If you would like to ask our webinar guest speakers from WS Blue Whale Growth Fund, Taseko Mines, Kavango Resources and CQS Natural Resources fund a question please submit them here.
Recordati intends taking this through the centralised route, which involves submission of a Type II variation (covering non-clinical/clinical data, safety, efficacy, formulation, risk management plan). Timetable guidance is provided after the pre-submission scientific advisory meeting and will depend on the breadth and depth (or lack) of data.
As to "good news", you need to consider this development in context. An Rx to OTC switch generally occurs towards at the the end of the product lifecycle/close to loss of market exclusivity, where there is an extensive safety base and with a strong and established brand. For example,Pfizer took 10 years from launch to submit a Viagra switch, although this was quickly withdrawn when they could not satisfy EMEA concerns (even with a 35 million man safety database and data from 120 clinical studies). Almost another decade went by until "Viagra Connect" was accepted (via the national route) as a pharmacy only medicine.
That Recordati would contemplate a switch after less than 2 years after launch through a centralised procedure, with next to no post-marketing experience, and with none of the deficiencies identified in the EPAR addressed, is unprecedented (and unfathomable). While there was never any great expectation around Fortacin, it now appears to have been written off as a promotable Rx product, with classification switching being a last and desperate kick of the ball.
Ah, dear old Bunion- how's the Aricept working out for you?
And that's certainly no way to refer to Recordati's commercial director- I think his or her opinion to abandon Fortacin as a viable prescription product is perfectly valid, even if they are in for a frosty reception from the EMA with respect to the paucity of data, although a Pharmacy only designation might be achievable in some countries.
With the urology franchise winding down, makes sense to throw it in with the other small fry in the OTC portfolio, with the hope that it might bob along at €1m or so each year, with a hefty reduction in wholesale pricing necessary if they want to take this out through retail chains. Still, better than deep-sixing it entirely, although that might still be on the cards.
Possibly a world record in attempting an OTC switch within 21 month of launching as an Rx product. The other piece of record-breaking being that PLE/RP have managed to get every single prediction concerning the "value proposition"- pricing, uptake, KOL engagement, patient satisfaction- so utterly and completely wrong. Looking forward to RP's explanation of the Recordati decision.
From the EMA Pharmacovigilance Risk Assessment Committee Agenda this week:
Applicant: Recordati Ireland Ltd
PRAC Rapporteur: Maria del Pilar Rayon
Scope: Change in the legal status from ‘medicinal product subject to medical prescription’ to ‘medicinal product not subject to medical prescription’ in view of the safety profile of Fortacin (lidocaine/prilocaine), the post-marketing experience already available with other medicinal products containing amide local anaesthetics and in view of making the medicinal
product more accessible to the target population.
May not happen, given the lack of chronic toxicity data (and that other lidocaine-prilocaine products are all Rx), but looks like they've given up on getting traction among prescribers or trying to differentiate it from €5 knob sprays.
Trademark here: http://tinyurl.com/pjq3qc2
Only rumour, but I'd heard that they were working on a CDB-infused Fortacin formulation with the hope that it would calm down punters angered by having spaffed forty notes on a mediocre knob spray.
Trademarked "*******" in honour of the CEO. To be launched 2035, eh no, 2037, maybe 2042? Greece and Romania 2060....
Bothwell, as far as dependence on future return from Fortacin goes, the answer is "yes and "yes".
Sales simply reflect a reality that RP has chosen to ignore: that, while no worse than other PE treatments, Fortacin lacks the attributes required to attract and retain presribers and punters and meaningfully expand a very small market.
These flaws are inherent in Fortacin's make up and will continue to constrain uptake in Europe and in any future sales territories. If that were not enough, add in the impact of limited clinical and safety data, no patent protection and residual/minimal market exclusivity, no reimbursement under public or private healthcare plans and significant pricing pressure and competition from products already ensconced in the prescriber/distance prescribing channels.
