FDA is going to require clinical trials for fob's, even if you claim to be making exact replicas.
That’s not the point; rather, the point is whether the FDA will require a full fledged clinical program or an abbreviated clinical program that relies in part on the clinical data for a reference drug.
If the latter, it’s an FoB; if the former (what MRK is talking about), it’s simply a branded biologic for an established target.
“The efficient-market hypothesis may be the foremost piece of B.S. ever promulgated in any area of human knowledge!”