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Re: dianebRN post# 33046

Monday, 06/28/2010 9:38:51 AM

Monday, June 28, 2010 9:38:51 AM

Post# of 105534
Hello dianebRN, great discussion and I appreciate your insight. That said, however, I don't know if the intro of Pall is that cut and dry. FDA NDA classification was stressed by the CEO regarding the new device which might be pretty important from an investor standpoint.

Sure all bags can be considered the same or are they? Are all cars the same? Every automobile accomplishes a similar task: increased mobility yet they are not all the same.

At some point we must also accept a hospital doesn't manufacture biologics. If by chance it does is it safe to say not on the same scale as CBAI? Manufacturers have a different set of rules and therefore admin share a similar field but with a different set of responsibilities. Hospital doctors are writing scripts to now store biologics for a known medical necessity.

The manufacturer is tasked with testing, processing, storing and at some later time dispensing the drug back to the doctor as a treatment. The manufacturer has to make sure the drug meets FDA safety and efficacy standards and that the manufacturing practices also meet certain standards.

So CBAI and hubs manufacture and anything with special markings, acronyms or achieved accreditations becomes very important to me as an investor.

Here's what I found regarding NDA. Let me know if I am off target.

Clinical Submission Approval Under FDA Section 505(b)

A clinical submission filed under FDA Section 505(b)(1) is an NDA is required to demonstrate clinically meaningful treatment benefits and statistically significant safety and efficacy objectives and endpoints. In addition, clinical submissions filed under FDA Section 505(b)(1) are a new chemical entities with a new indications.

The new investigational drug will be administered to the patient in a new formulation, with a new dosage form, new dose strength and is patented.

The pharmaceutical company and/or manufacturer seeks market exclusivity for the NDA. Approval of the NDA under Section 505(b)(1), is granted by FDA only after an extensive Phase 1, 2, 3 clinical development program. When all 3 clinical phases are complete, the pharmaceutical company and/or manufacturer, submits an NDA including all results from all studies, nonclinical, preclinical, CMC, clinical, bioanalytical, pharmacologic and pharmacokinetic to FDA. The NDA is filed, reviewed for filing completeness and then sent to the appropriate division at FDA for review. The regulatory "clock" begins for the file.

An NDA is the culmination of 10-15 years of discovery, R&D, clinical development and by the time an NDA is approved by FDA, the pharmaceutical company and/or manufacturer, has invested numerous years and many millions for the approval. Post-marketing, post-approval is the next step and requires a 12 - 36 month commitment to monitor and assess new drug attributes such as risk, benefit, safety, effectiveness, SAE reports and otherwise. At the time of approval of an NDA, FDA grants a period and right of exclusivity to the submitter for the newly approved drug. The approved drug and patent(s) are protected for up to 20 years from the date of the first filing of the patent application.

Under the Hatch-Waxman Act, a new drug application and clinical submission process will fall into one of two categories depending on drug profile and background. The two categories are NDAs and ANDAs (Abbreviated) New Drug Applications. Under FDA Section 505(b), a new drug application and clinical submission is further divided into Sections 505(b)(1) and 505(b)(2). An ANDA is further delineated with respect to Bioequivalence requirements and is submitted as a 505(j) application and clinical submission. The 505(j) drug moiety is not a new chemical. Pharmaceutical companies and/or manufacturers filing under Section 505(j) must follow the "generic" approval process for drug application and clinical submission.

NDAs and ANDAs require QC and QA to ensure fileability, quality content, accurate, consistent data and documentation and a successful clinical and regulatory approvability outcome with FDA and otherwise. NDAs and ANDAs are submitted in a CTD (Common Technical Document) presentation and format. CTD content, completeness and format must be quality-controlled and quality-assured to ensure regulatory compliance and reviewer friendly dossier navigation.

CBAI is a pharmaceutical co/manufacturer of a new-age drug... different set of rules imo. The QC and QA and all other admin roles in the biologics manufacturing setting differ from that of a hospital. Again, let me know if I am off the target in that presumption.

Again... Thanks

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