Title: ONTAK denileukin diftitox Postapproval Clinical Commitment
1- ONTAK (denileukin diftitox) Post-approval
Clinical Commitment
Oncologic Drugs Advisory Committee Meeting March
12-13, 2003 Bethesda, MD
2ODAC MeetingLigand Attendees
- James LItalien, Ph.D.Sr. Vice President,
Regulatory Affairs Compliance - Gordon Bray, M.D. (Speaker)Sr. Medical Director
of Clinical Research - Andrés Negro-Vilar, M.D., Ph.D.Sr. Vice
President, Research DevelopmentChief
Scientific Officer - Eric Groves, M.D., Ph.D.Vice-President, Project
Management - Francine Foss, M.D. (Consultant) Professor of
Medicine Tufts-New England Medical
CenterBoston, MA
3Presentation Objectives
- Review structure, mechanism of action and
clinical characteristics of denileukin diftitox
(ONTAK) - Review clinical basis for accelerated approval
and key development milestones - Describe the outstanding clinical commitment for
final approval - progress to date
- ongoing efforts to achieve completion of the
study - challenges encountered
- Summary
4Denileukin Diftitox Structure
- Fusion protein that targets cytocidal activity of
diphtheria toxin to tumor cells expressing the
receptor for IL-2 (IL-2R) - Leukemic and lymphoma cells of B and T cell
origin (including cutaneous T-cell lymphoma),
constitutively express one or more subunits of
IL-2R
5Denileukin Diftitox (ONTAK?) Mechanism of Action
DT
IL2
HIGH affinity IL2 receptor
Cell exterior
MEDIUM affinity IL2 receptor
ONTAK
DT
IL2
g
b
Cell membrane
Cell interior
Internalization of IL2R with bound toxin
CELL DEATH
DT
IL2
DT
Cleavage Toxin release
Protein synthesis terminated by toxin-mediated
ADP ribosylation of elongation factor 2
6ONTAK? Clinical Characteristics
- Indicated for the treatment of patients with
persistent or recurrent, CD25 () cutaneous
T-cell lymphoma (CTCL) - Acceptable safety profile
- Minimal myelosuppression
7Clinical Data Supporting ONTAK? Approval
- Accelerated approval based on data in CTCL
patients from 2 clinical studies - 37 response rate (Phase I/II Study)
- 30 response rate (Phase III Study)
- Full approval requires completion of 3 arm,
blinded, placebo controlled CTCL trial L4389-11
8Post-approval Clinical Commitment for ONTAK?
- Study L4389-11
- On target for submission of a final study report
in early 2006, per prior communications with FDA
9Key Regulatory/Development Milestones
August 1996
Orphan Drug designation
December 1997
BLA submitted by Seragen, Inc.
Accelerated approval granted
Ligand Pharmaceuticals assumes all development
responsibility
February 1999
10L4389-11 Study Design (1)
- Persistent/refractory CTCL
- Disease Stage Ia-III
- CD25 ()
- 3 prior therapies
- Efficacy endpoints
- response rate
- time-to-progression, response duration
11L4389-11 Study Design (2)
- Following discussion with FDA during 1999, study
population was increased from 120 (404040) to
195 (397878) - maintains original size of the placebo group
- weights randomization toward active study drug to
encourage enrollment
12L4389-11 Study Design (3)
- 5 daily treatments every 21 days tumor burden is
assessed at Baseline and Day 1 of each course
after Course 1
13Enrollment in L4389-11 Progress to Date
105
98
89
Patients Enrolled
82
73
73
Year
14Ongoing Efforts to Complete Study L4389-11
28
22
Cumulative Active Sites
10
9
1
Year
15Current Status of L4389-11
- Enrolled 105 of 195 patients needed to complete
study - 28 active enrolling sites
- Seven patients enrolled in the first two months
of 2003 - We estimate that 29 of 39 required placebo
patients have enrolled - On target for submission of a final study report
in early 2006
16Challenges Encountered in Conduct of L4389-11
- Small population size few large clinical
research centers - Practice patterns for CTCL management
- Impact of prior therapies on eligibility
- Impact of the placebo arm
17Small Population Size
- CTCL constitutes only 2.2 of all lymphoma cases
in the U.S. - Annual incidence approximately 4 per million
- Approximately 1,100 new U.S. cases of CTCL
reported per year - Approximately 400 CTCL patients treated with
ONTAK in 2002
Surveillance, Epidemiology and End Results
(SEER) data, NCI (1973 through 1992)
18Impact of Practice Patterns and Prior Therapies
on Accrual
Clinical Stage
IA IB IIA
IIB III IVA IVB
Eligible for L4389-11
19Impact of the Placebo Arm
- Patients often decline participation in placebo
study due to symptoms/complications associated
with CTCL (severe pruritis, ulcerations) - Investigators are reluctant to consider a placebo
controlled study, especially for late stage
patients - Governmental opposition attempts to conduct
study at six sites in France were unsuccessful - After approval by local Ethics Committees, the
French MOH declined the clinical trial
application, citing the revised Declaration of
Helsinki
20Summary
- Study enlarged from 120 to 195 patients to
encourage patient enrollment while maintaining
original size of placebo group - Multicenter, international expansion of study
L4389-11 to a total of 28 study sites - 1.5 2.0 patients/site/yr will achieve the goal
of completion by 2006 - On target for submission of a final study report
in early 2006