFETY OFTHE DRUG
`
`Same as #14 Above
`
`I agree not to begIn clinIcal Investigations untIl 30 days alter FDA's receIpt of the (ND unless I receIve earlier notificatIon by FDA that the studies
`may begin. I also agree not to begin er continue clinical Investigations covered by the l?W Itthose studies are placed on clinIcal 1mM. I agree.
`that an InstItutional Review Board (IRS) that compiles with the requIrements act fourth in 21 CFR Putt 68 wIll be responalbie for Initial and
`continuing review and approval of each of the studies In the proposed clInIcal Investigation. I agree to conduct the InvestigatIon in accordance
`with all other applicable regulatory requirements,
`16. NAME OF SPONSOR OR SPONSORS AUThORIZED
`REPRESENTATIVE
`
`17. SIGNATURE OF SPONSOR OR SPONSOR'S AUTHORIZED
`REPRESENTATIVE
`
`Gregory tBroph Ph.D., Director
`
`IS. ADDRESS(NuntoçSeoor,ClçSeteancJZipCoW)
`
`Eli Lilly and Company
`Lilly Corporate Center
`Indianapolis, IN 48285
`
`UMBE
`. TELEPHON
`Ame COC)
`
`20. DATE
`
`(317) 277-3799
`
`11/18198
`
`ARNlNG; A wIflMIy false statement Is a criminal offense. U.S.C. TItle IS, Sec. 1001.)
`Public repoding burden tot this collection of information is estimated to average 100 hours per response, InCOJdIng the thne for reviewing Inatluctions, searching
`existIng data sources, gathering and maintaining the data needs, and completing reviewing the collection of Information. Send comments regardIng ttIs burden
`estimate or any other aspect of th1 collection of Intormatlon, Including suggestions ton reducing tilts burden to:
`
`01*15 Repoits Clearance Officer
`Papeiwotic Reduction Project 091 O'at4
`Hubert H. Humphrey BuIldIng, Room 53141
`ZO Independence Avenue, S.W.
`I
`Washington, DC
`
`FORM FDA 1511(1197)
`
`"Ass agency may not conduct or Sponsor, and a person Is not required to respond to. a collection
`of Information unless It dIsplays a currently valid 0MB control number."
`
`Please DO NOT REmUIN thIs applIcation to this address.
`
`PAGE 2 OF 2
`
`CONFIDENTIAL
`ELAP000087O2
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`This document contains trade secrets, or
`commercial or financial information,
`privileged or confidential delivered
`in confidence and reliance that such
`information will not be made available
`to the public without express written
`consent of Eli Lilly and Company
`
`8028
`
`CONFIDENTIAL
`ELAP00008T03
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8029
`
`LY231614 (MTA} End of Phase 2 Meeting with the FDA
`Biopharmaceutics Issues Wed. Sept. 23, 1998 at FDA
`
`FDA Participants: Division of Oncoloay Druci Products
`Robert White, M.D., Medical Reviewer
`Atiq Rahman, Ph.D., Biopharm Team Leader
`Liang Zhou, Ph.D., Chemistry Team Leader
`Linda McColluni, Consumer Safety Officer
`Lilly Participants:
`Steven Hamburger, Ph.D., U.S. Regulatory Affairs
`Robert D Johnson, Ph.D., Pharmacokineticist
`Mary Pat Knadler, Ph.D., Drug Disposition
`Clet Niyikiza, Ph.D., Statistician
`David Seitz, M.D., Ph.D., Medical Advisor
`Jackie Walling, Ph.D., Director of Science, MTA Team
`John Worzalla, U.S. Regulatory Affairs
`Lilly Consultant:
`Sharyn Baker, PharrmD., Cancer Therapy and Research Center, San Antonio
`Cancer Institute
`
`Meeting Request Submission Date: July 13, 1998
`Briefing Document Submission Date: July 29, 1998
`Additional Submission Dates: Sept. 8, 1998
`
`Meeting Minutes:
`
`Issue 4: MTA and NSAIDS
`
`The FDA showed the following acetate:
`'MTA and NSAIDS - Currently the Phase 2 studies and all registration directed
`studies have excluded those patients who have a need for chronic administration
`of NSAIDS or aspirin. Do you agree that if this study shows no pharmacokinetic
`interaction that this will be sufficient evidence to take the course of action
`outlined, i.e., remove the exclusion criterion, and to prevent this exclusion from
`being part of the label?"
