throbber
E U R O P E A N J O U R N A L O F C A N C E R 4 2 ( 2 0 0 6 ) 1 3 4 4 – 1 3 5 0
`
`a v a i l a b l e a t w w w . s c i e n c e d i r e c t . c o m
`
`j o u r n a l h o m e p a g e : w w w . e j c o n l i n e . c o m
`
`Review
`
`Prostate-specific antigen (PSA) alone is not an appropriate
`surrogate marker of long-term therapeutic benefit in
`prostate cancer trials
`
`Laurence Collettea,*, Tomasz Burzykowskib, Fritz H. Schro¨ derc
`aEuropean Organisation for Research and Treatment of Cancer (EORTC) Data Center, Avenue E. Mounier 83/11, 1200 Brusells,
`Biostatistics Department, Brussels, Belgium
`bCenter for Statistics, Hasselt University, Diepenbeek, Belgium
`cDepartment of Urology, Erasmus MC, University Medical Center, Rotterdam, The Netherlands
`
`A R T I C L E I N F O
`
`A B S T R A C T
`
`Article history:
`Received 27 January 2006
`Received in revised form
`2 February 2006
`Accepted 6 February 2006
`Available online 30 May 2006
`
`Keywords:
`PSA
`Surrogate endpoint
`Clinical trials
`Prostate cancer
`Prognostic factor
`
`The prostate-specific antigen (PSA) is the most studied marker of prostate cancer. It is used
`for screening and as indicator of disease evolution for individual patients. PSA being a prog-
`nostic factor is however not sufficient to justify using PSA-derived endpoints as surrogate
`for definitive survival endpoint in phase III trials. First, we clarify the terminology and
`requirements for a marker to be a valid surrogate endpoint. We then review the published
`literature pertaining to the validation of PSA endpoints as surrogate in all disease stages.
`We discuss the limitations of these studies and conclude that so far, PSA is not a validated
`surrogate endpoint in any of the disease settings and treatment conditions considered. We
`give some recommendations for the planning of trials that would use PSA endpoints (in
`hormone refractory disease) and for the early stop of (endocrine treatment) trials on the
`basis of intermediate results based on PSA.
`
`Ó 2006 Elsevier Ltd. All rights reserved.
`
`1.
`
`Introduction
`
`Phase III cancer clinical trials that evaluate the clinical benefit
`of new treatment options often require large patient numbers
`and long follow-up. Recent advances in the understanding of
`the biological mechanisms of disease development have re-
`sulted in the emergence of a large number of potentially effec-
`tive new agents. There is also increasing public pressure for
`promising new drugs to receive marketing approval as rapidly
`as possible, in particular for life threatening diseases such as
`cancer. For these reasons, there is an urgent need to find ways
`of shortening the duration of cancer clinical trials. The dura-
`
`tion of phase III trials results from the use of long-term clinical
`endpoint (clinical progression, survival). Therefore, to replace
`this endpoint (the ‘‘true’’ endpoint) by another (a ‘‘surrogate’’
`endpoint), that could be measured earlier, more conveniently
`or more frequently, and that would adequately reflect the ben-
`efit of new treatments on the clinical endpoint(s), seems an
`attractive solution. In the field of prostate cancer, prostate-
`specific antigen (PSA) has probably been the most studied bio-
`marker.1 It has been investigated as a prognostic factor and as
`a potential surrogate endpoint across disease stages.
`It is a common misconception that established prog-
`nostic factors necessarily make valid surrogate endpoints. A
`
`* Corresponding author: Tel.: +32 2 774 16 69; fax: +32 2 771 38 10.
`E-mail address: laurence.collette@eortc.be (L. Collette).
`0959-8049/$ - see front matter Ó 2006 Elsevier Ltd. All rights reserved.
