Higher Dose13 Nov 2022 14:57
Remember this is FDA recommendation to use higher dose. They are not telling IMM/Avion to do. It's a recommendation, the option to do it or not to do it.
After the original phase 3 inconclusive result, the FDA gave IMM the authority and allowed another phase 3 to go ahead. It is this written reponse Avion signed a licensing deal to fund and take it into phase 3, not phase 1 or 2.
The FDA cannot backtrack on this or it will be opened to legal challenge.
Now it looks like IMM/Avion will take this recommendation. Having higher dose does not mean it will be better. Neither the original dose or the higher dose will guarantee success.
The question is which one will have a higher chance of success.
With the original dose, we have a rich data to date. We know what went right and what went wrong. We are almost there to the finishing line with the second phase 3 we were about to start.
With this new higher dose, we are going backwards. We have no data on human subjects. Once we have the optimum dose level and move into into phase 3, we are going blind, fingers crossed and hoping it will pan out well. If it succeed, hooray approval awaits. If it fails, then what? They will have to resort going back to the original dose and the phase 3 what was originally planned. Years and money would have been wasted. With this original dose we know what we getting. With the higher dose it is thwart with danger of failure and carry a higher risks.
My personal opinion on this, if I was IMM/Avion is to run both the original dose and the higher dose concurrently in separate trials. As it were, get the best of both worlds. That's of course if FDA allows it. This would mean Avion will have to spend another £25m on top of the licenced deal £25m. IMM and Avion will have to renegotiate the licencing deal and to compensate this Avion now take the whole worldwide rights to Lupuzor and IMM will now receive higher royalty, say, between 20% to 25% in return. Just my opinion on this of course.