`
`Bethesda, MD, February 22-23, 2011
`
`Drug Products (PODP)
`
`Division of Therapeutic Proteins
`Office of Biotechnology Products
`
`Center for Drug Evaluation and Research
`
`U.S. Food and Drug Administration
`
`Expert Review Scientist
`
`Ingrid Markovic, Ph.D.
`
`Extractables and Leachables
`
`Safety Qualification of
`
`Regulatory Perspective on
`
`Novartis Exhibit 2179.001
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`manufacturing process, product stability, etc.)
`
`•Quality considerations(e.g., impact on the
`
`development of neutralizing activity via NAb
`
`a product → loss of activity; L may induce
`
`•Efficacy considerations(e.g., L interacting with
`
`formation)
`
`immunogenicity, etc.)
`
`•Safety considerations(e.g., toxicity,
`
`E&L
`
`Risk-based Approach in Evaluating
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.002
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`May promote non-specific inflammation
`
`Altering the PK of the drug
`
`-thrombocytopenia)
`
`endogenous protein (e.g., erythropoietin -anemia/PRCA; thrombopoietin
`
`May be life-threatening if NAbs are developed against a non-redundant
`A decrease or loss of efficacy due to development of neutralizing activity
`
`May promote development of anti-drug antibodies
`
`may be a serious safety concern for therapeutic proteins
`
`In contrast to vaccines where adjuvant effect is a desired effect, this
`
`system without having any specific antigenic effect
`
`Adjuvants are substances that increase the activity of the immune
`
`•Adjuvant effects:
`
`endocrine dysregulation, etc.)
`
`•Toxicity (e.g., acute, chronic, synergistic, additive, carcinogenicity,
`
`Safety considerations
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.003
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`therapy)
`be tolerated if drug is considered a part of essential
`•Therapeutic necessity of the drug (higher levels may
`
`•Prior clinical exposure to leachables may enhance
`
`sensitivity in case of re-exposure
`
`exposure)
`(e.g., SC vs. IV, life-time dosing and chronic
`
`•Drug dose, mode and frequency of administration
`
`Safety considerations (cont.)
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.004
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`•Risks often assessed on a case-by-case basis
`
`phosphate buffer)
`
`•Formulation/choice of excipients; (e.g., liquid vs. lyophilized; pH;
`
`ethylhexyl)phthalate, which is linked to various toxicities)
`
`•Type of polymeric material (e.g., PVC at risk for leaching di(2-
`
`•Contact time
`
`•Surface-to-volume ratio
`
`•Storage temperature (e.g., freezing vs. 2-8C)
`
`final product)
`
`•Type of the processed/stored material (e.g., purification buffer vs.
`
`finished product)
`typically risks are greater as production moves closer to the
`•Place in the process stream (e.g., upstream vs. downstream;
`
`Manufacturing considerations
`
`www.fda.gov
`
`Fli)~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.005
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`•Leachables studies are often omitted
`
`over time
`
`stability studies, which monitor changes in product quality
`
`•Analysis of extractables is done in conjunction with
`
`extraction medium (role of excipients important)
`
`Note: Drug Product vehicle may or may not be used as an
`
`Alternatively, the drug manufacturer may rely on the E
`
`studies done by the vendor
`
`conditions (organic solvents, accelerated T°, pH, etc.)
