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	<title>Comments on: FDA Is Approving Fewer New Molecular Entities</title>
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	<description>News, Comment and Conversation</description>
	<pubDate>Fri, 10 Feb 2012 22:47:50 +0000</pubDate>
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		<title>By: CMC guy</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-364700</link>
		<dc:creator>CMC guy</dc:creator>
		<pubDate>Mon, 30 Jun 2008 03:15:36 +0000</pubDate>
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		<description>Good discussion and will jump in late with a few observations.  Nathan, Jack2 and Atlex are correct about the technical definition of NME (or older NCE tag) as any change in structure would be classified this way (so JIM answer NO in my experience).  However techdilligence point about metabolites (and I'll add prodrugs) is that even though we might consider only near new-NMEs they can behave differently.  

As noted "me toos" are necessary because don’t find found theperfect drug(s) due to individual responses (positive and negative) to different compounds in spite of same target or structural similarities.  Nathan correct about people chasing same targets at different shops as "ideas" occur simultaneously because people read same papers and go to same conferences (and have much the same training). Usually by time you find out other companies working on same thing the investment is too big and likely requires greater costs as race begins.  I think also tied to "blockbuster" mentality as limits possible areas of effort willing to get into.

Bob's question of drug price with biotech discovery sources I would suggest not much impact since FPME notes prices largely determined by what market will tolerate (which may force down in future).  It may help control early development costs a bit but biotechs are often even less efficient that big pharma in R&#38;D and generally can't do later steps well at all.  The smaller companies are less afflicted with blockbusteritis so that help widen fields of investigations</description>
		<content:encoded><![CDATA[<p>Good discussion and will jump in late with a few observations.  Nathan, Jack2 and Atlex are correct about the technical definition of NME (or older NCE tag) as any change in structure would be classified this way (so JIM answer NO in my experience).  However techdilligence point about metabolites (and I&#8217;ll add prodrugs) is that even though we might consider only near new-NMEs they can behave differently.  </p>
<p>As noted &#8220;me toos&#8221; are necessary because don’t find found theperfect drug(s) due to individual responses (positive and negative) to different compounds in spite of same target or structural similarities.  Nathan correct about people chasing same targets at different shops as &#8220;ideas&#8221; occur simultaneously because people read same papers and go to same conferences (and have much the same training). Usually by time you find out other companies working on same thing the investment is too big and likely requires greater costs as race begins.  I think also tied to &#8220;blockbuster&#8221; mentality as limits possible areas of effort willing to get into.</p>
<p>Bob&#8217;s question of drug price with biotech discovery sources I would suggest not much impact since FPME notes prices largely determined by what market will tolerate (which may force down in future).  It may help control early development costs a bit but biotechs are often even less efficient that big pharma in R&amp;D and generally can&#8217;t do later steps well at all.  The smaller companies are less afflicted with blockbusteritis so that help widen fields of investigations</p>
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		<title>By: Jun</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-364676</link>
		<dc:creator>Jun</dc:creator>
		<pubDate>Sun, 29 Jun 2008 21:20:33 +0000</pubDate>
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		<description>To Nuria: I think this story and its data are bogus. I do research on orphan drugs. If you read the title of the graph, it says "... through February." I think they are only showing the first two months of every year. There is no doubt that FDA has approved more NMEs and NBEs per annum. As for NMEs being a small proportion of NDAs, this is a no-brainer, because all types of applications go through as NDAs, such as new formulations, new manufacturers, new labeling etc.</description>
		<content:encoded><![CDATA[<p>To Nuria: I think this story and its data are bogus. I do research on orphan drugs. If you read the title of the graph, it says &#8220;&#8230; through February.&#8221; I think they are only showing the first two months of every year. There is no doubt that FDA has approved more NMEs and NBEs per annum. As for NMEs being a small proportion of NDAs, this is a no-brainer, because all types of applications go through as NDAs, such as new formulations, new manufacturers, new labeling etc.</p>
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		<title>By: Nuria Homedes</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-286520</link>
		<dc:creator>Nuria Homedes</dc:creator>
		<pubDate>Tue, 15 Apr 2008 23:20:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-286520</guid>
		<description>Could someone clarify why the FDA page lists a much higher number of NME per year? see link below
http://www.fda.gov/oc/history/NDAapprovals.html#table

