Nasrat was right on both statements during the past two CCs.
1. Intas invalidating some of Purdue's patents are completely irrelevant for the 180-day exclusivity.
2. The "substantially complete" ANDA application filing begins the PDUFA date, NOT when the FDA formally accepts the application.
- "With respect to 180-day generic drug exclusivity , we note that Roxane was the first ANDA applicant to submit a substantially complete ANDA with a paragraph IV certification for Sodium Oxybate Oral Solution, 500 mg/mL."