`
`•Extractables studiesare performed using exaggerated
`
`What’s done in practice…
`
`Novartis Exhibit 2179.006
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Inappropriate sample size that is needed to understand the true variability
`
`in the C/C system (e.g., tungsten and PFS syringes)
`
`scenario risk assessment)
`
`manufacturing, storage and transportation conditions (no worst case
`
`Differences in the levels of leachables at the extremes of the
`
`inorganic leachables such as tungsten, Fe, Al, etc., are never evaluated
`
`Stability studies are often not geared to detect leachable impurities (e.g.,
`
`and organic leachables may be missed)
`
`
`
`
`
`
`
`Product Quality considerations:
`
`•
`
`Product that is at the end of its dating period is rarely evaluated in clinic
`
`Mode of administration (e.g., SC is often more immunogenic than IV)
`
`Potential for adjuvant effect and immunogenicity is not addressed
`
`Toxicity studies are usually acute studies that do not measure chronic
`
`exposure to potential leachables
`
`
`
`
`
`
`
`
`
`regard to leachables studies
`
`Risk assessment and risk reduction with
`
`Safety considerations:
`
`•
`
`Novartis Exhibit 2179.007
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`properties throughout the expiry period
`and product physico-chemical and biological
`
`•Perform stability studies, which monitor impurities
`
`•Ideally, Drug Product material that is at the end of its
`
`shelf-life should be tested in clinic
`
`Without the product (i.e., in placebo alone)
`
`In the presence of product
`
`product
`measuring leachables over the entire shelf-life of the
`
`•Monitor the clinical outcome in conjunction with
`
`Leachables studies
`
`Novartis Exhibit 2179.008
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Some support in the literature
`
`immunomodulatory factors
`
`Leachables as adjuvant and/or
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.009
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`I
`I
`CH a
`
`CH3
`
`C"3
`
`I
`
`
`II
`
`CH a
`
`-Si-O-Sii-0-91-0-Sii-
`
`CH a
`
`I
`
`J
`CH a
`
`CHa
`
`l
`
`
`.I
`
`CH9
`
`PDMS
`
`D4
`
`Locatelli et al., 2004, Nephrol Dial Transplant, 19:288-293
`
`Naim et al., 2000, Clin Diagnostic Lab Immunol, 7:366-370
`
`Naim et al., 1995, Immunol Invest, 24:537-547
`
`•Silicone oil –polydimethylsiloxane and octamethyl-
`
`cyclotetrasiloxane (D4)
`
`immunomodulatory factors
`
`Leachables as adjuvant and/or
`
`Novartis Exhibit 2179.0010
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Nilsen et al., 1997, Toxicology, 124:225-232
`
`Lovik et al., 1997, Toxicology, 121:165-78
`
`•Polycyclic aromatic hydrocarbons (PAH)
`
`Larsen et al., 2007, Tox Letters, 170:223-228
`
`Larsen et al., 2001, Toxicology, 169:37-51
`
`Larsen et al., 2001, Tox Letters, 125:11-18
`
`Mono-2-ethylhexyl phthalate (MEHP)
`
`•Di-(2-ethylhexyl) phthalate (DEHP) and
`
`immunomodulatory factors (cont.)
`
`Leachables as adjuvant and/or
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0011
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Yano et al., 2003, J Health Sci, 49:195-204
`
`•Alkyl phenols
`
`Schmidt et al., 2010, Nature Immunology, 11:814-820
`
`•Nickel
`
`386
`
`Marth et al., 2001, Inter J Occupational Med and Environ Health, 14:375-
`
`Beck-Speier et al., 2009, Particle and Fibre Toxicology, 6: 34-46
`
`•Soluble iron
`
`•Cadmium
`
`immunomodulatory factors (cont.)
`
`Leachables as adjuvant and/or
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0012
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Known's and Unknown’s
`
`leachables in biologics:
`
`Establishing threshold levels for
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0013
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`approach be applied to biologics?