`doi:10.1016/j.ejca.2006.02.011
`
`MYLAN PHARMS. INC. EXHIBIT 1122 PAGE 1
`
`

`

`E U R O P E A N J O U R N A L O F C A N C E R 4 2 ( 2 0 0 6 ) 1 3 4 4 – 1 3 5 0
`
`1345
`
`prognostic factor is an intermediate outcome that is corre-
`lated with the true clinical outcome (T) for an individual pa-
`tient.2
`Its knowledge may be useful
`for diagnostic or
`prognostic assessment of an individual patient. For a prog-
`nostic factor to be a surrogate endpoint (S), it is further re-
`quired that ‘‘the effect of treatment on a surrogate endpoint
`must be ‘‘reasonably likely’’ to predict clinical benefit’’.2,3 In
`other words, a biomarker S will be a good surrogate for the
`true endpoint T if the results of a trial using outcome S can
`be used to infer the results of the trial if T had been observed
`and used as endpoint and this with sufficient precision. To
`demonstrate surrogacy, a high association between the treat-
`ment effects on the surrogate and on the true endpoint thus
`needs to be established across groups of patients treated with
`a new versus a standard intervention.
`Fig. 1 shows a schematic of two situations: a) where post-
`treatment PSA level (S) is prognostic for mortality risk (T) (as
`shown by the diagonal orientation of the ovals representing
`the individual patient data in two treatment groups), but is
`not surrogate, as is indicated by the line linking the two
`group’s averages being horizontal; and b) where post-treat-
`ment PSA level (S) is weakly prognostic for mortality risk (T)
`(as shown by the more horizontal orientation and more circu-
`lar shape of the ovals representing the individual patient
`data), but is a strong surrogate of the treatment difference
`on the mortality risk, as shown by the bar linking the group’s
`averages being diagonal, so that differences in average post-
`treatment PSA level between the treatment groups correlate
`with difference in average mortality risk.
`To illustrate this, let us consider the recently published
`secondary results of the Tax-327 study.4 This study compared
`a weekly and a three-weekly schedule of docetaxel plus pred-
`nisone to mitoxantrone and prednisone in hormone refrac-
`tory prostate cancer (HRPC). In this study, like often in this
`disease state, patients who achieved a PSA response had a
`60% reduction in mortality risk compared with non-responders
`(hazard ratio (HR) = 0.40, 95% CI: 0.31–0.51). The reduction of
`the PSA by 50% or more from baseline value, which was de-
`fined as a PSA response, was a strong prognostic factor for
`survival. Now considering PSA response as an endpoint and
`as a putative surrogate for overall survival, we observe with
`the authors that the weekly docetaxel arms resulted in a
`
`Median survival
`
`17.4 m
`
`16.5 m
`
`P=0.362
`
`Weekly Docetaxel
`
`Mitoxantrone + Prednisone
`
`P<0.0001
`
`0%
`
`32%
`
`48%
`
`PSA response rate
`
`Fig. 2 – A prognostic factor does not make a surrogate
`endpoint–the Tax 327 trial.
`
`response rate of 48% which was significantly different from
`the 32% response rate that was obtained with standard arm
`mitoxantrone plus prednisone (P < 0.0001). However, the med-
`ian overall survival on the weekly docetaxel arm amounted
`17.4 months and did not differ statistically significantly from
`the 16.5 months median survival achieved with the standard
`treatment (P = 0.362, Fig. 2). The benefit amounting less than a
`month was also not medically relevant, contrary to the differ-
`ence in response rates. Thus in this study, PSA response
`although it was a strong prognostic factor for survival at the
`patient level, did not appear to be reliable as a surrogate for
`survival when comparing the weekly docetaxel treatment to
`mitoxantrone plus prednisone.
`
`2.
`
`Statistical validation of surrogate endpoints
`
`Traditionally, the ‘‘Prentice Criteria’’5 were used for the pur-
`pose of demonstrating surrogacy on the basis of data from a
`single trial. The Prentice criteria require that four conditions
`be shown to be true in order to demonstrate the validity of
`a putative surrogate endpoint (here PSA), as a replacement
`endpoint for a true endpoint T (here survival):
`
`(a) There must be a statistically significant treatment effect
`on the PSA endpoint (in univariate analysis)
`(b) There must be a statistically significant treatment effect
`on survival (univariate analysis)
`
`Fig. 1 – Prognostic factor versus Surrogate endpoint. Schematic of two situations where (a) the surrogate S (PSA) is a good
`prognostic factor for the true endpoint T (mortality risk) in both treatment groups but is a not a surrogate for T and (b) the
`surrogate S (PSA) is only a weak prognostic indicator of the endpoint T (mortality) at the individual level and is a good
`surrogate endpoint for replacing the true endpoint T (mortality) in phase III clinical trials.
