IN THE CIRCUIT COURT FOR

Janet Watkins

PDF AMDAC-20190807-Transcript
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FOOD AND DRUG ADMINISTRATION

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CENTER FOR DRUG EVALUATION AND RESEARCH

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ANTIMICROBIAL DRUGS ADVISORY COMMITTEE MEETING

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(AMDAC)

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Wednesday, August 7, 2019

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8:30 a.m. to 4:54 p.m.

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FDA White Oak Campus

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White Oak Conference Center

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Building 31, The Great Room

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10903 New Hampshire Avenue

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Silver Spring, Maryland

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Meeting Roster

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DESIGNATED FEDERAL OFFICER (Non-Voting)

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Lauren Tesh Hotaki, PharmD, BCPS, BCIDP

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Division of Advisory Committee and Consultant

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Management

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Office of Executive Programs, CDER, FDA

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ANTIMICROBIAL DRUGS ADVISORY COMMITTEE MEMBERS

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(Voting)

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Lindsey R. Baden, MD

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(Chairperson)

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Director of Clinical Research

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Division of Infectious Diseases

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Brigham and Women's Hospital

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Director, Infectious Disease Service

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Dana-Farber Cancer Institute

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Associate Professor, Harvard Medical School

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Boston, Massachusetts

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CAPT Timothy H. Burgess, MD, MPH, FACP

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Director

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Infectious Disease Clinical Research Program

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Preventative Medicine & Biostatistics

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Uniformed Services University of the Health

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Sciences

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Bethesda, Maryland

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Michael Green, MD, MPH

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Professor of Pediatrics, Surgery and Clinical &

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Translational Science

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University of Pittsburgh School of Medicine

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Division of Infectious Diseases

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Director, Antimicrobial Stewardship & Infection

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Prevention

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Co-Director, Transplant Infectious Diseases

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Children's Hospital of Pittsburgh

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Pittsburgh, Pennsylvania

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Barbara M. Gripshover, MD

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Associate Professor of Medicine

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University Hospitals Cleveland Medical Center

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Case Western Reserve University

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Division of Infectious Diseases and HIV Medicine

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Cleveland, Ohio

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Jennifer Le, PharmD, MAS

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Professor of Clinical Pharmacy

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University of California, San Diego

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Skaggs School of Pharmacy and Pharmaceutical

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Sciences

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La Jolla, California

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Ighovwerha Ofotokun, MD, MSc

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Professor of Medicine

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Division of Infectious Diseases

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Department of Medicine

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Emory University School of Medicine

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Atlanta, Georgia

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George K. Siberry, MD, MPH

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Medical Officer

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Division of Prevention, Care & Treatment

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Office of HIV/AIDS (U.S. President's Emergency Plan

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for AIDS Relief)

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U.S. Agency for International Development

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Arlington, Virginia

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Sankar Swaminathan, MD

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Professor and Chief

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Division of Infectious Diseases

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Department of Internal Medicine

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University of Utah School of Medicine

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Salt Lake City, Utah

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Roblena E. Walker, PhD

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(Consumer Representative)

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Chief Executive Officer

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EMAGAHA, INC.

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Mableton, Georgia

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Peter Joseph Weina, PhD, MD

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Colonel, Medical Corps, US Army

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Branch Chief

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Research Regulatory Oversight Office

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Office of the Under Secretary of Defense

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(Personnel and Readiness)

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Defense Health Headquarters

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Falls Church, Virginia

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TEMPORARY MEMBERS (Voting)

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Laura W. Cheever, MD, ScM

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Associate Administrator, HIV/AIDS Bureau

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Health Resources and Serviced Administration

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U.S. Department of Health and Human Services

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Rockville, Maryland

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Demetre C. Daskalakis, MD, MPH

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Deputy Commissioner

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Division of Disease Control

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New York City Department of Health and Mental

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Hygiene

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New York, New York

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Lori E. Dodd, PhD

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Mathematical Statistician

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Biostatistics Research Branch

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Division of Clinical Research

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National Institute of Allergy and

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Infectious Diseases (NIAID)

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National Institutes of Health (NIH)

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Bethesda, Maryland

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Thomas P. Giordano, MD, MPH

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Professor and Chief

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MD Anderson Foundation Chair Section of Infectious

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Disease Department of Medicine

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Baylor College of Medicine

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Research Scientist

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Michael E. DeBakey Veterans Affairs (VA) Medical

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Center

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Houston, Texas

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Matthew Bidwell Goetz, MD

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Chief, Infectious Diseases

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VA Greater Los Angeles Healthcare System

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Professor of Clinical Medicine

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David Geffen School of Medicine at UCLA

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Los Angeles, California

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Patricia Lupole (via phone)

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(Patient Representative)

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Norfolk, Virginia

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Sarah W. Read, MD, MHS

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Deputy Director, Division of AIDS

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NIAID, NIH

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Rockville, Maryland

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Dawn K. Smith, MD, MS, MPH

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Biomedical Interventions Implementation Activity

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Lead

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Epidemiology Branch, Division of HIV/AIDS

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Prevention

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National Center for HIV, Viral Hepatitis, STD, and

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Tuberculosis Prevention

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Centers for Disease Control and Prevention

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Atlanta, Georgia

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ACTING INDUSTRY REPRESENTATIVE TO THE COMMITTEE

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(Non-Voting)

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Walid M. Awni, PhD

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(Acting Industry Representative)

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Awni BioPharmaceutical Consulting, LLC

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Riverwoods, Illinois

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FDA PARTICIPANTS (Non-Voting)

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John Farley, MD, MPH

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Deputy Director

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Office of Antimicrobial Products (OAP)

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Office of New Drugs (OND), CDER, FDA

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Debra Birnkrant, MD

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Director

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Division of Antiviral Products (DAVP)

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OAP, OND, CDER, FDA

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Jeffrey Murray, MD, MPH

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Deputy Director

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DAVP, OAP, OND, CDER, FDA

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Wendy Carter, DO

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Medical Officer Team Leader

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DAVP, OAP, OND, CDER, FDA

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Peter Miele, MD

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Medical Officer

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DAVP, OAP, OND, CDER, FDA

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Jenny H. Zheng, PhD

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Clinical Pharmacology Reviewer

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Division of Clinical Pharmacology IV

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Office of Clinical Pharmacology

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Office of Translational Sciences, CDER, FDA

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C O N T E N T S

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AGENDA ITEM

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Call to Order and Introduction of Committee

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Lindsey Baden, MD

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Conflict of Interest Statement

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Lauren Tesh Hotaki, PharmD, BCPS, BCIDP

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FDA Opening Remarks

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Jeffrey Murray, MD, MPH

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Applicant Presentation - Gilead Sciences, Inc.

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Introduction

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Diana Brainard, MD

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DISCOVER Study Design, Treatment

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Population, and Efficacy Results

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Scott McCallister, MD

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DISCOVER Safety and Extrapolations

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Moupali Das, MD, MPH

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Clinical Context

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Richard Elion, MD

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Clarifying Questions

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C O N T E N T S (continued)

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AGENDA ITEM

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FDA Presentation

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NDA 208215/S12 - Descovy PrEP

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Peter Miele, MD

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Clarifying Questions

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Open Public Hearing

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Clarifying Questions (continued)

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Questions to the Committee and Discussion

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Adjournment

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P R O C E E D I N G S

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(8:30 a.m.)

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Call to Order

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Introduction of Committee

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DR. BADEN: It's 8:30. Good morning. I

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would first like to remind everyone to please

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silence your cell phones, smartphones, and any

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other devices if you have not already done so. I

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would also like to identify the FDA press contacts,

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Alison Hunt and Charles Kohler. If you're present,

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please stand. They're in the back. If there are

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questions for the press, please address them to

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Alison and Charlie.

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My name is Lindsey Baden. I will be

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chairing today's meeting. I will now call the

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Antimicrobial Drugs Advisory Committee to order.

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We'll start by going around the table and

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introducing ourselves. We'll start with the FDA to

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my left and go around the table.

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DR. FARLEY: Good morning. John Farley,

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deputy director of the Office of Antimicrobial

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Products, CDER, FDA.

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DR. BIRNKRANT: Debbie Birnkrant, director,

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Division of Antiviral Products, CDER, FDA.

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DR. MURRAY: Jeff Murray, deputy, Division

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of Antiviral Products, CDER, FDA.

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DR. CARTER: Wendy Carter, clinical team

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leader, Division of Antiviral Products, CDER, FDA.

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DR. MIELE: Pete Miele, medical officer,

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Division of Antiviral Products, CDER, FDA.

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DR. ZHENG: Jenny Zheng, clinical

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pharmacology reviewer for antiviral products, CDER,

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FDA.

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DR. CHEEVER: Hi. I'm Laura Cheever from

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the HIV/AIDS Bureau at the Health Resources and

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Services Administration.

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DR. SWAMINATHAN: I'm Shankar Swaminathan,

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infectious diseases division chief at the

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University of Utah.

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DR. SIBERRY: George Siberry, Office of

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HIV/AIDS, Global Health Bureau, USAID.

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DR. GRIPSHOVER: Barbara Gripshover from

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University Hospitals Cleveland, Case Western

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Reserve University, adult infectious disease.

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DR. GREEN: Michael Green, University of

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Pittsburgh School of Medicine, Children's Hospital

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Pittsburgh, pediatric infectious diseases.

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DR. WEINA: Peter Weina, adult infectious

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diseases, Research Regulatory Oversight Office,

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Defense Health Headquarters.

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DR. HOTAKI: Lauren Hotaki, designated

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federal officer.

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DR. BADEN: Lindsey Baden, adult infectious

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diseases, Brigham and Women's Hospital, Dana Farber

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Cancer Institute, Harvard Medical School, Boston

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Mass.

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DR. OFOTOKUN: Igho Ofotokun, adult

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infectious diseases, Emory University, Atlanta,

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Georgia.

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DR. BURGESS: Tim Burgess, adult infectious

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diseases. I'm director of DoD's Infectious Disease

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Clinical Research Program at Uniform Services

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University.

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DR. LE: Jennifer Le, professor of pharmacy

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at UC San Diego, pediatric infectious diseases.

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DR. WALKER: Good morning. Dr. Roblena

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Walker, EMAGAHA, Inc., Atlanta, Georgia, consumer

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representative.

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DR. GIORDANO: Tom Giordano, adult

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infectious disease, Baylor College of Medicine and

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the Michael E. DeBakey VA Medical Center, Houston,

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Texas.

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DR. DASKALAKIS: Demetre Daskalakis, adult

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infectious diseases, and also deputy commissioner

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for disease control at the New York City Department

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of Health and Mental Hygiene.

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DR. READ: Sarah Read, deputy director of

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the Division of AIDS at the National Institute of

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Allergy and Infectious Diseases.

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DR. SMITH: Hi. Dawn Smith, medical

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epidemiologist, Centers for Disease Control and

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Prevention.

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DR. GOETZ: Matthew Goetz, VA Greater Los

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Angeles Healthcare System, David Geffen School of

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Medicine, adult infectious diseases.

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DR. AWNI: Walid Awni, retired. I retired

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from AbbVie last year as vice president of clinical

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pharmacology and pharmacometrics. I'm the acting

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industry representative.

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DR. BADEN: Thank you. Dr. Dodd?

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DR. DODD: Dr. Dodd, biostatistician at

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National Institute of Allergy and Infectious

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Diseases.

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DR. BADEN: I think we may have someone on

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the phone. Ms. Lupole?

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MS. LUPOLE: Yes, sir. Good morning

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[inaudible -feedback].

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DR. BADEN: You have a bit of feedback.

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MS. LUPOLE: I'm sorry. Can you hear me

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now?

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DR. BADEN: Yes, we can.

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MS. LUPOLE: Patricia Lupole, patient

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representative.

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DR. BADEN: Thank you.

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For topics such as those being discussed at

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today's meeting, there are often a variety of

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opinions, some of which are quite strongly held.

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Our goal is that today's meeting will be a fair and

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open forum for discussion of these issues and that

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individuals can express their views without

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interruption. Thus, as a gentle reminder,

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individuals will be allowed to speak into the

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record only if recognized by the chairperson. We

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look forward to a productive meeting.

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In the spirit of the Federal Advisory

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Committee Act and the Government in the Sunshine

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Act, we ask that the advisory committee members

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take care that their conversations about the topic

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at hand take place in the open forum of the

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meeting.

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We are aware that members of the media are

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anxious to speak with the FDA about these

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proceedings. However, FDA will refrain from

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discussing the details of this meeting with the

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media until its conclusion. Also, the committee is

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reminded to please refrain from discussing the

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meeting topic during breaks or lunch. Thank you.

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I thank everyone for making the time to be

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here to participate in this discussion. We know

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how busy everyone is.

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I will ask Dr. Lauren Hotaki to read the

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Conflict of Interest Statement for the meeting.

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Conflict of Interest Statement

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DR. HOTAKI: The Food and Drug

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Administration is convening today's meeting of the

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Antimicrobial Drugs Advisory Committee under the

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authority of the Federal Advisory Committee Act of

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1972. With the exception of the industry

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representative, all members and temporary voting

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members of the committee are special government

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employees or regular federal employees from other

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agencies and are subject to federal conflict of

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interest laws and regulations.

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The following information on the status of

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this committee's compliance with federal ethics and

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conflict of interest laws, covered by but not

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limited to those found at 18 U.S.C. Section 208, is

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being provided to participants in today's meeting

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and to the public.

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FDA has determined that members and

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temporary voting members of this committee are in

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compliance with federal ethics and conflict of

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interest laws. Under 18 U.S.C. Section 208,

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Congress has authorized the FDA to grant waivers to

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special government employees and regular federal

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employees who have potential financial conflicts

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when it is determined that the agency's need for a

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special government employee's services outweighs

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his or her potential financial conflict of

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interest, or when the interest of a regular federal

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employee is not so substantial as to be deemed

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likely to affect the integrity of the services

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which the government may expect from the employee.

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Related to the discussion of today's

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meeting, members and temporary voting members of

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this committee have been screened for potential

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financial conflicts of interest of their own as

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well as those imputed to them, including those of

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their spouses or minor children, and, for purposes

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of 18 U.S.C. Section USC Section 208, their

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employers. These interests may include

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investments; consulting; expert witness testimony;

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contracts, grants, CRADAs; teaching, speaking,

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writing; patents and royalties; and primary

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employment.

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Today's agenda involves discussion of

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supplemental new drug application 208215,

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supplement 12, DESCOVY, emtricitabine

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200 milligrams and tenofovir alafenamide

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25 milligrams submitted by Gilead Sciences, Inc.,

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proposed for pre-exposure prophylaxis to reduce the

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risk of sexually acquired HIV-1 infection among

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individuals who are HIV negative and at risk for

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HIV. This is a particular matters meeting during

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which specific matters related to Gilead's sNDA

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will be discussed.

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Based on the agenda for today's meeting and

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all financial interests reported by the committee

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members and temporary voting members, conflict of

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interest waivers have been issued in accordance

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with 18 U.S.C. Section 208(b)(3) to Dr. Lindsey

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Baden and Dr. Barbara Gripshover.

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Dr. Baden's waiver addresses his employer's

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current research contract for related study by a

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competing firm for which his employer receives

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between $0 and $50,000 annually. Dr. Baden's waiver

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also addresses his employer's current research

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contract for related studies through the HIV

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Vaccine Trials Network sponsored by the National

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Institute of Allergy and Infectious Diseases of the

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National Institutes of Health and a competing firm,

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for which his employer receives $1.5 to $2.5

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million annually.

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Dr. Gripshover's waiver addresses her

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employer's current research contracts for four

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related studies involving competing/affected

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products for which her employer receives between

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$50,001 to $100,000 annually for two studies, and

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between $300,000 to $400,000 annually, and to $0 to

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$50,000 annually for the other two studies.

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The waivers allow these individuals to

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participate fully in today's deliberations. FDA's

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reasons for issuing the waivers are described in

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the waiver documents, which are posted at the FDA's

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website. Copies of the waivers may also be

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obtained by submitting a written request to the

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agency's Freedom of Information Division,

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5630 Fishers Lane, Room 1035, Rockville, Maryland,

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20857, or requests may be sent via fax to 301-827-

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9267.

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To ensure transparency, we encourage all

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standing committee members and temporary voting

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members to disclose any public statements that they

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have made concerning the product at issue. With

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respect to FDA's invited industry representative,

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we would like to disclose the Dr. Walid Awni is

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participating in this meeting as a nonvoting

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industry representative, acting on behalf of

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regulated industry. Dr. Awni's role at this meeting

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is to represent industry in general and not any

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particular company. Dr. Awni is an independent

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pharmaceutical consultant.

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We'd like to remind members and temporary

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voting members that if the discussions involved any

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other products or firms not already on the agenda

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for which an FDA participant has a personal or

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imputed financial interest, the participants need

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to exclude themselves from such involvement, and

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their exclusion will be noted for the record. FDA

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encourages all other participants to advise the

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committee of any financial relationships that they

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may have with the firm at issue. Thank you.

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DR. BADEN: Thank you.

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We will proceed with the FDA opening remarks

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from Dr. Murray.

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FDA Opening Remarks - Jeffrey Murray

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DR. MURRAY: Good morning. The Division of

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Antiviral Products extends its warm welcome to the

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committee and to the audience to discuss a new

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supplemental application for Descovy, for the

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prevention of sexually-acquired HIV infection, and

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we're happy to be talking about expanding the HIV

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prevention armamentarium today.

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Some of you on the panel, and perhaps in the

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audience, may have been here in 2012, in this very

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room -- I know I was -- when the advisory committee

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voted on whether Truvada should be approved for

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PrEP. As you recall, the committee voted yes, and

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Truvada became the first U.S. approved product for

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PrEP, and really the first product for HIV PrEP for

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sexually-acquired HIV infection anywhere in the

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world. Fast forward to seven years, and that

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brings us to today's topics.

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There are similarities and differences

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between these two products. Both our fixed-dose

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combinations that contain emtricitabine. Both

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contain a prodrug of tenofovir with the same active

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metabolite. Both are approved for HIV treatment,

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both of the products. Tenofovir components are

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also approved as single agents for the treatment of

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chronic hepatitis B.

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However, there are also differences,

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specifically as they relate to the bioavailability

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of tenofovir as delivered by these two different

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prodrugs in these fixed-dose combination. Descovy

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delivers lower levels of plasma tenofovir in tissue

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and organs and higher levels of intracellular

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tenofovir diphosphate of active metabolite.

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As I said, there are also differences in

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tissue and organ distribution. This results in

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somewhat a different safety profile, but did not

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result in efficacy differences for HIV treatment.

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The other differences, Truvada is already approved

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for prevention and Descovy is not, and that's a

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topic for today.

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To support the prevention indication of

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Truvada, I remind you the applicant submitted two

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clinical trials, a clinical trial in MSM

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transgender women, iPrEx, and a trial in discordant

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heterosexual couples, Partners PrEP, which allowed

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for a broad indication among at-risk populations.

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Today we're dealing with one clinical trial.

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What are some of the regulatory

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considerations about the basis of supporting an

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approval? Really, the number of clinical trials

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needed to support an approval depends on the

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regulatory situation.

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For a new molecule entering the market,

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generally two or more drugs are expected -- or two

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or more trials are expected. However, for a new

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and related indication for a previously approved

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drug, often only one trial is needed to support

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approval.

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Likewise, if there's a new dosing schedule,

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say twice daily to once daily, and you can't make a

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pharmacokinetic link, that's also been supported by

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one trial, or for a new population where PK is

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different, usually we rely on one clinical trial.

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For Descovy, FDA's initial drug development

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advice was that clinical trials should be conducted

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in the relevant population, and that a PK link

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alone would not be possible. So for this

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application, as I said, we have one trial in MSM

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and transgender women but none in cisgender women

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at risk.

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The primary issue for today and what you'll

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be asked in the question is given the uncertainty

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around the protective correlate, can extrapolation

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be used to further expand the indicated population?

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With that being said, this application is a

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special case in the development of drugs for HIV

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prevention, and with that, I have the following

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caveat that the approach for Descovy may not apply

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to future new molecular entities because in this

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case, a prodrug, tenofovir for PrEP, has already

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been approved, and there is a possibility that data

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within and external to the Descovy program can be

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leveraged. So we ask the committee today for their

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advice on how this data can be best leveraged.

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Thank you.

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DR. BADEN: Thank you. We'll now move on to

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the applicant presentations.

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Both the FDA and the public believe in a

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transparent process for information gathering and

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decision making. To ensure such transparency at

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the advisory committee meeting, FDA believes that

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it is important to understand the context of an

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individual's presentation.

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For this reason, FDA encourages all

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participants, including the applicant's

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non-employee presenters, to advise the committee of

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any financial relationships they may have with the

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applicants, such as consulting fees, travel

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expenses, honoraria, an interest in a sponsor,

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including equity interests and those based upon the

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outcome of the meeting.

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Likewise, FDA encourages you at the

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beginning of your presentation to advise the

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committee if you do not have any such financial

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relationships. If you choose not to address this

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issue of financial relationships at the beginning

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of your presentation, it will not preclude you from

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speaking.

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We'll now proceed with Gilead's

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presentations. Dr. Brainard?

4

Applicant Presentation - Diana Brainard

5

DR. BRAINARD: Good morning. Ending the HIV

6

epidemic requires not just highly effective

7

treatments for people who have already been

8

infected, but additional options for preventing new

9

infections.

10

My name is Diana Brainard, and I lead the

11

HIV and emerging viruses group at Gilead Sciences.

12

I am an infectious diseases physician and have

13

worked as a clinician and scientist in both the

14

U.S. and Africa to care for people living with HIV

15

and tackle the epidemic. It is a pleasure and

16

honor to be here today to work with this committee

17

to bring forward another HIV prevention option that

18

will help us achieve our shared goal of HIV

19

elimination.

20

Seven years ago, as Dr. Murray mentioned,

21

Truvada was approved to prevent sexually-acquired

22

HIV infection and remains today the only approved

A Matter of Record (301) 890-4188

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1

therapy for HIV pre-exposure prophylaxis or PrEP.

2

Truvada is the fixed-dose combination of 2 HIV

3

reverse transcriptase inhibitors, emtricitabine and

4

tenofovir disoproxil fumarate. Truvada is approved

5

as part of a complete regimen for the treatment of

6

HIV in adults and adolescents, as well as for PrEP.

7

Tenofovir disoproxil fumarate is also

8

approved as a single agent for the treatment of

9

chronic hepatitis B. Descovy is the fixed-dose

10

combination tablet of emtricitabine and tenofovir

11

alafenamide. It is approved for HIV treatment, and

12

tenofovir alafenamide is approved as a single agent

13

for treatment of chronic hepatitis B. Descovy is

14

not approved for PrEP.

15

We are proposing an indication for Descovy

16

for PrEP in adults and adolescents based on the

17

data we are discussing today. Tenofovir disoproxil

18

fumarate and tenofovir alafenamide are both

19

prodrugs of tenofovir, but they have markedly

20

different metabolism. Tenofovir alafenamide, or

21

TAF, is dosed at one 12th that of tenofovir

22

disoproxil fumarate, or TDF, because of the

A Matter of Record (301) 890-4188

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1

difference in half-life.

2

TDF is rapidly converted to tenofovir, or

3

TFV, resulting in high plasma tenofovir levels

4

which have direct and indirect adverse effects on

5

kidney and bone. The half-life of TAF is 75 times

6

longer than that of TDF, which results in

7

90 percent lower plasma tenofovir levels.

8

Descovy's lower levels of circulating tenofovir

9

translate to fewer clinically relevant adverse

10

renal and bone effects.

11

The longer half-life of TAF also allows it

12

more time to enter peripheral blood mononuclear

13

cells. Intracellularly, TAF is metabolized to the

14

active metabolite, tenofovir diphosphate, or

15

TFV-DP, where it achieves 4 to 7-fold higher levels

16

of tenofovir diphosphate than those achieved by

17

TDF.

18

For both TAF and TDF, tenofovir diphosphate

19

within PBMCs and specifically CD-4 positive

20

T cells, is responsible for the inhibition of HIV

21

replication, which leads to protection against HIV

22

infection in the setting PrEP, as well as viral

A Matter of Record (301) 890-4188

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1

suppression in the case of HIV treatments.

2

Tenofovir diphosphate is an adenosine analog

3

that inhibits the enzyme HIV reverse transcriptase,

4

which transcribes HIV RNA into proviral DNA. This

5

mechanism of action is the same for both the

6

prevention of HIV acquisition as well as for

7

suppression of viremia in the setting of treatment,

8

and the level of intracellular tenofovir

9

diphosphate correlates with antiviral activity.

10

Pharmacokinetic differences between TAF and

11

TDF result not only in higher levels of tenofovir

12

diphosphate with TAF versus TDF, but also a faster

13

rise of tenofovir diphosphate levels within PBMCs,

14

including the target cells for HIV replication,

15

CD-4 positive T cells. After a single dose,

16

Descovy achieves intracellular tenofovir

17

diphosphate levels above 40 femtomoles per million

18

cells within 2 hours.

19

This threshold is relevant for PrEP based on

20

its correlation using Truvada clinical data from a

21

trial in men who have sex with men, with a

22

90 percent reduction in risk of HIV acquisition as

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1

compared to placebo.

2

In contrast, Truvada takes approximately

3

3 days for the mean level to reach this EC90, and

4

steady state levels remain lower than those for

5

Descovy. Once steady state is achieved with either

6

Descovy or Truvada, if drug is stopped, tenofovir

7

diphosphate levels start to decline at a similar

8

rate. However, since levels are so much higher

9

with Descovy as compared to Truvada, they remain

10

above this EC90 for 16 days with Descovy compared

11

with 10 days for Truvada.

12

These pharmacokinetic advantages of Descovy

13

suggested to us that Descovy could be highly

14

effective for PrEP, and the safety advantages

15

observed in people living with HIV taking Descovy

16

could also be realized among those at risk for HIV

17

infection.

18

In 2015, when the DISCOVER study design was

19

coming together, there was uncertainty around

20

whether drug levels in the genital tract or

21

peripheral blood mononuclear cells best correlated

22

with protection against HIV. The higher levels of

A Matter of Record (301) 890-4188

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1

Tenofovir diphosphate in PBMCs with Descovy could

2

potentially confer an efficacy advantage and offer

3

a more forgiving regimen for PrEP, provided these

4

levels correlated with protection. However, if

5

genital tract tissue levels drive efficacy, Descovy

6

could be less effective for prevention.

7

Data from healthy volunteers show that

8

rectal tissue levels are 10-fold lower following

9

Descovy administration compared to Truvada. Our

10

hypothesis was that prevention efficacy for oral

11

drugs would be best measured by peripheral blood

12

mononuclear cell drug levels rather than tissue

13

homogenate levels, and that, therefore, Descovy

14

would be at least as efficacious as Truvada in

15

spite of this difference in rectal tissue levels.

16

This hypothesis was based on advances in the

17

understanding of mucosal transmission of HIV. HIV

18

must first breach the epithelium to reach the

19

subepithelium, and it is generally believed that a

20

single cell first becomes infected and initiates

21

subsequent events.

22

Chemokines, primarily secreted by

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1

plasmacytoid dendritic cells, attract PBMCs.

2

Specifically, CD-4 positive and CD-8 positive

3

T cells from the pool of PBMCs traffic from the

4

circulation to the tissue. This then results in a

5

small founder population of initially infected CD-4

6

T cells located in the subepithelium.

7

The recruitment of target cells for HIV, the

8

CD-4 T cells, from the periphery is critical in

9

order for systemic infection to occur.

10

Dissemination of these recruited and now infected

11

CD-4 positive T cells occurs as they enter the

12

lymphatic system to travel to regional lymph nodes

13

and spread throughout the body.

14

Protection against systemic HIV infection

15

can occur via both topical and systemic modalities.

16

Topical antiretrovirals, such as investigational

17

tenofovir gel, allow for the diffusion of drug into

18

tissues within the genital tract. Efficacy depends

19

on reaching therapeutic levels intracellularly

20

within the local CD-4 positive T cells. These

21

methods have generally proven less effective than

22

PrEP delivered systemically.

A Matter of Record (301) 890-4188

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1

Truvada and Descovy distribute widely

2

throughout the body and can offer a greater degree

3

of protection. They can both reach the genital

4

tissues through the blood supply, where they can

5

then access resident lymphocytes.

6

Importantly as well, PBMCs that contain the

7

active metabolite of both Truvada and Descovy,

8

tenofovir diphosphate also can reach the genital

9

tract and can be among the cells recruited to the

10

site of initial infection, as well as into the

11

regional draining lymph nodes so as to prevent

12

systemic infection.

13

While there has been no clear evidence of a

14

correlation of preventive efficacy of Truvada for

15

PrEP with tissue levels, efficacy strongly

16

correlates with drug levels of tenofovir

17

diphosphate within PBMCs.

18

A subset of participants in the IPREX study,

19

in men who have sex with men of Truvada versus

20

placebo, had tenofovir diphosphate levels assessed

21

in PBMCs. Because of the wide range of adherence

22

and that trial and the placebo arm to which a

A Matter of Record (301) 890-4188

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1

direct comparison could be made, it was possible to

2

construct a relationship between PBMC tenofovir

3

diphosphate levels and risk production with respect

4

to HIV incidence.

5

It was with these data that Dr. Anderson

6

established the correlate of protection for

7

90 percent risk reduction for tenofovir diphosphate

8

levels at 40 femtomoles per million PBMCs and

9

showed that there's a range of protection above and

10

below that level. These data are now well

11

recognized and have been cited in the most recent

12

CDC PrEP guidance issued on July 18th of this year.

13

When the DISCOVER study was being designed,

14

the scientific and clinical understanding of HIV

15

prevention was less mature. At that time, Truvada

16

for PrEP was only approved in adults. Descovy was

17

under review by the FDA for the treatment of HIV.

18

We knew that rectal tissue levels with Descovy were

19

10-fold lower than those achieved with Truvada.

20

If the primary driver for prevention

21

efficacy, with orally administered tenofovir

22

prodrugs is local tissue drug levels, then Truvada

A Matter of Record (301) 890-4188

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1

should be better than Descovy at preventing HIV

2

infection. However, if obtaining high levels in

3

PBMCs is what's important, then Descovy should be

4

at least as effective as Truvada.

5

This question was addressed in the phase 3

6

DISCOVER trial. The DISCOVER trial, an

7

international phase 3 study, was conducted to

8

assess the safety and efficacy of Descovy for HIV

9

prevention. This was a double-blind, active

10

comparator, noninferiority trial, comparing Descovy

11

to the standard of care for prevention, Truvada.

12

The study enrolled over 5,000 cismen and

13

transgender women who have sex with men. The trial

14

was designed and conducted in close collaboration

15

with FDA and the community. Importantly, the study

16

met its primary endpoint, demonstrating

17

noninferiority of Descovy to Truvada for the

18

prevention of HIV infection.

19

Among individuals randomized to Descovy, 7

20

acquired HIV infection for an incidence rate of

21

0.16 per 100 person-years. In the Truvada group,

22

there were 15 infections resulting in an incidence

A Matter of Record (301) 890-4188

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1

rate of 0.34 per 100 person-years. The incident

2

rate ratio, the prespecified method for determining

3

noninferiority, was 0.47 with an upper bound of the

4

confidence interval less than the prespecified

5

margin of 1.62.

6

Additionally, the prespecified

7

alpha-controlled secondary safety endpoints were

8

met, demonstrating superiority of Descovy to

9

Truvada with respect to markers of bone and renal

10

toxicity. Collectively, these data demonstrate

11

that Descovy is highly effective at preventing HIV

12

acquisition and demonstrates safety benefits over

13

Truvada.

14

What we know now is that both Truvada and

15

Descovy are highly effective for PrEP if taken.

16

Adherence is the key determinant of efficacy. A

17

correlate of protection has been established for

18

tenofovir diphosphate levels in PBMCs. The

19

DISCOVER trial confirms that 10-fold lower rectal

20

levels of tenofovir diphosphate with Descovy versus

21

Truvada are not relevant for HIV protection, and

22

that the 7-fold higher tenofovir diphosphate levels

A Matter of Record (301) 890-4188

40

1

with Descovy versus Truvada might confer a

2

potential efficacy advantage for Descovy.

3

These results support the conclusion that

4

PBMC drug levels drive the efficacy of orally

5

administered tenofovir prodrugs. This finding is

6

an important consideration for the extrapolation of

7

the DISCOVER results from cismen and transgender

8

women to ciswomen.

9

To date, clinical trials in women have had

10

heterogeneous efficacy results reflecting highly

11

variable adherence. Data from clinical trials

12

demonstrate that when controlling for adherence,

13

Truvada is equally efficacious in women and men.

14

There is a biologic rationale for this finding.

15

The biology of HIV as well as the

16

intracellular antiviral activity of tenofovir

17

diphosphate are independent of gender. HIV

18

replicates within CD-4 positive lymphocytes, which

19

must be recruited to the site of initial infection

20

in order to successfully lead to systemic

21

transmission. Adequate drug levels within these

22

recruited cells are necessary and sufficient to

A Matter of Record (301) 890-4188

41

1

mediate protection against HIV infection.

2

Multiple lines of evidence support bridging

3

the efficacy results for Descovy for PrEP from the

4

men and transgender women in DISCOVER to ciswomen.

5

In the setting of HIV treatment, the efficacy and

6

safety of Descovy-based therapy have been well

7

established in over 2000 women and are comparable

8

to results in men.

9

Descovy and Truvada both inhibit HIV

10

replication in CD-4 T cells through the same active

11

metabolite, tenofovir diphosphate. Extensive

12

pharmacology assessments have demonstrated that the

13

levels of tenofovir diphosphate are similar

14

irrespective of HIV status or gender. Taken

15

together, these data support the use of Descovy for

16

HIV prevention in women.

17

There is similar support for the

18

extrapolation to adolescence. Descovy and the

19

three other Descovy-containing single-tablet

20

regimens are all indicated for HIV treatment in

21

adolescence based on the safety and efficacy

22

established in this group. HIV behaves similarly

A Matter of Record (301) 890-4188

42

1

independent of age, and therefore the extension of

2

safety and efficacy of Descovy for PrEP to

3

adolescents can be based on similar pharmacokinetic

4

exposures to Descovy between the DISCOVER study

5

participants and adolescents, as well as the

6

similar mechanism of action of these drugs. We

7

also know that HIV infection status has no relevant

8

impact on these parameters. Taken together, these

9

data support the use of Descovy for HIV prevention

10

in adolescents.

11

Based on the data from the DISCOVER study,

12

the established safety and efficacy of Descovy for

13

HIV treatment across men, women, and adolescents

14

and pharmacokinetic bridging, the following

15

additional indication is proposed for Descovy.

16

Descovy is indicated for pre-exposure prophylaxis

17

to reduce the risk of sexually-acquired HIV in

18

at-risk adults and adolescents weighing at least

19

35 kilograms.

20

You will next hear from Dr. Scott

21

McCallister, who will provide an overview of the

22

phase 3 DISCOVER trial and the efficacy results.

A Matter of Record (301) 890-4188

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1

Then Dr. Moupali Das will present the safety of

2

Descovy for PrEP, as well as the basis for its use

3

for HIV prevention in women and adolescents.

4

We're honored to have Dr. Rick Elion with us

5

today. Dr. Elion has a long-standing history of

6

providing HIV treatment and prevention services to

7

individuals in the D.C. area for marginalized

8

communities, and he'll provide clinical context for

9

the results of the DISCOVER trial. I will then

10

return to lead our responses to questions. We have

11

Gilead team members spanning multiple disciplines

12

to address these questions.

13

In addition, we're pleased that Dr. Peter

14

Anderson is here today to address questions around

15

adherence. Dr. Anderson is a professor of

16

pharmaceutical sciences at the University of

17

Colorado. His laboratory specializes in the

18

assessment of drug levels in dried blood spots, and

19

they performed nearly 4,000 dried blood spot

20

analyses in DISCOVER as part of our adherence

21

assessments.

22

I'd like to now welcome Scott McAllister to

A Matter of Record (301) 890-4188

44

1

the lectern.

2

Applicant Presentation - Scott McCallister

3

DR. McCALLISTER: Thank you, Diana, and good

4

morning, everyone. I'm also an infectious disease

5

specialist with a long history of clinical patient

6

care and clinical research in HIV. In this

7

section, I'll describe the DISCOVER study design,

8

the treatment population, and the efficacy results.

9

DISCOVER is an ongoing, randomized,

10

double-blind, noninferiority trial that enrolled

11

both cismen and transgender women who have sex with

12

men. As shown at the top, participants were

13

randomized 1-to-1 to either Descovy or Truvada

14

daily. Each of the nearly 2700 MSM or transgender

15

women received 1 tablet of active drug and 1 dummy

16

placebo tablet.

17

The primary efficacy endpoint analysis was

18

time based and was conducted when all participants

19

completed 48 weeks in the study and half had

20

completed 96 weeks. The primary endpoint was the

21

HIV incidence rate per 100 person-years on study.

22

The study was blinded to investigators and study

A Matter of Record (301) 890-4188

45

1

participants until the final person enrolled

2

completed 96 weeks. At the next scheduled visit,

3

individual participants are unblinded and offered a

4

switch to open-labeled Descovy. Unblinding is

5

currently ongoing and not yet complete.

6

Eligibility criteria were designed to ensure

7

that the study enrolled a population at high risk

8

of HIV infection. All participants were required

9

to have at least 1 of the 2 following sexual risk

10

criteria: two or more episodes of condomless anal

11

sex with more than one unique partner in the 12

12

weeks before enrollment or a diagnosis of either

13

rectal gonorrhea, rectal chlamydia, or syphilis in

14

the 24 weeks before enrollment. All needed to be

15

HIV and hepatitis B negative. Prior or current use

16

of PrEP was permitted, and no washout of PrEP drugs

17

was required.

18

DISCOVER sites were mostly urban. They were

19

specifically chosen to be in locations with a high

20

background HIV incidence, and all sites were

21

required to be able to enroll people with

22

significant sexual risk for HIV acquisition. We

A Matter of Record (301) 890-4188

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1

also selected sites with the cultural competence to

2

enroll and retain people of color and transgender

3

women.

4

Ultimately, DISCOVER included 94 sites in 11

5

countries in North America and Western Europe.

6

Some were hospitals, some private practices, and

7

some local sexually transmitted infection clinics.

8

Each site was responsible to determine the best

9

recruitment practice within their own community.

10

All of those who met eligibility criteria were

11

allowed to enroll. It was our goal to allow each

12

person who knew themselves to be at risk of our HIV

13

infection to participate.

14

When we designed DISCOVER, we consulted with

15

investigators from the prior PrEP trials in MSMs.

16

We wanted to ensure that the study included the

17

right design elements, comparable sexual risk

18

eligibility criteria, optimal HIV testing, and STI

19

testing, so that our study would yield reliable

20

results. We also discussed design issues with both

21

site investigators and with community members in

22

North America and Europe to ensure that the study

A Matter of Record (301) 890-4188

47

1

was practical and aligned with existing clinical

2

practice.

3

Community members encouraged us to establish

4

advisory boards for ongoing dialogue with them. As

5

a result, three community advisory boards were set

6

up, one that was DISCOVER specific and two that

7

dealt with broader HIV issues in North America and

8

the EU. We drew valuable input from these

9

interactions during the trial, during the design

10

phase, during recruitment, and during study

11

conduct.

12

The primary efficacy endpoint was based on

13

the number of HIV infections diagnosed in DISCOVER

14

divided by person-years of exposure in the study.

15

Noninferiority of Descovy to Truvada was assessed

16

by an incidence rate ratio in which the HIV

17

incidence rate in the Descovy arm was divided by

18

the rate in the Truvada arm.