`
`•What we don’t know: Can the same
`
`etc.) that can be applied across board
`PQRI, ICH Q3C, published literature,
`been proposed and/or established (e.g.,
`
`•Toxicological threshold levels have
`
`What we know
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0014
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`unfolding and aggregation, whereas in another case, it had no effect
`API that had different formulation: in one case tungsten caused
`
`E.g., tungsten oxides had a very different effect on two analogous
`
`protein products, formulation composition and C/C systems
`
`Needs to be assessed on a case-by case basis due to diversity of
`
`•Threshold for product quality
`
`1,000x less sensitive to LPS compared to humans)
`unlikely to be predictive of the clinical outcome (e.g., mice are
`However, the threshold levels identified in animal studies are
`
`after a change in the C/C system) and in identifying potential risks
`Such studies may be useful in looking at relative differences (e.g.,
`
`Adjuvant effects of leachables may be studied in animal models
`
`(e.g., in mice)
`
`•Threshold for the adjuvant effect:
`
`A feasibility exercise
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0015
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`injectables administered frequently at relatively high volumes and doses of mg/ml)
`•Drug dose, mode and frequency of administration (e.g., many biologics are sterile
`
`protein)
`hydrophilic and hydrophobic sites (the latter are usually buried in the interior of the
`Proteins may be more efficient in solubilizing leachables due to abundance of both
`
`of potential sites of interaction
`Large size (e.g., MAb 150 KD) and extensive surface area ensures →high frequency
`
`•
`
`•
`
`function)
`release testing is unlikely to detect areas of protein unfolding unless it impacts the
`
`•Routine analytical testing often doesn’t detect finite changes in the protein (e.g.,
`
`–Changes in glycosylation
`
`–Deamidation and/or oxidation
`
`–Aggregation and/or degradation
`
`environment
`
`–Protein conformation (e.g., secondary, tertiary) is sensitive to external
`
`•Manufacturing and stability issues:
`
`for the following additional reasons…
`
`Biologics may deserve a special consideration
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0016
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Case studies
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0017
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`S.c. route of administration was contraindicated in CRF patients, which
`
`Stricter control of the cold-chain from manufacture to administration
`
`was subsequently reversed
`
`Switch to teflon-coated stoppers
`
`•Resolution:
`
`•Hypothetical MoA: leachables acted as adjuvants leading to formation
`
`of neutralizing Abs to endogenous protein
`
`safety: serious adverse event (pure red cell aplasia, PRCA)
`
`no notable changes in protein physico-chemical properties
`
`storage (e.g., Vultac 2 di, tri, tetra, penta, hexasulfide, etc.)
`
`•Source: Vulcanizing agents leached from the rubber stopper during
`
`•C/c system: pre-filled syringes with uncoated rubber stoppers
`
`Impact:
`
`•
`
`•Change from HSA to polysorbate formulation
`
`Pharm, 5:86-91)
`
`(Casadevall et al., 2002, N Engl J Med, 346:469-475; Sharma et al., 2004, Eur J Hospital
`
`Leachables from the uncoated stoppers
`
`Novartis Exhibit 2179.0018
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`125
`
`115
`
`105
`
`95
`
`85
`
`75
`
`65
`
`55
`
`Time (min)
`
`placebo w/ uncoated rubber stoppers
`
`Leachables
`r15
`
`125 1
`
`Time (min)
`
`105
`
`95
`
`85
`
`75
`
`65
`
`55
`
`C
`
`< 0.05
`.c
`(/)
`0 0.10
`.c
`n,
`g 0.15
`0.20
`
`Q)
`
`/ Drug
`
`uncoated rubber stoppers
`
`B
`
`Time (min)
`
`.c < 0.05
`i 0_10
`g 0.15
`0.20
`
`Q)
`
`(/)
`
`125
`oni=:==:::;====::::::::====:::::::::====:::::====::....._-==:.==-=-.
`
`115
`
`105
`
`95
`
`85
`
`75
`
`65
`
`55
`
`o.
`
`/Drug
`
`coated rubber stoppers
`
`A
`
`profile of the drug + leachables
`
`(Sharma et al., 2004, Eur J Hospital Pharm, 5:86-91)
`
`.c < 0.05
`0 0.10
`.c
`n,
`g 0.15
`
`(/)
`
`Q)
`
`0.20
`
`Novartis Exhibit 2179.0019
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Eventually, the problematic presentation was removed from the market
`
`Conduct additional studies to determine the impact on product Q and S
`
`Implement Teflon coated stoppers
`
`Return to the original dating period of 15 months
`
`•Resolution:
`
`•Action: >10 DP lots were recalled due to OOS results
`
`–moderate decrease in potency
`–OOS result for protein content (e.g., >50% of the product was modified)
`
`Several sites on the protein were modified primarily at the N-terminus (primary
`
`targets were peptides with –OH, –NH3and –SH groups)
`
`Fe catalyzed oxidation of the preservative + additional excipient triggering
`
`formation of the protein-preservative adducts
`
`•Critical excipients: preservative and other components