`
`MYLAN PHARMS. INC. EXHIBIT 1122 PAGE 2
`
`

`

`1346
`
`E U R O P E A N J O U R N A L O F C A N C E R 4 2 ( 2 0 0 6 ) 1 3 4 4 – 1 3 5 0
`
`(c) The PSA endpoint must be a statistically significant prog-
`nostic factor for survival (univariate analysis)
`(d) The treatment effect on survival must completely van-
`ish in a survival model with both the treatment and the
`PSA endpoint as explanatory variables (multivariate
`analysis).
`
`Although often used, the criteria are not a proper tool to
`check the validity of a surrogate. They do not aim at verifying
`the quality of prediction of clinical benefit. Condition (b) lim-
`its the applicability of the criteria to trials that showed a sta-
`tistically significant treatment effect on the true endpoint, a
`condition which is rarely fulfilled by clinical trials in prostate
`cancer. Condition (d) is impossible to verify in practice, as it
`amounts to ‘‘proving a null hypotheses’’, i.e., showing that
`the treatment effect is zero. Usually, it is checked by requiring
`that a statistical test shows the treatment effect to be statis-
`tically not significant in a model adjusted for the surrogate
`endpoint. Statistical tests however are designed to reject a
`null hypothesis and non-rejection of the null hypothesis
`never stands as definitive proof that the null hypothesis is
`true.6 In fact, one can obtain a non-significant test result sim-
`ply by having an inadequate sample size. Finally, it was
`shown that for time-to-event endpoints, the Prentice criteria
`are neither necessary nor sufficient to demonstrate that sur-
`rogacy holds true.7 Thus, failure to demonstrate that the four
`criteria hold does mean a biomarker should be disregarded as
`a surrogate endpoint, while successful demonstration that
`the four criteria hold true is not sufficient to actually demon-
`strate that a biomarker is a surrogate for a time-to-event
`endpoint.
`More recently, a new methodology known as the ‘‘meta-
`analytic validation’’ was developed.8,9 Using data from several
`trials, this method consists in deriving a model that can pre-
`dict the magnitude of the treatment effect on the true end-
`point,
`from the treatment difference observed on the
`surrogate (PSA) endpoint. A surrogate is valid if the prediction
`is sufficiently precise. This new methodology aims directly at
`verifying whether ‘‘the effect of treatment on a surrogate end-
`point is reasonably likely to predict clinical benefit’’. Further-
`more, it does not require that any of the treatment effects in
`
`Treatment effect
`observed in the
`trials
`
`R²trial indicates t he
`quality of the
`regression
`
`1
`
`.5
`
`0
`
`Treatment
`Effect
`on
`True
`Endpoint
`(β)
`
`-.5
`
`-1
`
`0
`1
`-1
`Treatment Effecton Surrogate Endpoint (α)
`
`Fig. 3 – Prediction using data from several trials: the
`meta-analytic validation method.
`
`It does
`the individual studies be statistically significant.
`necessitate, however, large databases from multiple random-
`ized clinical trials with similar design and treatments. Using
`data from several trials, the method consists of simulta-
`neously estimating the treatment effect (e.g., hazard ratio)
`for the true (survival) endpoint and for the surrogate (PSA)
`endpoint in each trial. The association between the treatment
`effects on the true endpoint and the corresponding effects on
`the surrogate endpoint is then modelled in a way similar to
`standard linear regression (Fig. 3), although mathematically
`more sophisticated. Alike in linear regression, the strength
`of the association is measured by the squared correlation
`coefficient (R2
`trial) that also indicates the precision with which
`the treatment effect on the true (survival) endpoint can be
`predicted from the observed effects on the surrogate (PSA).
`The maximal possible value of R2
`trial is 1 which indicates a per-
`fect prediction. In practice, observing R2
`trial ¼ 1 is not possible
`and one rather seeks a value close to one which indicates a
`strong association between the treatment effects and thus a
`relatively precise prediction.8,10
`
`Published results on PSA surrogacy
`3.