19

We derived the noninferiority margin of 1.62

20

by pooling the incidence rates in the Truvada arms

21

of the three prior randomized controlled trials in

22

MSMs: iPrEx, PROUD, and IPERGAY. If the upper

A Matter of Record (301) 890-4188

48

1

bound around the confidence interval of the

2

incidence rate ratio in DISCOVER was less than

3

1.62, Descovy would be noninferior to Truvada.

4

The incidence rate ratio analysis of the

5

primary endpoint was a robust means of evaluating

6

the effectiveness of Descovy, ensuring that the

7

result was due to the drugs used in the study and

8

that the treatment population was at sufficient

9

risk of HIV.

10

At each visit, we assessed general safety,

11

including graded adverse events, adverse events

12

leading to discontinuation, serious adverse events,

13

and general safety labs. There was renal lab

14

testing at each visit, bone mineral density testing

15

every 48 weeks, and sexually transmitted infection

16

testing from 3 anatomic sites also at each visit.

17

We used an analysis cascade for 6

18

prespecified secondary safety endpoints, where

19

previous data suggested a possible difference

20

between the arms due to lower levels of plasma TFV

21

in those on TAF. The safety's cascade began with

22

changes from baseline in bone mineral density, or

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1

BMD, at both the hip and spine.

2

If there were significant differences

3

favoring Descovy on each of these, we then

4

evaluated spillage of the specific proximal renal

5

tubular proteins associated with plasma TFV, the

6

beta-2 microglobulin, and retinol binding protein

7

to creatinine ratios. Then with continued

8

significant differences favoring Descovy, we moved

9

to evaluate glomerular function with general urine

10

proteins, serum creatinine, and estimated

11

glomerular filtration rate.

12

All participants completed confidential

13

questionnaires on an iPad at the screening visit

14

and at all study visits. These questions inquired

15

about the sexual behavior of each participant since

16

their last visit, including the number of partners,

17

the type of sex, the frequency of sex, condom use

18

habits, and about recent study drug adherence.

19

At each visit, all participants received HIV

20

risk reduction education, adherence support, and

21

condoms and lubricant from site staff. In

22

addition, opt-in/opt-out text messaging could be

A Matter of Record (301) 890-4188

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1

used to remind the individual to take their study

2

meds daily with the actual words used in the text

3

chosen by sites and participants.

4

Adherence is a critical determinant of PrEP

5

efficacy, so we measured it in multiple ways. We

6

employed two subjective tests, the confidential

7

iPad-based questionnaires and counts from returned

8

pill bottles, both at each visit. We used one

9

objective test, a dried blood spot collection to

10

evaluate TFV diphosphate levels in red blood cells

11

also at each visit. Dried blood spots provided

12

validated analysis of chronic adherence over the

13

8 weeks prior to the collection date, and we looked

14

at a randomly selected subset of 540 participants,

15

about 10 percent of the DISCOVER population.

16

In addition to the randomly selected subset,

17

we also analyzed dried blood spots in a case

18

control analysis of those diagnosed with HIV in

19

DISCOVER with matching controls for each. In our

20

case control study, we compared every individual

21

diagnosed with HIV on study and matched them with

22

5 uninfected controls. The matched controls were

A Matter of Record (301) 890-4188

51

1

specifically chosen to be geographically linked, to

2

have similar time on the study drugs in DISCOVER,

3

and to have comparable sexual exposure as evidenced

4

by the on-study diagnosis of a rectal STI.

5

From the group of uninfected study

6

participants who were a match for each case, 5 were

7

randomly selected. Once all controls were

8

selected, dried blood spot analyses of the TFV

9

diphosphate level in red blood cells were tested on

10

the date of the HIV diagnosis and also on one visit

11

prior.

12

More than 5800 people were screened for

13

DISCOVER; 364 did not meet eligibility criteria,

14

including 49 who tested HIV positive; 5,399 were

15

randomized but 6 in each arm were not treated.

16

leaving 2694 treated in the Descovy arm and 2693

17

treated in the Truvada arm.

18

The full analysis set included 535,335

19

participants who were randomized, treated, and had

20

any post-baseline data. Of those who were

21

randomized and treated in the study, the median age

22

was 34, 12 percent of the population or emerging

A Matter of Record (301) 890-4188

52

1

adults below age 25 and not yet at peak bone mass.

2

In the ratio breakdown, across the 11 North

3

American and European countries, 84 percent

4

self-identified as white and 9 percent as black;

5

25 percent reported being of Hispanic or Latinx

6

ethnicity; 74 participants, or 1 to 2 percent of

7

the population, self-identified as a transgender

8

woman. From responses on the confidential

9

questionnaire, the self-reported sexual orientation

10

was gay or homosexual in 91 to 92 percent, bisexual

11

in 6 to 8 percent, and heterosexual in 1 percent.

12

Baseline sexual behavior data from the

13

confidential questionnaire showed that the

14

treatment population was at significant risk of HIV

15

infection. 58 to 60 percent had at least

16

2 condomless receptive anal sex partners in the 12

17

weeks prior to study entry; 9 to 13 percent

18

reported rectal gonorrhea, rectal chlamydia or

19

syphilis in the 24 weeks before study entry.

20

Two-thirds of DISCOVER participants had used

21

recreational drugs, and nearly a quarter reported

22

binge drinking, defined as 6 or more drinks on at

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53

1

least one occasion and occurring at least monthly.

2

A total of 23 percent had used Truvada for PrEP in

3

the past, and 16 to 17 percent were on it at study

4

entry. While on study, DISCOVER participants

5

maintained this high level of sexual behavior

6

throughout all visits.

7

Participants averaged just under

8

4 condomless receptive anal sex partners at

9

baseline and continuing throughout the study,

10

similar between the arms. They also had high rates

11

of sexually transmitted infections; 57 percent of

12

those on the study were diagnosed with gonorrhea or

13

chlamydia from at least 1 of the 3 anatomic sites

14

tested. And including syphilis, the overall rate

15

on study for any one of these STIs range from 139

16

to one 145 per 100 person-years in DISCOVER.

17

Overall, 42 percent of participants had a

18

rectal STI on the study, most likely due to

19

condomless receptive anal sex, and 16 percent had a

20

urethral STI associated with condomless insertive

21

sex.

22

At the time of the primary endpoint

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1

analysis, 16 to 17 percent of participants

2

discontinued study drug in DISCOVER. The most

3

common reasons for discontinuation from study drug

4

were participant decision or lost to follow 6 to

5

7 percent each. Only 1 to 2 percent of study

6

participants discontinued drug due to an adverse

7

event, and the other reasons for discontinuation

8

were less than 1 percent each.

9

As Diana described, the study met its

10

primary efficacy endpoint for noninferiority. In

11

over 8700 person-years on study across the 2 arms,

12

a total of 22 HIV infections were diagnosed; 7 in

13

the Descovy arm, 15 in the Truvada arm,

14

corresponding to HIV incidence rates of 0.16 and

15

0.34 per hundred person-years, respectively. The

16

rate ratio, where 0.16 is divided by 0.34, is 0.47.

17

For the primary endpoint analysis, the rate

18

ratio of 0.47 represents a 53 percent reduction in

19

HIV incidence for the Descovy arm relative to the

20

Truvada arm. The upper bound of the confidence

21

interval around 0.47 is 1.15. This is lower than

22

the 1.62 prespecified noninferiority margin that's

A Matter of Record (301) 890-4188

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1

establishing the noninferiority of Descovy to

2

Truvada for PrEP.

3

We categorized the 7 diagnoses in the

4

Descovy arm and the 15 in the Truvada arm based on

5

whether or not they occurred prior to study entry.

6

Evaluating all available data and prior to

7

unblinding, a 3-physician panel concluded that 5 of

8

the 22 HIV diagnoses most likely occurred prior to

9

DISCOVER study entry between the screening and the

10

randomization visits. The 5 with suspected

11

baseline infections are shown here in the black

12

section at the bottom of each bar. Just above are

13

the 17 individuals, 6 in Descovy and 11 in Truvada,

14

who acquired HIV while on study.

15

To better understand the impact that the

16

5 suspected baseline infections had on the primary

17

efficacy endpoint, we went on to conduct a

18

sensitivity analysis. By excluding the

19

5 individuals with suspected baseline infection, 1

20

in the Descovy arm, 4 in the Truvada arm, the

21

incidence rate ratio in this sensitivity analysis

22

is 0.55.

A Matter of Record (301) 890-4188

56

1

The confidence interval around it extends to

2

1.48, which is still below the prespecified 1.62

3

noninferiority margin. Therefore, even excluding

4

the suspected baseline infections in the

5

sensitivity analysis, the incidence rate in the

6

Descovy arm remained noninferior to the rate in the

7

Truvada arm.

8

We next looked at efficacy analysis by

9

baseline subgroups. In this forest plot, the HIV

10

incidence rates for the 2 arms are shown again at

11

the top and just left of center. The rate ratio

12

and surrounding 95 percent confidence interval are

13

shown at far right. The rows of the table provide

14

incidence rates for both demographic and baseline

15

risk behavior subgroups.

16

For each of these subgroups, the incidence

17

rates are low and consistent with the rates in the

18

overall study, and the incidence rate ratios

19

demonstrate that the effect of Descovy or Truvada

20

was consistent with the rate ratio in the overall

21

study across all demographic and baseline risk

22

behavior subgroups.

A Matter of Record (301) 890-4188

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1

In this diagram are genotypic resistance

2

data of the 22 individuals diagnosed with HIV; 19

3

had samples that could be successfully amplified

4

and evaluated. Of these 19, only 4 had Gina

5

genotypic resistance detected to either of the

6

study drugs.

7

All 4 occurred in the Truvada arm. All 4

8

were M184 mutations consistent with resistance to

9

FTC, and all 4 occurred in those with a suspected

10

baseline infection. Each of the 4 individuals with

11

M184 detected were able to be successfully

12

suppressed on ART, 3 with a Descovy-based regimen.

13

Our analysis of subjective adherence

14

measures demonstrates that there was a very high

15

level of adherence across the arms. With

16

self-report from the confidential questionnaires,

17

about 80 percent reported that they took their

18

study meds more than 95 percent of the time across

19

all study visits and similar across the arms. With

20

pill counts from returned bottles of study drug,

21

about 70 percent appeared to be using their study

22

meds more than 95 percent of the time, also similar

A Matter of Record (301) 890-4188

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1

across the arms.

2

The levels of TFV diphosphate in red blood

3

cells from the subset of dried blood spots tested

4

also demonstrate that there was a high level of

5

adherence in DISCOVER for both study arms. From

6

the nearly 4,000 dried blood spots tested in the

7

random subset, 80 to 90 percent had TFV diphosphate

8

levels in a range consistent with taking 4 or more

9

tablets per week for both arms.

10

In contrast, very few, just 5 to 9 percent

11

at any visit, had TFV diphosphate levels consistent

12

with taking less than 2 tablets per week. In the

13

case control analysis where the 22 HIV cases were

14

compared to HIV uninfected controls, the dried

15

blood spot data analysis there provides a clear

16

explanation for the difference between those with

17

HIV and their matched controls.

18

Low or no adherence was the most significant

19

risk factor associated with HIV in the study for

20

both arms. In the case control study, drug

21

adherence as measured in dried blood spots was

22

significantly lower among those who became infected

A Matter of Record (301) 890-4188

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1

as compared to matched controls. Most cases had

2

TFV diphosphate levels in red blood cells

3

consistent with using study drug less than 2 doses

4

per week, while more than 90 percent of controls

5

had TFV diphosphate levels consistent with higher

6

levels of adherence.

7

Finally, let's move from the TFV diphosphate

8

levels in red blood cells, which provide us this

9

measure of adherence, over to the levels in PBMCs,

10

which provide a measure of efficacy. The

11

data from dried blood spots showed a high and

12

comparable level of adherence across both arms.

13

The levels of activated drug TFV diphosphate

14

in PBMCs, however, were not the same across the

15

arms. At week 4, once steady state was achieved,

16

the median TFV diphosphate level in PBMCs was

17

6-fold higher in the Descovy relative to the

18

Truvada arm; 404 femtomoles per million cells in

19

Descovy and 61 femtomoles per million cells in

20

Truvada.

21

The amount of activated drug in the PBMCs

22

seen in DISCOVER is consistent with established PK

A Matter of Record (301) 890-4188

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1

data observed from multiple clinical studies with

2

TAF and TDF-based regimens in chronic HIV

3

treatment. Given that 40 femtomoles per million

4

cells represents the 90 percent effective

5

concentration, or EC90, of TFV diphosphate in PBMCs,

6

98 percent in the Descovy arm were above this EC90,

7

while only 68 percent in the Truvada arm had levels

8

above this mark.

9

In summary, DISCOVER was conducted in MSMs

10

and transgender women with a high baseline risk of

11

HIV infection that was consistent over the course

12

of the study. Over 8700 person-years, the HIV

13

incidence rates were very low and the

14

noninferiority of Descovy to Truvada for HIV

15

prevention was established. Low adherence was the

16

most significant risk factor associated with an HIV

17

diagnosis on study.

18

While M184 mutations occurred in the Truvada

19

arm, there was no resistance to study drugs

20

reported in the Descovy arm. TFV diphosphate

21

levels in PBMCs were over 6-fold higher in the

22

Descovy arm as compared to Truvada with a

A Matter of Record (301) 890-4188

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1

significantly higher proportion above the EC90 for

2

HIV protection. This PK advantage represents a

3

potential clinical benefit of Descovy for PrEP.

4

Thank you for your attention. I'd now like

5

to turn our presentation over to my colleague,

6

Dr. Moupali Das, who will describe the DISCOVER

7

safety data, and she'll provide a description of

8

the PK bridging data in support of an indication in

9

ciswomen and adolescents.

10

Applicant Presentation - Moupali Das

11

DR. DAS: Good morning, everyone. My name

12

is Moupali Das, and I'm also an infectious disease

13

physician. My career has been devoted to helping

14

end the HIV epidemic by increasing virologic

15

suppression rates and PrEP uptake. For the last

16

six years, I've worked exclusively on clinical

17

trials comparing the efficacy and safety of the two

18

tenofovir prodrugs.

19

The DISCOVER trial is the largest individual

20

trial with a single variable comparison of TAF with

21

TDF. It offers a unique opportunity to compare the

22

safety of TAF with TDF in the absence of underlying

A Matter of Record (301) 890-4188

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1

HIV or hep B infection and without any accompanying

2

third agents.

3

The safety and tolerability of Descovy and

4

TAF have been thoroughly established in HIV and hep

5

B treatment with over 26,000 person-years of

6

experience in clinical trials and over 1.6 million

7

person-years of clinical experience. Descovy has a

8

superior renal and bone safety profile compared

9

with Truvada due to the 90 percent lower plasma

10

tenofovir levels with TAF compared with TDF. Early

11

favorable changes in renal and bone safety

12

biomarkers correlate with fewer clinical renal and

13

bone adverse events over longer term follow-up.

14

The DISCOVER results are the first

15

demonstration that these well understood renal and

16

bone safety advantages of Descovy compared with

17

Truvada are also true for the HIV uninfected

18

population. There was a meeting exposure of 86 to

19

87 weeks in Descovy and Truvada. The bone mineral

20

substudy had 9 weeks of exposure. Both Descovy

21

and Truvada were safe and well tolerated.

22

The type, frequency, and severity of adverse

A Matter of Record (301) 890-4188

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1

events were similar between the Descovy and Truvada

2

arms. Most adverse events were grade 1 or 2 in

3

severity. There was a low percentage of study drug

4

related serious adverse events or adverse events

5

leading to discontinuation in both Descovy and

6

Truvada.

7

During treatment, 1 person died in each arm.

8

The most common adverse events in the DISCOVER

9

trial were sexually transmitted infections; 6 of

10

the 9 most common AEs were bacterial sexually

11

transmitted infections or exposure to STIs. This

12

is in contrast with Descovy treatment trials and

13

may reflect increased STI screening in DISCOVER,

14

which happened at every visit, or differences in

15

sexual behavior among DISCOVER participants

16

compared to the treatment trial participants, or a

17

combination of both.

18

I will review the STI data for the next few

19

slides and then come back to the general safety

20

data. The rates of sexually transmitted infections

21

were high and persistent throughout the trial.

22

About 15 percent of participants had lab-diagnosed

A Matter of Record (301) 890-4188

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1

gonorrhea or chlamydia at any of the 3 anatomic

2

sites at baseline and throughout the study. There

3

were no differences between Descovy and Truvada.

4

Two of the most common AEs were rectal

5

gonorrhea and chlamydia. Approximately 10 percent

6

of participants had rectal gonorrhea or chlamydia

7

at baseline, and this did not change during the

8

study. There were no differences between Descovy

9

and Truvada. The by-visit positivity rates reflect

10

high and persistent sexual behavior over the study

11

with the persistent rectal STI rates reflecting

12

continued high risk for HIV acquisition.

13

The most commonly prescribed medications in

14

the DISCOVER trial were also different from our HIV

15

treatment trials. Four of the seven most commonly

16

prescribed medications are antibiotics used to

17

treat sexually transmitted infections. More than

18

half of the participants received azithromycin or

19

ceftriaxone. There was a high burden of STIs,

20

including rectal STIs diagnosed and treated during

21

the study.

22

Returning back to general safety, the common

A Matter of Record (301) 890-4188

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1

study drug related adverse events reflect the most

2

common adverse events in the Descovy treatment

3

trials. Twenty percent of participants in Descovy

4

and 23 percent in Truvada had study drug related

5

adverse events. Common related adverse events were

6

low in frequency and similar between arms. The

7

majority were mild GI events and headache.

8

Laboratory abnormalities were also uncommon in the

9

study. Grade 3 or higher lab abnormalities

10

occurred at a low frequency and none were

11

clinically significant.

12

In the HIV treatment trials and in the

13

Truvada adherence subset in the iPrEx trial, the

14

lipid-lowering effect of Truvada has been well

15

documented. In DISCOVER, Truvada was also

16

associated with a reduction in lipid parameters.

17

Total cholesterol, HDL, and LDL cholesterol all

18

declined. The magnitude of these declines is not

19

clinically significant, whereas total cholesterol,

20

LDL, and HDL levels were generally unchanged in

21

participants taking Descovy.

22

Importantly, these changes resulted in no

A Matter of Record (301) 890-4188

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1

difference in the total cholesterol to HDL ratios

2

between arms, which is strongly associated with

3

cardiovascular risks. While both Descovy and

4

Truvada were safe and well tolerated, Descovy was

5

significantly superior to Truvada on all 6

6

prespecified renal and bone safety endpoints.

7

To assess the renal safety of Descovy

8

compared with Truvada, we reviewed cases of

9

proximal renal tubulopathy, including Fanconi

10

syndrome, as well as all renal adverse events

11

leading to discontinuation.

12

To specifically assess glomerular function,

13

we measured the prespecified renal safety endpoint

14

of serum creatinine and calculated the estimated

15

glomerular filtration rate using the

16

Cockcroft-Gault equation. We also evaluated total

17

urine proteinuria by dipstick and quantitative

18

proteinuria by the urine protein to creatinine

19

ratio or UPCR.

20

To evaluate proximal tubular function, we

21

looked at 2 urine tubular protein to creatinine

22

ratios. In DISCOVER, after 8600 person-years of

A Matter of Record (301) 890-4188

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1

exposure to study drug, there were no cases of

2

proximal tubulopathy or Fanconi Syndrome on

3

Descovy. There was one case of Fanconi Syndrome on

4

Truvada. There were numerically fewer

5

discontinuations due to renal AEs on Descovy

6

compared to Truvada, 2 versus 6.

7

Descovy had significantly improved

8

glomerular function compared with Truvada. The

9

differences in eGFR with Descovy and Truvada were

10

apparent as early as week 4 and continued through

11

week 48, the prespecified time point for the

12

assessment of secondary safety endpoints. At

13

week 48, Descovy participants also had significant

14

and lower serum creatinine, the prespecified safety

15

endpoint.

16

Glomerular proteinuria was significantly

17

lower in Descovy compared with Truvada. At

18

week 48, 21 percent of participants on Descovy

19

compared with 24 percent on Truvada developed

20

dipstick proteinuria. Fewer participants on

21

Descovy, 1 percent, compared to Truvada, 2 percent,

22

developed clinically significant quantitative

A Matter of Record (301) 890-4188

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1

proteinuria as defined by the national kidney

2

foundation as a urine protein to creatinine ratio

3

of greater than 200 milligrams per gram.

4

Descovy also had superior outcomes to

5

Truvada in the two markers of proximal tubular

6

proteinuria. Retinal binding protein and beta-2

7

microglobulin are two low molecular weight

8

proteins, which are freely filtered across the

9

glomerularis and reabsorbed at the proximal tubule.

10

Increased spillage of these proteins into the urine

11

is a marker of increased proximal tubular

12

dysfunction and is reflected in higher urine RBP to

13

creatinine and urine beta-2 microglobulin to

14

creatinine ratios.

15

On the left panel, the Truvada group had a

16

20 percent increase from baseline in tubular

17

proteinuria indicating increased proximal tubular

18

dysfunction, while Descovy remained stable. On the

19

right panel, the Truvada group had a 15 percent

20

increase in tubular proteinuria from baseline

21

indicating worsening of tubular function, while the

22

Descovy group had a 10 percent decline or

A Matter of Record (301) 890-4188

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1

improvement in tubular proteinuria.

2

The superior renal safety of Descovy was

3

also demonstrated in participants who were on

4

Truvada at baseline who switched to Descovy

5

compared to those who remained on Truvada. The

6

DISCOVER trial included participants taking Truvada

7

for PrEP at baseline and did not require a washout

8

of Truvada. There were a large number, 905 people,

9

who were on Truvada at baseline.

10

We prespecified sensitivity analyses of the

11

participants on baseline Truvada for key renal and

12

bone safety endpoints. As in the overall DISCOVER

13

population, those on baseline Truvada who switched

14

to Descovy had improvements in renal function

15

compared to those who remained on Truvada. The

16

improvements in eGFR and those who switched to

17

Descovy were apparent as early as week 4 and

18

persisted through week 48.

19

The improvements with switching to Descovy

20

are also present in markers of proximal tubular

21

function. Those who switch to Descovy had

22

significant declines in tubular proteinuria

A Matter of Record (301) 890-4188

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1

indicating improved tubular function, while those

2

who remained on Truvada had an 11 percent increase

3

in retinal binding protein to creatinine ratio on

4

the left and a stable beta-2 microglobulin to

5

creatinine ratio on the right.

6

These changes again became apparent as early

7

as week 4 and continued through week 48. Descovy

8

was superior to Truvada on all prespecified

9

biomarkers of renal function. This was

10

demonstrated in both the overall population as well

11

as in the Truvada switchers.

12

We evaluated bone safety with the bone

13

mineral density substudy. The median age of

14

DISCOVER participants was 34, so approximately half

15

of the participants were still building to peak

16

bone mass, which is achieved in the early to mid

17

30s.

18

Descovy participants had a statistically

19

significant increase in mean spine bone mineral

20

density of about 0.5 percent from baseline and

21

stable hip bone mineral density, whereas those on

22

Truvada had statistically significant declines of

A Matter of Record (301) 890-4188

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1

1 percent of both spine and hip bone mineral

2

density from baseline through week 48. Descovy was

3

statistically superior to Truvada in both

4

prespecified bone endpoints.

5

Using the T scores from the Baseline BMD

6

assessment, participants were classified into the

7

clinically relevant categories of normal bone

8

mineral density, osteopenia, and osteoporosis. At

9

baseline, 27 to 29 percent of participants had

10

either spine osteopenia or osteoporosis in the

11

Descovy and Truvada arms. After 48 weeks,

12

participants on Descovy had significantly less

13

osteopenia and osteoporosis than those on Truvada.

14

As Scott showed you, there were

15

6 prespecified secondary safety endpoints. Descovy

16

was superior to Truvada in all 6 prespecified,

17

alpha-controlled bone and renal safety endpoints at

18

the week 48 endpoint. We continue to follow

19

long-term renal and bone safety in the DISCOVER

20

study participants.

21

Both Descovy and Truvada were safe and well

22

tolerated. The rates of serious adverse events or

A Matter of Record (301) 890-4188

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1

adverse events leading to discontinuation of study

2

drug were low and balanced between arms. The

3

magnitude of the differences in the early safety

4

endpoints between arms was similar to what is

5

observed in HIV and hep B treatment trials

6

comparing to Descovy to Truvada.

7

This large trial confirmed that the

8

well-established superior renal and bone safety

9

profile of Descovy to Truvada from HIV and hep B

10

treatment is also true in HIV prevention. The

11

safety benefits were seen in both the people

12

starting PrEP for the first time as well as those

13

switching from Truvada to Descovy.

14

This is a significant development from a

15

clinical perspective, so we can now offer a

16

similarly efficacious but safer drug as another

17

choice for HIV uninfected people who are simply at

18

risk for HIV acquisition. The efficacy and safety

19

of Descovy for ciswomen, cismen who have sex with

20

men, and adolescents can be inferred from DISCOVER.

21

The extensive clinical experience with

22

Descovy and Truvada for treatment and prevention

A Matter of Record (301) 890-4188

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1

allows for the inference of efficacy and safety in

2

ciswomen and adolescents. We have over 15 million

3

person-years of clinical experience with Truvada

4

and TDF and 1.6 million person-years with Descovy

5

and TAF in HIV and hep B treatment.

6

We have over 108,000 person-years in Truvada

7

for PrEP and 6500 person-years for Descovy for PrEP

8

from the DISCOVER trial. Both Truvada and Descovy

9

are highly effective for treatment and prevention.

10

Efficacy is driven by tenofovir diphosphate in

11

peripheral blood mononuclear cells or PBMCs. In

12

contrast, safety is driven by plasma tenofovir.

13

The 90 percent lower plasma levels with Descovy

14

compared with Truvada is associated with an

15

improved bone and renal safety profile.

16

The PK of Descovy or Truvada is independent

17

of intrinsic and in extrinsic factors. This means

18

that the PK of plasma tenofovir and tenofovir

19

diphosphate in PBMCs is not affected by sex at

20

birth, current gender identity, or sexual

21

orientation. HIV infection status also does not

22

affect PK.

A Matter of Record (301) 890-4188

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1

The active moiety for both Truvada and

2

Descovy associated with both HIV treatment and

3

prevention efficacy is tenofovir diphosphate in

4

PBMCs. Tenofovir diphosphate levels are comparable

5

with Descovy in the MSM and transwomen in DISCOVER

6

on the left and Descovy in ciswomen and cismen.

7

In contrast, the tenofovir diphosphate

8

levels are lower with Truvada on the right.

9

Tenofovir diphosphate levels are 4 to 7-fold higher

10

with Descovy than with Truvada, and this is

11

consistent with findings in prior trials. Efficacy

12

is high in both women and men on Descovy-based

13

regimens for HIV treatment as it is with Truvada.

14

Virologic suppression rates are similar on Descovy

15

and Truvada-based regimens for HIV treatment and

16

similar in women and men.

17

The key metabolite for both Truvada and

18

Descovy associated with safety is plasma tenofovir.

19

Plasma tenofovir with Descovy is similar in women

20

with HIV and in HIV uninfected female volunteers.

21

The PK is independent of HIV status. Plasma

22

tenofovir is 10-fold higher with Truvada shown here

A Matter of Record (301) 890-4188

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1

in women with HIV on the right. Women with HIV

2

have improved renal safety on Descovy compared with

3

Truvada-containing regimens for HIV treatment.

4

In 519 women who were switched from Truvada

5

to Descovy or remained on Truvada, there were

6

significant improvements in both glomerular

7

function on the left and proximal tubular function

8

on the right through 96 weeks in the women switched

9

to Descovy. These renal improvements are

10

consistent with the DISCOVER results in those on

11

baseline Truvada who switched to Descovy.

12

Women on Truvada-containing regimens who

13

switched to Descovy also had clinically significant

14

improvements in osteopenia and osteoporosis within

15

48 weeks. At baseline, a third of women on

16

Truvada-based regimens for HIV treatment had

17

osteopenia or osteoporosis. Women who switched to

18

Descovy had less spine osteopenia and less

19

osteoporosis at week 48 compared to those who

20

continued on Truvada. These results were

21

statistically significant.

22

Descovy is also an efficacious and safe

A Matter of Record (301) 890-4188

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1

treatment for HIV in adolescents. Descovy is

2

approved for HIV treatment in adolescents weighing

3

at least 35 kilograms in combination with third

4

agents and in 3 Descovy-containing, single-tablet

5

regimens. Descovy has similar renal and bone

6

safety benefits compared with Truvada in

7

adolescents with HIV. Truvada has been approved

8

for PrEP in adolescents weighing at least

9

35 kilograms since 2018, based on the extrapolation

10

of efficacy from adults.

11

Tenofovir diphosphates and PBMCs is the

12

active moiety associated with both HIV treatment

13

and prevention efficacy. Tenofovir diphosphate

14

levels are similar in adults in DISCOVER and in

15

adults and adolescents with HIV. As we saw before,

16

HIV infection status does not affect PK, so we

17

would expect similarly high levels in PBMCs in

18

adolescents if they were taking it for PrEP.

19

Fifty adolescents who initiated a

20

Descovy-containing regimen for HIV treatment were

21

also evaluated. The mean age in the study was 15

22

years and over half the participants were female.

A Matter of Record (301) 890-4188

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1

Descovy was highly efficacious in adolescence for

2

HIV treatment. Efficacy was similar in adolescent

3

girls and boys.

4

Plasma tenofovir is associated with safety.

5

With Descovy, the plasma tenofovir levels in adults

6

without HIV and adults and adolescents with HIV are

7

similar across all three populations shown on the

8

left. Plasma tenofovir is 10-fold higher with

9

Truvada in adolescents with HIV, which is

10

consistent with results from prior studies.

11

Truvada has adverse effects on bone mineral

12

density in adolescents on Truvada for PrEP or HIV

13

treatment. Importantly, due to the 90 percent

14

lower plasma tenofovir concentrations with Descovy,

15

there is no such impact on bone growth.

16

Bone mineral density in the two key

17

pediatric metrics of total body less head and spine

18

increased through week 48 with a 0.19 percent

19

increase in total body and at 3.3 percent increase

20

in spine. Adolescent participants continue to

21

build bone mineral density similarly to an age-,

22

sex- and race-matched population.

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1

Descovy is noninferior to Truvada in HIV

2

treatment and prevention efficacy. The tenofovir

3

diphosphate levels in PBMCs are comparable in the

4

men and transwomen in DISCOVER, in ciswomen, and in

5

adolescents. Descovy is superior to Truvada in

6

renal and bone safety.

7

Plasma tenofovir is 90 percent lower with

8

Descovy than Truvada and comparably low in

9

DISCOVER, ciswomen, and adolescents. The efficacy

10

and safety of Descovy for PrEP can be inferred for

11

ciswomen and adolescents. Taken together, the

12

comparable exposures and the extensive efficacy and

13

safety data support the purposefully inclusive

14

indication.

15

We have planned multiple effectiveness

16

studies of Descovy for PrEP in a diverse range of

17

populations, including ciswomen and adolescents.

18

We considered numerous approaches to studying the

19

efficacy of Descovy in women in 2015 when we were

20

designing the DISCOVER trial. Ciswomen were not

21

included in discover because the HIV incidence rate

22

in the sites where DISCOVER was conducted is about

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1

13-lower in women with high risk for HIV compared

2

with the MSM with high risk in those locations.

3

With respect to doing a dedicated trial in

4

ciswomen, there are three generally accepted

5

approaches to randomized clinical trials for

6

efficacy. A placebo-controlled trial with Descovy

7

versus placebo is not ethical, as Truvada is

8

approved and highly effective for PrEP in adherent

9

women.

10

A superiority trial for Descovy over Truvada

11

was also not reasonable as both are oral daily

12

pills differentiated, primarily, although not

13

exclusively, on safety. Lastly, we considered a

14

noninferiority trial. Unlike DISCOVER where we

15

pulled treatment effects from three randomized

16

control trials with similar efficacy in MSM and

17

transwomen, the 5 randomized controlled trials in

18

women lacked a consistent treatment effect from

19

which we could conduct a defensible noninferiority

20

margin.

21

Using only the two trials with the highest

22

efficacy in women taking Truvada, we were able to

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1

estimate that a noninferiority trial would require

2

enrollment of about 22,000 women in the high

3

incidence regions. This would require

4

approximately 8 to 10 years to conduct.

5

The design of the DISCOVER trial was not

6

amenable to the inclusion of adolescents. Truvada

7

was not approved for adolescents until 2018, so we

8

would be comparing this safety and efficacy of two

9

investigational agents. More importantly, we knew

10

from data with Truvada that adolescents require a

11

higher visit frequency to maintain adherence and

12

may benefit from age appropriate targeted

13

interventions to maximize recruitment and retention

14

in clinical trials.

15

The efficacy and safety of Descovy for PrEP

16

in women and adolescents can be inferred from the

17

totality of evidence for Truvada and Descovy for

18

HIV prevention and our extensive safety database

19

from HIV treatment. Clinical data are now needed

20

to inform providers and individuals at risk for HIV

21

regarding the clinical effectiveness of Descovy for

22

PrEP in ciswomen and adolescents.

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1

We are dedicated to generating these data,

2

and we will be supporting a number of studies in

3

over 3400 ciswomen and adolescents in the United

4

States and in Africa. Key effectiveness research

5

questions include the evaluation of the safety of

6

Descovy for PrEP in pregnant and breastfeeding

7

women and how the improved safety tolerability and

8

smaller size of Descovy could improve PrEP uptake

9

and persistence.

10

We are strongly committed to understanding

11

how having an additional choice for PrEP with

12

Descovy, which has an improved renal and bone

13

safety profile and pharmacologic properties

14

consistent with an earlier and longer duration of

15

protection from HIV, can help address our shared

16

goals of increasing PrEP uptake and helping to end

17

the HIV epidemic.

18

Thank you. I'm now pleased to invite

19

Dr. Rick Elion to talk about the clinical impact of

20

the DISCOVER trial.

21

Applicant Presentation - Richard Elion

22

DR. ELION: Good morning. My name is

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1

Dr. Rick Elion. My conflicts are I do research

2

currently with Gilead, ViiV, and Proteus. I'm a

3

member of an advisory panel for Gilead and ViiV.

4

I'm on the speakers bureau of Gilead, ViiV, and

5

Janssen. I have no stock or financial interest in

6

these proceedings.

7

I have been active in the care of HIV

8

patients since I left residency in 1983. I began

9

in Brooklyn and moved to the East Village in

10

Manhattan in 1985, at the time of the first HIV

11

test in April of that year, and I've been

12

continuously at the front lines of caring for HIV

13

patients and seeking solutions and improvements in

14

care for over 30 years. I've watched countless men

15

and women die in my first 10 years of practice.

16

Advances in treatment and now prevention

17

have transformed what was once a harrowing job to

18

one of immense satisfaction. I'm currently

19

director of research at the Washington Health

20

Institute that serves a low-income population in

21

the District and a clinical professor of medicine

22

at George Washington University. I've been the

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1

director of research at Whitman Walker Health,

2

where we were a site for one of the first PrEP

3

demonstration projects, and I have supervised

4

hundreds of patients starting PrEP since 2013.

5

I also work at the Department of Health in

6

Washington, D.C. in the Wellness Program, which is

7

the Center for Caring for Those with Sexually

8

Transmitted Infections and providing PrEP and

9

research and methods to improve HIV prevention in

10

the District. I also continue to follow patients

11

at the Washington Health Institute, some of which I

12

have cared for, for 20 years or longer. I'm

13

grateful and honored to have the chance to share my

14

perspective on why Descovy is an important addition

15

to our prevention toolbox.

16

It's estimated that approximately 90 percent

17

of all new infections are coming from people who

18

either don't know their diagnosis, or they've been

19

diagnosed and are not engaged in care, or not

20

virologically suppressed. While treatment as

21

prevention is very successful at preventing new

22

infections, the bulk of new infections will not be

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1

prevented with just treatment alone.

2

We need multiple options for patients to

3

choose their ideal method of prevention, as when

4

consumers have more choices, it leads to greater

5

engagement. We will not likely have a vaccine soon

6

to protect uninfected individuals, so PrEP is

7

critical to help us cut down the rate of new

8

infections.

9

Prevention is much broader than just a pill

10

to protect against HIV. They have a variety of

11

options, which allow each person to choose what's

12

right for them. Choice is critical for patients,

13

as they're much more comfortable and committed to

14

the choices that they make rather than being told

15

what to do.

16

Biomedical interventions including treatment

17

as prevention and PrEP are among the most useful.

18

Treatment as prevention has been fundamental in

19

helping the decline of 18 percent of new cases in

20

the United States. It's the future synergies of

21

these approaches for treatment for HIV infected

22

individuals and PrEP for uninfected individuals.

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1

The analysis shown here looked at the change

2

in new diagnoses of HIV over a 5-year period in

3

states grouped by PrEP use. This data is

4

controlled for rates of virologic suppression and

5

in states with low PrEP use as defined as 3 percent

6

on PrEP. You can see about a 1 percent increase in

7

annual HIV diagnosis.

8

This can be compared to the high PrEP use

9

group with 11 percent on PrEP where you see almost

10

a 5 percent reduction in new cases. These rates of

11

PrEP utilization are still quite low considering

12

the risk profiles of patients in these communities

13

and could be greater if there were greater adoption

14

of PrEP.

15

This CDC report makes clear that communities

16

at need are receiving PrEP. This slide

17

demonstrates, however, the imbalance between the

18

potential need for PrEP in certain communities and

19

the actual use of PrEP. Dawn Smith, who's here

20

this morning, and colleagues reported on the

21

disparities between the potential members of

22

various populations that would qualify for PrEP

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1

versus those who are using PrEP.

2

These differences are staggering in the

3

communities in need as can be seen in this life.

4

Gross differences exist but only a fraction of

5

these communities are benefiting from PrEP, ranging

6

from racial disparities for blacks and Hispanic to

7

women as well. Though not shown here, certainly

8

adolescents , those from 15 to 25 years of age, who

9

are sexually active are also facing these same

10

disparities.

11

We know that Truvada for PrEP is efficacious

12

in adolescents with adequate adherence. DISCOVER

13

demonstrated efficacy in cismen and transgender

14

women. Descovy pharmacology is consistent across

15

different ages. The PK profile of Descovy could

16

have some advantages for adolescents as reflected

17

by the higher exposures that are achieved and the

18

higher intracellular drug levels that stay elevated

19

longer after missed doses.

20

This notion of forgiveness of suboptimal

21

adherence is critical for this population. Aside

22

from the potential benefits of a better PK profile,

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1

Descovy will be a safer medication for a population

2

that's actively building bone mass into their early

3

30's. They are depositing bone as part of their

4

normal growth, and the bone mineral density loss

5

with Truvada could potentially have a lasting

6

effect on adolescents, who after using Truvada may

7

not ever reach peak bone mass.

8

In this slide, we use the notion of a Z

9

score. A Z score compares your bone density to the

10

average values for a person of your same age and

11

gender. A low Z score below 2 is a warning sign

12

that you have less bone mass and/or may be losing

13

bone more rapidly than expected for someone of your

14

age.

15

Consideration of Z scores, which

16

standardized bone mineral density for age, race and

17

sex, is most important during adolescence when bone

18

mineral density variability increases. Z scores

19

are stable over at least three years during periods

20

of rapid bone accrual. Persistent Z score decline,

21

which you can see here, after stopping PrEP,

22

especially in the younger participants, is a

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1

concerning finding of these analysis.