Thanks</description>
		<content:encoded><![CDATA[<p>Could someone clarify why the FDA page lists a much higher number of NME per year? see link below<br />
<a href="http://www.fda.gov/oc/history/NDAapprovals.html#table" rel="nofollow">http://www.fda.gov/oc/history/NDAapprovals.html#table</a></p>
<p>Thanks</p>
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		<title>By: techdiligence</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205925</link>
		<dc:creator>techdiligence</dc:creator>
		<pubDate>Wed, 12 Mar 2008 21:38:53 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205925</guid>
		<description>This has been a great series of comment, far better than most threads.  As a former development chemist from large pharma I recall that the FDA had a definition for NCE (new chemical entity); “a chemical structure not previously marketed for human therapeutic use."  I assume this definition remains for the NME label.
The me-too issue is well summarized by Nathan in his several posts.  The existence of these has nothing to do with one company looking at a new, successful drug and then trying to copy it; it is the result of multiple companies making the same decisions 10 years (or more) in the past, and having technical and clinical organizations that have the same (high) level of ability since they are hired from the same pool of talent.  No one should be surprised that two organizations going after the same biological target actually produce the same drug, perhaps within months of each other. 
And me-too drugs do serve a real, clinical purpose.  My wife cannot tolerate atenolol but metoprolol is fine.  As a chemist, I can say that the structures of these two molecules do not show sufficient difference to make me think there is a huge intellectual step to get from one to the other, and I am surprised only that the initial patent (on atenolol) did not cover the metoprolol structure - but I say this 40 years after the fact.  Thus, I can suggest only one practical mechanism to decide what is a me-too drug and determine that it is unnecessary; prove safety and efficacy, then put it on the market and let the decision be made there - by the people actually taking the drug.
The issue posed by Atlex will hopefully recede as clinical work becomes more thorough.  I cannot speak for Nexium, but the Clarinex molecule is a metabolite of Claritin, and the current patent laws do allow this to be claimed as a new material.  The only way to avoid this (in reality) is to test for metabolites and their biological activity during both discovery and development of the drug.  This is done now, but is not easy to predict until there are clinical results, and then it is too late to change (although one could still patent).</description>
		<content:encoded><![CDATA[<p>This has been a great series of comment, far better than most threads.  As a former development chemist from large pharma I recall that the FDA had a definition for NCE (new chemical entity); “a chemical structure not previously marketed for human therapeutic use.&#8221;  I assume this definition remains for the NME label.<br />
The me-too issue is well summarized by Nathan in his several posts.  The existence of these has nothing to do with one company looking at a new, successful drug and then trying to copy it; it is the result of multiple companies making the same decisions 10 years (or more) in the past, and having technical and clinical organizations that have the same (high) level of ability since they are hired from the same pool of talent.  No one should be surprised that two organizations going after the same biological target actually produce the same drug, perhaps within months of each other.<br />
And me-too drugs do serve a real, clinical purpose.  My wife cannot tolerate atenolol but metoprolol is fine.  As a chemist, I can say that the structures of these two molecules do not show sufficient difference to make me think there is a huge intellectual step to get from one to the other, and I am surprised only that the initial patent (on atenolol) did not cover the metoprolol structure - but I say this 40 years after the fact.  Thus, I can suggest only one practical mechanism to decide what is a me-too drug and determine that it is unnecessary; prove safety and efficacy, then put it on the market and let the decision be made there - by the people actually taking the drug.<br />
The issue posed by Atlex will hopefully recede as clinical work becomes more thorough.  I cannot speak for Nexium, but the Clarinex molecule is a metabolite of Claritin, and the current patent laws do allow this to be claimed as a new material.  The only way to avoid this (in reality) is to test for metabolites and their biological activity during both discovery and development of the drug.  This is done now, but is not easy to predict until there are clinical results, and then it is too late to change (although one could still patent).</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205674</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Wed, 12 Mar 2008 15:30:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205674</guid>
		<description>Yes, Atlex, we agree.  The last sorts of examples you give - which are really a third category - are what drive me crazy as well.  

As for Angell and others, there has been a bit of a "me too" phenomenon there as well - particularly in many of the pop critiques that have followed on.  There is also work that is new and does, indeed, deserve serious attention.</description>
		<content:encoded><![CDATA[<p>Yes, Atlex, we agree.  The last sorts of examples you give - which are really a third category - are what drive me crazy as well.  </p>
<p>As for Angell and others, there has been a bit of a &#8220;me too&#8221; phenomenon there as well - particularly in many of the pop critiques that have followed on.  There is also work that is new and does, indeed, deserve serious attention.</p>
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		<title>By: Bob Freeman</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205658</link>
		<dc:creator>Bob Freeman</dc:creator>
		<pubDate>Wed, 12 Mar 2008 15:07:37 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205658</guid>
		<description>Another way incremental innovations enter the market(me toos, if you prefer) is through in-licensing from Japanese companies.  For many years Japanese companies thrived in Japan by tinkering with molecules--the regulatory and reimbursement systems encouraged this practice.  Since Japanese companies didn't have a significant marketing presence in the US, it was easy to out-license the North American rights to a pharma company that was strong in the US.  Justice, your Prevacid was in-licensed from a Japanese comapany (Takeda) and sold through a separate joint venture (TAP) formed between Takeda and Abbott.