`
`4A NO. The decision to remove exclusion criterion for Ibuprofen will
`depend on the outcome of the study. Depending on the P1< parameter
`variability, sample size of the proposed interactions study may be
`inadequate to rule out absence of interaction between MTA and Ibuprofen.
`Please submit a detailed protocol for Agency Review.
`
`CONFIDENTIAL
`ELAP0000S7O4
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8030
`
`Acetate #1
`
`Evaluation of response in solid tumors
`
`"Important note:
`Data from the NCI US support simplifying
`response evaluation through the use of
`unidimensional measurements and the sum of the
`longest diameters instead of the conventional
`method using two measurements and the sum of
`the products. This new approach is implemented
`in the present document."
`
`WHO criteria for Response Evaluation in solid Tumors
`August 1998
`
`CONFIDENTIAL
`ELAP000087O5
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8031
`
`Acetate #2
`
`Comparison of nnidimensional (New) and WHO
`response criteria in the same patients
`
`CR
`
`Pit
`
`SI)
`
`PU
`
`KR
`
`Brst (n=48)
`WHO
`New
`Uzstr 572)
`WHO
`New
`8.3211 (n3I)
`WHO
`New
`McIanana(nI9O)
`WHO
`New
`NSCLC (r24>
`WHO
`Ncw
`I_elan (n3 I)
`WHO
`New
`Sarnm(n2)
`WHO
`New
`hary (n4)
`
`New
`
`4
`4
`
`4
`4
`
`12
`12
`
`9
`9
`
`0
`0
`
`I
`
`I
`
`I
`
`I
`
`0
`0
`
`22
`22
`
`36
`40
`
`10
`0
`
`37
`34
`
`4
`
`4
`
`6
`
`5
`
`4
`
`5
`
`7
`
`6
`
`54%
`54%
`
`23%
`26%
`
`71%
`71%
`
`24%
`23%
`
`27%
`17%
`
`23%
`21%
`
`18%
`21%
`
`16%
`13%
`
`16
`9
`
`IS
`17
`
`13
`58
`
`9
`25
`
`4
`I
`
`9
`8
`
`10
`4
`
`9
`4
`
`James, tEat 1998
`
`CONFIDENTIAL
`ELAP000087O6
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8032
`
`Acetate #3
`
`Folic Acid reduces toxicity of MTA but
`does not diminish antitumor activity in
`L5178/TK-/Hx- Lymphoma
`
`Dose mg/kg ip dailyx 10
`
`95%-100% Tumor
`Inhibition (fl)
`03
`
`30
`
`30
`
`Lethality
`
`100% Lethality
`
`3
`
`300
`
`1000
`
`none at 1000
`
`Low Folate Diet
`
`Standard Diet
`(1.5mg/kg/day folk ach
`
`Low Folate Diet + Folk Acid
`(15mg/kg day -2 to +2)
`
`Mice are more sensitive to MM when folate deprived
`Folate supplementation reduces toxicity but does not reduce anti-tumor activity
`
`CONFIDENTIAL
`ELAP000087O7
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8033
`
`4B The information that will be part of the labeling will be restricted to the
`population and the drug studied.
`4C Pharmacodynamic data (e.g., toxicity) should also be provided.
`
`Dr. White began the discussion asking why studies should not be done with
`aspirin. He mentioned the non-analgesic uses of aspirin for preventing coronary
`artery disease. Dr. Walling explained that one patient showed an apparent
`interaction between MTA and aspirin, and how this might be explained by renal
`impairment in this patient rather than due to drug interaction. Dr. Knadler
`explained that there is data from dogs to suggest a lack of interaction between
`MTA and aspirin. Dr. White asked whether methotrexate was studied in the
`same animal model - he said it would be hard to interpret our animal data
`without having data for methotrexate in the same model. Dr. Rahman asked if
`Lilly wouldn't be interested in having a label not excluding aspirin? There was
`further discussion on MTA interactions with aspirin and ibuprofen. Dr. Rahman
`stated that human data is needed for labeling. Lilly has a chance to present
`MTA with an improved label as compared to methotrexate.