Not only is the Fortacin pie always going to be on the teenie weenie side, but if you understand how deal terms relate to value split, RP will only ever see the crumbs.
A bit neg?, Well, yes, but I defy anyone to come up with a credible scenario where Fortacin rocks on as top dog, rather than being the runt of the litter, feebly scratching at the sack en route to the local duckpond.
Not singling you out, but like the other broken pencils, you are missing the point.
Recordati sees so much potential for UK sales that it's gone for an exclusive arrangement with a single online pharmacy. There is nothing underway in the form of targeted or shotgun promotion to prescribers on the understandable basis that no independent advisory (DTAB, the updated RTDC opinion) or CCG has ever expressed a positive opinion regarding Fortacin, and that it remains uniformly black or grey-listed.
Fortacin's problem is, uh, Fortacin- same mediocre performance as other PE treatments and no post-approval data to show that it's any different to yer common or garden, six-fold cheaper, knob spray containing the same pharmaceutical active but with a more benign safety profile. Hardly a platform for prescriber engagement.
And according to Recordati's own little SurveyMonkey efforts, only 4 out of 10 blokes are wiling to pony up again for a treatment which is claimed to be the answer to their prayers.
After over a full year in the market, net sales at the half year amounted to less than 0.08% of Recordati's pharma only revenue and generic silodosin introduction means the whole urology franchise is being wound down in once key territories.
Seriously, is there anyone who still believes that this is ever going to return more than Friday noodles and ice cream money?
Incorporation in Ireland is a hedge against no-deal Brexit issues relating to additional testing and packaging requirements for the importation of pharmaceuticals from non-EU countries. For example, the QP responsible for batch release has to be in an EU member state, packaging will need to carry new registration numbers.
More or less correct. It's an "informed consent" submission, meaning that it's made with the permission of the MAH, Recordati. It allows RP to submit EMA data under their own drug name/trademark where mutual recognition procedures are in place and to obtain a "certificate of pharmaceutical product" (a comfort factor for the importing country with respect to manufacture, drug strength, pharmaceutical form: CPP is a prerequisite for registration and not a substitute for a full dossier).
The Senstend trademark was granted back 2016. Fortacin is already claimed in China and several other non-Recordati countries and Plethora abandoned the US application a long time ago, and Senstend has been prosecuted in the US, China, Australia and other countries. The Fortacin trademark is registered to Plethora in Hong Kong (since 2018).
Nice to know that POM is still hoping that this dog will eventually have its day (if you are reading this, hope all is good with you). And, was I right or was I right about the rate of uptake in Europe?
Bothwell, yes, if you believe that Fortacin revenue is critical for RP's continued survival.
I can bang on about my rationale for this statement but instead I'll leave you with a quote which I've used for years when teaching pharma business development. Ironically, it's lifted from an analysis of Viagra market development:
"“The single most revealing measure of an innovation's economic value is the market's response to it.” (Alison Keith)
As usual, too little detail to divine the true state of affairs, but with only around 27,000 canisters sold in H1 of the second year of launch (in a territory now comprising six countries with a combined adult male population of over 106m), safe to say that wholesalers remain understandably indifferent to the “next big revolution after Viagra" (copyright MG Wyllie 2017). Wonder if he uses a Betamax recorder to catch up with The Great British Bake Off?
And what's with this "relaunch" malarkey? Certainly no evidence of new initiatives directed by the various national subsidiaries, unless you count an exclusive distribution agreement with a certain UK-based online pharmacy.
Having used Ipsos myself for market development support, I don't doubt the quality of the survey data but it's a very strange brief. Why focus on PE patients when it's prescriber perceptions that make or break a Rx product? As my dear old grey-haired grandma used to say "Punters don't prescribe. Prescribers prescribe. And you can't promote to punters".
I strongly suspect that very few of the interviewed sufferers had any experience of Fortacin, but, if the statement that only 40% of cats prefer Fortacin is to be believed, that makes it half as popular as Whiskas and suggests a higher early discontinuation rate than for SSRIs. This does not inspire confidence in a business plan which assumes chronic use and repeat scripts.