As an aside, I wonder how the "new" model of letting biotech companies take the risk of early stage drug discovery and then in-licensing the technology (or acquiring the company) will affect drug prices in the future, since royalty payments will be reflected as a cost of goods.  The record high prices for deal-making will have to be factored in at some point.</description>
		<content:encoded><![CDATA[<p>Another way incremental innovations enter the market(me toos, if you prefer) is through in-licensing from Japanese companies.  For many years Japanese companies thrived in Japan by tinkering with molecules&#8211;the regulatory and reimbursement systems encouraged this practice.  Since Japanese companies didn&#8217;t have a significant marketing presence in the US, it was easy to out-license the North American rights to a pharma company that was strong in the US.  Justice, your Prevacid was in-licensed from a Japanese comapany (Takeda) and sold through a separate joint venture (TAP) formed between Takeda and Abbott.</p>
<p>As an aside, I wonder how the &#8220;new&#8221; model of letting biotech companies take the risk of early stage drug discovery and then in-licensing the technology (or acquiring the company) will affect drug prices in the future, since royalty payments will be reflected as a cost of goods.  The record high prices for deal-making will have to be factored in at some point.</p>
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		<title>By: Former pharma Marketing Exec</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205651</link>
		<dc:creator>Former pharma Marketing Exec</dc:creator>
		<pubDate>Wed, 12 Mar 2008 14:56:03 +0000</pubDate>
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		<description>The point is Nathan, there are overlaps and that needs to be fixed.  Do I think industry will fix them themselves - no I do not...Dialog, Dialog, Dialog  I really do not want to "force" anything other than finding a way to make the system work better, overcome the overlaps without penalizing the innovators and researchers.  

You shouldn't take issue with my characterization of "me too" drugs, you admit that this does happen.  The point is those are the ones I am looking at, these can and should be highlighted as un-necessary.  Read my words carefully, I did not say this is an arbitrary issue.</description>
		<content:encoded><![CDATA[<p>The point is Nathan, there are overlaps and that needs to be fixed.  Do I think industry will fix them themselves - no I do not&#8230;Dialog, Dialog, Dialog  I really do not want to &#8220;force&#8221; anything other than finding a way to make the system work better, overcome the overlaps without penalizing the innovators and researchers.  </p>
<p>You shouldn&#8217;t take issue with my characterization of &#8220;me too&#8221; drugs, you admit that this does happen.  The point is those are the ones I am looking at, these can and should be highlighted as un-necessary.  Read my words carefully, I did not say this is an arbitrary issue.</p>
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		<title>By: Nathan</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205583</link>
		<dc:creator>Nathan</dc:creator>
		<pubDate>Wed, 12 Mar 2008 13:18:40 +0000</pubDate>
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		<description>FPME writes:
"If there was some sort of way to communicate with one another through a government entity wouldn’t the patient population be better served if the information was shared and managed in a way that would allow for a some variations of a treatment for a given disease"

There IS communication between us already.  We all know we are working on the same targets because we are all publishing about the same targets and we all go to scientific meetings and present work about the same targets.  We learn from one another AND compete with one another.  Remember, the drugs we are publishing about today will not be on the market for another 5-10 years.  We don’t need a government agency to tell us that there are significant R&#38;D overlaps between companies – we know that already.  What to DO about those overlaps is a different question…  It sounds like you want to force companies to eliminate or minimize those overlaps.  My opinion is that the government should not be in the business of dictating the use of private R&#38;D money.