`If Lilly can show a
`lack of interaction with ibuprofen clinically (under study in JMAW) then Dr. White
`felt that it would be important to show if methotrexate acts as a positive control in
`the animal studies Assuming this was shown to be the case, then Dr. White
`would be more comfortable with animal data showing a lack of interaction for
`MTA. Ibuprofen should serve as an example of its class, and the Agency
`recommended that Lilly pick the most frequently used drug in each class.
`
`The following was agreed to as an addition to 4A (shown above):
`4A Ibuprofen as example of class? This requires further discussion in
`the oncologic division of the FDA pertaining to the present rationale, plan
`and data, etc. (make a case)
`
`Next the discussion turned to the cross-over study design using 6 patients per
`arm. Dr. Rahman thought that the sample size was small, but this was
`dependent on the variability of the data. Dr. Johnson said that in Phase I studies
`the intra-patient variability in drug clearance observed was approximately 20%.
`Lilly stated a sample size of 16 to 20 patients would be adequate to secure an
`80% power to detect a difference of 33%. The agency requested a detailed
`protocol including sampling times, statistical analyses, justffication for the
`number of patients, etc.
`
`A discussion on the measurement of MTA in third space fluids was highlighted
`with Dr. Walling informing the FDA that the sponsor has 17 samples from three
`patients (acetates #1 and #2). Lilly does not have a validated assay for samples
`from this source, and there are questions on stability since the samples were
`over one year old. Dr. White suggested that he would be very interested in
`patient data on MTA levels in third space fluids, and that such data might help
`the label by differentiating MTA from methotrexate.
`
`CONFIDENTIAL
`ELAP0000S7O8
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8034
`
`Final resolution of the other issues for point number 4.
`4B and 4C - Final agreement as shown above.
`
`4D Division is particularly concerned with the similarity of MTA with
`methotrexate and this will likely be considered during review.
`
`4E Additional drug interaction information from animal data will be
`considered for review re: classes of NSAIDS - e.g. one from each class
`(supportive information).
`
`Issue 5: Population Pharmacokinetics
`
`The following was agreed:
`5. POPULATION PHARMACOKINETICS - The pharmacokinetic analysis of
`MIA has been completed in all Phase I and many Phase 2 patients. The
`pharmacokinetics of MTA determined from an interim analysis of
`approximately 100 patients after three cycles was highly predictable between
`and within patients. The clinical study reports (CSR's) for the Phase 1
`studies will contain complete pharmacokinetic analyses appropriate for the
`amount of available data. Do you agree with this strategy?
`
`If population pharmacokinetic analysis is intended to provide
`supportive P1< information, the strategy appears to be acceptable.
`However this issue should be revisited at the pre-NDA meeting with the
`Agency.
`Please submit any PK population data and analysis as soon as possible
`for Agency review.
`
`There was a very short discussion on this issue. Dr. Rahman said that anything
`in the labeling needs to be submitted at the time of NDA submission
`
`Issue 6: Renal Impairment
`
`6. RENAL IMPAIRMENT STUDY - Do you agree that the information from the
`mild renal impairment from the JMAW study will be sufficient as not to delay the
`review and approval of the NDA?
`A. No The NDA application review will not be delayed, but approval is data
`driven.
`
`Dr. Rahman made reference to their guideline on renal impairment. Dr. Johnson
`said that we will comply and the data will be analyzed according to these
`guidelines, and that he will look at the data as a continuous variable. The
`
`CONFIDENTIAL
`ELAP000087O9
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8035
`
`question was asked if this study is unfinished at the time of NDA submission, will
`this delay approval. The Agency answered no; this would not automatically
`delay approval as long as data is submitted for a sufficient number of patients,
`then approval can be granted based on the submitted data. Dr. Hamburger
`asked if a request for additional information would be treated as a formal
`amendment; the FDA responded, no. The amount of data from this study will be
`revisited at the pre-NDA meeting.
`
`Dr. Rahman suggested that the effect of MTA on cisplatin be studied as well as
`the effects of cisplatin on MTA.
`
`For Issue 6, the following was added:
`A. Clarification - if study analyses are unfinished at time of NDA
`submission will this delay the review? The application will be reviewed
`on basis of data provided at time of submission. Formal completion of
`this study after submission is a pre-requirement. We'll revisit this issue
`at pre-NDA meeting.
