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But it does have a confidential project listed with Atomwise Also, in September 2016, Abbvie partner AiCure announced how its AI-based patient monitoring platform improved adherence in an Abbvie phase 2 schizophrenia trial. ASCO18 meeting, Celgene will have more than 66 data sets presented, including 11 oral presentations.



2 This term is defined in the GDUFA II commitment letter as the letter sent by FDA stating that a bioequivalence study protocol contains safety protections comparable to those in the applicable REMS for the RLD. FDA will update this list on a semi-annual basis. Brand companies generally do not inform the Agency whether they have made samples of the RLD available after receiving a Safety Determination Letter.

If not, what options are available for these drugs? We note that, in some cases, prospective applicants may need to submit revised protocols and complete more than one review cycle for FDA to determine that the study protocols contain safety protections comparable to those in the REMS for the RLD. In connection with GDUFA II, FDA committed to reviewing 90% of bioequivalence study protocols for RLDs subject to a REMS with ETASU within 120 days of submission date.

This is because some of the protocol reviews are still in process internally or externally (either the Agency is still reviewing the protocols, or FDA has reviewed the protocols and communicated requested protocol revisions to the prospective generic applicant and we are awaiting a protocol resubmission). Safety Determination Letters are only available for a subset of the products the Agency has received RLD access inquiries about: those that have REMS with ETASU impacting distribution. Why has FDA Issued so few Safety Determination Letters (when compared to the total number of RLD access inquiries the Agency has received)?

If FDA determines that they do, we notify the prospective generic applicant of this determination by letter. This process is described in FDA's draft guidance on How to Obtain a Letter from FDA Stating that Bioequivalence Study Protocols Contain Safety Protections Comparable to Applicable REMS for RLD (How to Obtain a Letter Draft Guidance). To address these cases, FDA developed a process for informing the RLD sponsor in writing that FDA will not consider providing the RLD for these purposes to be a violation of the REMS.

Why are prospective generic applicants having difficulty obtaining samples of the RLD in some cases? As also described below, FDA regularly refers the RLD access inquiries we receive to the Federal Trade Commission (FTC). In some cases, brand drug sponsors may use these limited distribution arrangements, whether or not they are REMS-related, as a basis for blocking potential generic applicants from accessing the samples they need.

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