Avadel Wants Desmopressin Requirements

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Avadel Specialty Pharmaceuticals, which markets Noctiva (desmopressin acetate) nasal spray for treating nocturia due to nocturnal polyuria, is asking FDA to impose requirements on NDAs for desmopressin acetate products with that indication, including a resubmitted Ferring NDA for its Nocturna (desmopressin acetate). In its 5/18 petition, Avadel asks that the agency: 

  •          refrain from approving any NDA for a desmopressin acetate product for treating nocturia due to nocturnal polyuria, including Ferring’s pending NDA, unless the application includes data from at least two clinical trials in a subject population that is representative of likely product users;
  •          establish a standard for demonstrating effectiveness for a drug product to treat nocturia due to nocturnal polyuria that requires meeting appropriate primary and secondary endpoints, and that includes using a validated patient reported outcome and taking into consideration the data that demonstrated Noctiva effectiveness, and not approve any desmopressin NDA that does not meet the criteria;
  •          establish criteria for bioavailability and variability of absorption for a desmopressin drug for treating nocturia due to nocturnal polyuria, which criteria take into account the approved dosage form of Noctiva, an inhaled metered dose spray;
  •          refrain from approving Ferring’s desmopressin NDA unless it includes data from the risk mitigation studies recommended at a 1/12/15 advisory committee meeting and in a 2015 complete response letter to address concerns about using the Ferring drug in real-world conditions; and
  •          refrain from approving Ferring’s desmopressin NDA unless Ferring has provided patent certifications required under the Federal Food, Drug, and Cosmetic Act and its regulations, including specifically patents listed for Noctiva with the appropriate notices.

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