`
`Issue 7: Fleoatic Impairment
`
`The next issue was hepatic impairment and the Agency presented the following
`acetate:
`
`7. REPATIC IMPAIRMENT STUDY - Do you agree that a separate study in
`patients with hepatic dysfunction does not appear to be warranted?
`A. Since the markers of hepatic dysfunction will be assessed in the
`population pharmacokinetic analyses as well as in the multivariate
`analysis, a separate study in patients with hepatic dysfunction does not
`appear to be warranted at this time. However, the long-term effect on
`MTA on patients with liver dysfunction is unknown and may require study.
`
`Dr. White expressed concern that because of polyglutamation, the MTA
`metabolites will be retained for a long time. Dr. Walling showed acetate #3; this
`acetate presented the grade 3 and 4 toxicities observed for patient #806
`(advanced breast cancer) in study JMAG. Dr. White asked about animal data for
`hepatic toxicity - he suggested that the liver be observed in animals dosed
`chronically or alternatively giving MTA and then waiting 6 months. Further
`discussion on the relevance of preclinical data and the relative short half life of
`MTA (2 to 3 hours) led to Dr. White stating that he was 'becoming more
`comfortable" with the data.
`
`It was stated that a hepatic function study might be a requirement for Phase 4,
`but that would depend on data supplied in the NDA. The final agreement as to
`the hepatic impairment reads as follows:
`
`CONFIDENTIAL
`ELAP0000871 0
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8036
`
`A. Lilly has no data to indicate there are long term effects, but as standard
`procedure, patients will be followed for liver function.
`
`Dr. White asked why Lilly is not pursuing colorectal cancer for MTA, and Dr.
`Walling responded that while we have seen activity for MTA in chemonaive
`patients with colorectal cancer, MTA was not active as second line therapy in
`patients with colorectal cancer, and thus colorectal cancer has a lower priority.
`
`Issue 8: Nonclinical Information
`
`The final slide on Nonclinical Information was presented without discussion.
`
`8. NONCLINICAL INFORMATION - The toxicology, ADME nonclinical
`pharmacology plans for the MTA NDA are provided in the briefing
`document. Are these plans sufficient?
`Preclinical studies are in order in regards to toxicity and PK studies.
`Under the future studies on page 26, the segment II reproductive
`studies are planned in mice and rabbits. If one of the segment II
`studies is positive in one species, the same study in the second
`species is waived.
`
`Issues 10 and 11: CMC Issues; Multivitamins
`
`Before the meeting was adjourned, the acetates for the CMC issues were
`shown:
`
`Redacted
`
`CONFIDENTIAL
`ELAP0000871 1
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8037
`
`For the questions on multivitamins (Questions 1 Ia and 1 Ib) the agency did not
`wish to discuss these at the biopharrnaceutics meeting.
`
`The meeting was adjourned.
`
`CONFIDENTiAL
`ELAP0000871 2
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8038
`
`Acetate #1
`
`Does MTA accumulate in pleural effusions and cause excess toxicity?
`
`Phase I study of MTA and cisplatin
`
`PN 3lThe patient had a mesothelioma primary who received
`MTA 600mg/m2and cisplatin 100mg/rn2 on 11 March 97.
`The patient then had S taps before receiving the second
`dose of M TA/cisplatin:
`
`14 March97
`21 March97
`27 March 97
`8 April 97
`8 April 97
`TOTAL
`
`2100 ml
`2000 ml
`2700 ml
`1000 ml
`120 ml
`/92U ml
`
`This patient had only moderate toxicity in course 1 maximum. CTC 02 hem,
`ALT/AST 01, Cutaneous 02.
`
`The patient was noted to be responding after cycle 2. After cycle 3 there was
`increased clinical benefits and the effusions no longer needed to be tapped.
`cycle 4 the patient experienced CTC 03 & 4 neutropenia and came off study
`
`Thus response correlated with a decrease in the volume of pleural effusions
`excess toxicity was not observed in course 1.
`
`CONFIDENTIAL
`ELAP000087I 3
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8039
`
`Acetate #2
`
`Does MTA accumulate in pleural effusions and
`cause excess toxicity?