I also take issue with your characterization of "me-too" drugs as "slightly altered molecules".  Sometimes that is true.  If I'm struggling with a particular series of compounds, I might look at a competitor's patent and make a few intelligent "tweaks" to their molecules and start testing out those compounds myself.  However, more typically we are working on completely independent series of molecules.  In the end, they may have similar properties simply because we all have similar objectives -- but the molecules themselves were developed and optimized largely independently from one another.</description>
		<content:encoded><![CDATA[<p>FPME writes:<br />
&#8220;If there was some sort of way to communicate with one another through a government entity wouldn’t the patient population be better served if the information was shared and managed in a way that would allow for a some variations of a treatment for a given disease&#8221;</p>
<p>There IS communication between us already.  We all know we are working on the same targets because we are all publishing about the same targets and we all go to scientific meetings and present work about the same targets.  We learn from one another AND compete with one another.  Remember, the drugs we are publishing about today will not be on the market for another 5-10 years.  We don’t need a government agency to tell us that there are significant R&amp;D overlaps between companies – we know that already.  What to DO about those overlaps is a different question…  It sounds like you want to force companies to eliminate or minimize those overlaps.  My opinion is that the government should not be in the business of dictating the use of private R&amp;D money.</p>
<p>I also take issue with your characterization of &#8220;me-too&#8221; drugs as &#8220;slightly altered molecules&#8221;.  Sometimes that is true.  If I&#8217;m struggling with a particular series of compounds, I might look at a competitor&#8217;s patent and make a few intelligent &#8220;tweaks&#8221; to their molecules and start testing out those compounds myself.  However, more typically we are working on completely independent series of molecules.  In the end, they may have similar properties simply because we all have similar objectives &#8212; but the molecules themselves were developed and optimized largely independently from one another.</p>
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		<title>By: Former pharma Marketing Exec</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205553</link>
		<dc:creator>Former pharma Marketing Exec</dc:creator>
		<pubDate>Wed, 12 Mar 2008 12:37:15 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205553</guid>
		<description>Nathan and Justice,

This is good dialog about the issue of "Me too" - Nathan I can understand your frustration.  And although I know you are not a fan of what I have said before.  The example you share with us here on this thread highlights the point I was bringing up on the other thread.  If there was some sort of way to communicate with one another through a government entity wouldn't the patient population be better served if the information was shared and managed in a way that would allow for a some variations of a treatment for a given disease to be brought to market and incentive be given to help focus research into other areas.

I agree that two or three slightly altered molecules drive competition and the patients are helped because of the pricing issues.  But lets be clear on this as well, in marketing we study the prices of products in the same category and we honestly bring our product prices to match what the market will bear and that doesn't mean we are going to do much to bring the price down. Yes, there is some collusion amongst us, whether we admit it or not.

Today's system really needs an overhaul.  It adds way too much cost to the system and then we wind uo having to continue putting too much of an emphasis on marketing and sales which inevitably takes away from innovative research.</description>
		<content:encoded><![CDATA[<p>Nathan and Justice,</p>
<p>This is good dialog about the issue of &#8220;Me too&#8221; - Nathan I can understand your frustration.  And although I know you are not a fan of what I have said before.  The example you share with us here on this thread highlights the point I was bringing up on the other thread.  If there was some sort of way to communicate with one another through a government entity wouldn&#8217;t the patient population be better served if the information was shared and managed in a way that would allow for a some variations of a treatment for a given disease to be brought to market and incentive be given to help focus research into other areas.</p>
<p>I agree that two or three slightly altered molecules drive competition and the patients are helped because of the pricing issues.  But lets be clear on this as well, in marketing we study the prices of products in the same category and we honestly bring our product prices to match what the market will bear and that doesn&#8217;t mean we are going to do much to bring the price down. Yes, there is some collusion amongst us, whether we admit it or not.</p>
<p>Today&#8217;s system really needs an overhaul.  It adds way too much cost to the system and then we wind uo having to continue putting too much of an emphasis on marketing and sales which inevitably takes away from innovative research.</p>
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		<title>By: Atlex</title>
		<link>http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205531</link>
		<dc:creator>Atlex</dc:creator>
		<pubDate>Wed, 12 Mar 2008 12:09:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-is-approving-fewer-new-molecular-entities/#comment-205531</guid>
		<description>Justice, I'm pleased that your personal experience has demonstrated the need for follow-on drugs in a class.  There are many academics out there (eg, Angell) who would disagree with you.  As a pharma supporter, where I criticize the industry is in the development of products witht he same or near-same ME that offer no clear advantage.  I can understand the development of a 1x/day version of a TID drug--increased compliance has value.  This can be accomplished through a different delivery mechanism (timed release, eg.) or via a related chemical entity (pro-drug or metabolite).  What drives me nuts is the development of near-same MEs that offer little or no added value--eg, Nexium and Clarinex.  These may offer short term sales for the manufacturer, but they hurt the industry in the LT.</description>
		<content:encoded><![CDATA[<p>Justice, I&#8217;m pleased that your personal experience has demonstrated the need for follow-on drugs in a class.  There are many academics out there (eg, Angell) who would disagree with you.  As a pharma supporter, where I criticize the industry is in the development of products witht he same or near-same ME that offer no clear advantage.  I can understand the development of a 1x/day version of a TID drug&#8211;increased compliance has value.  This can be accomplished through a different delivery mechanism (timed release, eg.) or via a related chemical entity (pro-drug or metabolite).  What drives me nuts is the development of near-same MEs that offer little or no added value&#8211;eg, Nexium and Clarinex.  These may offer short term sales for the manufacturer, but they hurt the industry in the LT.</p>
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