Ig I am all for the SPA move ..I do not see it as an error. If you are going to sink almost 100 MM in a PIII, and you are a small company you need to reduce your risk.
SPA is a great tool .. if you are BP it is a different tale. Many FDA analist do end working in BP so there is a tendency to be easier on them now a small companies have a higher risk to encounter bumps on the road.