`
`Data from three patients in phase I study of MTA + cisplatin
`
`PN 2 Patient with a NSCLC primary treated with 60 mg/rn2
`cisplatin and 300 mg/rn2 MTA. 1300 ml of pleural efthsate
`was tapped 48 hours afier first dose. Patient did not experience
`significant toxicity (no neutropenia) Withdrew from study due
`to PD after course 1.
`
`PN 35 Patient with a colorectal primary with metastatic disease to the
`liver who received 1 cycle of MTA at 600mg/rn2 and cisplatin
`at 75 mg/rn2. On day 17, the patient had 1000 ml of ascites
`tapped. Toxicity in course 1= wbc CTC 03, FIb 02, ANC 04,
`platelets G4. Withdrew from study due to PD after course 1.
`
`CONFIDENTIAL
`ELAP0000871 4
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8040
`
`Acetate #3
`
`Vis
`
`0
`
`1
`
`1
`
`1
`2
`2
`2
`3
`
`3
`3
`3
`4
`4
`4
`5
`5
`
`5
`6
`6
`6
`
`Day
`0
`
`7
`
`14
`
`18
`30
`
`37
`
`41
`
`50
`57
`61
`64
`71
`78
`
`82
`
`92
`99
`
`103
`119
`126
`130
`
`ALT
`139
`533
`429
`360
`246
`156
`lOB
`117
`76
`74
`
`71
`114
`86
`75
`119
`107
`74
`120
`174
`
`141
`
`AST
`133
`298
`169
`200
`155
`132
`109
`177
`83
`94
`102
`128
`77
`80
`142
`121
`137
`168
`184
`178
`
`WA
`600
`
`Day
`0
`
`600
`
`600
`
`600
`
`600
`
`21
`
`44
`
`64
`
`85
`
`600
`
`113
`
`Proj
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`JMAG
`
`mv
`801
`801
`
`831
`
`801
`
`801
`801
`
`801
`801
`
`801
`801
`
`Pt
`806
`806
`806
`806
`806
`806
`806
`806
`806
`806
`808
`801
`801 806
`806
`801
`806
`801
`806
`806
`805
`801
`806
`801
`801 806
`806
`801
`
`801
`801
`
`JMAG - patient 806
`
`600 .-..U-
`
`-
`
`. U.
`
`a
`
`500-.
`
`a 400- I S
`0
`aooja -.\
`
`I-
`
`I
`:-V
`
`0
`
`o
`
`.
`
`..--
`A-.; -...
`
`-
`
`I-,
`N-
`
`Co
`
`Study Day
`
`-
`
`-
`
`.
`
`e.J
`0
`
`600
`
`-600
`
`-400
`5
`-soot
`
`;.:
`
`__-a,,n
`
`2
`
`E-y-i00
`iiri 0
`a
`
`en
`
`Co
`
`0--ALT
`
`.
`
`MTA
`
`CONFIDENTIAL
`ELAP0000871 5
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8041
`
`LY231 514 (MTA) End of Phase 2 Meeting with the FDA
`Clinical Issues - Friday, September 25, 1998 at FDA
`
`FDA Participants: Division of Oncology Drua Products
`Rachel Behrman, M.D., Deputy Office Director, ODEI
`Julie Beitz, M.D., Deputy Division Director
`Gang Chen, Ph.D., Statistics Team Leader
`John Johnson, M.D., Medical Team Leader
`Robert Justice, M.D., Oncology Division Director
`Robert White, M.D., Medical Reviewer
`Liang Zhou, Ph.D., Chemistry Team Leader
`Linda McCollum, Consumer Safety Officer
`Lilly Participants:
`Greg Brophy, Ph.D., U.S. Regulatory Affairs
`Steven Hamburger, Ph.D., U.S. Regulatory Affairs
`Robert D Johnson, Ph.D., Pharmacokineticist
`Astra Liepa, Health Outcomes
`Clet Niyikiza, Ph.D., Statistician
`David Seitz, M.D., Ph.D., Medical Advisor
`Gerald Thompson, Ph.D., MTA Product Team Leader
`Jackie Walling, Ph.D., Director of Science, MTA Team
`John Worzalla, U.S. Regulatory Affairs
`Lilly Consultants:
`Ned Patz, M.D., Duke University
`Nicholas Vogelzang, M.D., University of Chicago
`
`Meeting Request Submission Date: July 13, 1998
`Briefing Document Submission Date: July 29, 1998
`Additional Submission Dates: Sept. 8, 1998
`
`Meeting Minutes:
`
`Schedule and Dose: The FDA showed the following acetate:
`
`1. DOSE and SCHEDULE - Do you agree with the proposed dosing schedule
`for single agent MTA studies - specifically the registration studies involving
`NSCLC?