`in prostate cancer
`
`Although the literature concerning the association between
`PSA and long-term outcome with prostate cancer is exten-
`sive, there are relatively few reports of true validation studies
`of this endpoint. We shall critically review the published evi-
`dence assessing PSA endpoints (PSA response, time to PSA
`progression, PSA velocity, PSA doubling time) as potential sur-
`rogate endpoint for overall or progression-free survival, for
`each stage of prostate cancer.
`
`3.1.
`
`Non-metastatic disease
`
`D’Amico and colleagues11 studied the surrogacy of a PSA dou-
`bling time less than 3 months, as a potential surrogate for
`prostate cancer mortality, in a non-randomized cohort of
`5918 men treated with surgery and 2751 with radiation. They
`showed that the Prentice criteria were fulfilled, however the
`fourth condition was demonstrated by showing no effect of
`the initial treatment on the cancer specific survival after
`PSA relapse, in the subset of 1551 patients with PSA relapse.
`The value of the study is limited by the non-randomized nat-
`ure of the series, the fact that the three-month cut-point is
`data driven and the fact that the timing of salvage hormonal
`treatment was not accounted for. The applicability of the re-
`sults is limited by the fact that few patients actually have a
`PSA doubling time shorter than three months (74 of 611 cases
`with PSA relapse after radical prostatectomy, 12%).
`Sandler and colleagues12 showed that in the Radiation
`Therapy Oncology Group (RTOG) trial 92-02 that compared
`short-term versus long-term androgen deprivation in addi-
`tion to irradiation for T2c-T4 prostate cancer, time to PSA fail-
`ure (defined using the American Society for Therapeutic
`Radiation Oncology (ASTRO) definition) was not a surrogate
`for cancer-specific survival: the PSA endpoint failed the
`fourth Prentice criteria. In that study, time to PSA failure
`was longer on the long-term androgen deprivation arm but
`the survival time after PSA failure was shorter. The authors
`
`MYLAN PHARMS. INC. EXHIBIT 1122 PAGE 3
`
`

`

`E U R O P E A N J O U R N A L O F C A N C E R 4 2 ( 2 0 0 6 ) 1 3 4 4 – 1 3 5 0
`
`1347
`
`postulated that on the long-term androgen deprivation arm,
`some patients may have already had hormone insensitive
`disease at the time of PSA relapse and thus decreased respon-
`siveness to salvage treatment. They concluded that time to
`PSA failure should not be used as a surrogate endpoint in tri-
`als that test endocrine treatment of differing duration. Two
`years later, Valicenti and colleagues13 reported from the same
`study, showing that post-treatment PSA doubling time (calcu-
`lated using first-order kinetics on the basis of minimum three
`post-treatment measurements) of less than 12 months ful-
`filled all Prentice’s criteria in respect to the endpoint of pros-
`tate cancer mortality. In their study, 142 of the 1514 eligible
`patients had died of prostate cancer. These two reports sug-
`gest that dynamic measures of PSA might be stronger surro-
`gates than static measures such as the PSA increase above a
`threshold value.
`Newling and colleagues14 carried out a meta-analytic val-
`idation of PSA-doubling free survival (BPFS) as potential sur-
`rogate for clinical progression free survival (PFS) in over 8000
`patients with localized or locally advanced M0 disease, who
`were randomized within AstraZeneca’s Early Prostate Cancer
`Program between treatment with bicalutamide (Casodex) 150
`mg daily versus placebo in addition to standard care (radical
`prostatectomy, radiotherapy or watchful waiting). PFS was
`defined as the time to objectively confirmed disease progres-
`sion or death from any cause. They report an R2
`trial of 0.65
`(95% CI: 0.55–0.92) for the whole group and of 0.52 (95% CI:
`0.37–0.89) on only the European patients, and a lower associ-
`ation in prostatectomy patients (R2
`trial ¼ 0:46) than in irradi-
`ated patients (R2
`trial ¼ 0:65). They concluded that
`large
`positive treatment effects on BPFS are likely to reflect a clin-
`ically important benefit of bicalutamide as regards clinical
`PFS. They estimated the minimum reduction in the risk of
`a PSA doubling to yield a significant reduction (P < 0.05) in
`the risk of a PFS event to P20% in all patients, P30% in rad-
`ical prostatectomy patients and P50% in irradiated patients.