As for HK, the delay is possibly due to sprays not being terribly popular at the moment (thinking high pressure water, tear gas, pepper, dye....). And still no update on the TFDA bridging study submission.
It's generally Bunion's posts that make me laugh out loud, but this had me spraying Earl Grey all over my keyboard.
NDA submission (if at all) before the end of 2020 is, and remains, complete nonsense (and at odds with the estimate given in the PLE accounts signed off on 26th July, which at least recognises the time necessary for COA review). Is JG mistakenly referencing a typo in the RP release?
The statement regarding pivotal study size, if relative to the Phase II study, is equally nonsensical. However, allowing for JG's butterfingered grasp of all things study-related, it's possible that he means smaller than the two previous pivotal studies, not impossible since the expected delta between treatment and placebo groups and drop-out rate are predictable and power can be tweaked accordingly, although risky when you are dealing with multi-centre studies and multiple secondary endpoints.
As for "stock replenishment", canisters delivered to wholesalers at launch 18 months ago have now expired- wonder just how many thousands are sitting in recycling skips? And whatever happened to scale-up (no corresponding variation has been submitted)? Still unresolved "impurities" issues or simply not worth the faff for such low volumes?
All credit to Bignose for sharing, but the linked article dates from 2016, prior to the 21st Century Cures Act, and consequent changes in the FDA review process and a shift towards "patient-centric" drug development, with revision of the clinical outcomes assessment process being of obvious relevance.
The current FDA process should be viewed as a work in progress, with further major and minor revision anticipated as the 21st CCA is interpreted/reinterpreted and implemented over the next eight years.
All pharmaceuticals have, to a greater or lesser degree, safety concerns and Fortacin is of course no exception. Specific issues (drug interaction, age or disease-related hepatic impairment, potentially carcinogenic metabolite generation) and deficiencies in the safety data are clearly referenced in the EPAR.
The EMA took the reasonable and pragmatic view that outstanding concerns could be addressed through labeling and mandatory post-marketing studies. Recordati were able to wiggle out of the latter due to delays in marketing and absence of real life usage data.
The gamble is that the FDA (assuming "bother" is accepted in support of label claim) will also be pragmatic in consideration of a safety package comprising old and less than comprehensive data. Personal view is that, at the very least, it will require strong reassurance with respect to the metabolite questions and risk assessment around partner transfer. And let's not forget satisfaction of the crucial combination product rule.
I wouldn't read anything in to it- many clinical studies go months (or even years) without an update.
The rate-limiting factor is not "reluctance" per se, but the stringent subject selection criteria (limited to lifelong PE according to the ISSM definition, with a population prevalence of only a few percent, plus a raft of other exclusions), hence the need for a relatively large number of sites (18 listed) to recruit for what is after all a small (100 subject) pilot study.
Interims released this pm, bigs up the recent rare disease acquisitions and underscore the commitment to orphan/rare disease expansion (both by portfolio and geography).
Still apparent growth in Urorec revenue, although not clear whether this is through volume or price increase, but might mean that the urology field force in mature markets may not be wound down immediately.
That's "alluded", although I'm sure they would love to elude a requirement for two pivotal studies.
That's a bit harsh- RP is equally inconsistent with inaccurate information.
I see that the famous Gibson time dilation effect is still in effect. Good show if the validation study will complete early, but since there is no fixed timeline for a full COA qualification package review (and with the current street estimate being 6-10 months), a Q1 2020 start for pivotal study work is pretty nigh impossible. And let's not dismiss the risk around submitting what is no more than a pilot study for an otherwise untested endpoint.
Assuming there's not a typo in the dates, you are looking at the shortest Phase III and NDA submission in history:again, pretty nigh impossible. RP have eluded to a single pivotal study, but outside of cancer and high need conditions, the FDA requires two studies (and historically, this has been the case for the few PE pivotal studies submitted in the last decade). And when are they planning to address the combination product rule question?