2

The Z scores for individuals on Truvada for

3

PrEP declined for both spine, hip, and total body

4

during the 48-week period of PrEP, and then recover

5

in a comparable time period but not back to

6

baseline after at least 48 weeks of observation.

7

The clinical significance of this is

8

two-fold. The first is that the bone mineral

9

density based on the Z score does not recover to

10

baseline 48 weeks after PrEP has been discontinued,

11

suggesting that there is some insult to bone

12

deposition that does not fully recover. Second,

13

the insult is worse for those 15 to 19 who are more

14

actively depositing bone.

15

TAF on the other hand has not been shown to

16

have this impact on bone as reflected in

17

HIV-positive adolescents on treatment. It is a

18

better choice, therefore, for adolescents.

19

Offering them a medication that will allow their

20

bones to grow in a normal fashion is an important

21

consideration in selecting the best medicine for

22

HIV prevention for adolescents.

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1

It's equally important for women. I

2

previously mentioned the PK advantage for

3

adolescents. The PK data that were presented

4

earlier reflect a higher intracellular level of TAF

5

in the PBMCs, and hence, a longer period that these

6

levels stay above the threshold of efficacy, 16

7

days versus 10 days. This represents possibly a

8

significant difference between TAF and TDF if we

9

can accept the assumption that PBMCs have higher

10

drug levels and had been correlated with levels of

11

protection. This knowledge about HIV prevention

12

continues to evolve.

13

The DISCOVER study has demonstrated that the

14

failure of TAF to be present in higher tissue

15

levels for men was not a detriment to the overall

16

efficacy. This efficacy was likely driven by the

17

higher drug levels in the various components of the

18

PBMCs. The higher levels and the subsequent longer

19

time, until those levels fall below the threshold

20

of effectiveness, could portend a more forgiving

21

regimen and merit further study.

22

But forgiveness of missed or late doses

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1

could be a significant advantage for TAF/FTC and

2

provide a clinical advantage for those who don't

3

take their pills every day. This would be very

4

important for both adolescents and for women who

5

historically have had a greater percentage of

6

failures of PrEP due to poor adherence.

7

PrEP with Truvada has already been approved

8

for women based on the studies seen in this slide

9

that show comparable efficacy to men when adequate

10

adherence is maintained. VOICE and FEM-PrEP show

11

poor efficacy when adherence was equally deficient.

12

Women make up approximately 19 percent of new

13

infections and have a great deal of unsafe exposure

14

through sexual contact.

15

Ninety-three percent of HIV negative women

16

reported having vaginal sex without a condom and

17

26 percent reported having anal sex.. Women

18

therefore make up an important part of the

19

population for controlling HIV infection and are

20

underrepresented in their low use of PrEP. As of

21

2015, only 2 percent of women who were eligible for

22

PrEP were on PrEP.

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1

I work with colleagues at the Washington

2

Hospital Center in the Department of Health in the

3

District of Columbia on engaging women in PrEP in

4

our STI program, known as the Wellness Clinic, and

5

the Family Planning Program at Washington Hospital

6

Center. We have screened nearly a thousand women

7

who are at high risk through their sexual

8

practices, and only less than 1 percent have opted

9

to initiate PrEP despite a vigorous program using

10

videos, peer counseling, free medications, and peer

11

support. Despite our numerous efforts to explain

12

and encourage the adoption of more tools for HIV

13

prevention for women, we have been lagging behind.

14

This data of HIV incidence from

15

demonstration projects show the comparable rates of

16

new infections in men and women. There should be

17

little doubt that PrEP with Truvada works equally

18

well in men and women when adherence is

19

appropriate. These low rates of seroconversion

20

demonstrate real-world efficacy. There's no data

21

to suggest that this efficacy is different between

22

genders when adherence is similar.

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1

These data from real-world experiences

2

support the fact that women benefit in the same

3

fashion as men with PrEP, with Truvada in the real

4

world, not just in clinical trial settings.

5

However, as mentioned earlier, women have not

6

adopted PrEP in significant number.

7

The reasons for this are complex and involve

8

multiple issues. This study of African Americans,

9

both men and women, demonstrate some of these

10

challenges. Denial of risk is a critical issue for

11

women, as well as fear of side effects and trust

12

that these treatments will actually work.

13

Other surveys have pointed out that mistrust

14

of providers; stigma; fear of being ousted as

15

needing HIV protection; partner notification and

16

lack of support from one's partner; cost; and

17

access to medicine remain key drivers for women's

18

reluctance to start PrEP. There are multiple

19

reasons in the decision-making exercise by women in

20

adopting HIV prevention, so anything we can do to

21

lessen this burden might help women make a better

22

informed decision.

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1

The safety of TAF versus TDF regarding bone

2

demineralization is clear. There are clinical

3

consequences as reflected in higher risk of

4

fracture in the treatment population on Truvada.

5

These differences in bone mineral density could

6

potentially be even more important in women.

7

Bone mineral density in women can be

8

impacted by age and hormonal status. Approximately

9

1 in 2 women over the age of 50 will break a bone

10

because of osteoporosis. A woman's risk of

11

breaking a hip is equal to her combined risk of

12

breast, uterine, and ovarian cancer. HIV-positive

13

women have a 50 percent higher risk of osteopenia

14

at age 50 than men at a comparable age.

15

Descovy is a safer alternative for women

16

than Truvada who are at any risk for issues related

17

to bone health. Certainly in treatment settings,

18

I've switched patients on Truvada to TAF-containing

19

regimens to alleviate any concerns I would have or

20

they would have about their bone health.

21

We know that Truvada for PrEP is equally

22

effective in men and women. We know that PBMC

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1

levels have been associated with efficacy for both

2

HIV treatment and HIV prevention. There is no

3

correlate of protection established for tissue

4

levels, and only modest efficacy for topical

5

regimens that may provide lower levels in PBMCs, as

6

been mentioned already.

7

The low TFV tissue levels in men were not

8

predictive of the success seen in DISCOVER and

9

supports the notion that PBMC levels provide a

10

correlate of protection. PBMC drug levels are

11

similar for men and women and higher for Descovy in

12

both men and women. And since the PBMC compartment

13

is likely a significant predictor of efficacy, then

14

women would have similar levels of protection as

15

their male counterparts.

16

The key issues at this hearing are based on

17

the evaluation of Descovy for PrEP and whether the

18

indication should extend beyond the participants in

19

the DISCOVER trial. There's a history of

20

conflicting data regarding the role of tissue

21

levels in protecting against HIV acquisition versus

22

the role of systemic protection through components

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1

of the blood. This is obviously one of the key

2

questions before the committee today, establishing

3

efficacy and safety in HIV prevention for all

4

communities.

5

The data from the DISCOVER trial

6

demonstrated that systemic protection drives

7

efficacy in MSM and transgender women. There is an

8

established correlate of protection for the levels

9

of drug in PBMCs and iPrEx, and we see higher

10

levels in PBMCs with Descovy and lower levels in

11

rectal tissue. Yet, the point estimate in DISCOVER

12

showed a lower rate of infection on Descovy.

13

We do know that Descovy was safer in men and

14

transgender women, and we do know that there are

15

improvements in safety with TAF versus TD as well,

16

and we can debate whether these improvements will

17

convey a significant clinical benefit. I believe

18

they do convey a significant benefit from a safety

19

perspective for both adolescents and women, as

20

based on the data that has been shown today.

21

The differences in PK between TAF and TDF

22

could be a significant differentiator between the

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1

two options for PrEP, and the improved profile seen

2

with TAF might improve outcomes by mitigating

3

suboptimal adherence. This evidence supports the

4

extension of the efficacy data from DISCOVER to

5

women and to adolescents.

6

Further, at the end of the day, as a

7

clinician, counseling men and women about the need

8

for HIV prevention and PrEP, I can't stress enough

9

how detrimental it would be to give men a choice of

10

a safer medicine but not offer the same choice to

11

ciswomen.

12

Ciswomen should have the same options that

13

would be available to cismen and transwomen. They

14

should not have to wait for a separate study to

15

prove efficacy and safety in ciswomen that can take

16

at least four years to result in approval for TAF

17

or PrEP. Please at least allow women to have that

18

choice. Let them decide if the safety advantages

19

outweigh the concerns about efficacy.

20

There may be different opinions about the

21

level of certainty that disclosure will work

22

equally well in both sexes, and there is reasonable

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1

certainty, based on the success with Truvada for

2

HIV prevention, to extend this certainty from the

3

male and transgender women in DISCOVER to HIV

4

negative women and adolescents.

5

I am certain that if women and adolescents

6

don't have that choice and are told they can't use

7

a safer medicine that would have potentially been

8

approved for men, it will be seen as a signal of

9

uncertainty by these populations. They are likely

10

to feel left behind, and it will not lead to

11

increased engagement and use of HIV prevention. I

12

hope we don't give those vulnerable populations

13

that message and do allow them the option to choose

14

what will be best for them.

15

I have taught clinicians in Uganda, Kenya,

16

and Rwanda for the last five years, and these

17

clinicians also look to the U.S. and the FDA for

18

recommendations about indications for HIV

19

medications. Providing an effective and safe

20

medication for women in Africa, where women make up

21

over half the cases worldwide, is fundamentally

22

important, so these decisions today have

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1

implications not just in the United States,

2

potentially.

3

For the last 30 years as a clinician, my

4

role has been to explain to patients their

5

therapeutic options and help them make the best

6

decisions for themselves. Please allow me to keep

7

doing my job of guiding and helping patients to

8

make the best decision and don't take the choice

9

out of our hands. The totality of the evidence and

10

the favorable benefit-risk profile of Descovy

11

support making this drug available to all those in

12

need. Thank you.

13

DR. BADEN: Thank you. I'd like to thank

14

the applicant for a very thorough presentation of a

15

tremendous amount of data.

16

Before we have clarifying questions to the

17

presenters, we'll take a 10-minute break. Panel

18

members, please remember there should be no

19

discussion of the meeting topic during the break

20

amongst yourselves or with any members of the

21

audience. We will resume at 10:25. Thank you.

22

(Whereupon, at 10:14 a.m., a recess was

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1

taken.)

2

Clarifying Questions

3

DR. BADEN: We will now resume session. If

4

everyone can please take your seats, we have little

5

time and much ground to cover. We have about 50

6

minutes for clarifying questions for the

7

applicant's presentation. We may not complete all

8

of the clarifying questions, in which case we will

9

then resume after lunch, after we have a chance to

10

have the agency's presentations.

11

In the clarifying question process, for

12

those of you who are new to joining us, what I'd

13

like to do is to try to build on themes. I really

14

asked for committee members to please use the honor

15

system in how we do the clarifying question

16

process.

17

When we start, if you are interested in

18

asking a question, signal Lauren or I. We'll add

19

you to the list. If a question is asked and there

20

is a follow-on that builds on the theme, I would

21

very much like to build on the theme. Please take

22

your card, turn it on the side, and that will

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1

indicate you want to build on the theme so that we

2

can have a series of questions on the same topic

3

and not be bouncing around with every other

4

question, going back and forth between topics.

5

I just asked the committee members to really

6

build on a theme and not have that -- a way so you

7

can ask another question faster. We'll try very

8

hard to get through all of the questions as quickly

9

as possible, but I would like to, as much as

10

possible, build on themes because I think that's

11

more efficient and more effective.

12

We will start with our member on the phone.

13

We'll start with the first clarifying question.

14

MS. LUPOLE: Yes, sir.

15

DR. BADEN: Please go ahead.

16

MS. LUPOLE: The question is, what, if any,

17

are the long-term effects on bone density and renal

18

[indiscernible] related to [indiscernible]

19

adherence and failure?

20

DR. BRAINARD: I'm going to ask Dr. Moupali

21

Das to come to the podium and speak to the longer

22

term bone and renal effects of Truvada and Descovy

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1

use. I believe that was your question. We'll

2

start there. If you have an additional question,

3

we'll take it from there.

4

MS. LUPOLE: Yes, ma'am. Basically, the

5

failure to adhere and multiple incidences,

6

occurring multiple incidences.

7

DR. BRAINARD: The failure to what?

8

MS. LUPOLE: [Indiscernible - feedback]

9

DR. BRAINARD: The failure to adhere. Okay.

10

So we'll present the safety data first in

11

terms of the long-term effects, and then we'll talk

12

about adherence and how adherence is related to

13

efficacy.

14

DR. BADEN: And to our colleague on the

15

phone, if you can go on mute, as we're getting

16

feedback. Thank you.

17

DR. DAS: The bone mineral density

18

biomarker, and the renal tubular biomarkers, and

19

the glomerular function biomarkers chosen for

20

evaluation in DISCOVER are associated with

21

clinically meaningful differentiation between

22

Descovy and Truvada over the long term. First

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1

we'll look at bone, and then we'll look at renal.

2

Slide 1 up, please. The early declines in

3

bone mineral density between weeks 24 and 48 widen

4

over time through 3 years of follow-up in a

5

representative example of hip BMD from 2 pooled

6

clinical trials of Descovy- and Truvada-based

7

regimen in HIV treatment.

8

On the right, you can see that that

9

separation in the BMD curves is associated with

10

clinically meaningful increase in discontinuations

11

due to bone adverse events. This is over a 3-year

12

time period. We have longer duration of data from

13

the HIV treatment literature.

14

Slide 2 up. This is an analysis from the

15

EuroSIDA cohort with 619 fractures in over 86,000

16

person-years of follow-up. What you see here in

17

the multivariate analysis of fracture risk, which

18

was adjusted for demographics, HIV-specific

19

variables, and comorbidities, is having ever been

20

on Truvada -- excuse me, TDF versus never being on

21

TDF was associated with a 40 percent increase of

22

fracture risk. Being currently on TDF versus never

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1

being off of it was associated with a 25 percent

2

risk. You may ask what does this mean for people

3

on PrEP?

4

Slide 3 up. This is data from Chou, et al.,

5

published in JAMA earlier this year in terms of a

6

pooled meta-analysis of PrEP trials that was done

7

to support the U.S. Services Preventative Task

8

Force Recommendation with a grade A for PrEP for

9

HIV prevention. Here we see both TDF trials and

10

Truvada trials. The duration of follow-up in these

11

trials was significantly shorter than what we have

12

in the treatment literature, however, there was an

13

increased trend towards fractures in those

14

participants receiving TDF or Truvada.

15

Now we'll switch to renal discontinuations

16

in renal tubular biomarkers. Slide 1 up. A

17

similar pattern exists for the 2 tubular markers,

18

which are early markers of proximal tubular

19

dysfunction. There are early changes as early as

20

week 4, and the lines separate over time with

21

longer-term follow up through week 48 and week 96.

22

They continue to separate through week 144.

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1

On the right-hand side, you can see that

2

there were no discontinuations on people on

3

Descovy-containing regimens, that the cumulative

4

effect of tenofovir toxicity is evidenced by

5

increasing adverse events from renal causes leading

6

to discontinuations in a step-wise fashion through

7

week 48 through week 144.

8

With respect to how this is relevant for

9

people with PrEP, we turn again to Chou, et al's

10

meta-analysis from JAMA earlier this year; slide 3

11

up. Here we see that either TDF or Truvada PrEP is

12

associated with an increased risk of renal AEs. In

13

summary, we chose these biomarkers because we were

14

aware of their association with clinical meaningful

15

differentiation in terms of renal and bone safety

16

over a longer term follow-up, and we continue to

17

follow participants in DISCOVER to follow them long

18

term.

19

DR. BRAINARD: With respect to the adherence

20

question, I'll say that there have been multiple

21

clinical trials, as well as real-world data sets,

22

demonstrating the close correlation between

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1

efficacy to Truvada for PrEP and outcome.

2

Slide 1 up, please. This figure

3

demonstrates that across multiple different

4

clinical trials and real-world data sets, the

5

higher the adherence within the study or within the

6

subanalysis within the trial, looking at adherent

7

participants based on plasma tenofovir levels or

8

intracellular drug levels, the higher the efficacy

9

with respect to risk reduction for HIV acquisition.

10

DR. BADEN: If I may, on the

11

bone -- Ms. Lupole, do you have any follow-on

12

questions? If not, we'll have some follow-on in

13

the room.

14

(No response.)

15

DR. BADEN: Dr. Elion on slide 105 showed

16

TDF and adolescent bone development. Do you have

17

similar data for TAF and adolescent bone

18

development?

19

DR. BRAINARD: I'll ask Dr. Moupali Das to

20

review the data we have with TAF-containing

21

regimens in adolescents.

22

DR. DAS: First, I'll show you the data in

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1

adolescents with HIV. Slide 1 up. Descovy or TAF

2

does not have the same impact on bone mineral

3

density as does Truvada. Here is bone safety in

4

adolescents with HIV. You can see both that the

5

spine and total body less head continued to

6

increase and grow, and that there are minimal

7

changes in the Z scores, which reflect age, race,

8

and gender-matched populations.

9

In the DISCOVER study, we included people

10

who were 18 and older. The age range was 18 to 76,

11

however, we did look at the bone mineral density in

12

participants stratified by age less than 25.

13

Slide 2 up. This comparative data between

14

Descovy and Truvada in the participants less than

15

25 years on the left with spine and in the middle

16

greater than 25 years with spine. You can see that

17

the participants on Descovy continue to have the

18

same amount of increase in bone mineral density,

19

whereas those on Truvada had significant declines,

20

which is particularly relevant for this population.

21

Similar trends were observed with hip in terms of

22

continued growth on Descovy or stable on Descovy

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1

but declines on Truvada.

2

This is consistent with the findings in PrEP

3

that Dr. Elion showed.

4

DR. BADEN: Would these data -- compared to

5

age-matched controls, HIV uninfected, not on a

6

tenofovir compound, is the bone development on TAF

7

equal or is there a difference? Because comparing

8

it to tenofovir TDF, one may accept the decline and

9

say the decline is not as bad. How does it compare

10

to age-matched controls on none of these medicines?

11

DR. DAS: If we go back to slide 1, these

12

are participants with HIV, so there is that

13

consideration. But this is people who are on

14

Truvada, and you're asking about participants on

15

TAF.

16

DR. BADEN: Persons on TAF, and I'm

17

interested in the TAF comparison to bone

18

development in healthy age matched-controlled

19

children not on a tenofovir compound, so that the

20

bone development of a 20 year old on TAF and off

21

TAF is not different.

22

DR. DAS: Okay. In this slide, because we

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1

don't have any TAF data in adolescents without

2

HIV -- this is TAF data in adolescents with

3

HIV -- the dotted lines are the Z scores, which are

4

matched by age, race and gender for the population.

5

You can see in the dotted lines between zero and

6

week 48, there's really no difference in the blue

7

dotted-line Z score, which is a spine Z score, and

8

the pink dotted-line Z score, which is total body

9

less head.

10

DR. BADEN: And those would then be

11

age-matched control unaffected?

12

DR. DAS: Yes.

13

DR. BADEN: That's what I thought you said.

14

I just wanted that crystal clear --

15

DR. DAS: I'm sorry I didn't clarify that,

16

yes.

17

DR. BADEN: -- that as best as we can tell,

18

there is no abrogation of normal bone development,

19

as best as you can tell, realizing they're HIV

20

infected; otherwise they wouldn't be on this for a

21

long term.

22

DR. DAS: Exactly. Thank you.

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1

DR. BADEN: Thank you.

2

Did Dr. Goetz or Awni have a follow-on

3

question?

4

DR. GOETZ: My follow-up was related to the

5

adherence question rather than bone.

6

DR. BADEN: Please?

7

DR. GOETZ: The previous slide, the

8

backup 1232, showed the relationship between

9

adherence and efficacy. One of the considerations

10

is the relationship between adherence and efficacy

11

on Truvada-containing regimens, or TDF-containing

12

regimens, the same in women as in men. I think

13

that helps inform our thoughts as to where the

14

local tissue concentrations are important.

15

So looking at the VOICE/FEM-PrEP versus

16

iPrEP [ph] populations, I wonder if you can go into

17

more detail as to regards to how levels of

18

adherence, which then presumably correlate with

19

PBMC concentrations, correlate with levels of

20

protection in women versus men.

21

DR. BRAINARD: The levels of adherence

22

measured across these studies varied. They weren't

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1

all uniformly assessing adherence through the same

2

mechanism. However, the association between

3

adherence and efficacy by these measures, whether

4

it was tenofovir plasma levels or tenofovir

5

diphosphate within the peripheral blood mononuclear

6

cells, that relationship held up across men and

7

women.

8

These studies shown here represent some of

9

the larger studies conducted to date. But since

10

Truvada for PrEP was approved seven years ago,

11

there's an even larger data set that has

12

accumulated.

13

Slide 1 up, please. The CDC recently

14

updated their website with the new data on efficacy

15

and analyses across all available data and

16

concluded that adherence is highly correlated with

17

outcomes for both men and women and that the

18

efficacy of Truvada for PrEP is estimated to be 99

19

percent for men and for women who are using Truvada

20

for PrEP consistently.

21

DR. GOETZ: If I can follow up on that, then

22

I guess my question goes into people who are

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1

partially adherent. To the degree that it's

2

knowable -- these are hard questions -- is partial

3

adherence as effective in women as it is in men?

4

This indirectly gets at the question, is partial

5

adherence, we would think from the pharmacokinetic

6

data would lead to similar concentrations of TFV

7

diphosphate intracellularly and PBMCs, which may

8

not be sufficient.

9

Does it protect women as well as men?

10

Because if we get the same levels in PBMCs, they're

11

at the lower level, so there may be concerns about

12

tissue concentrations. So again, the question is,

13

does partial adherence protect women as equally to

14

men at thresholds? It's certainly going to be a

15

relationship between adherence and success.

16

DR. DAS: There was some recent data

17

presented just a few weeks ago at the IAS

18

conference from the HPTN 082 study, which was a

19

large study conducted in Africa in women. It was

20

looking at different interventions to increase

21

adherence. But in terms of the clinical outcomes

22

of that trial -- put slide 3 up, please -- among

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1

the 400 Women age 16 to 25, who were enrolled in

2

this study, there were 4 infections. That gave an

3

overall incidence rate of 1 per 100 person-years.

4

They used dried blood spots, which the

5

methodology from the iPrEx study as well as from

6

DISCOVER trial, and they found that the infections

7

closely correlated with these measurements of

8

adherence using the dried blood spots, which is to

9

say that two of the infections occurred with no

10

detectable drug level and the other two occurred in

11

the setting of adherence consistent with less than

12

2 doses per week. This is suggests that in the

13

setting of low adherence, there is a similar

14

relationship.

15

DR. BADEN: Dr. Giordano?

16

DR. GIORDANO: The adherence question

17

relates to the PBMC question in my mind. The

18

argument is that you achieve high levels of the

19

tenofovir active component in PBMC, and that is a

20

correlate of protection. My understanding of the

21

Anderson et al data is that those data were

22

generated from people who were less adherent to

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1

people who were more adherent to the tenofovir

2

drug.

3

So the PBMC data, are they not simply a

4

measure of adherence? And if you measured

5

tenofovir in hair or tenofovir in some other body

6

component, would you not arrive at the same

7

conclusion, that hair is a correlate of protection

8

for HIV prevention? So it gets to the strength of

9

those data, which are critical to this argument

10

that the company's making.

11

DR. BRAINARD: So tenofovir diphosphate,

12

when measured in red blood cells as is done with

13

the dried blood spot analysis, is a measurement of

14

adherence alone and can be analogous to measuring

15

tenofovir in hair levels or measuring plasma

16

tenofovir.

17

The advantage of the tenofovir diphosphate

18

in dried blood cells is that it allows for an

19

integrated assessment of efficacy over a longer

20

period of time, similar to a hemoglobin A1c.

21

Nevertheless, it doesn't speak itself to efficacy,

22

but we know that for tenofovir prodrugs orally

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1

administered, the drug is acting within CD-4

2

positive T cells, which are a component of

3

peripheral blood mononuclear cells.

4

We also can draw the correlation between the

5

level of tenofovir diphosphate within the red blood

6

cells and what the corresponding level is within

7

PBMCs based on phase 1 studies in healthy

8

volunteers that Dr. Anderson did to validate that

9

analysis.

10

So the dried blood spot data is adherence

11

data. You can get thresholds of adherence, and

12

then based on the phase 1 studies done, where they

13

were able to match those adherence bands to exactly

14

how many doses were given per week, they can then

15

correlate that to be expected intracellular PBMC

16

levels, and we correlate that with efficacy because

17

that's where we know that the virus replicates. It

18

can only replicate in CD-4 cells

19

DR. GIORDANO: But that correlation with

20

efficacy is still fundamentally based on adherence,

21

as I understand it. How do we know that someone

22

with the exact same adherence -- let me ask it

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1

differently. How do we know that the levels in

2

PBMC are the critical determinant of prevention,

3

not of treatment efficacy for someone who has HIV,

4

but of prevention?

That's what I'm not -- you

5

haven't really established that fact in my mind.

6

DR. BRAINARD: So we know that Truvada for

7

PrEP is highly an equally effective in men and

8

women and that adherence is the primary driver of

9

that efficacy. When we look at the vaginal and

10

rectal tissue levels of Truvada -- and I'll try to

11

show you that slide in one minute -- what we can

12

see is that the rectal levels of a tenofovir

13

diphosphate following Truvada use are 100-fold

14

higher than they are in vaginal tissue.

15

If genital tissue or rectal tissue -- and

16

I'll put slide 1 up please. These are the data I

17

just spoke to with the 100-fold higher rectal

18

tenofovir diphosphate levels as compared to vaginal

19

tenofovir diphosphate levels in the setting of

20

Truvada with healthy female volunteers.

21

So if genital tissue levels were driving

22

efficacy, then you wouldn't expect to see equal

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1

efficacy in men and women. You'd see

2

disproportionate efficacy, but we don't. We also

3

know from the DISCOVER trial that Descovy is highly

4

effective at preventing HIV acquisition in men who

5

have sex with men and transgender women.

6

I'll put slide 2 up, please. These data add

7

in the Descovy data in the vaginal and rectal

8

compartments. What you can see is that for

9

Descovy, rectal compared to vaginal, rectal levels

10

are 10-fold higher. And within the rectal

11

compartment, Truvada achieves 10-fold higher levels

12

than Descovy.

13

So again, comparing Truvada to Descovy, if

14

rectal levels were driving efficacy, then you would

15

expect Truvada would be better than Descovy, but

16

that's not what we saw in the trial. We saw that

17

they were noninferior, and we saw that adherence

18

was the primary driver of efficacy.

19

So we know that we have these high rectal

20

levels. We know that vaginal levels with Truvada

21

are lower, but we know that Truvada is highly

22

effective in women who take the drug. Therefore,

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1

that provides evidence, if you will, that the

2

active tenofovir diphosphate and the circulating

3

PBMCs is driving the efficacy and not the tissue

4

levels within the homogenate of the tissue.

5

DR. BADEN: We have several more follow-on

6

questions. Dr. Awni, did you have a follow on?

7

DR. AWNI: I actually thought it was a

8

follow-on, but related to the size, there were a

9

couple of statements saying the size of the two

10

tablets between the Truvada and Descovy, how much

11

difference in size? Size of the tablet could have

12

an impact on somebody taking it, easy to take it

13

somewhere else.

14

DR. BRAINARD: Yes. Descovy is

15

substantially smaller than Truvada because it's

16

such a smaller dose, 25 milligrams versus 300

17

milligrams.

18

Slide 1 up, please. Obviously not to size,

19

but you get the relative comparison between the

20

size of the two pills there. And size has been

21

cited in patient surveys as a factor that's been

22

seen as favorable.

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1

DR. BADEN: Dr. Gripshover, we're still

2

doing follow-ons.

3

DR. GRIPSHOVER: My follow-on is back to the

4

PBMC question. I think the data that we've seen,

5

that you tried to show that it correlated with

6

efficacy, was based on the iPrEx study of men who

7

have sex with men, I think, and then we've seen it

8

in the DISCOVER trial with Descovy.

9

Do we have data from Partners PrEP, where we

10

did see Truvada being effective in women? Do we

11

know that that also works in women from any other

12

trials, or is it just in these two trials?

13

DR. BRAINARD: There are other trials

14

besides Partners PrEP that showed efficacy in

15

women. For example, TDF2 was a study conducted in

16

both men and women, and in the TDF2 study, if you

17

look at the as-treated population, which censors

18

people after they have no longer been taking drug

19

for at least 30 days, then the efficacy in men and

20

in women is comparable.

21

DR. GRIPSHOVER: Actually, my question was

22

do you have the T of the PMBC data in women in all

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1

to know that that marker of efficacy works in those

2

trials? That was my question; not did it work.

3

Sorry.

4

DR. BRAINARD: So within Partners PrEP, we

5

had adherence, but I don't believe that there were

6

tenofovir diphosphate levels; it's plasma tenofovir

7

levels. So we can take a look and see if we can

8

find specific data regarding tenofovir diphosphate

9

levels in clinical studies within women.

10

But what I would say, I want to reemphasize

11

that the connection between adherence and the

12

tenofovir diphosphate within PBMCs is made based on

13

the validation of the dried blood spot assay. So

14

you get the dried blood spot assay -- and I might

15

have Dr. Anderson come up and speak to this just so

16

he can walk through how that connection between the

17

dried blood spot tenofovir diphosphate is then

18

related and corresponding to a PBMC level.

19

Because it seems like what we're talking

20

about is tenofovir diphosphate within the CD-4

21

cells, within the PBMCs driving efficacy, but you

22

don't actually measure the PBMCs during the study

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1

for adherence; you measure the dried blood spot.

2

Then we know from the validated assays what that

3

level correlates to with respect to tenofovir

4

diphosphate and PBMCs. I'll also say that we know

5

across men, women, HIV infected, HIV uninfected,

6

that tenofovir diphosphate levels are consistent.

7

DR. ANDERSON: Good morning. I have

8

received grants and contracts from Gilead Sciences

9

paid to my institution, as well as some consulting

10

honoraria for my time here, but I do not have a

11

financial interest in the outcome of this meeting

12

or in the company.

13

So I wanted to explain the relationship

14

between DBS concentrations in efficacy as well as

15

PBMC concentrations and efficacy. If I can just

16

have slide 2 up, please.

17

First, I want to start with DBS. DBS was

18

used in the DISCOVER study as an adherence

19

biomarker. What we measured is intracellular

20

tenofovir diphosphate in red cells. And the reason

21

is the half-life in the red cell is 17 to 20 days.

22

That means the concentration will be proportional

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1

to the exposure to the drug or adherence, so we'll

2

have a proportional relationship there. It's a

3

wonderful marker for assessing and quantifying

4

adherence.

5

If I could have slide 3 up, please. The way

6

that we operationalize this is dried blood spots

7

come into the lab. We take a punch from that spot,

8

so we normalize the amount that we assay. We then

9

use a validated method. We get a result, the

10

tenofovir diphosphate result. Then we have to

11

understand what that result means.

12

To do that, we conducted separate directly

13

observed dosing PK study in healthy volunteers, one

14

Descovy and one with Truvada, and gave them varying

15

adherence rates. Then we measured their

16

concentrations. And we could tell by then the

17

concentration, what adherence that person -- we

18

made that a standard curve relationship.

19

Then we wanted to know do these bands of

20

adherence relate with efficacy -- if I could have

21

slide 2 up, please -- and they do. These are DBS

22

results from the iPrEx open-label extension that

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1

shows HIV incidence on the Y by the dried blood

2

spot level on the X-axis. Then the different

3

adherence bands you can see along the top, less

4

than 2 doses per week on average, 2 to 3 and

5

greater than 4.

6

People that had blood spot levels of greater

7

than 4, there were no infections in that group.

8

People who had blood spot levels of 2 to 3 had an

9

approximately 90 percent reduction in HIV incidence

10

relative to not being on PrEP. So if you hold

11

those dosing categories in mind, this is very

12

similar to what we see in PBMCs.

13

If I could have slide 2 up, please. Just

14

switching your mind now from dried blood spots to

15

PBMC intracellular tenofovir diphosphate, these are

16

the active sites now in peripheral blood

17

mononuclear cells. This is a case control from the

18

iPrEx randomized-controlled trial, and the

19

relationship between drug concentration in PBMC,

20

tenofovir diphosphate in PBMC, and efficacy

21

compared to placebo.

22

Now look at the bands along the top. These

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1

are PBMC concentrations from a directly observed

2

dosing study showing 2 doses per week on that as

3

well as 4 or more doses per week. We saw

4

approximately the same efficacy relationship in the

5

PBMCs. Those that were in the roughly 2- to 3-dose

6

range had about a 90 percent reduction. Those in

7

the 4 or more had essentially a hundred percent

8

reduction in HIV incidence.

9

That is the connection that we make through

10

adherence. It's through adherence, and I think

11

that was the point that was brought up earlier, is

12

we're making a connection through adherence. The

13

difference with PBMCs is we know that's the active

14

site.

15

DR. BADEN: Dr. Swaminathan?

16

DR. SWAMINATHAN: So you've sort of drawn a

17

line between --

18

DR. BADEN: Please talk closer to your

19

microphone.

20

DR. SWAMINATHAN: You've sort of drawn a

21

line between the levels from the dried blood spot

22

test and PBMC levels, and the correlation with the

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1

efficacy data. I guess the thesis is that because

2

PBMCs or T cells are the sites of replication of

3

the virus, and that TAF has good intracellular

4

levels in PBMCs, that the efficacy would be

5

expected to be as good or better.

6

But the connection between the PBMC levels

7

in previous PrEP trials depends on the

8

pharmacokinetics of Truvada. So whatever the

9

actual target cell that's necessary for effective

10

PrEP is, we know that it correlates with PBMC

11

levels; not that the PBMCs are the actual target

12

that makes PrEP efficacious.

13

How do we know that the correlation between

14

the PBMC levels and cell X is the same with regard

15

to the pharmacokinetics of these two different

16

drugs?

17

DR. BRAINARD: So we know cell X. Cell x is

18

a CD-4 positive T cell because that's the only cell

19

within which HIV will replicate in order to spread

20

infection. Now, that CD-4 positive T cell could be

21

within the tissues or it could be within the

22

peripheral blood mononuclear cells, recognizing

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1

that these are not distinct subsets but that there

2

is circulation around the body and trafficking of

3

cells in and out of tissues.

4

I'll put slide 2 up, please, and then CC-15

5

and back, please. Just reviewing, again, how

6

infection is established, infection is initially

7

established, for mucosal transmission, by the

8

infection of a local cell. But in order for

9

infection to disseminate, two different things need

10

to happen. CD-4 T cells need to be recruited to

11

that site of initial infection so that a founder

12

population can be established, and then that

13

founder population needs to disseminate via the

14

lymphatic system.

15

We know from nonhuman primate studies that

16

these CD-4 T cells that form the founder population

17

are coming from the peripheral blood mononuclear

18

cells, and we know that when you're talking about

19

systemic oral drugs, that systemic drugs load both

20

peripheral blood mononuclear cells, but there are

21

also drugs circulating throughout the plasma.

22

Slide 2 up, please. Again, understanding

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1

how that infection is occurring, with systemic

2

therapy or with oral tenofovir prodrugs, drug is

3

loaded within these peripheral blood mononuclear

4

cells, which are circulating around the body and

5

trafficking to different locations, including the

6

lymphatic tissue, and including to tissue,

7

particularly when there's a chemokinetic signal.

8

But also TAF, in the case of Descovy and plasma

9

tenofovir in the case of Truvada, are also

10

circulating throughout the blood and distributing

11

throughout the body. As those drugs get into the

12

tissues, they're also able to load resident cells

13

and provide protection that way.

14

So there are really two different ways that

15

systemic oral agents can provide protection against

16

HIV infection. Topical agents can also provide

17

protection, but the way they do that is not by

18

sitting on top of the mucosa but actually diffusing

19

into the subepithelium [ph]. Then in the case of

20

tenofovir gel, for example, they still have to get

21

inside that CD-4 T cell because that's the only

22

place that HIV replicates, and that's independent

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1

of female, male, vagina, and rectum.

2

DR. SWAMINATHAN: I agree with most of what

3

you said, but I would just have to disagree with

4

this idea that there's this instantaneous dynamic

5

flux in equilibrium between peripheral blood

6

mononuclear cells and cervical or other submucosal

7

lymphoid populations.

8

The phenotype of resident memory T cells in

9

different tissues has been demonstrated to be

10

different, and there are high CCR5 resident

11

lymphocytes in vaginal tissue, for example, that

12

are different from rectal tissue, and certainly

13

different from PBMCs. Dendritic cells in the

14

vaginal tissue are also thought to play a role.

15

All I'm saying is that unless one actually

16

knows what the pharmacodynamics of these different

17

compounds, intracellularly, in different resident

18

populations, which is the population -- there's not

19

recruitment until after the virus gets there, and

20

there's infection locally of cells to come into the

21

site of infection. So the level of intracellular

22

drug in the lymphocytes that are going to be

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1

infected immediately after exposure is what's

2

relevant, and no one has really been able to

3

measure, from what I understand.

4

DR. BRAINARD: I would like to -- oh, sorry.

5

DR. BADEN: Unfortunately, it's 11:07, and

6

we need to go to the agency's presentation. I

7

would have you respond, except this is a longer

8

discussion. So I think, as I anticipated, we

9

almost got through one question. So I will be very

10

interested, as all the committee members are, on

11

further discussion on this point. I think you

12

understand the key issue, and perhaps over lunch,

13

you'll further clarify how to educate us on the

14

rationale.

15

But we need to move to the agency's

16

presentation and clarifying questions to the

17

agency. And if there's time, we'll come back to

18

further clarifying questions to the applicant or

19

we'll do that after lunch.

20

DR. BRAINARD: Great. Thanks very much.

21

DR. BADEN: Thank you.

22

Dr. Miele, thank you for presenting the

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1

agency's perspective on some of these key issues.

2

FDA Presentation - Peter Miele

3

DR. MIELE: Good morning. I am Peter Miele,

4

a medical officer in the Division of Antiviral

5

Products. I will be presenting on behalf of the

6

FDA review team for NDA 208215, supplement 12 for

7

Descovy, for pre-exposure prophylaxis or PrEP

8

indication. Here's my agenda.

9

I'll begin with a brief discussion of the

10

indication being proposed by this application, and

11

then move on to some context and background; in

12

particular, a brief discussion of the issues we've

13

been having here with regards to the potential role

14

of mucosal tissue drug concentrations in HIV

15

prevention.

16

I'll summarize the FDA findings from the

17

DISCOVER trial in men and transgender women who

18

have sex with men, and conclude with a discussion

19

of the extrapolation approach that's being proposed

20

in this application to support a PrEP indication in

21

cisgender women and the data that has been

22

submitted to support that approach.

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1

As you know, this application proposes a new

2

indication for Descovy or F/TAF, which is

3

pre-exposure prophylaxis to reduce the risk of

4

sexually-acquired HIV-1 in at-risk adults and

5

adolescents weighing at least 35 kilograms.

6

To be clear, this indication would apply to

7

adult and adolescent men and transgender women who

8

have sex with men, men who have sex with women and

9

cisgender women who have sex with men. As such,

10

the proposed indication is similar to the currently

11

approved indication for PrEP for Truvada, which is

12

emtricitabine tenofovir disoproxil fumarate or

13

F/TDF, and the indication is listed for you here.

14

Now, as you know, the data that the agency

15

reviewed to support the PrEP indication for Truvada

16

consisted of data from a phase 3 double-blind,

17

placebo-controlled trial in MSM and transgender

18

women, or the iPrEx trial; as well as phase 3,

19

double-blind, placebo-controlled trial in adult

20

heterosexual men and women in HIV serodiscordant

21

relationships or the Partners PrEP trial; as well

22

as data from a phase 2 open-label trial in

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1

adolescent MSM. The Adolescent Trial Network study

2

113.

