To: Louis A. Rawden who wrote (27394 ) 1/14/1999 8:20:00 AM From: Henry Niman Respond to of 32384
Louis, There would be no advantage for LGND to cut the Phase II breast cancer trial short. It is a fairly complicated trial using Targretin at several concentration, with and without Tamoxifen, so they would want to get as much data as possible before starting Phase III trial(s). I think that an explanation of "Off Label" use might be appropriate at this time. After Phase III trials are completed with Targretin oral for CTCL, they will submit their NDA, probably later this year. If it receives a "priority review" then the FDA will have to make a decision within 6 months (it is likely that at the time of NDA submission, the only approved treatment for CTCL will be ONTAK, which will probably be labeled for advanced cases, and Targretin will probably get a priority review since it will be submitted for treating CTCL patients whose disease is not as advanced). LGND could get a Targretin approval for CTCL by the end of the year. The market will be relatively small, and the label will determine which CTCL patients would be considered in the labeled category. For those patients, LGND will be able to promote Targretin use, but once approved, a physician can prescribe the drug for any indication. For oncology, off label use is fairly common. Although Targretin is not currently approved for anything, some physicians are already using it on a compassionate use basis for patients who are not responding to approved treatments. Under the FDA reform act, LGND can actually promote off label use after publication of clinical data (I think that it is publication in two peer reviewed journals). LGND has already published Targretin treatment and prevention of breast cancer in animal models, but I believe that the FDA requires clinical data. Targretion is already in several clinical trials for various cancers (breast, lung, CTCL, and I believe ovarian) as well as diabetes (in Europe), psoriasis, and actinic keratosis. Thus if any of the above data is publishable, LGND could actually start promoting Targretin for those indications as soon as it was approved for CTCL (and the above data was published). Thus, there would be no advantage for shortening Phase II trials for breast cancer. If the data looks good enough to halt a trial, then they good enough to publish, and LGND would publish the partial data and set the stage for off-label promotion, especially if the clinical data bore any resemblance to the outstanding animal model data for treatment and prevention of breast cancer.