`A. Our agreement is limited to the proposed dosing schedule for single
`agent MTA. There does not appear to be sufficient efficacy advantage
`with the 600 mg/rn2 dose of MTA over the 500 mg/rn2 dose. Also there
`is a trend for hematologic toxicity to be greater for the 600 mg/rn2 dose
`of MTA than for the 500 mg/rn2 dose. Therefore, the 500 mg/m2 dose is
`
`CONFIDENTIAL
`ELAP0000871 6
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8042
`
`recommended unless a dose response for overall response has been
`shown. Alternatively, patients can start at 500 mg/rn2 and the dose can
`be escalated to 600 mgfm2 if tolerated.
`
`The FDA agreed with the proposed 21 day dosing cycle. There was a
`discussion on the safety profile of the 500 mg/rn2 and 600 mg/m2 MTA doses
`between Dr. Walling, Dr. White, Dr. Johnson and Dr. Vogelzang. The FDA
`recommended an MTA starting dose of 500 mg/rn2 for single agent studies with
`dose escalation to 600 mg/rn2 allowed. Dr. Walling pointed out that there was no
`significant increase in Grades 3 and 4 neutropenia seen at the 600 mg/rn2 dose
`(45% versus 41% at the 500 mg/rn2 dose, but the increase was not statistically
`significant). Also no excess of toxic deaths has been seen with the 600 mg/rn2
`dose. There is not enough data yet to examine the dose response with respect
`to efficacy, but Lilly agreed to the 500 mg/rn2 staffing dose.
`
`The following addition to 1A was provided.
`
`FDA recommendation to use 500 mg/rn2 is advice and not a requirement.
`
`Mesotheliorna: The FDA showed the following acetate:
`
`1. MTA in Mesothelioma - The indication being pursued is "MTA Injection is
`indicated for the treatment of pleural mesothelioma."
`
`FDA Preliminary comment: Usually, lead indications are approved with two
`studies. Mesothelioma is a rare disease. Depending on the quality of the
`mesothelioma trial design and data, further discussions may convince the
`Agency to accept one mesothelioma study and confirmatory evidence from a
`closely related disease.
`
`2a Do you agree this is an acceptable registration strategy (i.e., patient
`population, patient nurnbers endpoints) for accelerated approval for this
`indication?
`NO. Serial measurement of disease are difficult and inaccurate in
`mesothelioma. Confirmation of responses by FDA is likely to be
`impossible and the clinical benefit of response in rnesothelioma is
`uncertain.
`In order to
`Accelerated approval based on response rate is unlikely.
`gain accelerated approval with the combination of MTA + cisplatin,
`you would have to provide evidence that MTA + cisplatin is better
`than any other combination in response and response duration.
`Survival should be the primary endpoint. Since survival is short in
`this population, it should not take long to reach the endpoint.
`Tumor related symptoms could also be addressed in a blinded trial.
`
`CONFIDENTIAL
`ELAP0000871 7
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8043
`
`A lengthy discussion took place on the issues of response rate and
`unidimensional measurements for mesothelioma. These discussions were led
`by Drs. Vogeizang and Patz. Dr. Vogelzang explained that unidimensional
`measurements can be easily obtained, the number of responders is always low
`and a high correlation was shown in a recent paper between clinical benefit and
`response. Dr. Patz explained how the CT scans can have resolution down to I
`mm, and that the scans would be digitized and blinded and then read only by Dr.
`Patz and a colleague in France. Dr. Patz showed an acetate (#1) with W.H.O.
`guidance on the use of unidimensional measurements and another acetate (#2)
`with a table showing good concordance between uni and bi-dimensional tumor
`measurements. Dr. White noted that there were no mesothelioma studies which
`correlated these measurements. A number of slides with several mesothelioma
`scans were shown and the technique for using unidimensional measurements
`was discussed. A discussion suggesting several ways in which unidimensional
`measurements could be taken at different locations and what changes in these
`measurements would qualify for a response did not sway the FDA concerning
`response rate as the primary endpoint. It was restated by the FDA that survival
`should be the primary endpoint, but response rate might be considered for
`inclusion in the label.