3

As you've heard already, there are some

4

differences between TAF and TDF. Both drugs have

5

been approved for the treatment of HIV-1 and

6

chronic hepatitis B, but compared to

7

TDF 300 milligrams, oral administration of 25

8

milligrams of TAF results in a 4- to 7-fold higher

9

intracellular level of the active metabolite

10

tenofovir diphosphate in PBMCs, while also

11

resulting in 90 percent lower plasma levels of

12

tenofovir.

13

It's these differences in the plasma

14

exposure to tenofovir that may explain some of the

15

differences in a safety profile observed between

16

TAF and TDF, as if there's less circulating

17

tenofovir in plasma, there's a reduction in the

18

risk of off-target effects of tenofovir.

19

That said, there have been published

20

single-dose PK studies that suggest that

21

25 milligrams of oral TAF achieves lower tenofovir

22

and tenofovir diphosphate levels in rectal and

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1

vaginal mucosal tissues as measured in homogenates

2

compared to oral 300 milligrams of TDF.

3

Why is this important? As you've heard in

4

the previous discussions, the relative importance

5

of mucosal tissue versus systemic drug

6

concentrations to PrEP efficacy is unknown.

7

Importantly, the minimum drug concentration in

8

mucosal tissues, if they are relevant, that would

9

be considered protective against HIV-1 infection is

10

also unknown.

11

But we have some indirect observations that

12

might support a role for mucosal tissue drug

13

concentrations in PrEP efficacy. For one, as has

14

been mentioned before, topical microbicide

15

experience suggests that vaginal mucosal tissue,

16

drug concentrations, at high enough levels and with

17

very limited systemic exposure can reduce the risk

18

of HIV-1 infection. And as you've heard, we know

19

that oral TDF dosing results in lower tenofovir

20

diphosphate exposure in vaginal tissue versus

21

rectal tissue.

22

It is this differential drug distribution

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1

that has raised concerns that in combination with

2

poor adherence, it may have contributed to the

3

mixed efficacy results observed in PrEP clinical

4

trials of F/TDF in cisgender women as compared with

5

MSM. That's a controversial topic, and that has

6

been greatly debated over the last few years, but

7

the end result is that we're not entirely sure to

8

what extent this differential drug distribution may

9

have on the efficacy; or in other words, is

10

suboptimal adherence less forgiven in women than

11

men?

12

These concerns have practical implications.

13

The CDC PrEP guidelines, for example, acknowledge

14

the lack of scientific consensus on protective

15

contribution of drug exposure in specific body

16

tissues. The CDC addresses this issue by reporting

17

the time to achieve maximum intracellular

18

concentrations of tenofovir diphosphate in the

19

various compartments as based on PK studies. Some

20

state PrEP guidelines have followed suit in

21

recognizing the tissue differential also in

22

discussing the time to achieve protective

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1

concentrations.

2

For example, the New York State PrEP

3

guidelines recommend a 7-day lead in of oral PrEP

4

use for protection with receptive anal sex. In

5

contrast, they recommend 20 days of daily PrEP use

6

for protection with receptive vaginal sex. Now,

7

these differences would not be necessary if there

8

was consensus that systemic PK was the prime

9

motivator or the prime driver for PrEP efficacy.

10

As we know, there are no gender differences with

11

respect to systemic PK for TDF.

12

So given that there is a lack of consensus

13

regarding the contribution of local tissue versus

14

systemic drug exposure to PrEP efficacy, and these

15

reports of lowered mucosal tissue tenofovir

16

diphosphate concentrations with oral TAF versus TDF

17

dosing, the agency determined that fully powered

18

clinical trials would be needed to support efficacy

19

of F/TAF for PrEP using F/TDF as the active

20

control.

21

Back to this application, the data that's

22

been submitted to support a PrEP indication for

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1

Descovy consists of one phase 3 double-blind active

2

control clinical trial in MSM transgender women or

3

the DISCOVER trial. To support indication in

4

cisgender women and adolescents, an extrapolation

5

approach has been proposed. The FDA presentation

6

will focus on the extrapolation approach in

7

cisgender women.

8

The DISCOVER trial was designed as a

9

double-blind noninferiority trial of 5,000 subjects

10

randomized to F/TAF or F/TDF for at least 96 weeks.

11

Following the day 1 visits, subjects returned for

12

study visits at weeks 4 and 12 and then every

13

12 weeks. And at each follow-up visit, as you

14

heard, they received at risk reduction counseling

15

and adherence counseling, as well as STI screening

16

at all three anatomical sites, oral, rectal, and

17

urine.

18

The primary efficacy endpoint was the

19

incidence of HIV-1 infections per 100 person-years

20

when all subjects had reached a minimum of 48 weeks

21

of follow-up and at least 50 percent had reached

22

96 weeks of follow-up or permanently discontinued

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1

from the trial.

2

For the relative risk analysis, a

3

noninferiority margin of 1.62 per 100 person-years

4

was derived based on historical data from three

5

clinical trials of F/TDF for PrEP and MSM, namely

6

the iPrEx, PROUD, and IPERGAY studies. Based on

7

equal weighing of the three trials, an HIV

8

incidence of 1.44 was assumed for the control arm

9

of F/TDF with a confidence interval of 2.64 and

10

9.7. Because the analysis for the DISCOVER trial

11

was a rate ratio, the square root of the lower

12

bound of this confidence interval provided the

13

noninferiority margins. So the square root of 2.64

14

is 1.62.

15

5,399 subjects were randomized in DISCOVER,

16

6 subjects per arm were randomized but not treated,

17

giving us a safety population of 5,387. The full

18

analysis set was used for the primary efficacy

19

analysis, and that consisted of subjects who were

20

randomized and treated HIV negative at baseline and

21

had at least one follow-up HIV test during the

22

trial, and that population was 5,335.

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1

In the safety population, the baseline

2

characteristics and demographics were well balanced

3

between the two arms. As you've heard, the median

4

age was 34 years, and 99 percent of subjects were

5

MSM and 1 percent were transgender women; 84

6

percent of subjects were white, black, or mixed

7

black race made up 9 percent of subjects and

8

Hispanics made up 25 percent.

9

At baseline, 16 percent of subjects were

10

using Truvada for PrEP and 44 percent were

11

uncircumcised. The median duration of exposure was

12

86 weeks, and that was balanced between the two

13

arms. And as you've heard, adherence to study drug

14

was high by multiple measures in this trial.

15

For the primary efficacy analysis, a total

16

of 22 HIV infections were reported, 7 in the F/TAF

17

arm for an HIV infection rate of 0.16, and 15 in

18

the F/TDF arm for an HIV infection rate of 0.342.

19

The HIV infection rate ratio was 0.468 with the

20

confidence intervals shown here. Because the upper

21

bound of the confidence interval was below the

22

prespecified NI margin of 1.62, the DISCOVER trial

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1

demonstrated noninferiority of F/TAF to F/TDF.

2

As an update, we received a report of an

3

additional HIV infection after the submission was

4

filed, one more HIV infection in the F/TAF group,

5

but this does not impact the primary efficacy

6

conclusion.

7

Data from the DISCOVER indicate that F/TAF

8

provides a similar level of protection as F/TDF

9

against rectal acquisition of HIV, but if we

10

consider other potential routes of HIV transmission

11

in men, such as penile HIV exposure, we do not have

12

any direct evidence to support the efficacy of

13

F/TAF for this relatively low-risk route of

14

transmission.

15

That said, we can assume that insertive sex

16

was occurring in the DISCOVER trial. At study

17

entry, subjects reported a mean of 4 unprotective

18

insertive anal intercourse partners in the 90 days

19

prior to screening, and during the trial, 16

20

percent of subjects had urethritis diagnosed with

21

gonorrhea or chlamydia likely from unprotected

22

insertive anal intercourse.

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1

Thus, given the low rates of HIV infection

2

observed overall in the DISCOVER trial, it may be

3

reasonable to assume that men who practice

4

insertive sex were protected.

5

I'm now going to switch gears and talk about

6

safety as observed in the DISCOVER trial. Both

7

F/TAF and F/TDF were safe and well tolerated. We

8

observed no notable differences between the two

9

arms in the types, incidence, severity, or onset of

10

adverse events, or laboratory abnormalities.

11

As you've heard, the most common AEs were

12

sexually transmitted infections. If we exclude the

13

STIs and other infectious adverse events, the most

14

common AEs were diarrhea at 16 percent, nausea at 7

15

percent, headache at 7 percent, and fatigue at 6

16

percent, with comparable rates between the arms.

17

Six percent of subjects in the F/TAF arm

18

were considered serious adverse events and 5

19

percent of subjects in the F/TDF arm had serious

20

adverse events. The majority of these events were

21

not considered related to study drug. We also

22

observed low rates of adverse events leading to

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1

drug discontinuation, 1 percent in the F/TAF arm

2

and 2 percent in the F/TDF arm.

3

The most common adverse events leading to

4

drug discontinuation were gastrointestinal

5

disorders, which led to drug withdrawal in less

6

than 1 percent of subjects in each arm. When we

7

looked at GI events overall, they tended to occur

8

in the first month of treatment, which is

9

consistent with the start-up syndrome described in

10

previous trials of F/TDF PrEP.

11

These issues did not seem to have a major

12

impact on body weight, however, there was a mean

13

increase of weight from baseline at week 48 of

14

1.1 kilograms for F/TAF and essentially no change

15

in weight for F/TDF.

16

Looking at renal safety, when we looked at

17

the mean absolute change in serum creatinine, there

18

was minimal change in either group at both weeks 48

19

or 96. The graph on the right shows the mean

20

change in estimated GFR from baseline. The blue

21

line shows the changes in the F/TAF group, which

22

essentially stayed pretty much consistent with

A Matter of Record (301) 890-4188

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1

baseline, whereas in the F/TDF group, there was a 2

2

to 5 milliliter per minute decrease from baseline

3

over the course of the trial, which became apparent

4

as early as week 4.

5

The distribution of urine protein to

6

creatinine ratio, or UPCR categories, was a key

7

alpha protected safety endpoint in this study.

8

UPCR is generally regarded by the FDA Division of

9

Cardiovascular and Renal Products as a useful

10

laboratory assessment of proteinuria.

11

As shown here, the proportion of subjects

12

who had no significant proteinuria at baseline and

13

who then went on to develop significant proteinuria

14

at week 48 was low in both groups, but was higher

15

in the F/TDF group at 2 percent versus 1 percent in

16

the F/TAF group.

17

Conversely, the proportion of subjects who

18

had significant proteinuria at baseline, of which

19

there were only 25 per arm and who then had

20

improvement in their UPCR category, was higher in

21

the F/TAF group compared to the F/TDF group, at 57

22

versus 44 percent, respectively. These differences

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1

were statistically significant at week 48, however,

2

the differences were not significant at week 96.

3

We also observed a greater frequency of

4

treatment emergent proteinuria by urine dipstick in

5

the F/TDF arm overall at 24 percent versus 21

6

percent per F/TAF. Most of these abnormalities,

7

however, were grade 1, and we saw no difference in

8

the frequency of grade 2 proteinuria between the

9

two arms.

10

Likewise, we saw very little differences in

11

the frequencies of graded treatment-emergent

12

laboratory abnormalities as they pertained to serum

13

creatinine, 2 percent for F/TDF and 1 percent for

14

F/TAF overall, and we saw no differences at all

15

between the two groups with respect to

16

hypophosphatemia regardless of severity.

17

Likewise, we saw very little difference

18

between the two groups in the frequency of

19

treatment-emergent adverse events related to renal

20

safety. There was one case of Fanconi syndrome

21

acquired in the F/TDF arm, but also a case of

22

glomerulonephropathy in the F/TAF arm, as well as a

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1

case of nephrotic syndrome in the F/TAF arm.

2

The cases in the F/TAF were not considered

3

related to study drug, whereas the Fanconi syndrome

4

in the F/TDF arm was. But when we looked at other

5

adverse events as grouped by their MedDRA high

6

level terms for renal failure and impairment,

7

urinary abnormalities, electrolyte analyses, namely

8

blood phosphorous, decreased renal function, and

9

urinalysis not elsewhere classified, we saw no

10

differences between the groups in the reporting of

11

these adverse events. Likewise, there was very

12

little difference between the two groups in renal

13

adverse events that led to drug discontinuation,

14

although the numbers were very small.

15

In summary, for adverse events or graded

16

treatment-emergent laboratory abnormalities related

17

to renal function or safety, we observed no major

18

differences between the two groups in this

19

particular subject population. I would also remind

20

you that, as with Truvada, approved labeling for

21

Descovy still carries with it a warning for new

22

onset or worsening renal impairment.

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1

Moving on to bone safety, mean percent

2

change from baseline at week 48 and hip and spine

3

bone mineral density were also key alpha-protected

4

safety endpoints. As shown on the table here,

5

there were differences between the two groups at

6

both hip and spine and at both weeks 48 and 96,

7

with essentially no great change in the F/TAF arm

8

but decreases of about a mean of 1 percent at each

9

time point, at each site for the F/TDF arm. These

10

differences were statistically significant at both

11

time points.

12

Consistent with other tenofovir-containing

13

product labeling, we conducted a categorical

14

analysis of the percent change in BMD from baseline

15

using the falling cutoffs, 7 percent change from

16

baseline for hip and 5 percent change from baseline

17

for spine, as these are cutoffs that the agency

18

considers clinically meaningful.

19

With regards to the hip, we saw absolutely

20

no difference between the two arms, whether in

21

decreases or increases. We also saw no difference

22

between F/TAF and F/TDF for decreases from baseline

A Matter of Record (301) 890-4188

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1

in spinal BMD. However, there was a slight or

2

greater proportion of subjects in the F/TAF arm

3

that had a 5 percent or greater increase from

4

baseline in spine BMD at week 48.

5

The applicant has shown you results from a

6

categorical analysis regarding the change in BMD

7

clinical status from baseline to week 48 for the

8

spine. We concur that there was a greater

9

proportion of subjects in the F/TDF arm that had

10

worsening status at week 48 and conversely a

11

greater proportion of subjects in the F/TAF arm

12

that had greater improvement of their BMD status in

13

the hip at week 48.

14

However, when we did the same analysis for

15

the hip, we saw no differences in the proportion of

16

subjects at worsening status at week 48, and there

17

was actually a greater proportion of subjects in

18

the F/TDF arm that had improvement.

19

When we turn to adverse events as reported

20

in the DISCOVER trial, during the course of the

21

trial, we saw no differences between the two groups

22

with respect to fractures, most of which were

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1

traumatic and occurred at a relatively low rate of

2

2 percent, or in pathological fractures, as well as

3

in reports of back pain, spinal pain, or bone pain.

4

Likewise, we saw no differences between the two

5

groups with respect to what the investigators

6

themselves reported as bone density decrease, bone

7

loss, osteopenia, osteoporosis, or

8

hypophosphatemia.

9

We looked also at the median change from

10

baseline in fasting serum lipids, and we noticed

11

that there was an overall trend to decrease in

12

fasting cholesterol and LDL in both arms, but the

13

magnitude of the decrease from baseline was greater

14

for F/TDF. We also noted that there was a slight

15

increase from baseline in fasting triglycerides

16

with F/TAF.

17

However, it's important to note that we saw

18

no differences in the median change from baseline

19

for the ratio of total cholesterol to HDL, either

20

within groups or between groups. That said, the

21

F/TAF group had consistently higher incidence of

22

graded laboratory abnormalities related to total

A Matter of Record (301) 890-4188

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1

cholesterol, LDL, or triglycerides, across all

2

toxicity levels.

3

Lastly, we conducted a categorical analysis

4

of the shifts from baseline based on LDL categories

5

as adapted from the NIH's National Cholesterol

6

Education program. As shown here, we found that a

7

greater proportion of subjects in the F/TAF group

8

had worsening LDL category at week 48 compared to

9

the F/TDF group, 17 versus 10 percent. And

10

conversely, a greater proportion of subjects in the

11

F/TDF group had improvement in the LDL category

12

compared to F/TAF, 40 versus 28 percent,

13

respectively.

14

These findings did not translate into any

15

major differences between the two groups with

16

respect to adverse events, clinical adverse events,

17

such as the cerebrovascular or cardiovascular

18

events, which were very low in the trial anyway.

19

That said, while the proportion of subjects who

20

were on lipid-modifying agents at study entry was

21

balanced between the two arms, a slightly greater

22

proportion of subjects in the F/TAF arm initiated

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1

these agents during the study at 2 percent versus

2

1 percent for the F/TDF arm.

3

In summary, again, both F/TAF and F/TDF were

4

both safe and well tolerated. Differences between

5

the groups were observed for various indices,

6

namely changes from baseline in renal biomarkers,

7

bone mineral density on DEXA scans, and fasting

8

serum lipids, consistent with previous trials that

9

compare TAF to TDF. In general, F/TAF and F/TDF

10

had similar adverse event profiles, including low

11

rates of serious adverse events or adverse events

12

leading to drug discontinuation.

13

I'll now turn to our discussion of the

14

indication for PrEP in cisgender women, but before

15

that, we acknowledged that conducting a trial in

16

women for a PrEP indication is challenging. As you

17

know, previous clinical trials in women have

18

demonstrated variable efficacy of oral F/TDF,

19

mostly driven by adherence it seems. As such, FDA

20

recommends superior designs whenever possible for

21

trials in women because determination of a

22

noninferiority margin is not readily feasible.

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1

In this application, two extrapolation

2

strategies are proposed. One is the extrapolation

3

of F/TAF efficacy from MSM in the DISCOVER trial to

4

support indication in cisgender women. For this,

5

one must demonstrate comparable systemic exposures

6

between men and cisgender women, including

7

tenofovir and TAF concentrations in plasma, as well

8

as tenofovir diphosphate concentrations in the

9

PBMCs.

10

The second approach is to extrapolate

11

efficacy from F/TDF to support F/TAF in women. And

12

as you've heard, this approach makes use of a

13

published EC90 value of 40 femtomole per million

14

PBMCs as derived from the iPrEx trial of F/TDF in

15

MSM. For this approach, one must demonstrate

16

comparable or higher tenofovir diphosphate

17

concentrations in systemic PK but also in cervical

18

vaginal tissue with TAF relative to TDF.

19

With respect to the first approach, we don't

20

expect that there's going to be any clinically

21

relevant differences in the PK of emtricitabine, or

22

TAF, or PBMC-associated tenofovir diphosphate

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1

between men and women. However, for reasons that

2

have been discussed already, matching systemic drug

3

exposures alone may not suffice because of the

4

unknown contribution of mucosal tissue

5

concentrations to PrEP efficacy.

6

For the second approach, where we tried to

7

extrapolate efficacy of F/TDF to support F/TAF,

8

while there's some overlap with the prior approach

9

regarding systemic drug exposures, for this

10

approach, the applicant has cited 40 femtomole of

11

tenofovir diphosphate per million PBMCs as a

12

threshold, or EC90 value, for PrEP efficacy.

13

The two things to consider here, as you've

14

heard, this threshold concentration was associated

15

with adherence to 3 to 4 doses of F/TDF per week,

16

specifically in MSM from the iPrEx trial. Also,

17

this concentration has not been validated as a PK

18

surrogate for tenofovir-based PrEP efficacy for all

19

populations.

20

The concern with relying on this PBMC

21

threshold concentration is that it may not

22

accurately reflect the drug concentrations at the

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1

tissue level. For example, we know that with

2

F/TDF, with multiple dosing, we can achieve this

3

threshold concentration of 40 femtomoles per

4

million PBMCs in a matter of days, about 3 days.

5

And we know that this concentration in PBMCs

6

correlates to a rectal tissue concentration that is

7

greater than the 100 femtomoles per milligram or

8

significantly greater than the lower limit of

9

quantification.

10

In contrast, a single dose of F/TAF can

11

reach this PBMC concentration of 40 femtomoles in a

12

matter of hours, but the vaginal tissue

13

concentration can be reported as below the level of

14

quantification. In both scenarios, we have

15

achieved this threshold concentration that's being

16

proposed as a surrogate in PBMCs with diverse

17

results in relevant tissue concentrations.

18

The more conservative approach is to try to

19

match PK, both systemic and tissue, to support an

20

extrapolation of F/TDF efficacy in cisgender women

21

to F/TAF in the same population. For the systemic

22

part of this extrapolation approach, we already

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1

know that TAF achieves higher levels of tenofovir

2

diphosphate in PBMCs, so we can check that off.

3

With regards to the tissue concentrations,

4

we know that single-dose TAF or TDF results in

5

concentrations that are mostly below the level of

6

quantification in tissue. What we don't know is

7

whether multiple dosing with TAF or TDF achieves

8

different results at the tissue level. And to that

9

end, data from an external study in healthy female

10

volunteers, study A15-137, was submitted to support

11

this latter part of the extrapolation.

12

This is the study design for study A15-137.

13

It was conducted in two parts, including a single

14

dose and multiple dose part where subjects were

15

treated for 14 days with F/TAF or F/TDF. We're

16

going to focus only on the approved doses for F/TAF

17

and F/TDF.

18

Multiple samples were collected for PK and

19

plasma, PBMC, rectal and cervical vaginal fluid, as

20

well as tissue biopsies, and we're going to focus

21

on the results for the rectal cervical and vaginal

22

tissue biopsies here, and in particular the

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1

evaluations for tenofovir diphosphate

2

concentrations.

3

I will also note one thing about this

4

particular study design is that each woman

5

contributed cervical vaginal tissue samples at only

6

one given time point, and that's because tissue

7

samples were collected at different clinical sites

8

at different time points. Rectal tissues were

9

collected 4 hours post dose following 14-day

10

administration. Cervical vaginal tissues were

11

collected at 4 hours post-dose following

12

single-dose administration, as well as 4, 24, and

13

48 hours following 14-day administration.

14

The measurement in this study were tissue

15

homogenates, and assuming a tissue density of

16

1 gram per mL, final sample concentrations in the

17

lower limit of quantitation of 0.3 nanograms per mL

18

were converted to fmol/grams for tenofovir

19

diphosphate.

20

Here are the results that we obtained.

21

Following single-dose administration of F/TAF or

22

F/TDF, 83 percent of vaginal tissue samples were

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1

below the lower limit of quantitation, or BLQ, at 4

2

hours. Following multiple doses of F/TAF or F/TDF,

3

a significant proportion of tissue PK samples were

4

also BLQ.

5

In vaginal tissues, tenofovir diphosphate

6

concentrations were higher for oral F/TAF dosing

7

compared to F/TDF only at 4 hours post-dose, but

8

they were mostly unquantifiable at 24 and 48 hours.

9

It is unclear if this isolated finding at 4 hours

10

translates to comparable or higher tenofovir

11

diphosphate concentrations in vaginal tissues

12

beyond 4 hours after multiple dose administration.

13

This table represents the results from the

14

multiple dose part of the study. It's a busy

15

study, so I'll try to walk you through it. If you

16

look at the first row, the 4-hour row and at the

17

column for F/TDF, you'll see that 62 percent of

18

vaginal tissue samples in the F/TDF arm were below

19

the level of quantification. In contrast, none of

20

the tissues in the F/TAF arm were BLQ.

21

Correspondingly, a median tenofovir diphosphate

22

concentration was calculated at 151 femtomoles per

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1

milligram.

2

Similar results were seen with cervical

3

tissue biopsies, and as for the rectal tissue, the

4

results confirmed the previous reports that dosing

5

with oral F/TDF results in higher tenofovir

6

diphosphate concentrations in rectal tissue

7

compared to F/TAF dosing.

8

However, for 24 hours and 48 hours, the

9

majority of the tissue samples for the vaginal and

10

cervical tissues were below the level of

11

quantification, and we were not able to determine a

12

median tenofovir diphosphate level for these

13

tissues with any degree of confidence.

14

In conclusion, F/TAF and F/TDF afford

15

similar protection against sexual acquisition of

16

HIV-1 infection in MSM and transgender women at

17

substantial risk. Both F/TAF and F/TDF are safe

18

and well tolerated. F/TAF dosing results in

19

smaller changes or improvements from baseline in

20

biomarkers of proteinuria and bone mineral density

21

compared to F/TDF, but with less favorable lipid

22

changes. No major differences were noted with

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1

respect to the side effect profile during the

2

course of this study.

3

However, clinical data regarding the use of

4

F/TAF for PrEP in cisgender women are lacking.

5

Robust tenofovir diphosphate concentration data in

6

the female genital tract are lacking. This

7

application proposes a PrEP indication in cisgender

8

women based on extrapolation of efficacy data via

9

tenofovir diphosphate concentrations and peripheral

10

blood mononuclear cells. However, the relative

11

importance of mucosal tissue versus systemic drug

12

concentrations to PrEP efficacy remains unknown.

13

That concludes my presentation, and I'll

14

take any clarifying questions from the committee.

15

Clarifying Questions

16

DR. BADEN: Thank you.

17

We will now take clarifying questions for

18

the agency's presentation, and I think

19

Dr. Daskalakis has the first question.

20

DR. DASKALAKIS: Peter, thanks for that

21

presentation. Just a question that may also

22

overlap with a question to the sponsor. You state

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1

that there's evidence that TAF/FTC is effective in

2

preventing HIV in MSM and transgender women, but

3

we've never actually seen the transgender female

4

data broken out in any way.

5

Do you have a sense of what that really

6

looks like or is that a better question to defer to

7

the sponsor?

8

DR. MIELE: What I can say, and the

9

applicant is free to chime in, first, there was a

10

very small proportion of transgender women

11

enrolled. I believe about 30 percent dropped out

12

early during the course of the trial. None of the

13

HIV infections were seen in the transgender women.

14

Beyond that, I can't really say too much.

15

DR. DASKALAKIS: And a related question, any

16

pharmacokinetic data on tenofovir and TAF versus

17

TDF, versus Truvada, in regards to whether any of

18

those transwomen were using estrogen?

19

DR. MIELE: I will defer to the applicant as

20

to concomitant medications being used by the

21

transgender women in the study. We have seen

22

reports about the effect of PrEP with feminizing

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1

hormone therapy, TAF, but no clinical drug

2

interaction studies have been conducted with TAF

3

and feminizing regimens.

4

I don't know if our clinical pharmacology

5

reviewer would like to discuss this topic further.

6

DR. ZHENG: Yes. There's no clinical drug

7

interaction study that's being conducted with TAF

8

and feminizing regimens, CYP-based drug

9

interactions are likely to be minimal. However,

10

some studies suggest that the estrogen can change

11

phosphorylation and the phosphorylation of

12

leukocytes and their analogs.

13

The study conducted with TDF in transgender

14

women receiving feminizing regimens, the paper

15

published recently by Dr. Cottrell, showing minimum

16

changes in plasma tenofovir concentrations for the

17

transgender woman and minimal changes in tenofovir

18

diphosphate concentration in PBMC for rectal tissue

19

as well.

20

The similar dATP to cisgender men, there was

21

significantly higher dATP in rectal tissues as

22

compared to ciswomen. We know that dATP may lower

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1

effective concentration of tenofovir diphosphate in

2

rectal tissues. The sample size is very small, so

3

it seems like the study shows that the lower

4

concentration of tenofovir diphosphate is mostly

5

driven by the higher dATP levels in rectal tissue,

6

but we don't have any data for TAF. I don't know

7

if the sponsor has more to add.

8

DR. BADEN: One second, Dr. Daskalakis. I

9

would ask the applicant -- this is clarifying

10

questions to the agency. We realize the applicant

11

has important data in that space. So if you can

12

keep a list of these questions, then we will come

13

back and engage your data set after we clarify with

14

the agency.

15

Do you have further --

16

DR. DASKALAKIS: I'll hold for that.

17

DR. BADEN: No other follow-on. Then,

18

Dr. Green?

19

DR. GREEN: This is not a follow-on.

20

DR. BADEN: Correct.

21

DR. GREEN: Thank you. If we could see your

22

slide 46 again. I just want to make sure I

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1

understand it. It was I think the last slide you

2

gave in your presentation, the one that you

3

described as complicated.

4

Now, my question is, simplistically for

5

percent BLQ, you want it to be lower because that's

6

the percentage, below the level that's quantified.

7

It's not really telling us what level is present;

8

it's just whether anything can be quantified or

9

not. And if I'm looking at this correctly -- I

10

just want to make sure I'm reading this

11

correctly -- I see that at 4 hours that F/TAF in

12

the vagina appears to be better than F/TDF, and in

13

cervical tissue, it appears to be better.

14

Then at 24 hours, F/TAF is not as good, but

15

neither one of them are very good in both

16

vaginal -- and it flips because it's better in

17

cervical, but neither one's very good. And at

18

48 hours, basically they all are not good. But

19

we're also demonstrating here that F/TDF doesn't

20

have that level of protection over time either.

21

So if mucosal levels are important, this

22

slide does not demonstrate that because you're not

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1

seeing a difference that benefits F/TDF, which

2

already has a drug indication and has been shown to

3

be efficacious. Is that correct?

4

DR. MIELE: I don't know that we can say

5

that one is better than the other. The tissue

6

samples are just not quantifiable, so we can't

7

really say much of anything about that. But I

8

agree with you that the TDF samples were also not

9

showing much. And it may be an issue with the

10

assay. It may be the cutoffs that we used to

11

determine quantifiable.

12

Again, I don't know if the clin/pharm

13

reviewer has any other input here.

14

DR. ZHENG: Backup slide with the LLQ

15

question.

16

DR. HOTAKI: Can you tell me which number it

17

is?

18

DR. ZHENG: Slide 79. Oh, no, slide 80.

19

You can see the published study used

20

compatible units for the lower limit of

21

quantitations, and some are using a femtomole

22

sample or nanogram per mL, which makes it difficult

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1

to compare assays sensitivities across studies.

2

In this, A15-137, we have a higher LLQ

3

compared to other study reported. The difference

4

in LLQ can be due to tissue biopsy size, and

5

because it's converted from the nanogram per mL to

6

femtomole per gram, so you have a smaller sample

7

size, it's more possible to have the LLQ values.

8

Also related to the sample storages,

9

stability, and some of those studies may not have

10

the long-term stability data, and also recovery

11

efficiencies, and also the assay sensitivity. So

12

it's probably related to, also, the assay

13

sensitivity, also has other issues.

14

DR. BADEN: Dr. Siberry, a follow-on?

15

DR. SIBERRY: Thanks very much. In thinking

16

about this problem of understanding whether the

17

drug levels in the genital compartment are the

18

actual proxy for protection, have you looked at the

19

trials where the only difference in treatment was

20

TAF and TDF in women to see if there was any

21

difference in plasma genital discordance and

22

suppression?

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1

We know that some women who are on

2

suppressive therapy still can have HIV present in

3

the genital tract, and that may be an additional

4

way to get at a differential impact of TAF versus

5

TDF in the genital compartment.

6

Then just a follow-on, can you comment from

7

the agency perspective about how we should view the

8

appropriateness of an application for a drug that

9

intended all the while to have an indication in men

10

and women, coming in with clinical trial data only

11

for men with an expectation to apply to women? I'm

12

just concerned because often women are excluded

13

because of concerns about fetal safety and possible

14

pregnancy and other reasons, and this feels to me

15

like a potentially concerning precedent. Thanks.

16

DR. MIELE: To your first question, we have

17

not looked at that data. You're talking about an

18

HIV treatment. We have not looked at that data, at

19

least I'm not aware if the company has that

20

information, but we have not.

21

Second question, ideally, the agency would

22

like to see clinical trials in the populations for

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1

which labeling is going to be indicated. We

2

recognize that conducting trials in women in the

3

current landscape with Truvada approved is

4

challenging. I think our first initial hurdle was

5

to agree on a trial, period; and that ultimately

6

was decided to be conducted in MSM and transgender

7

women.

8

Discussions about a trial in women were had

9

with the applicant. And again, we noticed that

10

there were challenges and difficulties, and the

11

agency itself was struggling with the appropriate

12

study design to recommend for this population. But

13

it was never really agreed upon that this

14

particular application, the way it appeared, would

15

support the indications that are being requested.

16

So at this point we're trying to work with

17

what was submitted to see if we can justify an

18

indication across the populations based on a study

19

that was conducted in one particular population.

20

But going forward, no; we're were not recommending

21

this particular approach. And again, as Dr. Murray

22

noted, this particular case is unique because we're

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1

talking about basically two prodrugs or the same

2

drug, and we have an approved drug already for

3

Truvada in all those populations. But ordinarily

4

we would not rely on a single trial in one

5

population to support an indication across multiple

6

populations.

7

DR. BADEN: Dr. Siberry got two questions in

8

there, and I have two follow-ons, one for each of

9

his questions.

10

Given your review of the sum total of the

11

data, what is your impression, or the agency's

12

impression, of a marker of protection in the

13

vaginal compartment? Has that emerged or is that

14

still unclear given the state of the data?

15

DR. MIELE: I think that remains very much

16

unclear. I also want to emphasize that it's not a

17

one or other. It's not necessarily mucosal tissue

18

versus systemic. There may be a contribution of

19

both going on here, and that's the part we don't

20

understand.

21

If vaginal tissue concentrations are

22

relevant, are they acting as the primary line of

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1

defense, and is systemic acting as a backup? I

2

think that was a theory that was floated by

3

Dr. Anderson actually. But we don't know at this

4

point. The only thing we can measure are these

5

tissue homogenates. Some studies have looked at

6

mononuclear cells within the vaginal tissues

7

themselves and have had mixed results with respect

8

to differences with the vaginal compartment and the

9

rectal compartment. I think the field itself, at

10

least to us, is a bit mixed or conflicted. So that

11

first question you asked is very much unclear in my

12

opinion.

13

DR. BADEN: Part of the challenge -- and

14

other members of the committee have mentioned this,

15

and I'll ask this of the applicant as well

16

later -- the vaginal compartment, there are

17

menstrual cycle issues, microbiome issues,

18

behavioral issues that are different than other

19

compartments, and it may be adherence or PBMC

20

concentration that may be all that matters, or

21

there may be an interaction with these other

22

factors.

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1

Trying to understand from the data available

2

to determine if perhaps adherence is all we need,

3

which is in part what's being suggested, still I am

4

struck by VOICE and the other trials that did not

5

show even results in protection, although there are

6

explanations. It always worries me when there are

7

lots of explanations and were asked to embrace the

8

positive but not worry about the negative, and then

9

assume that it should just work the way we want it

10

to.

11

So I guess my question is, should we just

12

assume the vaginal compartment is an extension of

13

the systemic component, in this setting? And

14

obviously, this will be asked of the applicant

15

later, which is building on the conversation we've

16

been having for an hour or two.

17

DR. MIELE: I think it would be challenging

18

to do that given that we know that the

19

pharmacokinetics are very different between TAF and

20

TDF, and I think part of that difference that we

21

see systemically may be extending to the

22

compartments in question, for various reasons. TDF

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1

itself may be cycling in the GI tract and achieve a

2

high protection in the rectal tissue, for example.

3

I don't know that we can confidently say that we

4

can extend the systemic to tell us what's going on

5

in the vaginal tissue.

6

DR. BADEN: My other follow-on I will take

7

in a minute. I will continue to follow on, on this

8

line of questioning.

9

Dr. Ofotokun?

10

DR. OFOTOKUN: Kind of along this line of

11

discussion was the significance of the time for

12

achieving protective concentration. That was

13

different for TDF, for different populations. It

14

was different for men and also different for women

15

from what we saw. And I think the guidelines vary

16

from state and different regions of the country

17

based on this time to achieve a protective

18

concentration for TDF.

19

Do we have a sense of that variability with

20

TAF?

21

DR. MIELE: I'll say this. I think the

22

guidelines are being conservative because of this

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1

uncertainty around the role of tissue

2

concentration. I think CDC has presented the data

3

for prescribers to be aware of, and then some state

4

guidelines have pushed that even further into

5

actual prescribing recommendations.

6

Again, I think in the services trying to be

7

the most conservative, for TAF, we don't have any

8

information like that. It really depends on

9

whether you believe that systemic PK is the driver

10

of protection, in which case you probably don't

11

need this lead-in time. But if you believe at all

12

that tissue may be contributing to PrEP efficacy, I

13

don't think we have any data to even help us with

14

what's going on with TAF, at least in the vaginal

15

tissue.

16

DR. BADEN: Dr. Swaminathan?

17

DR. SWAMINATHAN: These are drugs that stop

18

viral replication; they're not disinfectants. So

19

the applicant's very valid points that it's T cells

20

that are the issue, is it really useful to look at

21

drug concentrations of homogenates of biopsies,

22

which are primarily everything but lymphocytes?

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1

DR. MIELE: Well, in retrospect, probably

2

not. Going into this, what we had were these

3

single reports out there that were surprising I

4

think to the community that TAF was acting so

5

differently in local tissue compartments. And it's

6

probably what drove us to be conservative and

7

request a clinical trial to begin with.

8

If it had been established that systemic PK

9

were the main driver, we probably didn't need the

10

DISCOVER trial and 5,000 men. But there was a fair

11

amount of uncertainty, as I've tried to describe to

12

you, both in the literature and in the guidelines,

13

so the trial was conducted.

14

Now, I will say this. Granted, rectal

15

tissue concentrations with TAF are lower compared

16

to TDF, and the DISCOVER trial shows comparable

17

efficacy results regardless, but we don't know what

18

the minimum concentration would be. It may be that

19

whatever concentration is being achieved with TAF

20

and rectal tissue may suffice; we don't know.

21

But you're right. I don't know that tissue

22

homogenates is really the best measure to give us

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1

valuable information at this point. I don't know.

2

DR. BADEN: Dr. Giordano?

3

DR. GIORDANO: Switching topics a little

4

bit, you mentioned the idea that penile

5

transmission or acquisition seemed reasonably

6

protected against here. Did the sponsor gather

7

data on types of sex? Is there any signal that the

8

acquisition was more likely in men who reported

9

anal receptive versus anal insertive, or was there

10

so much overlap between the two in any single

11

person that you can't distinguish that?

12

DR. MIELE: My impression is that within

13

each individual, there's a variety of sexual

14

practices such that we can't really decipher

15

whether there was a subgroup that was strictly

16

practicing insertive sex. I believe pretty much

17

all of the HIV seroconverters were practicing anal

18

receptive intercourse. But that said, some of them

19

also had reports of insertive sex in there.

20

There were individuals who reported -- for

21

the most part, insertive sex had showed up with

22

rectal STIs. And again, all these reports are

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1

self-reported in the patient diaries. Like I said,

2

I don't think we have any direct evidence. Given

3

the low number of HIV infections, and the fact that

4

we presume that a lot of these individuals were

5

practicing insertive sex, that the protection

6

probably did confer to them as well.

7

DR. BADEN: Dr. Daskalakis, a follow-on?

8

DR. DASKALAKIS: Just a brief follow-up,

9

again, for clarification on this issue. If I

10

remember, I think about 60 something percent of the

11

folks in the DISCOVER trial were uncircumcised.

12

Any special circumcision signal

13

with seroconversion?

14

DR. MIELE: No. It was 44 percent.

15

DR. DASKALAKIS: Forty-four; sorry. I knew

16

it was high.

17

DR. MIELE: Yes. No, in terms of baseline

18

characteristics and HIV infection, we didn't see

19

any real correlation.

20

DR. DASKALAKIS: I do remember the

21

confidence interval for outside the U.S. was a lot

22

higher. Is circumcision at all involved in that?

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1

DR. MIELE: I have to defer to our

2

statistician if you recall anything.

3

DR. BADEN: Please state your name at the

4

microphone.

5

DR. ZENG: Wen Zeng, statistical reviewer

6

for this NDA. For the subgroup analysis, I think

7

the sponsor already presented. There's no such

8

baseline characters that have a great impact on the

9

final result.

