so it seems that the 5 criteria were already put forth as early as 2004 Beginning in 2004, scientists at FDA’s Office of New Drug Quality Assessment (ONDQA) expressed their disagreement with OGD’s five-criteria approach this blows a hole in the entire argument that MNTA essentially helped draft the criteria for approval of lovenox imo that leaves only immunogenicity and supply chain issues as obstacles for amphastar, and presumably only immunogenicity for teva immunongenicity may remain a difficult hurdle, but this does increase the odds of an eventual teva (and even amphastar) approval imo