`However, we must note that part of the association observed
`in their study may be induced by the overlap between PFS
`and BPFS for the patients in whom the first event is death
`in absence of PSA doubling.
`
`3.2.
`
`Metastatic disease
`
`As a counter example to time to PSA being a surrogate for sur-
`vival in metastatic disease, we can already mention trial Na-
`tional Cancer Institute (NCI) INT-10515 that randomized 1382
`eligible patients undergoing bilateral to additional flutamide
`or nil. In that study, the treatment differences in post-therapy
`PSA response; defined as a PSA level 64 ng/mL at any time
`after randomization did not translate into survival differ-
`ences; the PSA response rates on treatment and control were
`74.0% versus 61.5% (P < 0.0001) but there was no significant
`difference in overall survival (P = 0.14). The latter may be re-
`lated to a lack of statistical power for survival in this study.
`However, a meta-analysis of 8275 patients later confirmed
`the absence of benefit of maximal androgen blockade over
`castration.16
`More recently, Collette and colleagues17 reported a meta-
`analytic validation of several PSA endpoints (PSA response
`defined as P50% decline from baseline PSA level, PSA nor-
`
`malization, time to PSA progression) as potential surrogates
`for overall survival in a database of 2161 patients with pri-
`mary diagnosis of metastatic prostate cancer who had been
`treated within AstraZeneca’s Casodex (bicalutamide) develop-
`ment program. The patients were randomized between bica-
`lutamide monotherapy and castration or between combined
`androgen blockade with bicalutamide or with flutamide.
`The study showed that the association between the treatment
`effect on any PSA based endpoint and the treatment effect on
`overall survival was in general low (R2
`trial < 0:69 with wide con-
`fidence intervals). The association between the time to PSA
`progression defined as a confirmed 50% relative increase
`above the previously observed nadir yielded R2
`trial ¼ 0:66 (stan-
`dard error = 0.13) with a corresponding 95% confidence inter-
`val ranging from 0.30 to 0.85. Sensitivity analyses using
`prostate-cancer survival as the true endpoint led to similar
`results. Similar to Newling and colleagues,14 they concluded
`that non-null treatment effects on survival would potentially
`be identifiable only in new trials showing a very large effect
`on the PSA endpoint (e.g., HR around 0.50 with standard er-
`ror = 0.10) on the basis of large patient numbers. Moreover,
`irrespective of the size of the effect on the PSA endpoint,
`the prediction of the treatment effect on overall survival
`could not be precise, due to the large unexplained variability
`in the estimated prediction model (as indicated by low R2
`trial
`values). Thus, with the information at hand, a trial based on
`the PSA endpoint would not require fewer patients than sur-
`vival trial.
`
`3.3.
`
`Hormone refractory disease
`
`D’Amico and colleagues18 assessed whether PSA velocity (cal-
`culated by linear regression of all PSA values within one year
`of initially detectable and increasing PSA level) can serve as
`surrogate endpoint for prostate cancer specific mortality
`(PCSM) in 919 patients with non-metastatic hormone refrac-
`tory prostate cancer (HRPC) treated with salvage hormonal
`treatment for PSA failure after initial radical prostatectomy
`or radiation therapy. They demonstrated that a PSA velocity
`>1.5 ng/mL yearly fulfilled the Prentice conditions of surro-
`gacy for the endpoint PCSM. However, only 26 patients died
`of prostate cancer in their study, and their demonstration
`(in particular Prentice’s fourth criteria) is therefore potentially
`affected by lack of statistical power. In addition, the cut-point
`of 1.5 ng/mL yearly was data driven and needs further valida-
`tion in an independent dataset, the study is non-randomized
`and the models used did not control for the timing of the sal-
`vage hormonal treatment. In view of these limitations, the
`authors themselves conclude that they cannot claim that
`they have completely demonstrated surrogacy.