10

DR. BADEN: Follow-on? Not a follow-on, a

11

new topic.

12

Dr. Daskalakis, a new topic?

13

DR. DASKALAKIS: Yes, just a question about

14

a citation that you had in your briefing document

15

is a meta-analysis by Hale et al., that compares

16

TDF, that compares tenofovir, and Truvada versus

17

Descovy. Then subsequently, the safety data

18

presented talks about statistically significant

19

margins of safety.

20

Are any of these, from your perspective,

21

clinically significant?

22

DR. MIELE: I think in the clinical setting

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1

probably not, but over the long term they might be.

2

I think the current average use of PrEP at this

3

point is 6 to 12 months.

4

DR. DASKALAKIS: Just again, a quick

5

follow-up on that.

6

DR. MIELE: Anyway, no. We didn't see

7

anything different between the two arms in terms of

8

clinical events.

9

DR. DASKALAKIS: If you stratify the bone

10

and kidney complications or adverse events by age,

11

is there anything that sort of flushes out in terms

12

of just being more common among older adults?

13

Because there are some 60 year olds and 50 year

14

olds in the study.

15

DR. MIELE: There were a small number of

16

older participants. We didn't see any differences

17

come up on either end of the age spectrum.

18

DR. DASKALAKIS: Great. Thank you.

19

DR. BADEN: Dr Goetz?

20

DR. GOETZ: My question relates to the

21

nature of risk in the patient population and the

22

expected rate of HIV in the patient population. I

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1

know the study was projected at a rate of infection

2

that was somewhat higher. I wonder if someone from

3

the agency could run through the calculations that

4

predict what the expected rate of HIV infection was

5

in the absence of a prophylaxis.

6

Taking to the extreme, if the study is done

7

in a low-risk patient population, of course, no

8

infections are expected, and the two agents perform

9

similarly. So having confidence of the projections

10

of what the expected rate of infection is, I think

11

is an important consideration.

12

DR. MIELE: Do you mean without PrEP? This

13

wasn't a placebo-controlled trial, so to that end,

14

I think you're asking how would this compare. I

15

think the applicant did do a comparison to local

16

geographic areas in the U.S. based on

17

epidemiological data, looking at concurrent HIV

18

incidence in MSM not on PrEP. I think there were 4

19

to 5 incidents per 100 person-years. At least in

20

the U.S. population of MSM, in the geographical

21

areas where this study was conducted, the incidence

22

was much higher.

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1

DR. BADEN: And the STI rate, how does that

2

influence your thinking of being in a high-risk

3

population?

4

DR. MIELE: Dr. Murray has published a meta-

5

analysis looking at various PrEP trials, and trying

6

to correlate the STI rate, at least for rectal

7

gonorrhea and what the predicted HIV incidence

8

would be, as you heard, there was actually a high

9

amount of STIs going on in this trial. And based

10

on the correlations that we've looked at, that

11

should have correlated to an HIV incidence, I

12

believe, of 6; so a much higher incidence.

13

DR. BADEN: Six what? Six of a thousand?

14

DR. MIELE: Six per hundred.

15

DR. BADEN: Okay. So 10-fold higher.

16

DR. MIELE: Much higher.

17

DR. BADEN: If no other follow-ons, then I

18

have another follow-on to Dr. Siberry's earlier

19

comment. The issue of a trial in cisgender women,

20

you mentioned that it was hard to come up with a

21

noninferiority margin. Can you help us understand,

22

does that mean it's not possible or how would you

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1

frame a -- could that have been done or what might

2

it look like for us to understand the challenges in

3

a more fully powered trial?

4

DR. MIELE: The challenge is that we have

5

two trials that essentially showed no effect in

6

women, VOICE and FEM-PrEP. Then we have one trial,

7

the Partners PrEP trial. That did show

8

statistically significant protection, the TDF2

9

trial I don't think was powered for efficacy but

10

did show a point estimate that favored efficacy in

11

women.

12

So when you have such divergent results from

13

the historical trials, I think it becomes a

14

challenge to try to come up with an NI margin. I

15

don't know if the statisticians want to discuss

16

this any further, but that is basically -- the main

17

conundrum is that we would not be able to

18

adequately construct an NI margin with such

19

divergent variety in previous trials.

20

DR. BADEN: So in the MSM trans population,

21

where we have consistent results with Truvad, then

22

it's easier to design a trial that shows consistent

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1

results.

2

DR. MIELE: Exactly.

3

DR. BADEN: And in cisgender women, where

4

the data are very uneven, it's difficult to have a

5

trial, but we should assume that it should work.

6

I'm just trying to follow the logic that's being

7

put before us.

8

DR. MIELE: I think a strict NI margin, a

9

noninferiority trial, would be difficult to

10

construct. That said, there might be other

11

possible study designs such as comparisons to local

12

HIV incidence in the population of study and the

13

community it studied. These are novel study

14

designs that we're grappling with ourselves in the

15

agency, given that we have a product on the market

16

that is highly effective.

17

DR. BADEN: Dr. Gripshover?

18

DR. GRIPSHOVER: What about a switch study?

19

Is that something that the FDA would consider it

20

would be appropriate? So if we have women who are

21

already taking Truvada for PrEP, would that be a

22

study design that could be considered flipping half

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1

to TAF and going forward? You may not have a high

2

incidence rate, but at least you're comparing it to

3

an already approved drug.

4

I'm curious what the agency would think if

5

that's a study design that would work since you

6

don't have a noninferior number.

7

DR. MIELE: Yes. I don't know what the

8

comparison would be in a switch study other than

9

safety. We haven't really considered a switch

10

study for a registrational study.

11

DR. BADEN: Dr. Green?

12

DR. GREEN: This is a direct follow-on. You

13

can't easily come up with a strategy to give a

14

noninferiority study, but there's no reason to

15

presume that if you did a head to head, that it

16

would be superior. And it also seems like it would

17

be unethical to do a placebo study.

18

So you may be telling us that we're back to

19

the argument of the sponsor, that there's no

20

feasible way to assess it, so we have no choice but

21

to make a decision using extrapolation. I don't

22

know if that's your intent to say, but I'm hearing

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1

that at least. Tell me why that's not true.

2

DR. MIELE: No. I think you've hit the nail

3

on the head. The question is how confident do we

4

feel that an extrapolation approach would be

5

reasonable to extend the indication. At this

6

point, we haven't really discussed any other

7

alternative study design, so that may still be on

8

the table. But where we are right now is you're

9

right. And it's not a question of whether we think

10

this is appropriate, but whether in the absence of

11

other supporting data, we feel confident that this

12

might work.

13

DR. BADEN: Dr. Ofotokun?

14

DR. OFOTOKUN: I don't seem to buy the

15

argument that we cannot construct an inferiority

16

margin around the data that we currently have for

17

women because we know from looking at the data, and

18

all the four studies in PrEP in women, the reason

19

that those studies, where efficacy was not

20

demonstrated was that way because of poor

21

adherence.

22

So in studies where women took those drugs,

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1

the drug was effective, and we can construct a

2

margin around those studied. There's nothing that

3

says that you have to include all the studies that

4

have ever been done in order to construct an

5

inferiority margin in the study design. I remember

6

when the sponsor represented, they had a series of

7

planned studies in women. So how are they planning

8

to do that, if it's going to be impossible to have

9

what is a sample size calculation for studies in

10

women?

11

DR. MIELE: I'll answer your second part

12

first. We have not seen any of these proposals in

13

the agency that the applicant has proposed. We

14

have not seen any protocols. My understanding is

15

that these aren't going to be powered for efficacy

16

comparisons. They may be safety demonstration

17

projects.

18

To your first question, I think I'll defer

19

to our statistician colleague about constructing an

20

NI margin using just a select number of trials.

21

DR. BADEN: Please state your name.

22

DR. VALAPPIL: Yes. My name is Thamban

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1

Valappil. I'm team leader for statistics. Based

2

on the noninferiority guidance document that has

3

been published, you need to have a clear evidence

4

of treatment effect historically, meaning

5

that -- especially for this population, there is no

6

treatment effect compared to placebo. Both the

7

studies have failed.

8

So unless you have a measurable treatment

9

effect based on historical trials, you won't be

10

able to construct a noninferiority margin. So the

11

compliance or the adherence cannot be adjusted to

12

be able to look at the margin if the plans have

13

already failed.

14

DR. BADEN: Dr. Smith, you have a follow-on?

15

DR. SMITH: Yes. There's a lot of work

16

going on to develop new agents for PrEP, for

17

pre-exposure prophylaxis, and it's not clear to me

18

whether you're saying that from now on, no studies

19

will be done in women because we can't define the

20

margin, and therefore we can't do a noninferiority

21

trial.

22

The current PrEP is so effective, I don't

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1

understand what the implications of this decision

2

are for future trials. Given that, it may be

3

difficult to find a high incidence population of

4

women in the U.S. It's certainly not the case in

5

the developing world, and I think, in fact, in the

6

world at large, women are the largest number of new

7

infections.

8

So the need for effective prevention options

9

for women is even greater than for MSM, although

10

not in this country. So if we're saying from now

11

on that we'll do the studies in men and we'll do

12

some PK studies to extrapolate to women, that

13

doesn't sound like a good scientific approach. So

14

I'm trying to understand the boundaries that you're

15

drawing around this argument here and how that will

16

apply in the future.

17

DR. MIELE: Yes, Dawn, we're not saying that

18

at all. There is a path forward in terms of

19

superiority designs. A lot of new agents that are

20

being developed for PrEP are not necessarily

21

once-a-day pills. The challenge here is we have

22

two drugs that are very similar in terms of their

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1

route of administration and their dosage.

2

If you're looking at long-acting agents, for

3

example, you can do a superiority trial, so that's

4

what we've been advocating. Again, like I said,

5

this is a particular circumstance here that is

6

complicated because we have two very similar

7

products. But no, this PK extrapolation that's

8

being proposed is not meant to be precedence

9

setting for future trials in women at all.

10

DR. BADEN: We do need to remember that the

11

business at hand is the current application. There

12

are broader questions that I think are appropriate

13

for us to highlight, as we've been doing, to set

14

the stage for data in the future that are needed to

15

make informed choices. So your points are very

16

well taken. I'm not sure we'll resolve agency

17

policy going forward, but I think the points have

18

been heard.

19

Dr. Goetz, did you have a follow-on?

20

(Dr. Goetz gestures no.)

21

DR. BADEN: Dr. Giordano?

22

DR. GIORDANO: Can you clarify from the

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1

agency's perspective how much of a study needs to

2

be done in the U.S. versus abroad to achieve an

3

indication?

4

DR. MIELE: The guidance suggests we can

5

accept clinical data from foreign studies if the

6

sponsor has provided a justification or rationale

7

why that data are applicable to a U.S. population.

8

In this case, 60 percent of the subjects were in

9

the U.S., so I think we're covered.

10

I mean, it's not that preponderance of

11

foreign data here. But for PrEP in general, for

12

example, for women where most of these studies will

13

be conducted ex-U.S., the mechanism of transmission

14

of HIV and the mechanism of action for the drug

15

should be the same regardless of the geographical

16

populations.

17

DR. BADEN: Other questions for the agency

18

about their presentation and their analyses of the

19

data submitted?

20

(No response.)

21

DR. BADEN: If not, it is 12:20, and 12:25

22

is when we're supposed to take a break. I don't

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1

think we have enough time to delve into another

2

line of questioning, but to the applicant, I think

3

you've heard issues around, and perhaps after we'll

4

do the open public session, and then we'll come

5

back to clarifying questions to the applicant.

6

Crisp data on the efficacy in trans and

7

crisp data on the insertive male partner, if you

8

have it, were some of the issues raised that I

9

think you have the data, and it would be just great

10

for the committee to see.

11

Comments around the design issue in the

12

cisgender female, which have come up, I think would

13

be very helpful for the committee to hear your

14

thoughts on that. You've touched on them, but I

15

think they're central to our discussion. Then

16

after lunch, we'll have the open public hearing

17

session, and then resume the discussion with the

18

applicant and the agency, but I think the agency

19

has finished their clarifying component.

20

So we will now take a break for lunch.

21

We'll reconvene again in this room at 1:30 sharp.

22

Please take any personal belongings you may want

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1

with you at this time. Committee members, please

2

remember that there should be no discussion of the

3

meeting during lunch amongst yourselves, the press,

4

or any member of the audience. Thank you.

5

(Whereupon, at 12:20 p.m., a lunch recess

6

was taken.)

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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1

AFTERNOON SESSION

2

(1:30 p.m.)

3

Open Public Hearing

4

DR. BADEN: It is now 1:30, and we shall

5

resume. This is now the open public hearing part

6

of the meeting.

7

Both the FDA and the public believe in a

8

transparent process for information gathering and

9

decision making. To ensure such transparency at

10

the open public hearing session of the advisory

11

committee meeting, FDA believes that it is

12

important to understand the context of an

13

individual's presentation.

14

For this reason, FDA encourages you, the

15

open public hearing speaker, at the beginning of

16

your written or oral statement to advise the

17

committee of any financial relationship that you

18

may have related to the topic of the meeting.

19

Likewise, FDA encourages you at the

20

beginning of your statement to advise the committee

21

if you do not have any such financial

22

relationships. If you choose not to address this

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1

issue of financial relationships at the beginning

2

of your statement, it will not preclude you from

3

speaking.

4

The FDA and this committee place great

5

importance in the open public hearing process. The

6

insights and comments provided can help the agency

7

and this committee in their consideration of the

8

issues before them. That said, in many instances

9

and for many topics, there will be a variety of

10

opinions.

11

One of our goals today is for this open

12

public hearing to be conducted in a fair and open

13

way, where every participant is listened to

14

carefully and treated with dignity, courtesy, and

15

respect. Therefore, please speak only when

16

recognized by the chairperson. Thank you for your

17

cooperation.

18

Will speaker number 1 step up to the podium

19

and introduce yourself? Please state your name and

20

any organization that you're representing for the

21

record.

22

DR. HALL: Christopher Hall, San Francisco

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1

AIDS Foundation. Good afternoon. In my capacity

2

as vice president of medical affairs for the San

3

Francisco AIDS Foundation, I oversee the provision

4

of HIV pre-exposure prophylaxis through SFAF sexual

5

health clinic, serving populations at high risk for

6

HIV acquisition. Sorry. My disclosures are listed

7

in the previous slide. Thank you.

8

To date, these programs have prescribed

9

Truvada for PrEP to over 5,080 individuals. I will

10

present our position in support of the proposed

11

supplemental NDA by Gilead Sciences for the

12

fixed-dose combination of emtricitabine and

13

tenofovir alafenamide, which I will hereby refer to

14

as F/TAF for HIV PrEP.

15

We believe that FDA approval of F/TAF as an

16

additional PrEP option will expand the number of

17

individuals who will choose to use PrEP as an HIV

18

prevention method. And furthermore, F/TAF for PrEP

19

will allow centers like the ones we operate to

20

enroll more clients, especially those at higher

21

risk for HIV acquisition.

22

Before I continue, for transparency, I will

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1

state that where SFAF has received programmatic

2

support from Gilead, accounting for less than 4

3

percent of its total annual revenues in the last

4

fiscal year, 3 percent of which are programmatic

5

and 1 percent are research-related, this statement

6

is derived in my own professional medical review in

7

the position of the foundation leadership, and has

8

in no way been influenced by Gilead or its staff.

9

SFAF enrolled 59 participants in the

10

DISCOVER trial through May 2017. We understand

11

that early results demonstrate a very low incidence

12

of HIV in both treatment arms, only 7 infections in

13

the F/TAF group and 15 in the Truvada group. Thus,

14

we do not draw the conclusion that F/TAF is better

15

than Truvada but agree that it is shown to be at

16

least as good as Truvada for preventing HIV.

17

In addition, preliminary DISCOVER data

18

suggests better renal and bone outcomes for those

19

participants on F/TAF, that we agree with the

20

interpretation that such improved outcomes are

21

likely marginal in significance. Yet, based on

22

remote and recent understanding of motivators for

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1

PrEP engagement, we believe individuals at risk for

2

HIV, including those most at risk such as black and

3

Latino persons, may be more likely to engage with

4

PrEP, as more agents with improved side effect

5

profiles are available for approved use.

6

Additionally, F/TAF offers a PrEP

7

alternative for those who have compromised renal

8

function who cannot use Truvada for PrEP. As 12

9

percent of our PrEP patients are over 50 and thus

10

more likely to present with comorbidities,

11

including preexisting renal compromise or

12

osteopenia, an agent with a marginally better side

13

effect profile may promote engagement, and in fact

14

be meaningfully safer.

15

A strategic priority of the foundation is to

16

center its prep services on communities

17

disproportionately faced with alarming HIV

18

incidence rates, and this includes Black Americans.

19

Our recent efforts enrolling such persons on PrEP

20

have demonstrated the need for new approaches and

21

tools.

22

As black and African Americans face over

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1

3 times the rate of kidney failure in the U.S.

2

compared to Caucasians, choice of a PrEP agent with

3

a marginally improved renal safety profile may

4

predispose engagement based on both real and

5

perceived advantages.

6

The approval of F/TAF may also enhance

7

programmatic capacity to provide expanded PrEP

8

services at CBOs like ours. PrEP service delivery

9

is affected by local and/or other structural

10

factors such as depicted hopefully here.

11

Innovation of an express model of STI

12

screening supporting clinical PrEP follow-ups, in

13

2018 facilitated sustained increases in our program

14

capacity and was associated with an approximate 30

15

percent increase in the number of active PrEP

16

patients.

17

Clinical management of PrEP patients using

18

Truvada requires renal function and monitoring,

19

including a baseline check and others every 3 to

20

6 months. In our setting, that includes confirming

21

creatinine elevations with a secondary point of

22

care assay, and in some cases scheduling earlier

A Matter of Record (301) 890-4188

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1

and/or closer follow-up for those evidencing such

2

elevations. In the last year, for example, 1 in 15

3

clients required additional laboratory tests and/or

4

intensive follow-up while on Truvada.

5

With conventional use of F/TAF as an

6

antiretroviral, a lower threshold of diminished

7

renal function is tolerated before recommended

8

discontinuation. We believe that we can project a

9

more streamlined renal function monitoring

10

algorithm with use of F/TAF for PrEP, and in turn

11

an ability to follow more individuals on PrEP with

12

decreased laboratory expenditures, less intensive

13

lab monitoring, and fewer staff resources dedicated

14

to closer follow-up demanded by present use of

15

Truvada alone.

16

With all other circumstances held unchanged,

17

F/TAF, if approved for use and prescribed for a

18

portion of our PrEP patients, we project a future

19

internal PrEP capacity increased based on these

20

renal monitoring factors alone such that we can

21

enroll and follow an estimated 10 to 15 percent

22

more individuals on PrEP in the first year.

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1

Features of U.S. PrEP programs vary, but the

2

foundation believes that the impact of F/TAF's

3

introduction as the second FDA-approved agent

4

indicated for PrEP will lead to meaningfully

5

enhanced capacity to reach more individuals in need

6

of this proven biomedical HIV prevention

7

intervention, especially African American, Latino

8

individuals served by the foundation, and

9

elsewhere. Thank you for your time and attention.

10

DR. BADEN: Thank you. Will speaker number

11

2 step up to the podium and introduce yourself?

12

Please state your name and any organization you're

13

representing for the record.

14

DR. FOX-RAWLINGS: Thank you for the

15

opportunity to speak today on behalf of the

16

National Center for Health Research. I am

17

Dr. Stephanie Fox-Rawlings. Our center analyzes

18

scientific and medical data to provide objective

19

health information to patients, health

20

professionals, and policymakers. We do not accept

21

funding from drug or medical device companies, so I

22

have no conflicts of interest.

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1

A new treatment to prevent HIV infection

2

could be beneficial considering the safety concerns

3

of the currently available PrEP treatment.

4

However, Descovy would only provide benefit if it

5

is at least as effective and safe as Truvada for

6

each population for which it is indicated.

7

Otherwise, users could be at an unnecessarily

8

increased risk for HIV.

9

The DISCOVER trial found similar rates of

10

protection against HIV infection among participants

11

taking both drugs. While the trial seems well

12

designed to demonstrate comparable effectiveness of

13

these two drugs, it is still a single trial.

14

Replication is a key to scientific evidence, and

15

independent trials could result in different

16

infection rates due to differences in demographic

17

or treatment profiles of patients or other factors.

18

For example, study participants were more

19

likely to be white, older, and better educated than

20

the general U.S. population that is at risk for

21

HIV, which is the target audience for the drug.

22

While this population may be consistent with the

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1

people who are currently using Truvada, there are

2

questions about the generalizability of the data to

3

the whole population who could consider using this

4

drug. It is important to study the general U.S.

5

population that is at risk for HIV.

6

The study also found improvements for

7

biomarkers related to kidney health and bone

8

density, suggesting that this was safer than

9

Truvada, however, this is only relevant if it

10

translates into clinically meaningful difference in

11

the number of adverse events related to kidneys or

12

bone fractures, which were similar in both

13

treatment groups in the clinical trial.

14

The trial suggests that the benefits

15

outweigh the risks for men who have sex with men.

16

However, the benefit-risk ratio was less clear for

17

transgender women. This is due in part to the

18

relatively low number of transgender women in the

19

trial, the high dropout rate, and the lack of

20

subgroup analysis. If FDA is considering approving

21

Descovy for transgender women, then the efficacy

22

and safety of the drug for transgender women should

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1

be analyzed.

2

This is especially important given the

3

recent finding that feminizing hormone therapy can

4

interact with PrEP drugs. Similarly, there is

5

insufficient evidence that the drug is effective

6

and safe for PrEP for cisgendered women or

7

adolescents.

8

There are too many unanswered questions

9

regarding the levels of drug achieved, and relevant

10

tissues, and the amount needed in these tissues to

11

consider extrapolation for PrEP for use for

12

cisgendered women and girls.

13

Similarly, the benefits and the risks for

14

adolescent boys differ from that of men and should

15

be considered separately. Clinical trials

16

demonstrating effectiveness and safety for

17

cisgendered women and adolescents are needed if the

18

FDA is considering approval for them.

19

We understand the desire to provide a new

20

PrEP treatment indicated for a broad population,

21

especially when a new treatment may be expected to

22

have fewer risks for kidneys and bone density.

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1

However, it is inappropriate and potentially

2

dangerous to approve this drug for subgroups of

3

patients that haven't been adequately studied. The

4

FDA law requires substantial evidence that benefits

5

outweigh the risks for each subpopulation, and the

6

new indication would include. Thank you.

7

DR. BADEN: Thank you. Will speaker number

8

3 step up to the podium and introduce yourself?

9

Please state your name and any organization you're

10

representing for the record.

11

MS. JOHNSON: Thank you so much. My name is

12

Jeremiah Johnson. I'm the HIV project director at

13

Treatment Action Group in New York. We appreciate

14

that this hearing is being held today. Considering

15

how centrally Gilead has controlled this entire

16

process around TAF development, all the way from

17

delaying it for a decade when they purported safety

18

and preventive benefits for this medication; all

19

the way to centrally controlling the DISCOVER trial

20

without adequate participation of community; all

21

the way to rushing us through this regulatory

22

process, we believe it is extremely important that

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1

this regulatory agency and the community be given

2

time to have a transparent discussion about this,

3

and for us to take control of this process again,

4

and away from an applicant that has a vested

5

interest in maintaining a $2 billion a year market

6

in biomedical prevention in the U.S.

7

You may be familiar with TAG's work on

8

hepatitis C and tuberculosis as well. That's a

9

little bit about us. Within my 6 remaining

10

minutes, I'm going to go over three main points in

11

a small amount of time, so please pay attention.

12

To start, we're going to be talking about what

13

we've been talking about a lot here today in terms

14

of representation within DISCOVER and within the

15

broader body of evidence that we have as part of

16

this sNDA discussion today.

17

We have a number of concerns about Gilead's

18

active campaign against its own product, Truvada,

19

and what will be generic TDF/FTC PrEP within the

20

next year, and overstatement of efficacy and safety

21

benefits of Descovy compared to that, and have a

22

general discussion about the lack of transparency

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1

in this whole process and a rushed process when

2

these involve important discussions that clearly

3

the community was not adequately consulted on early

4

on in the process.

5

I won't go into this slide too much.

6

Obviously, the trial participants within the

7

DISCOVER trial do not represent the broader

8

epidemic that we see in the United States and

9

around the world. With 84 percent of trial

10

participants being white and 99 percent being

11

cisgender men, and only 74 participants identifying

12

as transgender women, clearly we are not seeing a

13

body of evidence that is reflective of all

14

populations that need to be considered in terms of

15

efficacy, safety, and effectiveness for scale up of

16

a new prevention option.

17

Right now, you're hearing here at this

18

podium, and there's a lot of discussion online

19

right now, there's a lot of debate amongst

20

community advocates about what does this data mean

21

and what should we be advocating for considering

22

that we don't have sufficient data? And for no

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1

good reason do we have insufficient data.

2

Some of us believe that we have to continue

3

to advocate for an indication for cisgender women

4

because we don't believe that the company sees it

5

as beneficial to their bottom line to do the

6

follow-up efficacy research in order to get an

7

indication for cisgender women. And if we miss out

8

on this opportunity, then there will be PrEPs for

9

different populations, and that's clearly a

10

problem.

11

But at the same time, we're concerned that

12

we're sending a message. Dr. Smith's comment

13

earlier was well taken that we're sending a message

14

that if we don't do adequate research within these

15

populations, that you don't have to do that, and

16

you can get a broader indication anyway, and that's

17

an enormous problem.

18

So it's up to the FDA here today and going

19

forward in this discussion whether you believe that

20

the information and the evidence presented thus far

21

is indicative of a broader indication or a narrow

22

indication. But what must be clear is that

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1

cisgender women cannot be left behind; neither can

2

any of the populations that have been left behind

3

in this entire process.

4

If it is not approved with a broad

5

indication, there must be a guarantee and there

6

must be requirements that the company continues to

7

fund efficacy, effectiveness, and safety studies

8

within cisgender women so that they are not left

9

behind in this process.

10

If it is approved, it needs to be contingent

11

upon open-label studies that continue to give us

12

more information for that population. That is

13

essential, and it must happen, and this regulatory

14

body needs to make up for the deficit of actions

15

that took place earlier in this process. We also

16

need to see that for all of the communities that

17

are highly prioritized within our broader epidemic

18

work but were not prioritized within this research.

19

In terms of efficacy, DISCOVER was a

20

noninferiority trial. We are very aware that

21

Gilead is trying to paint Descovy as a superior

22

option in terms of efficacy. That is not borne out

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1

in the evidence, and it stands to sabotage scaling

2

up of generic TDF/FTC next year, and to generally

3

sabotage Truvada's scale up for individuals who are

4

already stably avoiding HIV infection on that

5

regimen when there is no medical or efficacy

6

related reason for them to switch over.

7

They're also trying desperately to, even in

8

this room today, boldly assert that it is a safer

9

option when in fact we do not see clinically

10

different outcomes in the DISCOVER trial, and in

11

fact they continue to downplay statistically

12

significant increases in weight and challenging

13

issues around lipids that certainly indicate that

14

it is not necessarily a safer option.

15

It is important that this regulatory body

16

operate with the highest level of scrutiny with the

17

labeling, with the marketing, and with the

18

educational materials that come out of the

19

applicant should an indication be provided for

20

Descovy as PrEP.

21

Just quickly, these are slides that of

22

course Gilead will not be presenting today, but we

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1

saw from the DISCOVER trial that there was a

2

statistically significant increase in weight in the

3

TAF arm. And of course in terms of treatment, we

4

are seeing a disproportionate impact on weight

5

within cisgender women and individuals of African

6

descent, which further stresses the need for

7

additional research in those populations

8

considering that the DISCOVER trial was not

9

representative of these populations.

10

Ultimately, we have to ask what is the rush

11

in this entire situation. There's not one

12

peer-reviewed publication that has come out of the

13

DISCOVER trial. There is little transparency.

14

Today, we are just starting to see some of the

15

information from the trial. And all of this is

16

coming after a decade of delaying TAF development.

17

We are frustrated as community members that Gilead

18

continues to centrally control this process, the

19

FDA does not, and that community has not been

20

adequately involved.

21

So going forward, this body needs to send a

22

clear signal that any manufacturer engaging in the

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1

field of biomedical prevention research must do a

2

better job. They actually have to adhere to GPP;

3

they actually have to work with community from the

4

start; and they actually have to allow this

5

regulatory body to come up with a robust research

6

protocol that covers all populations and not just

7

their bottom line.

8

So with that, I will close in just saying

9

that we require robust postmarketing research

10

following this discussion today, that the labeling

11

and all materials need to be under high scrutiny,

12

and that we need a clear message from the FDA that

13

this process will go better in the future with

14

future provincial modalities. Thank you.

15

DR. BADEN: Thank you. Will speaker

16

number 4 step up to the podium and introduce

17

yourself. Please state your name and any

18

organization you're representing for the record.

19

MR. KRELLESTEIN: Hello. My name is James

20

Krellestein. I am a cofounder of the PrEP4All

21

collaboration. We are an all-volunteer group of

22

activists who are dedicated to ensuring universal

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1

low-cost access to HIV-1 pre-exposure prophylaxis.

2

I just wanted to review, before we

3

begin -- next slide, please -- what Descovy is.

4

Descovy of course is a co-formulation of two

5

different drugs, tenofovir alafenamide fumarate,

6

which was first approved back in 2015 as part of

7

Genvoya, a fixed-dose, single-tablet regimen for

8

HIV treatment, and emtricitabine, which was first

9

FDA approved as Emtriva back in 2002.

10

One of the things that has been talked about

11

extensively today is that tenofovir alafenamide has

12

some alleged advantages over tenofovir disoproxil,

13

which is that the prodrug catabolism occurs

14

intracellularly rather than tenofovir disoproxil,

15

which is actually metabolized primarily

16

systemically, allowing lower plasmic exposures to

17

tenofovir but higher levels of tenofovir

18

diphosphate, the pharmacologically active

19

anabolite, compared to tenofovir disoproxil, at

20

least in PBMCs. This is alleged to convey certain

21

safety benefits compared to TDF.

22

I think that one of the things that's really

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1

important, though, to realize in this entire

2

process is that TAF is not a new drug despite being

3

FDA approved in 2015. In fact, Gilead first filed

4

a patent application for TAF, claiming priority all

5

the way back to 2000, using of course its code name

6

at that time as GS7340. And of course, Gilead

7

scientists published a peer-reviewed scientific

8

journal in nucleosides, nucleotides, and nucleic

9

acids, all the way back in 2001 regarding the

10

metabolism of GS7340 now known as TAF.

11

I think the question that we should all be

12

asking ourselves is two things. First of all, why

13

in 2019 are we discussing an FDA application for

14

F/TAF as PrEP? And number two, why don't we have

15

better data on cisgender women?

16

Had F/TAF actually been developed when it

17

was supposed to be developed, we would have had an

18

F/TAF arm in iPrEx. We would have had an F/TAF arm

19

in Partners PrEP. We would have high-quality,

20

randomized-controlled evidence in all populations

21

that are being sought in indication for today.

22

So let's go through the development of TAF,

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1

if you would. Gilead began early phase 1 and phase

2

2 trials back in 2001 and 2002 and filed an IND

3

with this agency for the development of TAF back in

4

January of 2002. But in October 23, 2004, they,

5

based on an internal business review, discontinued

6

development of TAF, only on October of 2010 to

7

restart development of TAF.

8

What was the reason for this stop-start

9

approach to drug development? You don't have to

10

look to me, you don't have to look to Jeremiah, and

11

you don't have to look to anyone in this room to

12

actually understand what Gilead was doing. You can

13

look to their former CEO, Dr. John Milligan, who

14

stated that "one of the reasons why we were

15

concerned about developing TAF was we were trying

16

to launch Truvada versus Epzicom at the time. And

17

to have our own study suggesting that TDF wasn't

18

the safest thing on the market, which it certainly

19

was at the time, it didn't seem like the best. It

20

didn't seem like we would have a mixed message."

21

That was in 2011.

22

So as someone who takes TDF every single

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1

day, I have to say I'm highly disturbed by the

2

applicant's behavior to basically delay a drug that

3

they knew was going to present at least some safety

4

benefits compared to TDF, to protect their bottom

5

line rather than to protect the public health, and

6

I only wish that the FDA would share that very same

7

feeling. But instead, the FDA rewards Gilead's

8

decision to delay.

9

First of all, I was quite surprised by Dr

10

Murray's statement that TAF is similar to TDF, or

11

at least that it has the same active moiety as TDF

12

considering that the FDA had granted TAF new

13

chemical entity exclusivity in 2015, which prevents

14

any challenges through the patent paragraph 4

15

process until this year. It also recommended that

16

the USPTO give the maximum patent term adjustment

17

allowable under U.S. law, counting the entire

18

period of Gilead's delay as a testing phase. This

19

will prevent Americans from accessing generic

20

Descovy for an additional five years.

21

I think it is an extraordinarily disturbing

22

precedent that the Food and Drug Administration is

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1

rewarding the decision of a corporation to delay

2

the development of a drug that it is now purporting

3

is safer than TDF/FTC.

4

As a final note, I will say that we are

5

placed today -- this entire committee is placed

6

today -- in an incredibly difficult position. We

7

are basically placed with a catch-22. Either on

8

one hand we deny the ability for Descovy or TAF/FTC

9

from getting a broad indication for cisgender women

10

and other populations, and despite having no

11

effective efficacy data for this population, or we

12

choose to deny the extension of that indication.

13

That, unfortunately in today's environment, would

14

basically work to deny women the choice to make the

15

decision of the drug that they would like to take.

16

I believe personally, and not representing

17

my organization, that the right choice is to extend

18

the indication of F/TAF to cisgender women. But I

19

have to admit that I am incredibly disturbed by the

20

precedent that that would set. We have to say,

21

today and more than two decades after AIDS

22

activists seized control of both the Food and Drug

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1

Administration and the Centers for Disease Control

2

and Prevention, that cisgender women get HIV.

3

More than 50 percent of global infections

4

are in cisgender women, and the idea that an

5

applicant would decide not to basically provide

6

high-quality evidence supporting efficacy in this

7

population is disturbing. The fact that this

8

agency may be forced to grant a broad indication

9

with no efficacy data is also disturbing, and this

10

can never happen again.

11

I want to make that incredibly clear.

12

Cisgender women, transgender women, transgender

13

people, men who have sex with men, all of us

14

deserve -- that medical technologies that are

15

scaling up to fight one of the deadliest pandemics

16

of our time, they deserve high-quality evidence,

17

and we should never again encourage companies to

18

delay the development of innovative technologies,

19

and we should never allow them, once again, to not

20

provide high-quality evidence for these very

21

important technologies. Thank you.

22

DR. BADEN: Thank you. Will speaker number

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1

5 step up to the podium and introduce yourself?

2

Please state your name and any organization you're

3

representing for the record.

4

DR. GIPSON: Hello. June Gipson, CEO of my

5

Brother's Keeper in Open Arms Health Care Center

6

located in Jackson, Mississippi. My Brother's

7

Keeper is a community-based organization with a

8

mission to reduce health disparities throughout the

9

United States by enhancing the health and wellbeing

10

of minorities and marginalized populations through

11

the leadership in public and community health

12

practices, collaboration, and partnerships.

13

We do it through an array of programs and

14

services, including our center for community-based

15

programs, and we also have a center for research

16

evaluation and policy change. One of our most

17

prominent centers is going to be Open Arms Health

18

Care Center. That's our primary healthcare clinic.

19

Open Arms Health Care Center is an

20

innovative, holistic, primary healthcare clinic

21

that offers preventive clinical mental health

22

services to underserved, uninsured,

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1

underrepresented populations with an emphasis on

2

the LGBT population. We utilize a community-based

3

model that's a community health team led approach

4

to provide services to our clients that optimizes

5

their healthcare. We provide an array of services,

6

including women's health, family planning, men's

7

health, PrEP, HIV care, mental health, preventive

8

screenings, transportation, and emergency food

9

assistance.

10

When you look at our HIV and PrEP in

11

Mississippi, we've struggled, but we've been able

12

to accomplish some things. If you look at our

13

linkage for HIV testing and linkage to care, we're

14

either exceeding or we're meeting the national

15

goals. However, we continue to struggle in

16

retention and care and viral suppression.

17

When you look at our PrEP data, this is data

18

from Open Arms Health Care Center. This data is of

19

particular interest because we provide 75 percent

20

of all the PrEP in the state of Mississippi. As

21

you can tell, it's sparse. We are not hitting the

22

entire state. You have one red spot in the center

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1

that really optimizes and says who we're reaching,

2

so we have more to do. There are multiple reasons

3

why we aren't able to do this in Mississippi.

4

We've done assessments with our patients and our

5

staff, and of course there's a lack of access.

6

That's a prevalent thing; it's around the country.

7

We also have a stigma. Stigma exists in

8

every form of HIV care that we provide. There's

9

also some other concerns that have come up

10

throughout our assessments with our patients. Not

11

only is there a low perception of risk -- and you

12

would think in Mississippi that that wouldn't be

13

the thing, but it is -- but there's also a concern

14

about side effects.

15

When you live in a state like Mississippi,

16

side effects are huge because we are already

17

existing with so many other negative health

18

outcomes. When we see the commercials that talk

19

about the benefits of the medication and how

20

wonderful they are, and that last 15 seconds when

21

they run through all of the side effects, that's

22

what we hear. And I hear it in particular when you

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1

speak about Truvada because my dad is on dialysis.

2

My uncle is on dialysis. My cousin's on dialysis.

3

So we're living the side effects, and we need a

4

safer option.

5

We need a safer option for no other reason

6

that we have gone through enough. We have high

7

diabetes rates, high blood pressure rates, kidney

8

failure; you name it, we have it, and all of this

9

combined with HIV. We need Descovy for PrEP so we

10

can increase utilization. If we gave pills free to

11

everyone, that's access, but access is not

12

indicative of utilization.

13

So we need to have a safer option for our

14

community, and particularly with African Americans.

15

Again, we live these health disparities. We live

16

these side effects. And with women in particular

17

who may have a low perception of risk, it seems as

18

if we're taking Truvada, we're trading illnesses.

19

I get rid of one just to get a another? That's not

20

something that we want.

21

Particularly for adolescents, and I'm going

22

to include parents with our adolescents, parents

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1

generally want the best for their children. And

2

they really don't want to think about their kids

3

having sex, but we know that that's a real thing.

4

But if they see the advertisements for Truvada, and

5

they see the side effects, it gives an impression

6

that they're going to expose their children to

7

something that's going to give them a lifelong

8

problem.

9

When you're in the state of Mississippi, you

10

see your family in a dialysis clinic. If you ever

11

have an opportunity come and visit, stop by a

12

dialysis clinic. You'll see that it's filled with

13

African Americans.

14

As it relates to adolescence, I actually

15

have a call tomorrow with a parent. Her

16

16-year-old son came to us. He tested positive for

17

syphilis and chlamydia. We put him on PrEP. She

18

called a month later wanting to take him off of

19

PrEP because she's so concerned with the health

20

issues and the side effects associated with PrEP.

21

Now, you and I, we understand the correlation

22

between syphilis and HIV, but that's not her

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1

reality. That's not her perception. And we all

2

live within our perception because that's our true

3

reality. So I will like for Descovy to be approved

4

for PrEP for utilization broadly between African

5

American women and adolescents.

6

DR. BADEN: Thank you. Will speaker number

7

6 please step up to the podium and introduce

8

yourself? Please state your name and any

9

organization you're representing for the record.

