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Saturday, February 02, 2019 4:13:06 PM
you wrote:
"Cannot be specific on exact timing of unblinding".
"SAP to be developed and submitted to regulators. This is a ginormous (her word) effort. Lots of complexity to SAP; lots of decisions to be made".
"Doing things in parallel where we can. Final data collection ongoing; CRO physically visiting 81 trial sites; some case files can be more than 100 pages long; every discrepancy generates a query; and every query needs to be resolved".
I had to wait for the last question:
Question: While the SAP is being developed, are you in active dialogue with the regulator? Will you unblind only after regulator signs off on SAP?
Linda:
"I'll answer the second part first. Yes, we will unblind only after regulators sign-off on the SAP. Note that it's not just the FDA, but a total of 4 regulators. On the first part, we cannot comment about any dialogue with the FDA. The SAP will be a formal submission to FDA for sign-off".
My takeaway: It seems the SAP sign-off by regulators is the biggest rate-limiting factor. LP hedging her statements about time-line because she does not know how long the FDA will take to sign-off on SAP.
I have had an inkling that finalizing the SAP could be a lengthy process. Here it appears that she is indicating that the SAP needs to be "developed".
I imagine that this might mean that even if they had done some prior work on the SAP, that going down the path of looking for DCVax-L approval based on the long tail (as opposed to the delta of the Primary and Secondary Endpoints) is a novel approach.
And it would not dovetail into the original trial design documents.
She also appears to indicate that it will involve lots of decisions .... so it is likely not simply writing a few paragraphs about looking at the long tail for trial approval. I wonder whether the SAP will wind up being a 20-page or 50 page or 100-page document?
I suspect it could take beyond the "couple of months" to develop & finalize the SAP. Maybe 4 or 5 months?
And then: I get the impression from the above that they will look to get all 4 regulators (FDA & Germany & UK & Canada) to sign-off .... prior to unblinding. In a way this seems like a good thing: if NWBO gets all 4 regulators to sign-off on the SAP, which will include looking at the data differently than in the original trial design docs, then I would suspect that trial approval would look favorable if the data at unblinding is favorable. I can see that it would be risky to unblind before FDA (and others) indicate that they are willing to view the data in a new/novel way.
My guess is that it could take 4 to 8 months to get through the remaining 4 steps. I do not think that they will get everything done prior to ASCO 2019. But I do not believe they would then necessarily need to wait for ASCO 2020 either.
I was pleased to see that the data collection is ongoing, and that it is the "FINAL data collection".
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