`Crawford and colleagues19 used Prentice’s criteria to dem-
`onstrate the surrogacy of the three-month PSA change (PSA
`velocity) as surrogate for mortality in the SouthWest Oncol-
`ogy Group (SWOG) trial S9916 that compared docetaxel/est-
`ramustine to mitoxantrone/prednisone in 770 patients with
`HRPC. The four Prentice criteria were fulfilled and they con-
`cluded that PSA velocity measured during the first three
`months on study should be further studied as surrogate end-
`point for mortality in future studies of chemotherapeutic reg-
`imens for HRPC.
`
`MYLAN PHARMS. INC. EXHIBIT 1122 PAGE 4
`
`

`

`1348
`
`E U R O P E A N J O U R N A L O F C A N C E R 4 2 ( 2 0 0 6 ) 1 3 4 4 – 1 3 5 0
`
`The findings in the Tax 327 study mentioned earlier4 con-
`flict to some extent with those of Crawford and colleagues
`since the use of PSA changes would have resulted in wrong
`conclusions regarding the weekly docetaxel arm. Therefore
`the question whether PSA endpoints should be used as surro-
`gate in chemotherapy trials or in trials involving docetaxel re-
`mains not fully answered.
`The only meta-analytic validation study in HRPC we
`know of is the study by Buyse and colleagues20 who as-
`sessed several PSA-based end points in androgen-indepen-
`dent patients treated with liarozole, cyproterone acetate or
`flutamide. They showed that despite a strong prognostic
`association neither PSA response (defined as a decline by
`50% or more from baseline level), nor time to PSA progres-
`sion (defined as a greater than 50% increase over nadir va-
`lue) qualified as a surrogate for overall survival (R2
`trial was
`<0.45 for all tested PSA endpoints). One of the reasons for
`the lack of association may relate to the mode of action
`of
`liarozole which is an imidazole-like compound that
`causes elevation of retinoic acid, postulated to have anti-tu-
`mour activity and which effect may not be mediated by
`PSA. Other reasons for the lack of association might be that
`the patient population was very advanced and that PSA
`expression might be affected by tumour de-differentiation.
`This suggests at least that surrogacy of PSA endpoints
`might not be generally applicable between treatments with
`very different modes of actions or which effect on PSA is
`expected to differ substantially.
`
`4.
`
`Discussion
`
`The literature on PSA surrogacy thus far failed to satisfacto-
`rily demonstrate the value of PSA as a surrogate endpoint in
`prostate cancer.
`From this review, one can broadly conclude that for the
`comparison of primary treatments, PSA is until now not pro-
`ven to be a suitable replacement for a final survival endpoint.
`The association between PSA changes after initial treatment
`and survival is likely to diminish in the future, as second
`and third line treatments may become increasingly effica-
`cious. As seen in the RTOG 92-02 trial,12,13 caution is espe-
`cially needed when only one of randomized treatments
`involves long-term hormonal manipulations because PSA will
`not reflect the development of hormone refractory disease,
`that carries poor prognosis for salvage. Vicini and col-
`leagues21 recently reviewed the value of monitoring PSA after
`initial treatment for prostate cancer. They concluded that PSA
`reading should not be used rapidly to judge difference in
`treatment efficacy in this setting.
`The studies on PSA velocity and other dynamic measures
`of PSA changes suggest that, these might be more powerful
`than classical definitions of PSA changes using threshold val-
`ues and the results by D’Amico and colleagues11 need further
`validation. PSA doubling time and PSA velocity have other-
`wise been mostly studied for testing chemotherapeutic
`agents against HRPC. However, it is well documented that
`all pharmacological agents do not affect PSA in the same
`way:22 drugs may decrease, increase or not change PSA, with
`or without a delay after treatment initiation. Therefore the
`PSA endpoint in phase II or phase III trials should be designed
`
`to match the anticipated effect of the tested drugs on PSA lev-
`els.23 In addition, it is also essential to understand and docu-
`ment
`the drug’s effect on tumour growth and how it
`correlates with PSA changes, since drugs, e.g., suramin, were
`shown to modify PSA production without having an impact
`on tumour growth.24 For this purpose, the algorithm proposed
`by Schro¨ der and colleagues25 is very interesting. It incorpo-
`rates an experimental ‘‘proof-of-concept’’ in vivo study before
`or in parallel with the phase II clinical trial. The design of
`phase II trials of targeted agents is further discussed by Sta-
`dler,26 who shows that the Bubley definition27 of PSA response
`in phase II of HRPC is not an appropriate endpoint when test-
`ing cytostatic drugs. Consequently to this and as seen in the
`review, further research is still needed before using measures
`of PSA change as the final endpoint in phase III studies in
`HRPC.