10

MR. MYERS: Good afternoon. I'm Kirk Myers

11

of Abounding Prosperity in Dallas, Texas. I am the

12

founder and chief executive officer of an HIV and

13

AIDS prevention agency in Dallas, Texas. The

14

mission of my organization is to provide services

15

that address health, social, and economic

16

disparities among Black Americans with an emphasis

17

on the GBTQ community and their families.

18

I'm also a black man who has sex with men,

19

MSM, and who is living with HIV for over 26 years.

20

Through my lived experiences and managing my own

21

disease, and the leadership experience of managing

22

my agency, dedicated to decreasing new incidence of

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1

HIV and AIDS via various prevention programs, I

2

know the delays and deliberations that are

3

surrounding the prompt approval of Descovy for the

4

proposed use of PrEP for black women, MSMs, and

5

trans individuals is out of sync with our

6

real-world reality.

7

For me, the simple language that best

8

captures the reality among my people, especially

9

those black women, MSMs, and trans individuals, is

10

overwhelmed by the social, economic, and health

11

disparities that they confront daily. So while

12

some people have privilege on their side for

13

time-consuming contemplation over the prompt

14

approval of Descovy for the proposed use of HIV as

15

PrEP, my community makes immediate choices on a

16

day-to-day basis that ultimately could result in

17

the acquisition or spread of HIV-AIDS.

18

Therefore, I urge the prompt approval of

19

Descovy for the proposed use of HIV PrEP because it

20

is right to give black women, MSMs, and trans

21

people the option to make a safer effective choice

22

on a daily basis to protect their lives as they go

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1

about their business as usual. Whether their

2

business is at the level where I work as the CEO or

3

the street level of a sex worker, I will be

4

standing as an authentic voice to compel the

5

advisory community to consider the fact that I have

6

immediate access to those who would benefit from

7

Descovy for the proposed use of HIV prevention.

8

I have organized community forums, focus

9

groups, and one-on-one individual level

10

interventions to speak with authority that this

11

drug is wanted. The young women and gay men who

12

confide in me have expressed receptivity to a drug

13

that has the potential to protect them from HIV-

14

AIDS with lower side effects.

15

Finally, if anything is right at this

16

historical moment in HIV prevention efforts, it is

17

options to go beyond the past practice of

18

normalizing the majority and ignoring the pressing

19

needs of the minority. The right thing to do is to

20

empower black women, MSMs, and trans individuals

21

with the additional tools on a daily basis that are

22

purposefully designed to protect public health.

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1

Without this option, expediency, desperation, and

2

ignorance will continue to drive up the statistics

3

of new incidence of HIV and AIDS

4

With all due respect, I am asking the

5

advisory committee members to join me in doing the

6

right thing and assist on the prompt approval of

7

Descovy for the proposed use of HIV-based

8

prevention on my intimate relationships with MSM

9

and transgender individuals, who expect me to speak

10

out and share our testimony. This is the right

11

step.

12

Furthermore, we implore that this drug be

13

approved not just in gay men and transwomen, but

14

women need this drug, and it will not be in the

15

interest of public health to have this drug

16

approved without including women, and to then be

17

further stigmatizing by being looked at as a gay

18

drug. Everyone deserves the same choices of

19

prevention options as the rest of us.

20

Now, as a black man living with HIV here in

21

America

22

for the past 26 years, there has been this divide

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1

between black gay men and black women, and when we

2

look at our options, this is the best option for

3

all of us possible. I'm not a scientist. I didn't

4

have all the beautiful slides and all those things

5

to compel you to do anything, but I can tell you

6

from the grassroots level and at the street level

7

that this drug is needed. And again, if we only

8

approve it for one indication, it's going to create

9

further stigma that we do not need. Thank you.

10

DR. BADEN: Thank you. Will speaker number

11

7 step up to the podium and introduce yourself?

12

Please state your name and any organization you are

13

representing for the record.

14

MR. WARREN: Good afternoon. My name is

15

Mitchell Warren, and I'm the executive director of

16

AVAC, a New York-based global, nonprofit

17

organization focused on accelerating the

18

development and delivery of new prevention options.

19

We take no money from any pharmaceutical companies,

20

including from Gilead Sciences, although I should

21

note I was a member without any compensation of the

22

Independent Data Committee of the DISCOVER trial.

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1

I stood here, as some of you in this room

2

did as well, seven years ago, and the task was

3

easy. The data was robust, the evidence was clear,

4

and I'm delighted that that committee then, and the

5

FDA shortly thereafter, followed the evidence and

6

approved TDF/FTC for oral PrEP for all populations.

7

I wished the task were as easy today.

8

There, while the evidence was clear, today we sit

9

in somewhat of an evidence-free zone, at least in

10

some areas as has been well discussed today. It's

11

a dynamic space and one that I hope we don't return

12

to ever again, and I have some thoughts about that

13

toward the end. But the data are the data, and we

14

must act on that most urgent data point presented,

15

and that is an epidemic that continues in multiple

16

places, in multiple populations. And what we do

17

today matters, not just in the United States, but

18

particularly for women at great risk of HIV

19

infection in Africa.

20

I recognize full well that that is outside

21

of the purview of the FDA and certainly of this

22

committee. Your job is to look at safety and

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1

efficacy for the United States. That said,

2

decisions made in this room today, recommendations

3

made in this room, decisions made subsequently by

4

the FDA, will resonate and influence the global

5

response. And I realize that's a heavy burden, but

6

one that is real.

7

I'm going to take just a few minutes to go

8

through the two questions that you have on the

9

table, F/TAF for PrEP for men and transgender

10

women, first and foremost. It is very clear to me

11

and to AVAC, the organization I lead, that the data

12

presented in the application does indeed support a

13

noninferiority claim for F/TAF compared to F/TDF

14

for oral PrEP for gay men and transgender women.

15

I emphasize that as noninferiority. The

16

DISCOVER trial was set out to design for

17

noninferiority, and it certainly met that task. I

18

think that's a very important point not only as you

19

make your vote today in the committee, but as the

20

FDA works around the labeling with Gilead, that

21

this be very clearly registered as a noninferior

22

oral PrEP option.

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1

Any claims of superiority I think are

2

unfounded. Yes, there's a different safety

3

profile, and we saw data today that made it seem

4

both safer on some level but concerns in others

5

with lipid and weight gain. But we need to be very

6

clear so there is no confusion to PrEP users today

7

on TDF/FTC, or PrEP users of tomorrow that we are

8

somehow promoting one as a safer and more effective

9

drug. This is a noninferior oral PrEP option, and I

10

support that wholeheartedly, but all labeling must

11

be consistent with that and be strongly enforced.

12

In terms of the second question you all will

13

consider, it's perhaps the more challenging in so

14

many respects, and that is F/TAF for cisgender

15

women. It is extremely unfortunate that similar

16

safety and efficacy data for F/TAF were not

17

collected in an efficacy trial. We can spend a lot

18

of our time Monday morning quarterbacking why that

19

was and why decisions were made.

20

I would argue that the best time to debate

21

that is not sitting in an FDA hearing to consider a

22

drug approval. Those should've been open

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1

conversations we had with the company, with the

2

FDA, and with community groups far and wide to

3

discuss the best pathway for product development.

4

I do trust that that is the case, and I think

5

Dr. Murray in his introductory comment described

6

that for next generation new chemical entity PrEP

7

agents. That is not a change; that what we

8

discussed today is not creating a new status quo.

9

We do have to recognize that this is a tenofovir

10

prodrug and tenofovir-based prep, and I use my

11

comments in that regard.

12

If F/TAF is not extended to include

13

cisgender women, the one group, the only group that

14

will suffer and pay the price for that decision are

15

women at risk of HIV infection. The FDA won't

16

suffer, Gilead will not suffer, and other agencies

17

will not suffer. That said, we have to always be

18

clear that safety and efficacy matter.

19

Based on the data presented today, and I

20

should say in addition, not taking money from

21

pharmaceutical companies. I am not a statistician,

22

a trialist, an ethicist, or scientist of any type.

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1

I'm an advocate. But I will say that based on the

2

data presented here, recognizing the systemic

3

levels as monitored in a range of studies both for

4

the safety study presented, although less robust

5

than we would like, as well as the treatment

6

studies, there's a very clear rationale for F/TAF

7

to work as well as F/TDF in women.

8

I believe that that is critical to approve.

9

That said, I believe that that PrEP indication

10

needs to come with an incredibly strong, robust,

11

and enforceable postmarketing surveillance,

12

research agenda, and a risk evaluation mitigation

13

strategy that makes it very clear that over the

14

next 12 to 24 months, Gilead will be responsible

15

for collecting, in collaboration with other

16

research groups, the relevant data for safety and

17

effectiveness.

18

As well discussed here, efficacy of PrEP in

19

women is hard to measure currently with oral prep;

20

not impossible, but hard to do. Let us focus on

21

effectiveness, and let us ensure that an

22

FDA-enforced postmarketing surveillance in REMs

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1

ensures that we have that data.

2

I will say, too, in our work, in Africa

3

particularly, and has been reported in a number of

4

studies, including work that we have done, that

5

pill size does matter. It is one of the leading

6

reasons that women in programs in Africa talk about

7

not continuing with F/TDF. While again, I realize

8

Africa is not in the purview of this committee or

9

of the FDA, your decision will matter, and a

10

smaller drug, not necessarily safer or more

11

effective, but a smaller drug will be of enormous

12

benefit.

13

I want to emphasize again in closing that

14

the education prescriber information and supportive

15

materials that are part of any package going

16

forward with F/TAF need to be heavily monitored by

17

the FDA, and not just between the FDA and Gilead

18

but with community input; not tokenistically, but

19

in an active way to ensure that the language used

20

to describe this indication as a noninferior

21

product for all populations is clearly described,

22

clearly enforced, and robustly done.

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1

So we do urge the committee to approve for

2

all populations F/TAF for PrEP. We do urge the

3

committee to consider the consequences of you

4

voting no, which would send a signal of delay and

5

distrust of the research community in a product

6

development, and at the same time committing

7

together that we are not changing the rules for

8

future products of new PrEP agents, that we ensure

9

that we have better conversations earlier in the

10

process so the products coming to this committee

11

and to the FDA are done with the most robust and

12

complete package possible. Thank you very much.

13

Clarifying Questions (continued)

14

DR. BADEN: Thank you.

15

Once again, the open public hearing speakers

16

have presented us with incredibly powerful insights

17

in the challenge at hand before us, and we thank

18

all of the speakers for sharing your thoughts and

19

convictions and insights in balancing this very

20

difficult problem.

21

The open public hearing portion of this

22

meeting is now concluded and we'll no longer take

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1

comments from the audience. We'll now turn our

2

attention back to the business at hand, which is

3

evaluating the data presented before us, and we

4

will continue with our clarifying activities with

5

the applicant.

6

Prior to the applicant presenting some of

7

the follow-up, I just had one clarifying question

8

to the agency, which is adolescents, as I look at

9

all the materials we've received, seems to be

10

defined by a way to greater than or equal to 35

11

kilograms, and that is not how I've always thought

12

of adolescence. So I just want to know if there's

13

an age parameter there or simply a weight

14

parameter.

15

(Laughter.)

16

DR. BADEN: Is it 15 to 17 and of sufficient

17

weight or is it down to 10, or down to 5? I just

18

want to know are there any parameters around the

19

adolescent category?

20

DR. MURRAY: I think we're sticking with

21

weight. It becomes tricky to decide what age one

22

should be starting to use.

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1

DR. BADEN: So could it be 10 then?

2

DR. MURRAY: Well --

3

DR. BADEN: If it's purely weight, then I

4

guess it could be a big 10 year old, could be 36

5

kilos.

6

DR. MURRAY: We know the safety and how to

7

dose down to 35 kilograms, and exactly when a

8

physician or a person who's of adolescent age

9

should consider it is probably up to them. And

10

when you put an age in there, it kind of boxes you

11

in, with a lot of respect.

12

DR. BADEN: Is Truvada 15? I thought

13

Truvada was 15 to 17, or is that purely weight

14

based? It's purely weight based.

15

DR. MURRAY: Weight based.

16

DR. BADEN: Okay. Well, thank you for

17

the -- I just wanted to make sure I was reading

18

weight as the determinant and not other factors.

19

So back to the applicant, who wanted to

20

clarify some of the concepts from this morning that

21

needed your input, and then we will come back to

22

the many questions we have on the list from the

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1

panel members.

2

DR. BRAINARD: Thank you. We have four

3

clarifying answers to prior questions. The first

4

is around the data for Descovy in vaginal tissue,

5

and I'd like to just walk through what the

6

available data are, so everyone has a clear

7

understanding of the data in the literature.

8

Slide 1 up, please. There have been three

9

different studies of Descovy in vaginal tissue.

10

One was a single-dose study of Descovy, and in the

11

discussion of that manuscript, they compared those

12

results with another study that the same group had

13

conducted several years prior with Truvada.

14

The second study was done with a single dose

15

of Descovy and Truvada within the same study. The

16

third study was done by the same group and was

17

multiple doses of Descovy and Truvada looking at

18

vaginal tissue levels.

19

Slide 2 up, please. Here are the results

20

from those studies. In the first study, looking at

21

Descovy vaginal tissue levels following a single

22

dose of Descovy, the tissue levels of AUC was

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1

reported as 132,098. This was compared in a

2

cross-study comparison to the Truvada levels, which

3

were noted to be 1.3 to 1.8-fold higher than those

4

with Descovy.

5

The second study that was done with a single

6

dose of Truvada or Descovy in the same trial

7

demonstrated that after 4 hours, all of the samples

8

with Truvada were below the limit of

9

quantification, and 69 percent of the samples with

10

Descovy were below the limit of quantification.

11

The conclusion from that was that multiple dose

12

data are needed.

13

In the setting of multiple doses, which is

14

indeed the more relevant setting to assess tissue

15

levels for a daily administered drug, 4 hours after

16

dosing of Descovy or Truvada, levels were 2.6-fold

17

higher with Descovy as compared to Truvada. FDA

18

presented these data in their presentation. At 24

19

hours and 48 hours after dosing stopped, there were

20

comparable and low levels between Descovy and

21

Truvada in the vaginal tissue.

22

I'd like to now put these vaginal tissue

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1

data into context with what we know about the

2

rectal tissue data. Slide 1 up, please. The

3

vaginal tissue are just now a graphical

4

representation of the data I showed you at the

5

4-hour time point in the table, where you can see

6

that Descovy achieves slightly higher levels than

7

Truvada 4 hours after dosing.

8

As compared to rectal tissue levels, the

9

first thing to note is that Truvada achieves about

10

10-fold higher level than Descovy in the rectal

11

tissue. It's also relevant to note that the rectal

12

tissue levels with Truvada are somewhat of an

13

outlier as compared to the vaginal tissue levels

14

with both Descovy and Truvada, and the rectal

15

tissue with Descovy.

16

This has been hypothesized to be related to

17

the low bioavailability of Truvada, and the fact

18

that there may be drug delivered directly through

19

the GI tract to the rectal tissue with Truvada.

20

That's done so to a lesser extent with Descovy,

21

which has higher bioavailability. This is a

22

hypothesis without clinical or scientific proof.

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1

Nevertheless, what we know about Truvada is

2

that despite the lower levels in the vaginal tissue

3

as compared to the rectal tissue levels with

4

Truvada, Truvada for PrEP is highly an equally

5

efficacious in men and women. So these lower

6

levels of vaginal tissue nevertheless correlate to

7

having efficacy in the setting of Truvada for PrEP

8

use in women.

9

Similarly, what we now know with the

10

DISCOVER trial is that despite having 10-fold lower

11

levels of tenofovir diphosphate in the rectal

12

tissue as compared to Truvada, both drugs

13

demonstrated that they were highly effective and

14

Descovy was noninferior to Truvada at preventing

15

HIV acquisition. These data contribute to the

16

increasing body of understanding that systemic drug

17

levels are what's driving efficacy, and efficacy is

18

not related to particularly homogenate tissue

19

levels.

20

I can keep going to the other issues or we

21

can stop for comments, Dr Baden.

22

DR. BADEN: Thank you. Your point's well

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1

taken. Since this is such an important issue,

2

comments from the committee to better understand

3

these data since these bridging data are a critical

4

element.

5

DR. DODD: Lori Dodd, the statistician. One

6

of the concerns I have looking at these data is

7

they're extremely small numbers, and the box plots

8

you're seeing are really the interquartile range as

9

opposed to some confidence intervals. So I need

10

some help understanding how generalizable these

11

results are to the larger population. I'm unable

12

to do that based on the data presented.

13

DR. BRAINARD: In terms of the

14

generalizability, all tissue-level studies that

15

have been conducted have generally been in less

16

than 10 participants for group, occasionally

17

somewhere between 10 and 15. This is just related

18

to the invasive nature of conducting these studies

19

and the requirements for a biopsy.

20

In addition, we haven't seen any data

21

looking at tissue-level data in prevention studies

22

because, of course, taking biopsies in the setting

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1

of individuals who are at risk for HIV infection

2

could actually increase their risk. So those data

3

are not available, nor are they likely to be

4

generated.

5

I would agree that the data are variable and

6

that there are not a large amount of data.

7

Nevertheless, when we think about what these data

8

mean in the setting of a high amount of clinical

9

data around the efficacy of Truvada for PrEP in

10

both men and women, those data can provide

11

reassurance.

12

DR. DODD: A little more clarity would help,

13

too, then. How is it that states are coming up

14

with guidelines on the amount of time needed to

15

obtain maximum intracellular concentrations and

16

pushing in that direction when we're only able to

17

get 14 participants from this study? I might also

18

ask if it would be appropriate to ask the agency to

19

comment on this as well.

20

DR. BADEN: Yes.

21

DR. BRAINARD: During the lunch break, we

22

tried to track down the data that actually were

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1

behind the timeline recommendation around 20 days,

2

and the data really come back to very sparse tissue

3

data, and there are no data that connect to 20

4

days.

5

One study showed that when assessing vaginal

6

tissue levels and rectal tissue levels over time,

7

it seemed that at the 10-day time period, there

8

were stable and steady-state levels within the

9

rectal tissue obtained with Truvada, whereas in the

10

vaginal tissue, levels were still seen to be

11

increasing. It seems like that is the basis for

12

the extrapolation to 20 days required for

13

prevention. But this has never been validated, and

14

we don't know of any clinical data to speak to the

15

time to protection for women.

16

DR. BADEN: Would you like the agency to

17

comment if anyone is aware of the basis for those

18

recommendations?

19

DR. DODD: And also if they can comment on

20

their understanding of the uncertainty associated

21

with the concentrations in the tissues given the

22

small numbers.

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1

DR. MIELE: Right. We actually have

2

concerns about the reliability of that data because

3

of the inconsistency and the small numbers, and the

4

differences in methodology. But that's all we have

5

right now, and the extrapolation approach is what's

6

being proposed.

7

As to the time to achieve protection, I

8

don't believe the CDC has a recommendation in that

9

regard. What they're stating is the time to

10

achieve maximum concentrations. Some state

11

guidelines have interpreted that to mean protective

12

levels, which kind of makes sense. But I agree

13

that I don't know that the data are very robust to

14

that extent, and these are very conservative

15

measures.

16

We have not introduced any of that to the

17

labeling, for example. We have not reviewed any of

18

that data because as it stands right now, PrEP is

19

meant to be used in combination with safer sex

20

practices, so it's sort of counter-productive or

21

counter-intuitive to suggest a lead-in period when

22

you could come off condoms for example.

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1

So we have not entertained that and we have

2

not really reviewed that data, but I was pointing

3

it out that that concern about the differential

4

distribution is out there, and it's guiding some of

5

these recommendations that are being put out there

6

by states.

7

DR. BADEN: Do you have another follow-on,

8

Dr. Dodd?

9

DR. DODD: Just one final comment, and I

10

don't know if one of the statisticians who've

11

looked at the concentration data could comment.

12

But when I hear a number like a 10-fold increase in

13

the tissue concentrations. That can tend to stick

14

in everybody's mind, but we have to understand the

15

uncertainty associated with that.

16

Has the confidence interval been estimated

17

so that we don't get hung up on that number or

18

something like that? I think this actually is a

19

pretty important to point. I'll leave it at that,

20

but I just want to make that as a final point.

21

DR. ZHENG: This is Jenny from FDA. The

22

numbers we have for tissues normally were small

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1

numbers and presented as median quartiles because a

2

lot of below limit of quantitation was observed in

3

those tissue concentrations, so there are some

4

limitations.

5

DR. BADEN: Dr. Ofotokun?

6

DR. OFOTOKUN: Mine is just a minor

7

clarification about the method. These tissue

8

concentrations are generated in the rectal and the

9

vagina. Can you confirm or clarify to me whether

10

the vagina data, is it a biopsy of the vagina

11

tissue, or is this CVL, or aspirate, or swab? How

12

were they -- I know they are different sometimes

13

when you look at those different compartments as

14

opposed to rectal drug concentration.

15

DR. BRAINARD: There are a range of

16

methodologies used for these compartments studies,

17

and cervical vaginal lavage is often a method where

18

tissue or cells are washed from the cervix, and

19

sometimes with or without scraping. The data that

20

I shared with you are biopsy data.

21

Slide 1 up, please. This slide provides a

22

very high level schematic of how these tissue

A Matter of Record (301) 890-4188

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1

levels are measured. Whether it's in the rectum or

2

in the vagina, forceps are used to take biopsies.

3

Generally with rectal tissue, more biopsies are

4

taken than with vaginal sampling, where it's

5

generally limited to 1 to 2.

6

These biopsies consist predominantly of

7

epithelial cells and fibroblasts, which make up the

8

majority of the tissue and point to some of the

9

limitations of the sampling. Also contained within

10

that biopsy will be a variety of immune cells,

11

including relevant CD-4 T cells, but also

12

macrophages, B cells, neutrophils, NK cells, and

13

dendritic cells.

14

That tissue block is incubated with enzymes

15

in order to break up the cells because the

16

tenofovir diphosphate only exists inside cells. So

17

it's released from the cells through enzymes, and

18

then generally the amount of tenofovir diphosphate

19

is quantified using mass spec. So the total

20

tenofovir diphosphate level that is reported is the

21

tenofovir diphosphate across all of these different

22

cell types, recognizing that the predominant cells

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1

that are contributing to these levels are

2

epithelial cells and fibroblasts.

3

It's been hypothesized that part of the

4

reason those vaginal tissue levels drop off at 24

5

hours and 48 hours, and why there are so many BLQ

6

measurements at those time periods is because

7

epithelial cells have a more rapid turnover, and

8

therefore tenofovir diphosphate within the

9

epithelial cells, which are representing a higher

10

proportion of contribution to the levels, are

11

turning over and are no longer having tenofovir

12

diphosphate at the 24-hour and 48-hour time point.

13

That's just a hypothesis.

14

DR. BADEN: Thank you very much. Please

15

continue with the other follow-ons from this

16

morning.

17

DR. BRAINARD: Dr. Daskalakis asked about

18

transgender women. There were 74 transgender women

19

enrolled in the DISCOVER trial. None of those

20

participants acquired HIV infection. There was

21

also a question about gender-affirming hormone use,

22

and 53 of the 74 transwomen reported using

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1

gender-affirming hormones. We did look at the

2

subset of those participants who had PK sampling

3

down at the week 4 time point, and found that there

4

was no difference in tenofovir diphosphate levels

5

within that population.

6

Slide 2 up, please. This slide just shows

7

data on the 18 women who were part of the substudy

8

that had tenofovir diphosphate levels within PBMCs

9

measured at week 4. And you can see that there

10

trough concentration of tenofovir diphosphate is

11

similar to what was seen in the MSM population,

12

despite being on gender-affirming hormones.

13

DR. BADEN: Thank you. Any questions? I

14

think these are fairly clear. Thank you.

15

Continue.

16

DR. BRAINARD: The third issue was providing

17

some additional information about insertive anal

18

intercourse, and I'll ask Dr. Moupali Das to speak

19

to that.

20

DR. DAS: Just to remind everyone, the

21

eligibility criteria for the DISCOVER trial were in

22

two parts. The first piece was requiring two

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1

episodes of condomless anal sex with more than one

2

unique partner in the past 12 weeks prior to

3

enrollment, or the second criteria was evidence of

4

rectal gonorrhea, rectal chlamydia or syphilis in

5

the past six months, past 24 weeks. A high

6

proportion of people in the study, as you saw,

7

reported condomless anal sex.

8

We're going to share the data with you of

9

the people reporting condomless insertive anal

10

intercourse in terms of number of partners at

11

screening prior to baseline. Slide 2 up. The mean

12

number of insertive anal intercourse partners was

13

4, which is the same as the report of condomless

14

anal intercourse partners. There were no

15

differences between arms. All the people who are

16

infected in this study, the 22 people who acquired

17

HIV, had data and biologic evidence of condomless

18

anal intercourse.

19

DR. BADEN: Just to clarify, so I'm

20

understanding these data and what's implied, do you

21

have data on men who were insertive but not

22

receptive? So purely insertive, and what degree of

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1

transmission occurred in that population?

2

DR. BRAINARD: We don't have data on people

3

who were purely insertive, but the criteria for

4

eligibility in the study required evidence of

5

receptive anal intercourse that was unprotected.

6

There was no infections -- all the people who were

7

infected had evidence of receptive anal

8

intercourse.

9

DR. BADEN: Follow-on questions or

10

clarifications for this?

11

(No response.)

12

DR. BADEN: Okay. Please continue.

13

DR. BRAINARD: The last topic I'd like to

14

just proactively follow up is the question about

15

study design issues in ciswomen. As has been

16

pointed out by panelists, community members, and

17

FDA, there are challenges with conducting a

18

clinical trial in women, a superiority study for 2

19

oral drugs that are tenofovir prodrugs as

20

infeasible, and a placebo-controlled trial is not

21

going to be ethical given Truvada is effective in

22

women.

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1

We talked a little bit about noninferiority

2

and the challenges around establishing a

3

noninferiority margin and FDA's perspective on the

4

inability to construct a noninferiority margin

5

because of the lack of consistency. We did look at

6

taking the effect from the two most effective

7

randomized clinical trials in women Partners PrEP,

8

which was one of the registrational studies for

9

Truvada, and then the Bangkok study, which was

10

actually a study in injection drug users, but, most

11

of the HIV acquisition in women was due to sexual

12

transmission.

13

So using the treatment effect from those two

14

studies, we calculated a noninferiority margin

15

using the same methodological approach we used for

16

DISCOVER, and came up with a sample size of 22,000

17

in a high-risk population. That would take 8 to 10

18

years to conduct, which was part of the reason that

19

we didn't initiate that study, particularly in the

20

setting of the ongoing DISCOVER study.

21

However, we also recognize there's been a

22

lot of discussion since 2015 about this conundrum

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1

of what can be done to assess the efficacy of PrEP

2

in women, and also now where we are because of the

3

DISCOVER results and because there's highly

4

effective active comparator in Truvada, and now

5

Descovy, going forward in men as well.

6

Dr. Murray from FDA has been one of the

7

leaders in this area. We've been participating in

8

discussions as well as with PrEP experts, and

9

academics, and community members. There are some

10

novel trial design methodologies that don't fall

11

within the standard rubric, but I'm going to ask

12

Dr. Wulfsohn to discuss some of those approaches

13

from a statistical standpoint.

14

DR. WULFSOHN: Thank you. And just to

15

clarify, the 22,000 that Diana referred to would be

16

a study in Africa, so you're dealing with a high

17

incidence rate of 4 per hundred person-years. In

18

order to find the best noninferiority design, we

19

also selected 2 of the 5 women studies which had

20

the most benefit from Truvada. So we've cherry

21

picked the two studies to try and help us reduce

22

the sample size, and the lowest we can get it to is

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1

22,000.

2

Now we're certainly open to more innovative

3

ideas. And fortunately for us, Jeff Murray gave a

4

great talk at IAS a week ago, and we're very

5

receptive to some of the ideas that Jeff proposed,

6

and I'd like to go through some of these in terms

7

of how a woman's study could look. All of these

8

are our proposals from Jeff, so I won't mention his

9

name anymore.

10

It was proposed that there should be at

11

least two placebo anchors in order to interpret a

12

woman study. The two that come to mind would be,

13

firstly, an epidemiologic assessment of the placebo

14

incidence. We would envisage a study in Africa

15

where that would be known based on current

16

epidemiologic data, what the incidence is in women

17

not on antiviral protection.

18

The second approach to estimate a placebo

19

incidence could be based on the screening period

20

from the study. Knowing how long it was from the

21

last test to beginning treatment, that being the

22

risk period, we could look at the subset of women

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1

who are not on Truvada and assess the incidence.

2

And that would be a reference, placebo incidence.

3

The other thing that was proposed in order

4

to assess whether a PrEP drug is effective is that

5

it should lower the incidence by 5 to 10-fold. The

6

idea came from oral contraceptives, where oral

7

contraceptives actually lower the incidence about

8

40-fold, but we're trying to be realistic.

9

Just for reference, if you look at the

10

DISCOVER study where, granted, the adherence was

11

very high, we're estimating that Truvada lowered

12

the incidence by 10- to 20-fold based on two

13

different ways of estimating the placebo incidence,

14

and Descovy lowered the incidence by 20- to 40-

15

fold. So these are both effective agents.

16

I'd like to bring up slide number 1, which

17

is the noninferiority study we were talking about.

18

But just with reference to these five studies, the

19

two best studies, Partners PrEP and the Bangkok

20

study, which had the lowest risk ratio, in Partners

21

PrEP, we're lowering incidence 3-fold, and in

22

Bangkok, we're lowering incidence 5-fold. These

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1

are just the point estimates.

2

I would also add that in our own

3

demonstration project where we've got a lot of

4

real-world data in women, our estimate is that

5

we're lowering incidence approximately 5-fold based

6

on observing an incidence of 0.8 per hundred

7

person-years, largely from cohorts in Africa where

8

you'd expect of incidence of 4 per hundred

9

person-years.

10

The 5-fold is as far as we are currently

11

getting with current adherence rates. It's

12

potentially possible to improve adherence and get

13

greater effect sizes, but clearly the metric for

14

what constitutes good enough efficacy will need to

15

be tailored to the population and adherence that

16

we're getting.

17

Another criteria, which is an extra

18

criteria, not a different option, is that the

19

incidence rate in the experimental arm should be no

20

more than 0.5 higher than the active control, which

21

would be Truvada, and that seems somewhat

22

reasonable.

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1

Another separate approach was proposed, and

2

that is to look at the adherence subset of a study.

3

So in DISCOVER, if you look at the individuals who

4

are taking 2 or more tablets per week, we're only

5

seeing 2 infections, one in each arm. So we are

6

observing an incidence of less than 1 in a thousand

7

in adherence subjects. And it was proposed that

8

that threshold of 1 in a thousand is a reasonable

9

measure of what constitutes an effective agent.

10

These are all good ideas and very innovative

11

creative approaches that we can leverage and work

12

with the FDA on to try and design a woman's study

13

that answers the efficacy question, and we're

14

committed to doing this.

15

DR. BADEN: Thank you. If FEM-PrEP and

16

VOICE in the placebo groups had 5 per hundred

17

person-years, I'm having trouble understanding how

18

you come to a 22,000 person study, when if we look

19

at the DISCOVER, which had a 1 per hundred

20

person-years, you have a 5-fold increased event

21

rate, yet a 3-fold increase in sample size? I'm

22

having trouble understanding.

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1

DR. WULFSOHN: Slide number 1 up. The main

2

thing that's driving up the sample size is the

3

weaker performance of Truvada in these women

4

studies. In the design of DISCOVER, we estimated,

5

based on the three historical controls, that we

6

would lower incidence 5-fold. Here, when you pool

7

these two best studies, you're lowering incidence

8

3-fold. So it becomes a lot harder to retain 50

9

percent of a weak effect.

10

DR. BADEN: I see your point. Still, I'm

11

concerned with the assumptions, but I see your

12

point.

13

Other questions? Please, Dr. Goetz?

14

DR. GOETZ: I want to come back to what you

15

just said, the weaker performance of Truvada in

16

these women. Are you stating that irrespective of

17

adherence?

18

DR. WULFSOHN: No.

19

DR. GOETZ: And it comes back to Dr. Baden's

20

question, then, as to why the sample size must be

21

so large. Are you projecting that the women you

22

will enroll will be non-adherent?

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1

DR. WULFSOHN: Our interpretation of the

2

data is that adherence is a primary driver of

3

efficacy. As you've seen presented today, there

4

are several thousand women who've been, uh, given

5

PrEP and over a hundred thousand men who've been

6

given PrEP. And if you look at the literature,

7

there's a total of 6 case reports of individuals

8

getting infected while on treatment.

9

So it's highly unusual to get infected while

10

on adequate treatment or with adherence and that's

11

why the threshold for what constitutes good enough

12

is you need to have less than one in a thousand

13

individuals getting infected, because that's what

14

the current drugs can deliver.

15

DR. BADEN: Dr. Giordano?

16

DR. GIORDANO: But then, why did the

17

DISCOVER study work?

18

(Laughter.)

19

DR. BADEN: It's a circular problem we're

20

dealing with.

21

DR. GIORDANO: Because you expected a

22

10-fold higher rate of HIV than you saw in both

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1

arms. The adherence was extremely high, higher

2

than was across the board in the previous studies,

3

and yet you ended up with a noninferior drug,

4

statistically proven noninferior drug in this

5

population. I don't get it.

6

DR. WULFSOHN: My understanding is that if

7

you're perfectly adherent to both Truvada or

8

Descovy, there's no advantage to one or the other

9

drug from an efficacy point of view. That's a

10

hypothesis. In the data from Truvada, and similar

11

for Descovy, we're seeing 1 and 2 and a half

12

thousand approximately infections in individuals

13

who are adherent; to find a DBS that's done every

14

3 months, showing adequate drug levels.

15

On the other end of the spectrum, if you

16

stop taking the drug completely, there's no

17

difference between what the drug can provide you

18

because it's not providing you any benefit. So the

19

benefits, to the extent there is a benefit, is in

20

the middle, the individuals who are not fully

21

adherent but are taking some drug, and the PK

22

properties of the drug lead us to believe that, at

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1

least from the PBMC levels, that there could be an

2

advantage to the efficacy with Descovy.

3

These data are somewhat suggestive, an

4

unproven advantage. We don't have enough data to

5

say even in that subset there's an advantage, and

6

certainly the study overall hasn't shown

7

superiority, but that's a hypothesis that can be

8

tested in the future as well.

9

DR. BADEN: Dr. Walker, you had a question?

10

DR. WALKER: Yes, and it may not correlate

11

to the discussion that's going on at hand. And

12

forgive me if you have mentioned this. It's been a

13

lot of information that's been presented here. But

14

I just wanted to know, could you go back and let us

15

know some information about these baseline

16

demographics and exactly how the sites were

17

selected? I'm just curious to know, especially

18

within the U.S., knowing that HIV is not evenly

19

distributed amongst states and regions.

20

So I'm just curious to know how your sites

21

were selected, the 94 sites, and if you could just

22

kind of give me some details on the states, rural,

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1

urban, and if that led to the disproportion of

2

African Americans in this study.

3

DR. BRAINARD: I'll ask Dr McCallister to

4

come and describe our site selection process.

5

While he's coming to the podium, I will say that

6

the DISCOVER study enrolled 9 percent overall

7

African American subjects. Within the U.S., that

8

proportion was 13 percent. As I believe was

9

pointed out earlier today, the population that we

10

enrolled into DISCOVER was largely reflective of

11

people taking PrEP today. It was not reflective of

12

the people who are at highest risk for new

13

infections right now.

14

Slide 2 up, please. This slide shows the

15

percentage of blacks and Hispanic and Latino

16

individuals enrolled in the DISCOVER trial on the

17

left as compared to the percentage of blacks and

18

Hispanic or Latino individuals taking PrEP today in

19

the U.S. As you can see, our proportions were

20

similar for DISCOVER for black participants, and we

21

enriched somewhat for participants who

22

self-identified as Hispanic or Latino.

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1

I'll have Dr McCallister speak to the

2

efforts we took to enroll a diverse range of sites

3

in the study.

4

DR. McCALLISTER: We did specifically seek

5

out sites that were in high background HIV

6

incidence areas, in the U.S., Canada, and in

7

Europe. In so doing, we went to -- almost all of

8

them were urban centers, and they were in hospital,

9

in STI clinics, and health departments.

10

Within the U.S. population that wound up in

11

DISCOVER, we had a large percentage that were in

12

the northeast and southeast in particular. One of

13

the findings that has come out of our attempt to

14

understand what the background epidemiology was of

15

our sites, we used CDC data to get the HIV

16

incidence rate in these sites, and then compared it

17

to places where DISCOVER was conducted.

18

Could I get slide 1 up, please. These data

19

are incidence rates over time at 25 metropolitan

20

statistical areas inside the United States that

21

overlapped with DISCOVER sites. These are

22

incidence rates in MSMs in those locations who were

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1

not using PrEP. What you see is over time, the

2

general incidence rate in both the DISCOVER sites

3

as well as non-DISCOVER sites has gone down a bit,

4

but the DISCOVER sites were in places where the

5

incidence was higher consistently over time.

6

DR. BADEN: Dr. Giordano, you had a follow-

7

on?

8

DR. GIORDANO: Yes. Can you clarify if that

9

comparison was adjusted for the racial and ethnic

10

distribution of the participants matched for what

11

the distribution is in the MSAs, weight sampling,

12

in essence?

13

DR. McCALLISTER: Right. These data on the

14

screen are all people at risk with a CDC indication

15

within these MSAs. However, when you do break it

16

down racially, the numbers are very close. They

17

range from 3.3 to 4.2.

18

DR. GIORDANO: I'm not sure I understand

19

that.

20

(Laughter.)

21

DR. GIORDANO: In other words, what I'm

22

asking is does this comparison, where you're saying

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1

these are high-risk people in high-risk areas, yes,

2

they're in a high-risk area, but are they from a

3

racial and ethnic group, that is at high risk in

4

that area? So half of the HIV in Houston is in

5

African Americans right now. If you only enrolled

6

white people in Houston, you would get a lower rate

7

of HIV incidence than you would otherwise expect.

8

Does this adjust for that difference?

9

DR. McCALLISTER: It doesn't adjust -- it is

10

inclusive of all people in these MSAs.

11

DR. GIORDANO: So the answer is no.

12

DR. McCALLISTER: It's not adjusted --

13

DR. GIORDANO: Thank you.

14

DR. McCALLISTER: -- specifically just for

15

African Americans; that's correct. The rate in

16

African Americans and the rate in Caucasians from

17

these locations are very close to these numbers.

18

DR. GIORDANO: Am I being obtuse? Is he

19

being obtuse? We're not communicating.

20

DR. BADEN: The point has been made.

21

DR. GIORDANO: Okay. Thank you.

22

DR. BADEN: Dr. Le, did you have a

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1

follow-on?

2

(Dr. Le gestures no.)

3

DR. BADEN: Okay. Dr. Goetz, a follow on?

4

DR. GOETZ: Yes. I'll try to follow up on

5

what I think is Dr. Giordano's question. You had

6

presented data on MSA, 1 metropolitan statistical

7

area -- I believe that's what the MSA is -- would

8

be Houston and another one would be Boston. The

9

MSAs from which you recruited patients on average

10

have higher rates of HIV acquisition than other

11

MSAs.

12

But I think Dr. Giordano's question is, or

13

my question is, the patients enrolled in the study,

14

though, are they representative of the ratio makeup

15

of that MSA, and thus it would be predicted to have

16

that higher rate, or were patients who were

17

enrolled in this study be from populations of lower

18

risk, which gets back to the whole question of

19

what's the risk of the population enrolled and

20

thus, the efficacy of the intervention?