China timeline is close enough - 60 day IND review if nothing amiss with the submission, but there's no allowance for a pre-IND submission meeting, so add another 30-60 days and call it sometime late Q1 2020 until the NMPA response. Still no mention of the Taiwan FDA bridging study requirements.
As for the possible involvement in indigenous hemp/CBD production, hard to evaluate without more detail. Hemp production and CBD extraction are strictly regulated but there appears to be an increasing number of licences granted to Chinese companies. Hemp seek, oil and CBD are legal for use in cosmetics (but not ingestion), and not for medical use
The Chinese require animal testing for cosmetic approval (leading to a complex importation route for foreign cosmetics, although readily navigated by the majors) and no medical or wellness claims can be made that might assist with product differentiation. Chinese cosmetics do not meet EU or US conditions, so not possible to export finished product. So, all down to hemp/CBD export from China into increasingly competitive/self-sufficient markets?
All been written before, but Fortacin was acquired on the strength of being no more than a low-cost add-in to support an ageing urology franchise and perhaps squeeze a bit more out of an established field force.
Initial promotion was in line with what would you would expect for a minor product with well-recognized constraints on uptake: the early abandonment of active promotion may, in part, be due to realization of just how high the barriers are, but more likely reflects the bigger picture of abandonment of the urology franchise in developed markets (crucially, Italy, France and Spain) with the loss of Urorec exclusivity.
You are right to be wary of the developing competitive market. China (after Japan and Korea) has been an important market for the high-end cosmetics companies for several years and they already have well-developed marketing channels which exploit social media.
In February, China banned cosmetics companies from making "medical" claims, so CBD facials, shampoos etc will, as in other countries, be promoted as luxury products, with perhaps a nod to "natural" ingredients, through existing tried and tested channels. While a social media/infomercial approach is the way to go, I'm skeptical about early-mover advantage claims, since"early" was years ago for the big brands.
A major brake on the Chinese, and other, markets is regulation (or the current lack of it). The FDA are still in the process of developing guidelines for CBD consumer product safety assessment and evidence in support of wellness claims; other, less resourced, regulatory agencies have not even reached the roadmap stage. It's a far from static situation, but from past involvement in establishing OTC product and dietary supplement claims, it's going to be a long haul to regulatory clarity.
Small fry like RP might find eventually find a niche in the Asian CBD market, but the safety shot is to assume a long timeline and modest turnover (and not to forget RP's track record with regard to market predictions).
@the_italian- cannabinoid investment overview from Edison in my mailbox this morning (CBD gets a mention, but largely covers psychoactive products).
http://tinyurl.com/y2w77a3c
Own experience of CBD is confined to investment for medical development (cancer, cognitive function) although I have reviewed several consumer product (cosmetic/wellness) investor pitches for non-Asian businesses and have a passing interest in the bigger picture.
Ironically, while, along with Canada, being the world's largest producer of cannabis (as hemp) and with hemp seed and extracts being traditional medical ingredients for tens of centuries, China is still a long way from liberalizing CBD use (although legal in Japan and Korea). A usually reliable investment bank source estimates annual sales of CBD consumer products in China to be under $140 million.
US consumer CBD brands are busily looking for new markets ("wellness" and cosmetic claims are regulated in Europe and need to be backed with solid data, making Asia more attractive. US legislation is a work in progress, with federal law at odds with state law. The FDA has still to produce guidelines for ingested CBD products).
Product awareness is currently very low in China, and it's entirely credible that market development will be heavily reliant on social media. As a B2C/B2B operation, Yooya might pick up a portfolio of brands, although social media promotion is highly competitive and revenues would likely be modest and slow to develop (possibly more lucrative in other Asian countries?).
The few sanctioned Chinese CDB producers are understandably focused on the US as their main market, and personal view is that it will be years before there is a domestic market for locally-produced CBD consumer products. This might change as the 2018 Farm Bill will result in more US-produced hemp, in turn reducing export opportunities.