`The meta-analytic validation studies of Newling and col-
`leagues14 and of Collette and colleagues17 in hormonally trea-
`ted patients, confirm only moderate correlation between
`effects of hormonal treatments on the final clinical endpoint
`and on the PSA endpoints considered. Thus, phase III trials in
`these settings should not be based on PSA endpoints.
`However, PSA could still be used to shorten, in two ways,
`the duration of a phase III trial testing a new treatment the ef-
`fect of which is known (from preclinical and early phase stud-
`ies) to be expressed or mediated at least in part by PSA. First,
`early registration on the basis of a PSA endpoint could be
`envisaged in trials with clinical progression or survival as pri-
`mary endpoint. For that purpose, the trial sample size should
`be determined to demonstrate a very large effect on the PSA
`endpoint with great precision: for example to demonstrate
`the presence of a hazard ratio of the order of 0.50 on the
`PSA endpoint, with a standard error of the order of 0.10.
`The trial sample size calculation ought not to be on power
`considerations, as these would necessarily result in very
`small sample size due to the large target effect, but should
`be based on the required precision of the estimation of the
`treatment effect on the PSA endpoint. An interim analysis
`plan should be set up with plan for one or several interim
`looks at the PSA endpoint as well as to the safety data and
`one longer term analysis on the survival endpoint. At the in-
`terim, the trial results on the PSA endpoint could be used to
`estimate a prediction of the survival treatment effect using
`the regression results from former meta-analytic validation.
`Whenever the prediction interval for the survival hazard ratio
`would exclude the null effect, the trial results could be sub-
`mitted for early registration on the basis of the PSA results.
`In the light of the fact PSA is unlikely to capture all the poten-
`tial (negative) effects of the treatment on survival and be-
`cause PSA did not qualify as a surrogate endpoint, we
`recommend that the follow-up should continue to later docu-
`ment long-term safety of the treatments and their impact on
`survival. Of note, this procedure would likely not reduce the
`patient number to enter in studies. Second, even if PSA is
`not a surrogate, a treatment effect on the PSA endpoint might
`be seen, for specific drugs, as a pre-requisite for an ultimate
`effect on survival. Thus along the lines proposed by Royston
`and Parmar28 one could design a study with survival as the
`final endpoint, but with planned interim looks at the PSA end-
`point and a decision to stop the study for futility if insufficient
`
`MYLAN PHARMS. INC. EXHIBIT 1122 PAGE 5
`
`

`

`E U R O P E A N J O U R N A L O F C A N C E R 4 2 ( 2 0 0 6 ) 1 3 4 4 – 1 3 5 0
`
`1349
`
`benefit or a negative effect of the experimental treatment (e.g.
`HR > 0.5) was seen on the PSA endpoint. The assumption
`underlying this design is that a significant treatment effect
`on the final endpoint (survival) would be very unlikely if no
`beneficial effect was seen on the intermediate endpoint
`(PSA). The information on the correlation between the treat-
`ment effects on the PSA endpoint and on survival that is nec-
`essary to the set up of stopping rules according to Royston
`and Parmar is available from the value of R2
`trial obtained from
`meta-analytic validations, whenever they exist.
`PSA is the most widely available marker for prostate can-
`cer. However, PSA is not tumour specific. Prognostic studies
`have also shown that, in hormone independent disease, only
`17% of the variability in survival is explained by PSA.29 There-
`fore, it is unlikely that endpoints based solely on the marker
`PSA can make valid surrogate endpoints for long-term clinical
`outcome with prostate cancer. New serum and urine markers
`in prostate cancer are currently being studied, noticeably
`within the European Community project P-MARK (http://
`www.p-mark.org). A large number of these markers show
`promise to overcome the limitations of PSA30 and may in
`the future offer more solid surrogate endpoints to shorten
`the duration of phase III trials in prostate cancer.