21

DR. BRAINARD: I think what your question is

22

driving at is how confident can we be that we were

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1

in the right population with high risk for HIV, and

2

to address that, I'll ask Dr. Wulfsohn to come to

3

the podium and speak to the two ways we tried to

4

estimate the putative or potential placebo rate to

5

understand whether we were in the right population.

6

DR. WULFSOHN: Just to answer the question

7

directly, we did an analysis where we forced the

8

racial makeup in the MSAs to match that in

9

DISCOVER, and the rate went down by 0.3. It was

10

3.8 overall in 2017, and 3.5 when you force it to

11

match the racial makeup in DISCOVER. And we have

12

looked at another method of assessing the placebo

13

rate, and that's using the rectal gonorrheal

14

approach, which I can show.

15

Slide 1 up. There have been 8 different

16

cohorts within controlled trials of placebo

17

control. Each of the 8 black dots on this graph

18

represents a placebo cohort. What's notable is

19

that the higher the rectal gonorrheal rate, the

20

higher the HIV incidence rate in these placebo

21

cohorts, and that's a linear relationship.

22

On this graph, we've also superimposed the

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1

DISCOVER data, so just above 20 on the X-axis,

2

you'll see 2 little dots, and these represent data

3

from DISCOVER, gray for Truvada and blue for

4

Descovy. For both arms, we have the erectile

5

gonorrhea incidence, as well as the HIV incidence.

6

These 2 dots with the vertical confidence

7

intervals, which are hard to see because they're so

8

tight, are well below what the projected placebo

9

incidence would have been, and that gray area is

10

the 95 percent prediction interval around the

11

placebo rate.

12

DR. BADEN: Dr. Smith, did you have a

13

follow-on?

14

DR. SMITH: [Inaudible - off mic].

15

DR. BADEN: Microphone.

16

DR. SMITH: I had a question about the MSA

17

slide.

18

DR. BRAINARD: We'll pull that up for you;

19

just a sec.

20

Could we get the MSA slide, please?

21

DR. SMITH: Remind me the years in which the

22

DISCOVER trial was actually happening, '16 to '17

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1

or '15 to '17?

2

DR. WULFSOHN: It started at the end of '16,

3

and it was largely in '17 as the bulk of the

4

follow-up.

5

DR. SMITH: So the incidence was falling in

6

both sets of communities before the start of the

7

study, and you really only have the last two time

8

points that are presumably related to the DISCOVER

9

trial?

10

DR. WULFSOHN: That's correct. If I could

11

have the slide on the fold increase relative to

12

placebo from Truvada, with the MSAs? When we

13

designed the study relative to the three historical

14

studies that were used for the design, we expected

15

Truvada to lower incidence 5-fold. So 1.44 was

16

expected for Truvada versus 6.96 in placebo from

17

the three studies.

18

Slide 1 up. When you look at the actual

19

data from DISCOVER, we're noticing that Truvada is

20

lowering the incidence by actually 8.6 fold if you

21

were to use the MSA data; that's this middle CDC

22

estimate of the placebo rate. The placebo rate we

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1

estimated to be 3.83 during the duration of the

2

study versus the USA subset of DISCOVER, where the

3

observed Truvada incidence was 0.446.

4

Our active control was actually

5

substantially more active than we anticipated.

6

Using the rectal gonorrhea, it's actually 19-fold

7

reduction that we're seeing with our active

8

control, Truvada. So DISCOVER was actually a

9

better test of a new agent than we anticipated it

10

to be.

11

DR. SMITH: Okay.

12

DR. BADEN: Dr. Dodd?

13

DR. DODD: Yes. Was it really a better test

14

or was it just that the prevalence of circulating

15

HIV in the populations tested might have been

16

lower, and therefore exposure to HIV may have been

17

lower? I think you made the case that their

18

at-risk behavior was relatively high, but how do we

19

know that the gonorrhea curves that you showed and

20

the really low rates in the DISCOVER cohort weren't

21

just really because there was lower exposure to

22

HIV?

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1

DR. WULFSOHN: If I could have the

2

gonorrheal slide back? If you look at the lower

3

bound of the interval around the projected -- slide

4

1 up. If you look at the lower bound of the

5

interval around the HIV incidence that we projected

6

for placebo, while we projected an incidence

7

slightly above 6, the lower bound is slightly above

8

3. So even in a conservative way of looking at

9

this, there is a big gap between how placebo would

10

have performed relative to how these two agents are

11

performing.

12

DR. BADEN: Thank you. We're close to our

13

break, but before we go to break, which I'll

14

shorten to 10 minutes, one last question on

15

ciswomen. Separate from this committee's

16

deliberation and the agency's action, what is your

17

commitment to studies in ciswomen in terms of

18

generating the data that are absent?

19

DR. BRAINARD: We're firmly committed to

20

generating data in women. As Moupali showed in her

21

presentation, we've got a number of studies that

22

we're supporting, that we're hoping to initiate

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1

within the next year. These are not traditionally

2

powered for efficacy studies; these are clinical

3

effectiveness studies, and they are planned to be

4

conducted both in the U.S. as well as in high

5

incidence settings within Africa to demonstrate the

6

safety as well as the clinical efficacy across a

7

broad range of populations.

8

In addition, we are committed to generating

9

clinical data with Descovy for PrEP in women using

10

one of these novel approaches if we can come to an

11

agreement on what that approach should be.

12

Dr. Wulfsohn walked through some of the ideas.

13

We're in active discussions with investigators and

14

with experts on how to best get this done, and

15

we're committed to do it, and we're planning to

16

incorporate the feedback that we receive from FDA

17

and from the panelists into this decision.

18

DR. BADEN: So whether or not the indication

19

is granted, you will conduct studies in ciswomen to

20

determine the effectiveness.

21

DR. BRAINARD: Without a doubt.

22

DR. BADEN: And that's the hundred, in the

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1

tens, hundreds, or thousands? I'm just looking for

2

a zip code.

3

DR. BRAINARD: The indication allows us to

4

go more broadly into clinical effectiveness

5

demonstration projects, so it clearly allows us to

6

get to a higher number and reach a higher number of

7

women more quickly because we have endorsement from

8

a regulatory agency that this drug is safe and

9

effective in the population.

10

If we don't have an indication, we're still

11

generating data in women, but the nature of that

12

type of data has to be restricted until we get the

13

endorsement from the regulatory bodies that we can

14

then go and do these demonstration projects. So

15

we're committed, we're going to generate data, and

16

I think that the proportion and maybe the velocity

17

of that data depends on where we land, but the

18

commitment is there, and it will happen. The time

19

period is it just depends.

20

DR. BADEN: Understood the constraints you

21

have to work under.

22

It's 3:04. We will take a break and resume

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1

at 3:15 sharp.

2

(Whereupon, at 3:04 p.m., a recess was

3

taken.)

4

DR. BADEN: [Inaudible - mic off] -- before

5

that, we need to clarify as much as we can from the

6

applicant.

7

We have several committee members who still

8

have questions from this morning. I will ask the

9

committee members, as well as the applicant, to be

10

as pointed as possible in the question and the

11

response so that we can cover as much ground in the

12

next 15-20 minutes before we have to get to

13

discussion about the questions at hand.

14

I'm going to start with questions from this

15

morning. Dr. Daskalakis, you are on the list.

16

(Dr. Daskalakis gestures no.)

17

DR. BADEN: Thank you. Dr. Green?

18

DR. GREEN: Yes. Thank you. I have a

19

question that relates to the slide CC-50 from this

20

morning, which was the forest plot looking at the

21

different subgroups. I know there's been

22

conversation. I thought that adolescence was part

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1

of the populations that you were contemplating,

2

including in your request for indication.

3

I wonder if you could explain, because the

4

closest thing we have to adolescence is the age

5

less than 25, and it's one of the only two data

6

points on this curve that show a favoring to TBD,

7

although not clinically significant, so maybe you

8

could just comment on that.

9

DR. BRAINARD: Yes. I'll first make the

10

point that there are wide confidence intervals

11

around this point estimate related to the

12

relatively small sample size as compared to the

13

entire study design. The incidence rates within

14

the population of participants who are less than 25

15

are higher than the overall incidence rates.

16

This is related to the relationship between

17

younger age and lower adherence, which has been

18

demonstrated in many PrEP studies and certainly

19

demonstrated in the adolescent ATN study with

20

Truvada, and reflects that those participants had

21

lower adherence in that age bracket. However, I

22

would point out that both Descovy and Truvada

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1

nevertheless were highly effective and

2

substantially lowered the risk of HIV acquisition.

3

DR. BADEN: Thank you. A follow-on to that,

4

safety in the younger ones, I have learned that

5

adolescence is defined by weight of 35 kilograms.

6

The data you have on how low an age bound, you have

7

data. Do you have data on 10 year olds on Truvada,

8

12 year olds, 20 year olds? I just want to have

9

some sense of where we're are in the data-free zone

10

if we may be giving it to our 10 year olds.

11

DR. BRAINARD: We have Truvada, Descovy, and

12

then three other single-tablet regimens that

13

contain Descovy, as well as multiple regimens

14

containing Truvada, are indicated for adolescents

15

greater than or equal to 35 kilograms. And then we

16

also have indications in younger populations based

17

on the data that we've generated in treatment

18

trials.

19

So we have a fairly large body of evidence

20

to suggest that the Descovy-based therapy is safe

21

and well tolerated in these younger populations,

22

even extending less than 35 kilograms.

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1

DR. BADEN: When you say younger, is that

2

from 0 to 10 years old in treatment?

3

DR. BRAINARD: In the setting of HIV

4

treatment, our youngest -- I think our lowest

5

weight indication is 25 kilograms.

6

DR. BADEN: Again, any labeling is going to

7

need to take into consideration the absence of

8

data.

9

DR. BRAINARD: I'm getting a signal that the

10

age cutoff is 6 --

11

DR. BADEN: Six.

12

DR. BRAINARD: -- so down to age 6.

13

DR. BADEN: Okay. So you have safety data

14

down to that obviously with indication.

15

Dr. Goetz, do you have a follow on?

16

DR. GOETZ: Not a follow-on.

17

DR. BADEN: So moving down, Dr. Gripshover,

18

you have a question from this morning.

19

DR. GRIPSHOVER: Actually, yes. I had one

20

question about weight, because we did see one slide

21

from the audience earlier, too, especially in the

22

HIV treatment world where being concerned with

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1

obesity, they think some may be related to TAF,

2

some also the ACE inhibitors. I think in this

3

study they gained a kilogram in the men. It seems

4

that sometimes women gain more weight.

5

So I just wondered if we have any data maybe

6

in women on TAF outside of this if we're trying to

7

extrapolate this to a broader population of women.

8

DR. BRAINARD: I'll ask Dr. Das to come in

9

and discuss the weight gain in the DISCOVER study

10

and place it into context around what we know from

11

other PrEP trials. I'll also note that the data we

12

have from our HIV treatment setting suggests that

13

there are many factors associated with weight gain,

14

integrase inhibitor therapy being one of them, and

15

that's seen across different integrase inhibitors.

16

TAF in and of itself is not associated with

17

weight gain. What we see in the HIV treatment

18

space is that TDF is associated with a weight

19

suppressive effect, and when TDF is switched to

20

either a TAF-based regimen or a regimen without TAF

21

that doesn't contain TDF, that can be associated

22

with weight gain.

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1

DR. DAS: The difference in weight in the

2

DISCOVER study was driven by the TDF weight

3

suppressive effect that Diana just discussed.

4

Slide 2 up, please. We've known about the

5

potential for Truvada to potentially suppress

6

weight since the iPrEx trial. The USPI has weight

7

loss as a known adverse drug reaction for Truvada,

8

based on the iPrEx trial.

9

On the left-hand side, you see placebo

10

across the top and Truvada across the bottom, and

11

you see that with iPrEx, there was a weight loss

12

through week 48 with Truvada and a weight gain on

13

placebo. This is in median percent changes in

14

weight. In DISCOVER, the Truvada arm looked very

15

similar to the iPrEx arm with initial weight loss

16

and a little bit of stabilization towards the end,

17

and the Descovy arm looked very similar to the

18

placebo.

19

The average placebo weight gain -- excuse

20

me. The average amount an American age 18 to 40

21

gains in a year is 1 kilogram, and the placebo

22

weight gain in the iPrEx trial and the weight gain

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1

in the DISCOVER trial on the Descovy arm are

2

consistent with that. Further, if we look at

3

HPTN 077, at 41 weeks, the placebo arm also gained

4

about 1 kilogram. The cabo arm in that trial also

5

gained 1.1 kilogram.

6

So I think what we're seeing in trials that

7

compare TDF to TAF is the TDF weight suppression or

8

stabilization effect versus the release of that

9

effect in switch or the lack of that effect in the

10

TAF arm.

11

DR. BADEN: Thank you. Dr. Le?

12

DR. LE: Can you please go back to slide

13

CC-50 that you had earlier n in the subgroup

14

analysis of those less than 25 years? You alluded

15

to that this may have been where the incidence rate

16

is a little bit higher than the overall -- was

17

perhaps due to adherence as a reason for this.

18

What was the adherence for that group, and

19

was it similar to the treatment trials that you see

20

in adolescents? I'm trying to correlate this, for

21

younger people would we see the same trends?

22

DR. BRAINARD: I'll ask Dr. McCallister to

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1

address the issue of adherence by age within the

2

DISCOVER trial, and I will say that, overall, we've

3

seen lower levels of adherence within studies of

4

PrEP in adolescents and younger individuals.

5

That was really one of the drivers for why

6

we didn't include adolescence in the DISCOVER

7

trial, was because of the data suggesting that they

8

really benefit from an increased visit frequency.

9

They're going to benefit from increased

10

interventions to improve adherence and have age

11

appropriate retention and recruitment methodology.

12

DR. McCALLISTER: Adherence in the

13

individuals less than age 25 was lower than in

14

those above age 25.

15

Could I get the slide 1 up please? This is

16

the pill count data that is broken down by less

17

than 25 years on the left, 25 to 50 in the middle,

18

and above age 50 on the right. These are, as you

19

can see, far lower for those less than age 25.

20

Another way of looking at it is through the

21

dried blood spot data, so slide 3 up, please, and

22

we really see the same pattern in the less than 25

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1

using the TFV diphosphate levels in RBCs. There

2

were fewer of them in a range of 4 tablets per week

3

or higher. Of the 22 infections in DISCOVER, 7 of

4

them did occur in this group, and all 7 of them did

5

not have the detectable drug levels.

6

DR. BADEN: Thank you. Dr. Read from

7

earlier in the day.

8

DR. READ: Yes, my questions have already

9

been addressed. Thanks.

10

DR. BADEN: Dr. Giordano from earlier in the

11

day.

12

DR. GIORDANO: I have a question for the

13

agency. Is it within your -- two questions

14

actually for the agency. One is, is it within your

15

purview to say a registrational study should

16

include X proportion of people in Y category? In

17

other words, let's say a certain proportion are

18

black, African American, from U.S.. Is that

19

something you can say or is it really up to the

20

sponsor to design that?

21

DR. BIRNKRANT: We can make the

22

recommendation, but we wouldn't want to hold up a

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1

trial or an approval if they didn't meet what the

2

suggested rate would have been in that certain

3

population.

4

DR. GIORDANO: Another question is, this

5

request to approve based on essentially drug level

6

extrapolation for women, do you have other examples

7

of when the agency has allowed that to happen? Can

8

you give us any guidance on when that's appropriate

9

or considered inappropriate at the agency's level

10

to help inform the committee?

11

DR. BIRNKRANT: I don't think we have any

12

other examples, based on --

13

DR. MURRAY: The tissue level, we

14

extrapolate efficacy for children all the time, and

15

we still get the safety data. So we've matched

16

efficacy in different populations based on systemic

17

PK. I don't think we've ever made a regulatory

18

approval decision based on a tissue a non-systemic

19

PK argument.

20

DR. BADEN: And presumably the prior

21

decision, you inferred the correlate of protection,

22

so to speak, an antibiotic level in blood, where

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1

there's an understanding of what the protective

2

moiety supposedly is.

3

DR. MURRAY: We've always tried that, and

4

we've tried to match it to be as much

5

bioequivalent -- I use that term loosely -- to the

6

population that had the clinical data.

7

DR. BADEN: Yes. Dr. Goetz?

8

DR. GOETZ: That leads me to what I think I

9

can call a follow-up question. I want to go back

10

to one of the backup slides that was shown, which

11

showed correlation between dosage inferred from PBM

12

of red blood cell spots and protection. I think

13

that was BU461, is what I wrote down this morning,

14

and that was in the iPrEx study.

15

What I was interested in is trying to build

16

this bridge, which may or may not be buildable.

17

Are there similar data that are inferred based on

18

PBMCs or RBC studies in women that correlate the

19

same level of protection to 2 to 3 tablets per week

20

as being the cutpoint?

21

DR. BRAINARD: I'll ask Dr. Anderson to

22

address this question about the thresholds for

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1

adherence for women and for men.

2

DR. ANDERSON: I would say not this level

3

and formal analysis in women. We just don't have

4

that yet. We do have, though, the -- if I can show

5

O82, perhaps. There's a very recent study

6

HPTN 082; it was in women.

7

Slide 2 up, please. This study is one of

8

the very few studies in women that have collected

9

dried blood spots or a marker where you can tell

10

different gradients of adherence, and this study

11

did actually collect those. They had 4 infections

12

in this study, and none of those infections

13

occurred at the middle or the high drug, the DBS

14

level. They all occurred at the low level.

15

DR. GOETZ: So aside from this sparse data

16

set, there are no data at your disposal that allow

17

us to map adherence -- a proxy for taking drug

18

based on a biological measure that correlates, in

19

some degree, with drug levels to protection in

20

women, and shows equivalence between the level of

21

protection that we expected in men with that level

22

and the level of protection demonstrated in women,

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1

because that's the bridge that we're trying to

2

build, I think.

3

DR. ANDERSON: I think these results here on

4

the screen are consistent with what we saw. And

5

iPrEx OLE, it's a smaller data set, but it is

6

consistent; I would say that. And I think you had

7

something to add.

8

DR. GOETZ: Wide confidence interval.

9

DR. BRAINARD: I would also say that in the

10

Partners PrEP study, there was an assessment of

11

adherence based on tenofovir blood levels. And

12

unlike tenofovir diphosphate within red blood

13

cells, which is an integrated assessment of

14

adherence over 6 to 8 weeks, tenofovir plasma

15

levels reflect dosing within the last 4 days.

16

This is a measurement of adherence. It's

17

less precise, but it does offer an objective

18

assessment. And it is referenced in the new CDC

19

guidance as a meaningful assessment of what they

20

call recent PrEP use, which they correlate as

21

associated with a 90 percent protection for both

22

men and for women. Within that case-controlled

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1

study, Partners PrEP, where they looked at both men

2

and women who had detectable tenofovir diphosphate

3

levels -- I'll put slide 3 up please -- the overall

4

efficacy was 92 percent, and in men, it was 89

5

percent, and in women, it was 94 percent.

6

So this represents a lower level of

7

adherence than, for example, we saw in the DISCOVER

8

trial. But nevertheless, it shows that there's no

9

difference between men and women.

10

DR. BADEN: Thank you.

11

We've made it through the list. Are there

12

other questions from the committee? We're not all

13

satisfied given the nature of the data, but are

14

there other questions that could help inform the

15

committee in our deliberations?

16

(No response.)

17

Questions to the Committee and Discussion

18

DR. BADEN: If not, we'll now proceed

19

with -- don't go yet to the questions to the

20

committee, but thank you. We'll now proceed with

21

the questions to the committee and panel

22

discussions. I'd like to remind the public

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1

observers, while this meeting is open for public

2

observation, public attendees may not participate

3

except at the specific request of the panel.

4

I would like to thank Dr. Brainard and the

5

entire Gilead team for covering an incredible

6

amount of information. Given the size of the

7

problem, the amount of data could never approach

8

the magnitude of the problem. We were able to get

9

through I think about 15 percent of the slides you

10

had prepared. If I'm reading the lower right-hand

11

corner correctly, you have at least

12

1500-1600 slides. I think we got 150 to 200 of

13

them in front of us. So thank you for preparing

14

the information and sharing it with us.

15

Now we must turn to the questions at hand.

16

Before we move to the questions at hand, I have

17

some guidance I would like from the agency, and if

18

others have questions, let me know.

19

We're being asked -- and would be interested

20

in the agency's guidance, too -- particularly in

21

the cisgender women conundrum, I want to make sure

22

I understand the problem correctly. There are

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1

multiple studies with Truvada. At least two showed

2

no benefit; two showed benefit. One of them led to

3

the indication. However, these data were not

4

strong enough to allow a determination of a study

5

design with a noninferiority margin, yet these data

6

are strong enough to guide us with a bridging study

7

to lead to an indication.

8

Is that the position we're sort of in as

9

we're reflecting on how to move forward with our

10

deliberations?

11

DR. MURRAY: That's correct. Even though we

12

had low efficacy in some studies, it was attributed

13

to low or no adherence, but we think if women are

14

adherent, that they should be 90 percent effective.

15

DR. BADEN: But that wasn't strong enough to

16

set a noninferiority margin so you could have a

17

female trial analogous to a male trial.

18

DR. MURRAY: Well, noninferiority studies

19

are tricky; rely on historical data you're supposed

20

to use as much as possible. I think the problem

21

with noninferiority studies is you need that

22

constancy assumption. You need to assume that what

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1

you saw in the past is going to be repeated going

2

forward, and for studies in Africa, we're not sure

3

what the adherence rate is going to be, and then

4

that really hampers our ability to do a

5

noninferiority margin unless we did some novel way

6

of looking at noninferiority margins, which we

7

haven't done, Bayesian based on adherence and

8

things that we've really never looked at.

9

DR. BADEN: What tools do you have if broad

10

indications were given to mandate or require future

11

studies versus goodwill and intent to do future

12

studies?

13

DR. MURRAY: Well, obviously, I think this

14

would be a postmarketing commitment. Requirements

15

are for pediatric studies and for safety. This is

16

really expanding indications, so it would fall

17

under kind of a legal postmarketing commitment.

18

But those studies, particularly in the HIV arena,

19

are almost always completed, especially where

20

they're important, like this would be, to expand

21

the indication to women.

22

Anybody else want to comment on that?

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1

(No response.)

2

DR. BADEN: Any other clarifying -- we have

3

to deliberate -- sorry. Dr. Green?

4

DR. GREEN: So again, I'm going to be the

5

pediatrician. On the packet that you have, it

6

looks like the application -- again, it does

7

include adolescents weighing at least 35 kilograms,

8

but I noticed that neither question 1 nor

9

question 2 addressed our opinion on adolescence.

10

So you're not interested in any opinions

11

from the committee on adolescents?

12

DR. MURRAY: Yes, we were planning to ask

13

that question. We were willing to extrapolate to

14

adolescents based on what's known for PK and safety

15

for the treatment and the fact that there's an

16

indication in adolescence for Truvada. We're

17

willing to kind of make that leap for the same

18

gender in adolescence, because it's the route of

19

transmission that we think could be the variable or

20

acquisition.

21

DR. BADEN: Dr. Giordano?

22

DR. GIORDANO: Does an indication have to

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1

specify sex or can it specify behavior? So

2

approved for men who have sex with men or can it be

3

approved for men -- but does it have to be approved

4

for men? Do you see the distinction I'm making?

5

Is that something within the labeling options?

6

DR. MURRAY: It is. Are you talking about

7

MSM and heterosexual men, or those who have

8

insertive intercourse with women, or men who have

9

sex with men?

10

DR. GIORDANO: Before we get to that

11

discussion, because there's no -- essentially --

12

DR. MURRAY: Yes. It gets a little bit

13

tricky. But if the indication was limited just to

14

MSM, we'd really have to think about how the

15

indication would be worded for men in general.

16

DR. GIORDANO: Right.

17

DR. BADEN: Dr. Daskalakis?

18

DR. DASKALAKIS: Another labeling question.

19

On a label, are you able to say that this drug has

20

been studied in these populations; there's a

21

recommendation for use in another population, but

22

it's based on extrapolation? Is that something

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1

that can be explicitly stated in the label?

2

DR. MURRAY: I think so. We do that, to a

3

certain extent, when they describe pediatric data.

4

DR. BADEN: Dr. Smith, do you have a

5

question?

6

DR. SMITH: Yes. Is it possible to discuss

7

the MSM indication separate from the transgender

8

women recommendation? Right now, they're in a

9

single statement, and I think I have questions

10

about one but not the others.

11

DR. MURRAY: Well, we didn't plan to have

12

the question answered that way, but you might have

13

that as a comment after your vote. But I think if

14

we're prepared to go ahead with MSM, the agency was

15

prepared to go ahead with the transgender women as

16

well, realizing that you're not going to be able to

17

do a powered study in transgendered women. There

18

were zero seroconversions out of 74 probably

19

indicative of some protection in and of itself in

20

the DISCOVER trial.

21

DR. BADEN: But Dr. Smith, you're getting at

22

just the power issue, given the population sizes.

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1

DR. SMITH: Yes. I mean, if you look at the

2

iPrEx subset analysis that had 200 transgender

3

women defined slightly differently, there was no

4

evidence of the impact, statistically significant

5

evidence of protection.

6

So to me it's an extrapolation question. I

7

mean, they didn't include enough transgender women

8

in order to do a separate analysis, and now we're

9

asking to make an indication based on the fact that

10

it works for MSM. It was just my question.

11

DR. MURRAY: I think we're going to have it

12

voted on as a package deal, and then you can

13

explain why or why not you voted for it or not.

14

And if that's one of the issues, you can explain

15

that.

16

DR. BADEN: I think we'll vote on the

17

questions as written, but I think your point is the

18

guiding principle. We can then explain our

19

concerns or our reinforcements of how we look at

20

the different indications. After we vote, the

21

agency finds our comments even more helpful than

22

our vote. So it's very important that we'll vote,

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1

which looks yes/no, but in reality, we can express

2

different elements that we find reassuring or

3

concerning where they should pay attention to.

4

I will be mindful of time, so we have about

5

50 minutes, and we all have been very energetic,

6

and it's a complex arena for all the reasons

7

discussed earlier.

8

Any other discussion amongst the committee

9

before we move to the vote? Are there any aspects

10

of the data or what would charged with that it

11

would be helpful to discuss or clarify?

12

(No response.)

13

DR. BADEN: If not, we can move to -- I can

14

read -- we will be using an electronic voting

15

system for this meeting. Once we begin the vote,

16

the buttons will start flashing. It is a new

17

system, so hopefully we won't get confused.

18

(Laughter.)

19

DR. BADEN: They'll continue to flash even

20

after you have entered your vote. Please press the

21

button firmly that corresponds to your vote. If

22

you're unsure of your vote or you wish to change

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1

your vote, you may press the corresponding button

2

until the vote is closed.

3

After everyone has completed their vote, the

4

vote will be locked in. The vote will then be

5

displayed on the screen. The DFO will read the

6

vote from the screen into the record. Next, we'll

7

go around the room and each individual who voted

8

will state their name and vote into the record.

9

You can also state the reason why you voted as you

10

did if you want to. We'll continue in the same

11

manner until all the questions have been answered.

12

We will now move to the first question, and

13

I will ask if there are any questions about the

14

question before we vote. Has the applicant

15

provided substantial evidence of the safety and

16

effectiveness of Descovy for pre-exposure

17

prophylaxis, PrEP, to reduce the risk of

18

sexually-acquired HIV-1 infection in men and

19

transgender women who have sex with men?

20

If yes, provide your rationale. If no,

21

provide your rationale and list what additional

22

trials are needed. Please provide any additional

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1

comments or thoughts on your vote. If yes, you can

2

still have a rationale about studies that are

3

needed.

4

So any questions about the question?

5

(No response.)

6

DR. BADEN: If not, then let's proceed to

7

voting.

8

(Voting.)

9

DR. BADEN: I assume the voting from our

10

online member is being handled. Okay, so that is

11

being handled. So I'll wait until you close

12

the --

13

DR. HOTAKI: For the record, the vote is 16

14

yes, two nos, zero abstentions, zero no votes.

15

DR. BADEN: We will now go around the room

16

and state your name and your vote into the record.

17

And if you have comments to the agency, please

18

share them. We'll start with Dr. Goetz.

19

DR. GOETZ: Thank you. Matthew Goetz. I

20

voted yes, that the DISCOVER trial supports the

21

approval of the Descovy, et cetera. I think the

22

word "support" is totally appropriate here because

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1

it certainly supports the efficacy, and I use the

2

word "efficacy" appropriately as well.

3

I think what is really needed to enhance

4

this are the phase 4 trials to show the

5

effectiveness in real-world populations that span

6

transgender men -- I think I'm getting my

7

phraseology right here or I mean to you -- and also

8

in other populations and larger populations of

9

African American men, and populations where all

10

patients are to be fully adherent to PrEP.

11

The population that was tested here was

12

gratefully a highly adherent population, and we saw

13

a few infections. The real world I'm afraid

14

includes individuals who are less adherent, and

15

it's very important to demonstrate the

16

effectiveness in other populations that may face

17

challenges not seen in individuals who enrolled

18

here. Certainly, you want to see long-term safety

19

outcomes to see whether the biological signals that

20

favor TAF lead to clinical outcomes that are

21

favorable as well. I can go on, but I should leave

22

my panelists to say more.

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1

DR. BADEN: Dr. Smith?

2

DR. SMITH: I voted yes because I think

3

there is substantial evidence to support an

4

indication for men who have sex with men. I am not

5

convinced that there's substantial evidence for

6

transgender women, and I think that additional

7

studies are going to be necessary, as my colleague

8

said, to understand how this is actually used in

9

populations that are at the highest risk of HIV

10

acquisition and who stand to benefit from it.

11

Adolescents, black men and women, and

12

transgender persons all have documented adherence

13

problems with Truvada, generally, and I think it

14

will be important to understand how TAF adds

15

protection or not in those populations.

16

DR. BADEN: Thank you. Dr. Read?

17

DR. READ: I voted yes, and my comments

18

largely have already been stated, but I think they

19

bear repeating. I think the data provided by the

20

applicant do support the safety and efficacy of

21

Descovy by demonstrating noninferiority to Truvada

22

in men who have sex with men and transgender women.

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1

I think although there were a few infections

2

in the trial, the high rates of STI infections and

3

other indicators do support the high risk

4

characterization of the study population. And

5

further, Descovy appears to be safe as demonstrated

6

both in DISCOVER as well as the extensive treatment

7

experience in people living with HIV.

8

I do think that it has been stated

9

throughout the course of the day that the study

10

population enrolled in DISCOVER did not represent

11

the populations most at risk for HIV, and

12

therefore, if Descovy is approved for use in MSM

13

and transgender women, the applicant should be

14

required to collect postmarketing data on safety

15

and effectiveness in those underrepresented

16

populations, including transgender women, as has

17

just been stated, as well as people of color.

18

I think it's important, as was raised during

19

the public comment period, that the labeling and

20

advertising for Descovy, if approved, should only

21

speak to the noninferiority, not the superiority of

22

both the effectiveness as well as the safety of

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1

Descovy. I think it's important to note that the

2

markers for kidney and bone toxicity were

3

biomarkers only and did not indicate a clinical

4

benefit. And I also think that it's important not

5

to disregard some of the potential negative adverse

6

events, including weight gain and lipids.

7

DR. DASKALAKIS: I'm Demetre Daskalakis. I

8

also voted yes. Mirroring some of the prior

9

comments, I think that the data presented in the

10

DISCOVER trial are very strong for supporting the

11

noninferiority of Descovy for pre-exposure

12

prophylaxis in men who have sex with men. I do

13

want to state again the importance of selling this

14

as a noninferiority both from efficacy and safety.

15

I think overselling the safety here could

16

create an environment where drug switches are done

17

in a way that don't reflect the data and may also

18

create significant disparities in various

19

populations of men who have sex with men.

20

My expectation of this approval is that it

21

should be marketed responsibly from the perspective

22

of not creating these disparities and having

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1

Truvada be a drug for poor people and Descovy be a

2

drug for rich people, or for insured versus

3

uninsured. So I think it's really important that

4

we don't oversell the elements of noninferiority.

5

From the perspective of transgender

6

individuals, and I'm including transwomen and

7

transmen who have sex men on that list, I think

8

more data are necessary. I think that in the same

9

breath that we're going to probably discuss women,

10

we should also discuss transwomen and transmen and

11

the need and responsibility to actually get more

12

robust data.

13

Historically, the answer it's hard to do has

14

created a lot of disparity and mistrust of both

15

public health and research among transgender

16

individuals, so we need to work with strategies to

17

go beyond that rather than to stay with that.

18

Ultimately, then I think with the caveat of work to

19

do in the transgender population, I stand by my

20

vote of yes for noninferiority men who have sex

21

with men.

22

DR. GIORDANO: Tom Giordano. I voted yes

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1

largely for the reasons that have already been

2

stated. I agree completely with the comments

3

already made. I will comment that I am not

4

convinced that we have enough data to say anything

5

about transgender women.

6

However, I did vote yes on that, including

7

that language, mainly because the biological

8

similarities is anal receptive sex primarily is the

9

risk factor. So I agree that there's sufficient

10

evidence, that that population probably would be

11

protected with this noninferior drug.

12

DR. DODD: Lori Dodd, and I voted no because

13

the question had the term "men and transgender

14

women," so my concern is really related to

15

transgender women. I agree with the comments said

16

previously, so I won't articulate further.

17

DR. BADEN: Dr. Walker?

18

DR. WALKER: Dr. Walker here. I voted no

19

for all the reasons that were expressed. According

20

to the CDC, more than 290,000 African Americans

21

with stage 3 HIV have died since the inception of

22

the HIV epidemic. As African Americans remain

A Matter of Record (301) 890-4188

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1

disproportionately at risk for HIV, with gay and

2

bisexual men and heterosexual women being affected

3

more than any other race ethnicity, there was not

4

substantial or compelling evidence to indicate the

5

safety and effectiveness of Descovy for PrEP to

6

reduce HIV infection among this population. So

7

that's why I voted no.

8

As a public health researcher and a

9

community advocate, and an African American

10

heterosexual woman, I have alarming concerns

11

regarding the safety of Descovy, as well as the

12

sexual behaviors that will result from individuals

13

taking this drug. There was a lost opportunity to

14

provide data, substantial data, that is reflective

15

of the community in which its greatly impacted by

16

HIV. Furthermore, the data from the DISCOVER trial

17

failed to enough data on the prevention of HIV in

18

cisgendered women.

19

DR. BADEN: Thank you. Dr. Le?

20

DR. LE: I voted yes for this, for the

21

reason that the drug combination has demonstrated

22

noninferiority to Truvada and offers an alternative

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1

for PrEP, which is critical in light of data

2

showing that only 7 percent of CDC's estimate of

3

1.1 million people in the United States with PrEP

4

indication actually received PrEP. Also, Descovy

5

may offer potential advantages of reduced bone and

6

renal toxicity. Despite voting yes, I do agree

7

that we need more information on transgendered

8

women.

9

DR. BADEN: Thank you. Dr. Burgess?

10

DR. BURGESS: Tim Burgess. I voted yes. I

11

think that data from the DISCOVER trial met the

12

noninferiority to Truvada, and just that, in men

13

who have sex with men.

14

DR. BADEN: Dr. Ofotokun?

15

DR. OFOTOKUN: Igho Ofotokun. I voted yes

16

for the same reasons that have been expressed by my

17

fellow committee members. I am convinced that

18

Descovy is noninferior to Truvada, and I think it

19

should be emphasized that this is a noninferiority

20

study.

21

Even though I voted yes, I am particularly

22

very concerned about the low number of non-white

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1

participants in this study, and that should be

2

noted. I think if this moves forward, the agency

3

should strongly recommend a postmarketing study

4

that really include all this population, especially

5

men who have sex with men, black men who have sex

6

with men, who are most affected by this epidemic in

7

the U.S.

8

Again, I think, as has been expressed,

9

there's not enough transgender women to be able to

10

make a strong recommendation, but I believe, based

11

on the data, that it will be effective. And again,

12

this is another population that should be studied

13

should this approval move forward.

14

I think we should also emphasize the side

15

effects related to Descovy. It's sold as a safer

16

drug. I may be safer in some aspects, but there

17

are other aspects. For instance, the lipid profile

18

of Descovy is definitely something that should be

19

emphasized, and I am still concerned that the jury

20

is not yet out on the weight gain issue with TAF.

21

Thank you.

22

DR. BADEN: Thank you.

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1

Lindsey Baden. I voted yes. We'll just

2

highlight some key issues. The continuum of the

3

body of evidence from the prior studies with

4

Truvada, with DISCOVER, it's a continuous set of

5

data that work well together and are very

6

reassuring that in MSM, it works very well.

7

I share the concerns in the population

8

studied, that's where we have the data.

9

Transgender were a very small subset, and then

10

other ethnic and racial backgrounds also have

11

limited representation, so that will just have to

12

be part of the consideration to grow the data set.

13

I think the weight and the lipids are not

14

trivial issues and can become significant over

15

years of treatment and perhaps consequence or not,

16

but that's where data and follow up will be

17

required.

18

Dr. Weina?

19

DR. WEINA: Peter Weina. I voted yes. I

20

believe there is substantial evidence of the safety

21

and effectiveness to reduce the risk of

22

sexually-acquired HIV in the indicated population.

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1

Ignoring all the background politics, potential

2

gamesmanship, market pressures, whatever, this is

3

another approved product in our toolbox that gives

4

clinicians an option that we didn't previously

5

have.

6

While no package is ever ideal for all

7

potential patient populations, it actually was nice

8

to see a trial that was reasonably powered given

9

the targeted population, and in time when even more

10

is known about it, available to all patient

11

populations.

12

DR. BADEN: Dr. Green?

13

DR. GREEN: Michael Green. I voted yes. I

14

thought the data as presented clearly met the

15

criteria for noninferiority and have an equivalent,

16

if not superior, safety profile, though the impact

17

on lipid metabolism and weight gain might balance

18

out the bone density and renal benefits if they are

19

real. With the caveat that the study did not

20

include enough transgender women to allow subset

21

analysis, the study was generally well designed,

22

including a large cohort and robust follow-up.

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1

If approved, the label should clearly

2

highlight the noninferiority performance of F/TAF

3

and not infer superiority. Safety claims should

4

highlight not only the potential benefits in terms

5

of renal and bone density but also the potential

6

increased risk related to lipid metabolism and

7

weight gain and obesity. Thank you.

8

DR. BADEN: Thank you. Not yet,

9

Dr. Gripshover. We have Dr. Lupole on the phone.

10

Do you have?

11

MS. LUPOLE: [Inaudible - distortion]

12

DR. BADEN: We're having trouble hearing

13

you. Now we can hear you.

14

MS. LUPOLE: All right. Can you hear me

15

now? [Inaudible - distortion].

16

DR. BADEN: That may not be working well.

17

Mute your computer while you speak is the advice

18

I'm given.

19

MS. LUPOLE: I'm sorry. What, sir?

20

DR. BADEN: That sounds good. What you just

21

did worked.

22

MS. LUPOLE: Okay, good. I voted yes. I

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1

have concerns for transgender. I think more data

2

needs to be collected, but yes is the answer to the

3

question the way it was presented.

4

DR. BADEN: Thank you. Dr. Gripshover?

5

DR. GRIPSHOVER: I also voted yes. I

6

believe the DISCOVER trial showed the efficacy and

7

safety of Descovy to reduce the risk of HIV

8

acquisition in men. I think it's a little bit of a

9

stretch for transgender women, but I also agree

10

it's the same biologic, at least method, of

11

acquisition. But I think a small amount, but

12

statistically significant improvements in bone

13

mineral density and renal tubular function in TAF

14

versus TDF may be important in young adults

15

building bone and older ones losing it, or those

16

with other comorbidities and renal function.