`
`•Source: uncoated rubber stoppers released iron at levels <1 ppm
`
`•Change: extension of the expiry period from 15 to 18 months
`
`preservative adducts
`
`Impact:
`
`•
`
`Fe leachables cause formation of protein-
`=--
`
`Novartis Exhibit 2179.0020
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`~ Truncated
`
`product
`
`~ product
`Original
`
`coated stoppers implemented
`and replaced with the original one; Teflon
`in PK values; it was withdrawn from the market
`cardiovascular adverse events and a change
`
`• Adverse outcome: new formulation led to
`
`• Resolution: chelator (EDTA) added to DP
`
`formulation buffer
`
`Impact: product truncation at the N-terminus
`
`•
`
`(process-related impurity co-eluted with API)
`• Mechanism: activation of a metalloprotease
`
`• Uncovered during stability study under
`
`inverted conditions
`
`• Source: rubber stopper released divalent metal
`
`cations
`
`Metal leachables cause product truncation via
`
`metalloprotease activation
`
`• Change: from lyophilized to a liquid
`
`formulation
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0021
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`PFS
`development in vials and discontinue
`
`•Resolution: Continue product
`
`protein
`neutralizing Abs to the endogenous
`
`•Clinical outcome: Patients developed
`
`aggregation of the protein
`Impact: tungsten caused unfolding and
`
`•
`
`liquid
`into the product when contacted with
`oxides are deposited on the glass and
`
`•Source: tungsten salts and tungsten
`
`needle is attached
`perforate syringe barrel onto which a
`
`Tungsten filaments are used to
`
`•Container closure system: prefilled
`
`syringes
`
`Tungsten leachables from PFS barrels #1
`
`Novartis Exhibit 2179.0022
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`overlay process, special washing procedure, etc.
`
`Alternative -establish tungsten specifications, nitrogen
`
`Optimal -switch to platinum instead of tungsten filaments
`
`•Resolution (different approaches were used by different
`
`Sponsors):
`
`Up to 1% PFS tested positive for aggregates
`
`Up to 60% of aggregated product found in some syringes
`
`aggregation
`Impact: tungsten salts caused protein oxidation followed by
`
`•
`
`•Container closure system: prefilled syringes
`
`Tungsten leachables from PFS barrels #2
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0023
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`Reduce product dating period
`
`Switch to lower risk formulation (e.g., pH, buffers, etc.)
`
`temperature control (leads to lower surface alkalinity)
`
`Switch to a different vial manufacturing process with more stringent
`
`Switch to highly resistant glass (high coefficient of thermal expansion)
`
`Contact time (delamination is a time-dependent process) and temperature
`
`•Risk mitigation strategies include the following:
`
`High ionic strength
`
`Certain buffers
`
`Drug solutions formulated at alkaline pH
`
`Specific vial manufacturing process
`
`Glass vials with high surface alkalinity have higher propensity for delmination
`
`•Risk factors promoting delamination (not listed in the order of importance):
`
`solution interface causing breaking of Si-O bonds and weakening of the surface layer
`
`•Glass pitting and surface delamination is initiated by ion exchange at the glass-
`
`•Container closure system: Type I borosilicate glass vials
`
`glass vials
`
`Alkali oxide extractables cause delamination of
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0024
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`New glass vials are coated using a baked-on siliconization process
`
`Recall of lots that failed the particulate spec
`
`•Resolution:
`
`Impact: visible particles (up to 150 μm diam)observed in stability samples
`
`•
`
`over 12 month of age with no other OOS results
`
`vaccines, although at concentration leached, it is unlikely to exert
`
`Aluminum phosphate (i.e., alum) is widely used as adjuvant in
`
`such an effect
`
`formulation forming aluminum phosphate crystals
`
`•Mechanism: aluminum interacted with sodium phosphate in the
`
`•Source: aluminum oxide leached from the new glass vials
`
`•Change: change from molded to tubing glass vials
`
`form particulates
`
`Aluminum leachables from glass
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0025
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`data for 10 new vial lots
`established with commitment to generate stability
`
`•Resolution: acceptance limit for barium
`
`stability samples with no other OOS results
`
`•Impact: visible particles observed in 18 month
`
`crystals
`sulfate in the formulation forming barium sulfate
`
`•Mechanism: barium interacted with sodium
`
`•Source: barium leached from new glass vials
`
`•Change: vendor for glass vials
`
`form particulates
`
`Barium leachables from glass
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0026
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`• Resolution: product now packaged in non(cid:173)
