Extract to table
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Extract to table / post-clarion3-regulatory-path-memo.docx
post-clarion3-regulatory-path-memo.docx
Parties
HARKNESS LLP
Penterra Pharmaceuticals Corp
Callendar Baines Group LLC
Grange LLP
Thornfield Lewis LLP
Dates
November 17, 2022
November 21, 2022
May 4, 2022
June 7, 2022
July 28, 2022
November 22, 2022
October 28, 2022
October 3, 2022
September 8, 2022
September 26, 2023
Amounts
$250,000
$400,000
$1.47
$2.18
$6.3
Obligations
Because the study design required both co-primary endpoints to be met for the overall study to be considered positive, CLARION-3 must be classified as a failed confirmatory trial for purposes of the sNDA filing
During that meeting, the Division communicated several positions that are directly relevant to the current analysis: First, the Division stated that both co-primary endpoints in the confirmatory trial must be met in order for the confirmatory trial data to support the sNDA filing
This is a critical constraint on the analysis that follows: any regulatory path forward must account for the fact that FDA's stated standard — agreed to by both parties — was not achieved
However, the deferral is subject to an annual reporting obligation: Penterra must submit annual progress reports to FDA describing the status of the pediatric development program, regardless of whether the adult indication has been approved
Penterra must continue to submit these annual reports in a timely manner even during the dormancy period