17

However, for the vast majority of people,

18

TDF/FTC is safe, and I would not want those without

19

access to TAF due to geography or cost to forego

20

its benefit as PrEP, and I think we need to

21

emphasize that this was a noninferiority study.

22

DR. BADEN: Dr. Siberry?

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1

DR. SIBERRY: George Siberry. I voted yes.

2

Like many before me, I think the trial adequately

3

provided evidence for a claim for noninferiority as

4

an alternative, both from an efficacy and a safe

5

clinically meaningful safety standpoint. I'd add

6

that the claim would include adolescence. I

7

strongly support the use of weight without age down

8

to 35 kilos and accept the ability to extrapolate

9

for adolescents in that claim. Thank you.

10

DR. BADEN: Dr. Swaminathan?

11

DR. SWAMINATHAN: Yes. I agree that there

12

was evidence of noninferiority as far as the

13

efficacy in MSM, but that the numbers were

14

insufficient to draw a clear conclusion about

15

transgender women.

16

Nevertheless, because I think the number of

17

variables that would have to be controlled for the

18

number of patients that would have been required to

19

be enrolled wouldn't really been feasible, and I

20

agree that it may have to depend on postmarketing

21

evaluations. But the way the question was phrased,

22

I agree that they did provide substantial evidence

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1

of efficacy.

2

DR. BADEN: Dr. Cheever?

3

DR. CHEEVER: Laura Cheever. I voted yes,

4

and I think there is adequate evidence through the

5

DISCOVER trial for noninferiority. I am disturbed

6

that this far into the epidemic and this many

7

clinical trials, we still can't do trials in the

8

people most at risk in this country,

9

representatively, and that we really do need to be

10

looking at African Americans.

11

I echo other people talking about the lack

12

of transgender women really represented in this

13

trial. Once again, that needs to be looked at to

14

better understand the efficacy or noninferiority in

15

that population.

16

DR. BADEN: Thank you.

17

For question 1, it was 16 to 2, but even

18

those who voted no, there was a large consensus in

19

viewpoint that the data do support efficacy.

20

However, it's in the population studied, and there

21

was limited power in transgender and other key

22

populations, as well as some safety signal in

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1

weight and lipids.

2

Those will all have to be carefully followed

3

and monitored in a postmarketing setting. The

4

database expanded in the key at-risk populations,

5

especially the transgender, and it's a

6

noninferiority, not superiority, on either of the

7

key issues.

8

Now we can move to question 2. Do the data

9

from the DISCOVER trial, in combination with the

10

available pharmacokinetic data and other previous

11

HIV-1 prevention trials with Truvada in cisgender

12

women, allow for the expansion of the DISCOVER PrEP

13

indication to include cisgender women?

14

If yes, please provide your rationale. If

15

no, please provide your rationale and list what

16

additional studies/trials are needed. Also comment

17

on the trial designs that would be adequate to

18

expand the indication. Please provide any

19

additional comments or thoughts on your vote.

20

Any questions about the question?

21

Dr. Siberry?

22

DR. SIBERRY: It's not simply asking whether

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1

we would support expanding the indication, but

2

specifically saying do we think that the data are

3

the reason that we would expand it? Am I reading

4

that right? Because it's a little nuance there, I

5

think.

6

DR. BADEN: My read of this -- and the

7

agency can please correct me -- is do we believe

8

there are data establishing substantial efficacy

9

and safety in this population, which is cisgender

10

women, given the totality of the information

11

provided.

12

Is that the intent of the question?

13

DR. MURRAY: Yes.

14

DR. BADEN: Does that answer your question?

15

DR. SIBERRY: Yes.

16

DR. BADEN: If no other questions, then

17

let's vote.

18

(Voting.)

19

DR. HOTAKI: The online voter is being

20

handled; all done.

21

One more person needs to vote, so if

22

everyone can press theirs again.

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1

DR. BADEN: Everyone repress your button.

2

(Pause.)

3

DR. HOTAKI: For the record, the vote is 8

4

yes, 10 no, zero abstention, zero no voting.

5

DR. BADEN: Please state your name and your

6

vote into the record. We'll start with

7

Dr. Cheever.

8

DR. CHEEVER: Laura Cheever. I voted no. I

9

really think that the company's demonstrated

10

difference in metabolism in TDF and TAF, and we

11

really do not know the protective factors for PrEP,

12

exactly how it works in the mechanisms. I know

13

that we do know that we have differences in

14

immunologic milieu between the vagina and the

15

rectal mucosa, so I have real concerns there about

16

what has been shown.

17

That said, I wanted to vote yes because the

18

thought of not having this indicated for women I

19

think will only further inhibit the implementation

20

of PrEP among women. So from a public health

21

perspective, I think there's probably more harm

22

than good not approving it for this indication, but

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1

that wasn't the question that was asked.

2

So that's sort of how I split that. We've

3

talked about it all day long. The failure to

4

implement PrEP in women is huge. We keep glossing

5

over it and trying to just get to the adherent

6

women and throwing out all the rest, and I think

7

that is the wrong conversation to be having.

8

It's really about why women and why

9

transgender persons in youth and what we can do to

10

better get them to have protective effects of PrEP,

11

and whether that's different modalities or whatever

12

is part of that larger discussion that we weren't

13

having today.

14

DR. BADEN: Dr. Swaminathan?

15

DR. SWAMINATHAN: I voted no because -- I'll

16

just go through the reasons here. I think as far

17

as the question as to what the data allowed you to

18

conclude is what's key here. The cells that are

19

being infected in the vagina and cervix versus

20

those in the rectal or penile mucosa are not

21

clearly defined.

22

So although virus transcytosed in the

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1

mucosal epithelium must infect dendritic or CD-4

2

cells resident in all tissues, the resident target

3

cell population at the time of exposure is the

4

local pool of T lymphocytes. This pool is known to

5

be relatively static, and more so in vaginal

6

tissues than in the GI tract. They are also

7

long-lived and replenished by local expansion.

8

Thus, the PK and PD in these lymphocytes may

9

not be the same as those in the peripheral blood or

10

other anatomic sites. We just do not know. Thus,

11

the relative efficacy of TAF and TDF may differ

12

between rectal and vaginal tissues and between MSM

13

and cisgender women.

14

Measurements of tissue drug levels in this

15

context is not particularly relevant. As unlike

16

with PBMCs, the levels are not being measured

17

primarily in cells that are infected but by rather

18

in bulk populations of extremely heterogeneous

19

cells from biopsies. And while there's evidence

20

that the safety profile of TAF may be superior,

21

particularly for long-term use, this has to be

22

balanced against the possibility of inferior

A Matter of Record (301) 890-4188

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1

efficacy.

2

In this situation, a relative lack of

3

efficacy may translate into a currently incurable

4

infection. Thus, one has a potential choice

5

between long-term morbidity versus immediate risk.

6

Nevertheless, I do not believe that we can state

7

with scientific validity that TAF/FTC is as

8

effective as TDF/FTC in cisgender women for PrEP.

9

Extrapolation from one group to another is

10

defensible if there is no scientific reason to

11

believe that there could be pharmacokinetic or

12

pharmacodynamic differences between the two groups.

13

That is not the case here, and therefore the

14

basis for extrapolation from TDF to TAF in

15

cisgender women is not obvious. The absence of

16

actual clinical data in this group combined with

17

the potential difference in the site of exposure,

18

and other potential gender-based biological

19

co-factors, do not allow me to recommend labeling

20

this drug as effective in cisgender women.

21

I do not believe the drug should be approved

22

or labeled without adequate evidence merely because

A Matter of Record (301) 890-4188

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1

doing the necessary clinical studies would be

2

challenging. The alternative is to potentially

3

expose segments of the population who are

4

underrepresented in studies to ineffective therapy.

5

DR. BADEN: Dr. Siberry?

6

DR. SIBERRY: George Siberry. I voted no.

7

I think that there's good evidence of a biologic

8

correlate of adherence. I remain unconvinced that

9

we have a good biologic correlate for protection.

10

For the reasons Dr. Swaminathan said, I think it is

11

inappropriate to extrapolate to women. However, I

12

feel like we have failed women by letting this

13

application come in without data from women to

14

begin with, and I fear we're failing them again by

15

having approval for use in men and not women.

16

That's why I asked for that clarifying

17

question about the question because I think these

18

are two different things, and I would be supportive

19

of an indication that includes women with a strong

20

postmarketing requirement for clinical evaluation

21

in women. Thank you.

22

DR. BADEN: Dr. Gripshover?

A Matter of Record (301) 890-4188

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1

DR. GRIPSHOVER: Hi. Barb Gripshover. I

2

also voted no. I do not believe the data support

3

TAF/FTC efficacy as PrEP for women, as it's not

4

been studied in that population, and I don't think

5

it's clear that just the level of tenofovir

6

diphosphate in PBMCs is the sole determinant of

7

efficacy in women at risk for cervical vaginal

8

infections or the reasons the gentlemen have just

9

said.

10

I believe there is a large unmet need of

11

women at risk of acquiring HIV worldwide that

12

should be able to engaged in studies to answer this

13

question; maybe using matched geographic

14

demographic incidence rates as a control or

15

incidence in screening that has been suggested.

16

While I do not like the idea of approving a

17

drug for a single population, as it does look

18

effective in MSM, I also think we are obligated to

19

base our recommendations for use of a drug based on

20

data. Women in underserved populations deserve our

21

best efforts to make sure drugs are effective and

22

safe for them as well before we start recommending

A Matter of Record (301) 890-4188

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1

it in lieu of one that has demonstrated safety and

2

efficacy.

3

So if the drug is approved for MSM, then I

4

would absolutely require a strict efficacy setting

5

in women as part of the agreement.

6

DR. BADEN: Wait, Dr. Green. Dr. Lupole?

7

(No response.)

8

DR. BADEN: You're on mute if you are

9

talking.

10

(No response.)

11

DR. BADEN: Okay. We may have lost the

12

connection. We can try to bring Dr. Lupole on.

13

MS. LUPOLE: Can you hear me now?

14

DR. BADEN: We can hear you now.

15

MS. LUPOLE: Okay. Sorry about all this.

16

I voted no as well. The lack of data, the

17

lack of study participants, conflicting data, it's

18

my recommendation that the trial for this drug in

19

cisgender women and juveniles be redesigned to

20

examine the impact because it's clear it's not been

21

presented to me that it would be safe and

22

effective. Thank you.

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1

DR. BADEN: Thank you. Dr. Green?

2

DR. GREEN: Michael Green. I voted yes, but

3

I almost abstained and I almost voted no.

4

(Laughter.)

5

DR. GREEN: With regards to extension of

6

approval to cisgender women, the key concern of the

7

FDA appeared to have been relating to the tissue

8

level in vagina and cervix, and that those

9

associated with TAF were lower than TDF.

10

Therefore, the absence of a trial in cisgender

11

females directly to confirm efficacy, they're

12

asking us if we can extrapolate to extend approval

13

based on the DISCOVER population.

14

However, the data that was presented suggest

15

that TDF also has low levels, both at 4 four hours,

16

and at 24 hours, and 48 hours, and yet F/TDF

17

carries an approval in men, women, and adolescents

18

for pre-exposure prophylaxis against HIV and is

19

considered effective in these populations if those

20

taking it are compliant.

21

Accordingly, it's not clear that low tissue

22

levels had any impact on the effectiveness of

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1

Truvada, and it seems unlikely, at least to me,

2

that it would for Descovy. Clearly, there is not a

3

concern that intracellular levels in PBMCs would be

4

different between men and women. We've also heard

5

the agency state that they feel challenged by

6

developing design for noninferiority studies, and

7

that there's no reason to expect a positive outcome

8

in a superiority trial, and that a comparison to

9

placebo would be unethical.

10

Given these issues, I felt it was

11

appropriate to include cisgender women in the

12

indication, especially given the equity issues that

13

have been discussed during this committee hearing.

14

Having said that, it would be important to mandate

15

postmarketing studies and this indication be

16

undertaken by the sponsor. And if these subsequent

17

studies did not bear out efficacy in cisgender

18

women, that the label be modified to reflect this

19

if not having the indication removed. Thank you.

20

DR. BADEN: Dr. Weina?

21

DR. WEINA: Peter Weina. I voted yes, but

22

the answer is really maybe. The reality is that we

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1

really don't have a clue which is the appropriate

2

surrogate marker to use. Is it the tissue level?

3

Is it potentially PBMC levels? Is it adherence

4

that's the key? Or is it more likely something we

5

haven't even considered yet because we haven't

6

bothered to count it, and some revelation years

7

from now is finally going to give us that insight?

8

Right now, it seems like the surrogate

9

marker selected depends upon which opinion you'd

10

like to have supported, and the science behind it

11

is whichever you select, and that seems very

12

whimsical. So I reach back to the FDA's mission

13

statement, and the mission statement is to promote

14

and protect the public health by helping safe and

15

effective products reach the market in a timely

16

manner and monitor the products for continued

17

safety after they are in use.

18

This product is already out there for

19

treatment. It's already being demanded by patients

20

who are subjected to social media pressures, and

21

this is only going to accelerate. I have

22

absolutely no doubt that this is already being used

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1

in cisgender women somewhere here in the United

2

States, and it's not being followed.

3

We should follow the FDA's mission statement

4

to get this to the market for the broadest

5

population possible and reasonable, and then

6

monitor the product for continued safety. Here of

7

course, I'm referring also to the efficacy because

8

if it doesn't work, then it's putting the users at

9

risk.

10

If approved for MSM and transgender women,

11

it's definitely going to be used either off label

12

or on label in adolescents and in cisgender women

13

just because of the perception of better safety.

14

We may as well carefully guide the postmarket

15

surveillance of this product and how well it works.

16

Clearly, we need carefully prescribed and intensive

17

postmarketing required trials.

18

DR. BADEN: Dr. Baden. I voted no. The

19

question was do we have substantial evidence of

20

safety and efficacy? There are no efficacy data

21

presented, and the historical efficacy data are too

22

strong to allow a placebo trial, but too weak to

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1

allow a noninferiority margin. So one is choosing

2

which pieces of data to use to say that we cannot

3

study this population.

4

I share the open public hearing speakers, as

5

well as Dr. Siberry's comments we have failed

6

women. To be at this point and not have the data

7

to guide decision making is a shame on all of us.

8

I feel like Arrowsmith. "We are in a desperate

9

situation, therefore let's do something because we

10

can do something."

11

There are side effects to our interventions.

12

Our interventions are not benefit with no risk, and

13

the presumption that we can benefit and not have

14

risk is also shame on us. We need to generate some

15

data to guide the risk-benefit ratio, and the road

16

traveled for prevention in women is uneven with

17

high-quality large studies done. So for us to

18

presume that the good data are the ones we should

19

hang our hat on is presumptuous.

20

I think that given the mixed historical

21

data, the absence of data with this particular

22

agent, I cannot support an indication which has

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1

efficacy. On the other hand, there should be a

2

mandated study. Whether it's mandated as part of

3

an approval or mandated in order to get approval,

4

both can be done, but it should be mandated.

5

I think once there's an approval, it's

6

impossible to undo even if there's no benefit

7

shown. If there's no approval, then the pressure

8

is to do the study, but then there are women at

9

risk who don't have opportunity to access this

10

medication. Hence, we have failed this population.

11

But I voted no because there were no data in the

12

population in question.

13

Dr. Ofotokun?

14

DR. OFOTOKUN: Igho Ofotokun. I voted yes.

15

Taking a look at the data as a whole, the Descovy

16

data and the historical data from Truvada, based on

17

data in HIV-infected individuals who are treated

18

with Descovy, I am convinced that the product is

19

just as safe in men and in women, and the big

20

question is that of the efficacy in ciswomen.

21

I tend to have some confidence in the

22

pharmacokinetic data and the correlate of Truvada

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1

efficacy. The tenofovir diphosphate correlates

2

with protection, I seem to believe that that in

3

itself provides strong compelling data that TAF

4

would be just as efficacious in ciswomen.

5

I agree that it's a terrible failure that

6

the agency as well as the sponsor would come to

7

this committee with lack of data for women in this

8

hearing. I strongly believe, like others have

9

expressed, that there should be a mandated study to

10

look at women, ciswomen, either as part of the

11

approval process or before the approval of this

12

agent.

13

I also believe that approving Descovy for

14

PrEP in men who have sex with men alone would

15

create a two-tier system. It will just accentuate

16

this equity, the equity issue that already exist;

17

that either you're going to approve it for

18

indication for prep in men and women, or you're not

19

going to move forward with it.

20

I think creating a two-tier prevention

21

treatment will not be helpful, and we should remind

22

ourselves there are more women living with HIV in

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1

the world than there are men, and that the risk of

2

new infection is significantly higher among women

3

if we look at this globally.

4

So I will stop there, and thank you.

5

DR. BADEN: Thank you. Dr. Burgess?

6

DR. BURGESS: Tim Burgess. I voted yes, but

7

as some others have said, I very nearly voted no

8

and very nearly abstained. I share concerns about

9

what we think we understand about the putative

10

mechanism of protection depending on route of

11

exposure.

12

My overarching concern was about the public

13

health impact of an indication in one population

14

and not in another population. Coupled with the

15

fairly compelling articulation of levels in PBMCs

16

as the primary, if not total component of the

17

likely mechanism of protection, led me to vote yes.

18

I, like others, articulate a strong recommendation

19

for, compelled postmarketing surveillance, focusing

20

on effectiveness in women.

21

DR. BADEN: Dr. Le?

22

DR. LE: My vote for approval in cisgender

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1

woman was largely based on three factors: one,

2

data pertaining to vaginal tissue and PBMC as

3

presented earlier by Dr. Read; two, some safety

4

data but from other studies; and three, making this

5

drug combination available as an option for women,

6

not just for men, despite the lack of efficacy

7

data.

8

However, my vote for yes is contingent upon

9

full commitment from the applicant to incorporate a

10

robust package labeling, stating that efficacy and

11

effectiveness have not been established in

12

cisgender women with the use of this product, and

13

that vaginal tissue penetration was low, and that

14

the approval was based on extrapolation of existing

15

data in other populations.

16

Also, the applicant should commit to conduct

17

robust postmarketing studies to allow for us to

18

better understand efficacy and more effectiveness,

19

as well as incorporating safety monitoring for

20

weight gain, renal function, and on fasting plasma

21

lipid levels.

22

DR. BADEN: Thank you. Dr. Walker?

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1

DR. WALKER: Dr. Roblena Walker. It was a

2

strong no for me, no wavering on the fence. I'm

3

almost highly appalled. There's about 8 women on

4

the committee, and that the agency and the

5

applicant would present insufficient data to

6

support the prevention of Descovy amongst

7

cisgendered women, or heterosexual women, or just

8

women in general, I was highly appalled that more

9

dedication and passion wasn't put into the study.

10

DR. BADEN: Dr. Dodd?

11

DR. DODD: So I voted no, and I was not on

12

the fence on this, unlike the last one. My concern

13

is about confusion or a lack of trust that might be

14

generated by an approval that wouldn't be supported

15

by strong science. We can't approve something just

16

because there's a need.

17

I also want to commend the agency for their

18

good discussion about surrogacy. I think this is

19

often a confusion in reviews of studies. There are

20

lots of reasons why a good correlate of protection

21

may fail as a surrogate endpoint for the clinical

22

benefit endpoint. In this case, the clinical

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1

benefit endpoint is protection.

2

A correlate does not a surrogate make, and

3

we've seen data to support PBMCs as a good marker

4

of protection and women -- or we've not seen the

5

data; excuse me. And I thought the agency did a

6

good job of providing some reasonable arguments

7

about why PBMCs may not be a good marker of a

8

clinical benefit endpoint.

9

I think there probably should be both data

10

related to the biological mechanism supporting

11

additional surrogacy studies -- this looks like

12

more studies on tissue concentrations -- and

13

additionally, studies in ciswomen with an actual

14

clinical benefit endpoint of protection.

15

I'm not convinced that there's not a study

16

design out there that could be considered that

17

would support this. I don't know that it would

18

have to be something as large as a 20,000

19

participant study, but I think it's time to put

20

some creative heads together and think of some

21

feasible designs.

22

DR. BADEN: Dr. Giordano?

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1

DR. GIORDANO: Tom Giordano. I voted no.

2

It pains me to say that. I really wanted to vote

3

yes because I believe there is the potential for

4

creating two systems, and one drug for the rich,

5

one for the poor, one for men, and one for women, I

6

think that's a horrible precedent.

7

Nonetheless, the FDA's approval, to me,

8

means we know this drug is safe and effective. I'm

9

convinced we know this drug is safe in women, no

10

doubt about that, but is it effective? That

11

remains a hypothesis. And given that there's

12

different biology involved between men and women

13

and the acquisition of HIV in men and women, I

14

think you need efficacy data, and it just boils

15

down to that for me.

16

I think that we're in this position is

17

absolutely horrible, but that's the position we're

18

in. So I don't envy the agency's ultimate

19

decision, but, to me, there is no way you can say

20

this drug has efficacy in cisgendered women. And

21

who's to blame for that? That's not my decision.

22

DR. BADEN: Dr. Daskalakis?

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1

DR. DASKALAKIS: Demetre Daskalakis. I

2

voted yes. I think that there are a couple of

3

reasons. First, we have limited success with

4

topical agents that we know of to prevent HIV, and

5

I think we've seen data that intracellular levels

6

of drug seem to be protective, so that in

7

combination with what I thought was a pretty

8

convincing explanation for the role of a PBMC

9

level, intracellular level, and prevention made me

10

feel that I had enough evidence to recommend that

11

you consider approval for this drug for cisgender

12

women.

13

Now, I would put the caveat that labeling

14

would be very critical if it does come out like

15

this, so I think it would need to be an alternative

16

agent for women in certain clinical scenarios. And

17

I also think that it would be important to state

18

that there has not been an efficacy study done.

19

Now, from the safety perspective, I agree with what

20

everyone else has said, that I think safety has

21

been demonstrated by other studies, and that's not

22

really much of a debate.

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1

I also want to say that I don't think the

2

approval of this drug would increase PrEP uptake

3

among women. So bottom line is that's not the

4

problem, at least in the U.S. The size of the pill

5

and the marginal improvement in bone and kidney

6

outcomes, not the problem.

7

The problem is that patients and providers

8

are unable to do appropriate assessment of who

9

needs PrEP, and I'm just concerned that creating

10

the tiered system that we may be creating if we

11

don't approve the drug for women will create even

12

more confusion with providers and poor advice to

13

their female patients who are considering PrEP, so

14

that makes me very concerned.

15

I think a mandatory study, no matter what,

16

whether it is after approval or preapproval,

17

requiring that is critical, and that needs to help

18

answer this question about intracellular level

19

versus mucosal level. So really good science that

20

looks at the role of mucosal levels of tenofovir in

21

women will be critical.

22

I also recommend thinking about coupling the

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1

transgender female study with a women's study since

2

they are women, and that probably is a better way

3

to actually convince folks to enter the study. I

4

bet you one reason you can't recruit a transgender

5

study is because it says MSM, and that's not going

6

to work.

7

Another thing I just want to bring up

8

briefly is the precedent for extrapolating data.

9

We have U.S. preventative health services

10

recommendations that PrEP is an A recommendation,

11

and there is a line in there that says that

12

tenofovir could potentially be used as monotherapy

13

to prevent PrEP in women and heterosexual males and

14

females, and injection drug users.

15

I do not see us having a conversation about

16

using a generic, cheaper agent and extrapolating

17

that data to men who have sex with men, so we could

18

actually pour PrEP onto the entire country and be

19

less concerned about cost. So as we're having this

20

conversation about an expensive new drug, I would

21

encourage the agency to consider looking back at

22

the Bangkok PrEP study, at TDF2, at Partners PrEP,

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1

and ask the question, should we be asking the same

2

thing about a drug that could cost as less as $5 a

3

month? Thank you.

4

DR. BADEN: Thank you. Dr. Read?

5

DR. READ: Sarah Read. I voted yes, but

6

with a lot of the same hesitations that have been

7

expressed by the other members who voted yes. Just

8

to be clear, I also agree that it's extremely

9

disappointing to be in a situation in which there

10

are no clinical efficacy data in cisgender women, a

11

population clearly in need of more effective

12

prevention choices and in whom much remains to be

13

learned regarding acceptability and preferences for

14

prevention choices. However, I felt in this case

15

that it was reasonable to extrapolate data from the

16

DISCOVER trials as well as previous prevention

17

trials with Truvada.

18

In terms of safety, although cisgender women

19

were not included in the DISCOVER trial, I think

20

it's reasonable to extrapolate safety from the

21

study participants, as well as the large experience

22

in treatment of women with HIV. And based on

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1

treatment experience, I think that it's unlikely

2

that the safety profile will differ in cisgender

3

women relative to men.

4

In the absence of clinical efficacy data in

5

cisgender women and the question of the relevance

6

of PK in different compartments being not entirely

7

clear, extrapolation of the efficacy of cisgender

8

women is certainly not straightforward.

9

Although the collective data regarding PK

10

levels and correlation of clinical efficacy of oral

11

PrEP contain mixed results, I think it's reasonable

12

to extrapolate the clinical efficacy seen with

13

Truvada and Partners PrEP in cisgender women on the

14

basis of the data provided by the applicant,

15

indicating higher levels of TDF diphosphate in

16

PBMCs with F/TAF compared to Truvada.

17

PK data provided by the applicant on

18

cervical vaginal tissue levels, however, is less

19

clear given the number of samples that are

20

unevaluable. However, it's also unclear what

21

levels are required in this tissue. I therefore

22

think these data should largely be disregarded.

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1

I think it would be problematic to approve

2

an indication in men who have sex with men alone

3

without including women. Such a limited indication

4

and subsequent delay in access for women for many

5

years would be untenable and an unfair situation.

6

Consideration, therefore, I think should be given

7

either to the approval with a broader indication to

8

include women or no approval at all until evidence

9

of adequate efficacy can be achieved in that

10

population.

11

If an indication to include cisgender women

12

is approved, like others, I recommend strongly that

13

the applicant be required to perform trials to

14

collect both safety and effectiveness data in this

15

population. Not only is the effectiveness

16

important, but also the safety profile in this

17

population needs to be further supported.

18

I think it's important that the company has

19

attested and pledged that they will perform these

20

trials, and I think it's up to the agency to

21

require them to do so.

22

DR. BADEN: Thank you. Dr. Smith?

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1

DR. SMITH: I feel like we're moving

2

backwards from the 2012 meeting that approved

3

Truvada, in which there was a lot of discussion and

4

concern that we had data on African women and not

5

on African American women. And now we don't have

6

data on women at all. The decision has been made

7

that we'll do the trial in MSM, and then we'll

8

figure out what it means for women rather than

9

studying women themselves.

10

I find that bad science, and that's why I

11

voted no, but I also find it disrespectful and an

12

issue of sort of research equity. Women deserve

13

the same quality of data about the safety and

14

efficacy of the drugs that they're exposed to that

15

men get, and that's not the situation we find

16

ourselves in at the moment.

17

I also think that because we have Truvada

18

approved for women, we're not denying women access

19

to PrEP, and it's important to remember that. What

20

we are doing is saying that a second drug that is

21

similar in risk and benefit is available to one

22

population but not another, yet, based on the data

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1

that we have. I think that's preferable to

2

approving it, doing an efficacy study and somebody

3

suggested maybe taking it back or modifying it if

4

it doesn't work out as well.

5

That's a recipe for disaster among the

6

African American community if we get ourselves into

7

a situation where we're approving something and

8

then saying, oh well, no, actually we weren't

9

right; that didn't work, so I wouldn't even think

10

about doing that.

11

I think the other thing is that even though

12

we think about the fact that it may be hard to

13

explain why this is for this group and not for that

14

group, if the proper studies are done in the short

15

term over the next three or four years to get the

16

kinds of data that is missing, then we'll be in a

17

position to say whatever is appropriate about

18

women.

19

I think we are going to increasingly in the

20

PrEP field have this situation of some things are

21

for some people and other things are for other

22

people. Whether that's the dapivirine ring, if

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1

that becomes approved, that's surely not going to

2

be for all populations. I know we're nervous about

3

what that means when we suddenly have to start

4

making decisions, but I think this is not the

5

occasion in which that should overrule the absence

6

of data on efficacy for women as the basis for our

7

decision.

8

DR. BADEN: Dr. Goetz?

9

DR. GOETZ: Matthew Goetz. I did vote yes,

10

and I think I'm like the other 8 people who voted

11

yes. I do not hear a strong ringing endorsement

12

from anyone of strong data. I read the statement,

13

"allow for expansion" as a liberal statement,

14

"allow for expansion."

15

I thought critically about what we know

16

about surrogate markers, correlates of protection.

17

I think "correlate" is the right word in many

18

regards. The fact of the matter is that we will

19

need a phase 4 mandated clinical trial to

20

substantiate that this is I think an alternative,

21

and in any guidelines, documents, that are produced

22

by other societies, the strengths and weaknesses of

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1

this, the conditional nature, and this is an

2

alternative needs to be very clear.

3

I felt very strongly that I'm not sure that

4

tissue markers are the surrogate either. As has

5

been pointed out by many individuals, when we

6

biopsy, first of all, we get very limited samples.

7

It's not robust. Secondly, the cells that we

8

sample are not likely the relevant cells. So we

9

either need robust data showing across levels of

10

different adherence, and we want everyone to be

11

adherent of course.

12

Inevitably, some people are going to be less

13

adherent, and we need to be able to correlate if

14

we're going to substantiate in any way. PBMCs show

15

that the correlate between PBMC and protection is

16

similar across all the relevant risk groups, and I

17

think that will go a long ways to demonstrating

18

what we need to show here.

19

Perhaps finally -- I can go on for a lot

20

long longer -- I think adherence is a crucial

21

measure. What we have in this drug and the study

22

we have in DISCOVER is a population that was

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1

extraordinarily adherent. That's wonderful, but we

2

need to be clear that we want to really emphasize

3

adherence throughout. TAF may have a longer

4

half-life than plasma in cells, but that is not to

5

be taken as any opportunity to be less adherent;

6

phase 4 studies absolutely mandated.

7

DR. BADEN: Thank you. There you have it, 8

8

to 10 vote. The three key principles as I hear it,

9

because I will summarize the yes and the nos

10

together, the correlate is unclear and perceived

11

differently. The optics of approving for

12

population A but not population B has many

13

deleterious effects if done or not done. Everyone

14

agrees there needs to be actual data.

15

So then the challenge -- and I'll be

16

presumptuous, but I'll speak for the committee, and

17

to the agency, and to the applicant -- can you

18

please do the study as quickly as possible? And

19

it'd be designed -- I don't accept that it's too

20

hard, too big, too difficult.

21

There should be a way to do some type of

22

study systematically in a reasonable amount of time

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1

if there's collective will to generate data

2

expeditiously, and that will be the best way to

3

minimize the optics of some of the concerns raised.

4

Many of us believe that this should work and will

5

work, but we cannot have belief guide policy or

6

regulatory pathway.

7

So that is the voting segment. We have run

8

15 minutes over. I would like to take 5 minutes to

9

discuss the last question, and that will be an open

10

discussion unless the agency advises me otherwise.

11

The open discussion is please discuss whether the

12

data from the DISCOVER trial are relevant to

13

at-risk men who practice insertive vaginal sex with

14

cisgender women.

15

I'll open the discussion and look for

16

disagreement or augmentation. There are many

17

aspects of insertive vaginal sex that have elements

18

that are analogous to MSM in the sense of the

19

biology of how the drug works and the nature of the

20

exposure. We weren't able to extract out MSM with

21

only insertive, but presumably there will be some

22

of that in the population -- it was a large

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1

population -- and the biology in the prior

2

experience is such that I don't think it's

3

unreasonable to think that it's likely to work in

4

that population.

5

But I would like other comments from the

6

committee as to if others agree that it should

7

likely work in that population or if there are

8

concerns as to why it may not.

9

DR. SWAMINATHAN: Just to make clear, we're

10

talking about HIV, uninfected men having sex with a

11

discordant partner, female partner.

12

DR. BADEN: Yes, and circumcision has not

13

been addressed, but presumably the other preventive

14

strategies will be maximally encouraged.

15

Dr. Siberry?

16

DR. SIBERRY: I agree with your general view

17

that this can be extrapolated, but I do think that

18

the data should be looked at more carefully from

19

the DISCOVER trial. They enrolled people who had

20

condomless anal sex, not just condomless receptive

21

anal sex. So I think if they had collected

22

information about practices, you may be able to

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1

segregate those practices, predominantly insertive

2

sex from those who didn't, look at it stratified by

3

condoms, and see if there was a difference in the

4

protective -- the levels of infection in the two

5

arms.

6

Granted, the overall infection risks are

7

probably lower in both arms of that group if you

8

limit it to those, but I think we should ask for

9

additional scrutiny of data.

10

DR. BADEN: And perhaps new data to actually

11

look at that population.

12

DR. SIBERRY: Yes.

13

DR. BADEN: Dr. Gripshover?

14

DR. GRIPSHOVER: I'm sorry. I didn't

15

realize there's still a vote, but I do think the

16

fact that 44 percent were umcircumcised means that

17

at least there was a group that had not yet even

18

used that other protective mechanism, so that's I

19

think helpful, too.

20

DR. BADEN: Dr. Weina?

21

DR. WEINA: Given the way the trial was

22

enrolled, the data's just not there. So I'm not

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1

sure that you can actually extrapolate anything

2

from that trial.

3

DR. BADEN: So what is your view, then, on

4

the applicability to men who have vaginal sex?

5

DR. WEINA: I think it's just like -- well,

6

in my patient population, I have individuals that I

7

have in my patient population that are at high

8

risk, and in heterosexual relationships, and come

9

to me and are actually on Truvada for preventive

10

reasons, but the data is not really there to

11

support it. It just makes sense based upon the

12

data that is out there.

13

So there's an extrapolation because the

14

individual is at very high risk, and everything

15

that we can do to help prevent it is going to be

16

something that's worthwhile as long as they're

17

properly informed as to the risks associated with

18

taking the medication as well.

19

DR. BADEN: Well, let me push you a little

20

bit on that --

21

DR. WEINA: Sure.

22

DR. BADEN: -- in that if you have MSM who

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1

have insertive and receptive, presumably the

2

insertive risk would be similar to the insertive

3

risk in non-anally receptive.

4

DR. WEINA: Agree.

5

DR. BADEN: So therefore, if data suggest

6

that it works in that population, even those not

7

specifically pulled out, that would be suggestive

8

that it is likely to work in that population.

9

DR. WEINA: so again, just like I was

10

talking about before, suggestive and correlates and

11

surrogate markers and everything else are --

12

DR. BADEN: Although, I think it's a little

13

different. These are human data --

14

DR. WEINA: True.

15

DR. BADEN: -- in men who are in study on

16

drug and not getting infected.

17

DR. WEINA: True.

18

DR. BADEN: This is not extrapolating from

19

assays that we're not completely sure what they

20

tell us with a correlate, that we're not sure what

21

it tells us in 5 people.

22

DR. WEINA: True. So given the potential

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1

outcome of not putting the individual on Truvada,

2

when they come to me with exceedingly high risky

3

behavior with multiple unknown partners on a

4

regular basis, I inform them of the risks

5

associated with it and the potential benefits --

6

DR. BADEN: And the limitations of the data.

7

DR. WEINA: -- and allow them to make the

8

decision.

9

Dr. Daskalakis?

10

DR. DASKALAKIS: Just fusing this issue a

11

bit with the issue about the need for a study in

12

women, it seems as if there's a need for another

13

serodiscordant heterosexual study like a Partners

14

PrEP but that uses this drug.

15

DR. BADEN: Although part of a challenge

16

there is treatment as prevention.

17

DR. DASKALAKIS: Right, but still --

18

DR. BADEN: But still --

19

DR. DASKALAKIS: There's an environment

20

where it's still feasible with lower edge

21

retroviral uptake, so it wouldn't necessarily

22

launch that study --

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DR. BADEN: But generating the data makes

2

sense.

3

DR. DASKALAKIS: But I think that there's

4

other parts of the world where you can have

5

serodiscordant couples and follow that, realizing

6

that there will be -- that the sample size will

7

probably have to be bigger and the effect may be

8

smaller.

9

DR. WEINA: But the point is that there are

10

parts of the world in which this could be done just

11

like we do malaria studies in other parts of the

12

world because we haven't got a whole lot of malaria

13

here in the United States to get new drugs

14

approved.

15

DR. BADEN: Dr. Swaminathan?

16

DR. SWAMINATHAN: I guess the difference to

17

me is that there's a little bit more that you can

18

extrapolate from. You have data in discordant

19

couples where the woman is positive that tenofovir

20

works, and MSM couples it works, and we have

21

evidence that TAF works in MSM couples.

22

So now you're just sort of bringing in the

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1

fourth variable or a mix of those two variables to

2

say, well, TDF works for this situation and TAF

3

works for this situation, and TDF also works for

4

this situation, which is -- you can sort of

5

extrapolate a little bit more from that, that you

6

would expect the person who was protected by TDF in

7

the Partners study to be protected by TAF in the

8

future.

9

DR. BADEN: Dr. Goetz?

10

DR. GOETZ: I think another piece of

11

supporting evidence is the incidence of gonococcal

12

urethritis and other urethritis in the patient

13

population, which I think was 15 to 20 percent

14

thereabouts. So there was substantive exposure

15

to -- evidence of insertive practices.

16

Yet, if I recollect the data properly, all

17

the cases of infection were amongst those people

18

who clearly had receptive anal intercourse. The

19

presence of the urethritis I think is a strong

20

piece of evidence in favor of the fact that there

21

was risk in the patient population.

22

DR. BADEN: Dr. Smith?

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1

(Dr. Smith gestures no.)

2

DR. BADEN: So I think that that touches on

3

a lot of the key issues around this question. Are

4

there any other issues the agency would like us to

5

address?

6

(No response.)

7

DR. BADEN: If not, then I would like to

8

thank the applicant for a tremendous amount of data

9

being presented and entertaining a lot of

10

discussion in a challenging area; the agency for

11

sharing your views in the challenge here; the panel

12

members for a robust, high energy day in covering a

13

lot of complex issues; and the public as well for

14

sharing your thoughts.

15

I'll see if the agency has any closing

16

remarks.

17

DR. BIRNKRANT: Well, I, too, on behalf of

18

our division and the agency, want to thank the

19

committee for their thoughtful discussion and

20

deliberations today. I also want to thank the

21

speakers who commented during the open public

22

hearing as well. I want to thank the company for

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1

conducting the DISCOVER study and other pertinent

2

research and for committing earlier in the day to

3

conduct a trial, or trials, in women.

4

I also want to thank the trial participants

5

as well. Lastly, I'd like to thank our staff for

6

their dedication and diligence in conducting the

7

reviews and preparing for this committee. I want

8

to leave you with a couple thoughts before we end.

9

Our review of this application continues. We have

10

not made any final determinations as of today, and

11

your comments and the discussions will greatly

12

impact our final determination.

13

Lastly, I feel like we should dedicate our

14

collective efforts to ensuring the availability of

15

safe and effective medications for all populations

16

so that the next time we meet, we can definitively

17

state that the HIV incidence in the United States

18

has substantially declined in all populations, and

19

we are moving closer to defeating this epidemic.

20

Thank you very much.

21

Adjournment

22

DR. BADEN: Thank you, and I will now

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adjourn the meeting. Safe travels.

2

(Whereupon, at 4:54 p.m., the meeting was

3

adjourned.)

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