`
`siliconized syringes
`
`• Outcome: formation of amorphous polymers
`
`visible by the naked eye
`
`(J Pharm Sci, 2005, 94:918-927)
`denaturation and aggregation
`interact with proteins and cause protein
`
`• Silicone oil forms micelles in solution, which can
`
`effect) from the syringe barrel into the product
`• Observation: silicone oil was shed (break-loose
`
`lubricating agent to coat prefilled syringes
`
`• Source: silicone oil spray was used as a
`
`Silicone
`
`oil
`
`Silicone oil leachables cause
`
`product aggregation
`
`Novartis Exhibit 2179.0027
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`use) systems
`
`•Consideration of E&L for disposable (i.e., single
`
`standardization of E&L testing
`
`•Consideration for the improvement and
`
`minimize patients’ exposure to unnecessary risks
`mining, in order to reduce clinical uncertainty and
`leachables testing, in conjunction with clinical data
`
`•Greater emphasis should be placed on the
`Points to consider…
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0028
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`uncontrolled risk(Barry Cherney)
`its safety & efficacy doesn’t reduce risk, it’s simply,
`
`•Lack of transparency between a product quality attribute and
`
`as it relates to safety and efficacy
`resolve a problem while minimizing changes to product quality
`
`•Corrective actions should employ a simplest approach to
`
`included)
`time points reflective of product dating period should be
`It’s important to monitor leachables over time (e.g., extended
`
`•
`
`leachables acting as adjuvants triggering NAb response)
`significant impact on clinical safety and efficacy (e.g.,
`
`•Undetected differences in product impurities may have a
`
`changes in the C/C system and/or formulation
`
`•Biologic products can be sensitive to minor impurities and
`
`Summary
`
`=--
`
`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0029
`Regeneron v. Novartis, IPR2021-00816
`
`
`
`All of OBP
`
`DanielaVerthelyi
`
`Emily Shacter
`
`Amy Rosenberg
`
`Dov Pluznik
`
`Mike Norcross
`
`Steven Kozlowski
`
`Barry Cherney
`
`Acknowledgments
`
`Novartis Exhibit 2179.0030
`Regeneron v. Novartis, IPR2021-00816
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`Questions? Comments?
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`www.fda.gov
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`flu~ U.S. Food and Drug Administration
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`Protecting and Promoting Public Health
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`Novartis Exhibit 2179.0031
`Regeneron v. Novartis, IPR2021-00816
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`generally poorly described in submissions
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`•Justification of selected extraction conditions is
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`Ensures that methods with appropriate specificity and
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`Highlights immediate safety concerns (if any)
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`sensitivity are used
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`conditions)
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`extractables (depends on the specific extraction
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`Determines chemical profile and maximal levels of
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`•Appropriate extraction procedure is relevant
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`Extractables analysis
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`=--
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`www.fda.gov
`
`flu~ U.S. Food and Drug Administration
`
`Protecting and Promoting Public Health
`
`Novartis Exhibit 2179.0032
`Regeneron v. Novartis, IPR2021-00816
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`•Cleaning agents
`•Antistatic agents
`•Polycyclic aromatic hydrocarbons
`•Antioxidants (e.g., BHT, Irganox, Irgafos, etc.)
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`dithiocarbamate, etc.)
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`•Accelerators (e.g., thiuram, sulfenamide, guanidine,
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`•Vulcanizing agents (e.g., Vultac 2, etc.)
`•Nitrosamines (e.g., diphenylnitrosamines, etc.)
`•Organic solvents (e.g., acetone, isopropanol, etc.)
`•Silicone oil (e.g., polydimethylsiloxane)
`•Cyclic esters (from polyurethane adhesives)
`•Fatty acids (e.g., stearic, plamitic myristic, etc.)
`•Metals (e.g., Zn, Fe, Ba, Ca, Al, Ni, etc.)
`•Phthalates (e.g., Di(2-ethylhexyl) phthalate -DEHP)
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`Examples of more common E&L
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`Novartis Exhibit 2179.0033
`Regeneron v. Novartis, IPR2021-00816
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