`
`Conflict of interest statement
`
`The authors have no conflict of interest to declare.
`
`R E F E R E N C E S
`
`1. Small EJ, Mack III Roach. Prostate-specific antigen in prostate
`cancer: a case study in the development of a tumour marker
`to monitor recurrence and assess response. Semin Oncol
`2002;19:264–73.
`2. Biomarkers Definitions Working Group. Biomarkers and
`surrogate endpoints: Preferred definitions and conceptual
`framework. Clin Pharmacol Ther 2001;69:89–95.
`3. Johnson JR, Williams G, Pazdur R. Endpoints and United States
`Food and Drugs Administration Approval of Oncology Drugs. J
`Clin Oncol 2003;21:1401–11.
`4. Roessner M, de Wit R, Tannock IF, et al. Prostate-specific
`antigen (PSA) response as surrogate endpoint for overall
`survival (OS): Analysis of the TAX 327 Study comparing
`decetaxel plus prednisone to mitoxantrone plus prednisone
`in advanced prostate cancer. J Clin Oncol 2005;23:391s.
`5. Prentice RL. Surrogate endpoints in clinical trials: definitions
`and operational criteria. Stat Med 1989;8:431–40.
`6. Altman DG, Bland JM. Absence of evidence is not evidence of
`absence. Br Med J 1995;311:485.
`7. Buyse M, Molenberghs G. Criteria for the validation of
`surrogate end-points in randomized experiments. Biometrics
`1998;54:1014–29.
`8. Daniels MJ, Hugues MD. Meta-analysis for the evaluation of
`potential surrogate markers. Stat Med 1997;16:1515–27.
`9. Buyse M, Molenberghs G, Burzykowski T, Renard D, Geys H.
`The validation of surrogate endpoints in meta-analyses of
`randomized experiments. Biostatistics 2000;1:49–68.
`10. Burzykowski T, Molenberghs G, Buyse M, Geys H, Renard D.
`Validation of surrogate endpoints in multiple randomized
`clinical trials with failure-time endpoints. J R Stat Soc Ser C
`Appl Stat 2001;50:405–22.
`
`11. D’Amico AV, Moul JW, Carroll PR, Sun L, Lubeck D, Chen MH.
`Surrogate end point for prostate cancer specific mortality
`after radical prostatectomy or radiation therapy. J Natl Canc
`Inst 2003;95:1376–83.
`12. Sandler HM, Pajak TF, Hanks GE, Porter AT, DeSilvio M, Shipley
`WU. Can biochemical failure (ASTRO definition) be used as a
`surrogate endpoint for prostate cancer survival in phase III
`localized prostate cancer clinical trials? Analysis of RTOG
`protocol 92–02. J Clin Oncol 2003;22:381.
`13. Valicenti R, Deslivio M, Hanks G, et al. Surrogate endpoint for
`prostate cancer-specific survival: Validation from an analysis
`of the Radiation Therapy Group Protocol 92-02. J Clin Oncol
`2005;23:4549.
`14. Newling D, Carroll K, Morris T. Is prostate-specific antigen
`progression a surrogate for objective clinical progression in
`early prostate cancer? J Clin Oncol 2004;22:4652.
`15. Eisenberger MA, Blumenstein BA, Crawford ED, et al. Bilateral
`orchiectomy with or without Flutamide for metastatic
`prostate cancer. N Engl J Med 1998;339:1036–42.
`16. Prostate Cancer Trialists’ Collaborative Group. Maximum
`androgen blockade in advanced prostate cancer: An
`overview of the randomized trials. Lancet 2000;355:
`1491–1498.
`17. Collette L, Burzykowski T, Caroll KJ, Newling D, Morris T,
`Schro¨ der FH. PSA is not a valid surrogate endpoint for
`overall survival in patients with metastatic prostate

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