`
`The FDA recommended using Study JMCH as designed except using survival as
`the primary endpoint with clinical benefit (reduction in pain or dyspnea) as a
`secondary endpoint to qualify for full approval. Thus, if survival was improved,
`but fell short of statistical significance, then response rate plus clinical benefit
`(reduction in pain or dyspnea) might provide additional evidence for approval.
`
`Dr. Walling asked about the censoring rate for the survival study, and the FDA
`responded that 50% or less censoring rate (50% patients alive in the control arm)
`is the minimum, but that 25% censoring rate (25% of patients alive) would be
`better.
`
`The final agreement to points 2a. A and 2a. B above were listed as shown
`below:
`
`2a A. Lilly has access to the technology (Spiral Hi-Res CT scans),
`protocol, and dedicated assessment team in place to adequately
`assess response in mesothelioma
`2a B. We recommend that appropriately designed trials demonstrating
`clinical benefit, i.e., pain reduction breath shortness, etc., (see C & D)
`be the strategy for gaining full approval if survival benefit can't be
`shown instead of response rate for accelerated approval. (See
`previous FDA comments)
`The FDA also agreed that evidence of activity against NSCLC might also
`serve as confirmatory evidence (see FDA preliminary comment above).
`
`CONFIDENTIAL
`ELAP0000871 8
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8044
`
`A discussion was held on the suggestion of blinding for study JMCH. Dr. Justice
`said that approval could be given for an unblinded study. However, the FDA
`also pointed out that it would be easier to get approval with a blinded trial, since
`improved clinical benefit would be considered more robust in context of a blinded
`trial. Again, this was advice from the FDA, and it is Lilly's decision as to whether
`or not to do a blinded study.
`
`The following FDA acetate for issue 2b was shown:
`
`2b
`
`Is the design of study (JMCH) adequate and well controlled?
`Yes, with reservations. This would be a better study if it were blinded.
`A randomized trial of MTA + cisplatin vs. cisplatin alone is an adequate
`trial. However the addition of the vitamins to the MTA arm without data
`that efficacy is not reduced is risky. We would like to know the basis for
`your determination that the addition of vitamins will not affect efficacy.
`
`Dr. Walling answered this with an acetate (#3) with preclinical data from a murine
`L517BYITK-/Hx- lymphoma tumor model showing that folic acid at 15 mg/kg (45
`mg/rn2) ameliorates the toxicity of MTA, but it does not affect the efficacy. There
`still was concern from the FDA that folic acid might reduce efficacy. Dr. Walling
`again responded that we are using low doses of folic acid that are in a range
`(350 to 600 gg/day which is similar to the 100% RDA of 400 igIday) that would
`give physiologic levels that might be expected from dietary exposure to folate.
`Thus, if MTA efficacy was negatively impacted by these low levels of folic acid in
`the muftivitamins, then the activity of MTA would be compromised by similar
`levels of folate that could be ingested with food in a normal diet. The FDA
`responded that it was Lilly's decision whether or not to use folate.
`
`The following FDA acetates for issues 2c through 2e were shown, but agreement
`as to these had been reached in the discussions noted above:
`
`2c. Do you agree that the choice of primary and secondary endpoints, and the
`analysis plan in study JMCH is acceptable?
`NO. Response rate is not an acceptable primary endpoint in this
`disease. Survival should be the primary endpoint and superior survival
`in the patients on the MTA arm should be the basis for approval.
`Secondary endpoints of response rate, duration of response and time
`to progression could be supportive of the primary endpoint.
`
`2d. Do you agree that allowing the measurement of unidimensional disease will
`provide sufficient information for determining response rate?
`
`CONFIDENTIAL
`ELAP000087I 9
`
`Lilly Ex. 2101
`Sandoz v. Lilly IPR2016-00318
`
`

`
`8045
`
`A. NO. It is uncertain that unidimensional disease measurements in
`mesothelioma will provide sufficient information for determining
`response rate.
`
`2e. Do you agree that there will be sufficient safety data to support registration,
`

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