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Valtrex® (valacyclovir HCl) Caplets
NDA 20-550 / S-019

  • Harry W. Haverkos, M.D.
  • Medical Reviewer


  • Fraser Smith, Ph.D.
  • Statistical Reviewer



  • Division of Antiviral Drug Products, FDA


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Presentation Outline
  • Study Design
  • Efficacy Summary
  • Virology, Safety and Behavioral Results
  • Conclusions
  • Questions for Committee


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Supplemental NDA Overview
  • Submission Date:  October 31, 2002
  • NDA Due Date: September 1, 2003
  • Dosage: Valacyclovir 500 mg qd
  • Proposed Indication:                                   To reduce the risk of transmission of genital herpes with the use of suppressive therapy and safer sex practices
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Background
Current Indications
  • Treatment of initial genital herpes                 - 1000 mg bid x 10 days
  • Treatment of recurrent genital herpes            - 500 mg bid x 3 days
  • Chronic suppressive treatment of recurrent genital herpes                                                - 1000 mg qd or                                             - 500 mg qd (alternate dose)


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Supplemental NDA Submission
A single study - HS2AB3009
  • Design      -multinational, randomized, double blind trial                   - evaluate valacyclovir for prevention of HSV-2                        - discordant, monogamous, heterosexual couples
  • Sample size: 1500 couples (4030 screened)
  • Valacyclovir 500 mg qd versus placebo
  • Treatment duration: 8 months
  • All subjects encouraged to:                                                                     - use condoms                                                                                    - abstain from sex during  HSV outbreak
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HS2AB3009 (continued)
Inclusion criteria
  • Monogamous, heterosexually active couples
  • Source partner                                                                                                                            - HSV-2 antibody positive AND                                                               - < 10 symptomatic recurrences/year AND                                                                                               - a candidate for suppressive therapy
  • Susceptible partner                                                                                         - HSV-2 antibody negative
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HS2AB3009
Primary endpoint
  • Proportion of susceptible partners with:
    • clinical evidence of first episode of genital HSV-2
    • confirmed by laboratory (for HSV-2)
      • viral culture,
      • PCR and/or serology
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HS2AB3009
Monitoring
  • Safer sex counseling at each visit.
  • Source partner: Monthly
    • review of diary cards for HSV symptoms and recurrence
    • expected to return for HSV recurrence
  • Susceptible partner:  Monthly
    • Review of diary of sex exposures and practices, and signs of HSV
    • Return for any suspect HSV infection


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Virology
  • HSV-2 lab confirmation defined as one or more positive findings by:
    • Viral culture
    • Viral DNA amplified by PCR
    • Serology by Western blot
  • Seattle lab conducted all samples except 5 Canadian viral cultures in Vancouver lab
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Virology
Logistical Concerns
  • Samples from about 100 sites in >20 countries  transported to Seattle or Vancouver
  • Protocol violations included:                               failure to report at first sign of genital herpes, contamination, loss of sample
  • Effects of transit on virology results
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Pre-study GSK-FDA Discussions
  • Primary endpoint
  • Source patient inclusion:                                         - history of clinical HSV recurrences                        - candidate for suppressive therapy, and                   - less than 10 recurrences in past year
  • Two studies (different populations) versus one study
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Endpoints: HSV-2 transmission
  • Primary endpoint:                                  Clinical signs/symptoms of HSV and laboratory confirmation
  • Secondary endpoint:                               HSV-2 seroconversion
  • Overall acquisition:                            Meeting either or both of above endpoints
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Study History
  • Initiated February 1998, completed April 2002
  • 4030 couples screened, 1498 enrolled, 1484 randomized and received medication
  • July 1998 amendment:
  •   HSV shedding substudy added
  • May 2000 amendments:
  •   Sites added in Australia, Eastern Europe,
  •   and South America,
  •   Gender stratification waived
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     Efficacy Summary
  • Fraser Smith, Ph.D.
  • Statistical Reviewer
  • Division of Biometrics III
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Overview of Presentation
  • Demographic and Baseline Characteristics
  • Primary and selected secondary results
  • Robustness of analyses to discontinuations
  • Regional differences
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Demographic Characteristics Susceptible Partners
(ITT Population)
  • 2/3 Male, 1/3 Female
  • Median Age = 35 years


  • 90% White
  • 5% Hispanic
  • 3% Black
  • 1% Asian
  • <1% Other Races



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Baseline Sexual History
Susceptible Partners
  • 1% had sexual relations with other partners in last 3 months


  • Median duration of relationship with source partner was 2 years


  • 22% had been treated for an STD


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Baseline Sexual History
Susceptible Partners
  • 97% had sexual intercourse with source partner in last month


  • Median number of contacts in last month = 7


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Summary of HSV-1 Status for Female Susceptible Partners at Randomization
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Summary of HSV-1 Status for Male Susceptible Partners at Randomization
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Efficacy Evaluations
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Percentage of susceptible partners who acquired HSV-2 infection defined by the primary and selected secondary endpoints
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Percentage (+/- 95% CI) of Susceptible Partners with Clinical Endpoints, by Median Condom Use for Vaginal / Anal Intercourse
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Robustness of Efficacy Analyses to Discontinuations
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Discontinuations
  • None of the susceptible partners withdrew due to adverse events or lack of efficacy


  • <1% of source partners withdrew due to adverse events (16 / 1484)


  • <1% of source partners withdrew due to lack of efficacy (9 / 1484)


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Regional Differences
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Percentage of Patients with Confirmed Clinical Endpoints, by Geographic Region
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Overall Acquisition of Genital HSV-2 Infection by Geographic Region
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Summary / Conclusions
  • The percentage of dropouts (>20%) was much higher than the percentage of susceptible partners classified as having clinical evidence of a first episode of genital HSV-2


  • Primary reasons for discontinuation include withdrawal of consent, loss to follow-up, and the ending of relationships






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Summary / Conclusions
  • Statistical significance of primary endpoint depends on assumptions about how many discontinuations  should be counted as treatment failures


  • No transmissions were reported in Europe where approximately 20% of the patients were enrolled




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Summary / Conclusions
  • Largest treatment effects observed in Australia and Canada


  • US results similar to results for primary endpoint for all countries combined


  • Differences between valacyclovir and placebo were not as significant for HSV-2 seroconversions and overall acquisitions, particularly in the U.S.
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Viral Shedding Substudy / Safety and Behavioral Results / Conclusions
  • Harry W. Haverkos, M.D.
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Viral Shedding Substudy
  • 85 SOURCE patients followed intensively for 2 months at 4 U.S. sites
  • Daily diary recording signs/symptoms of HSV recurrence
  • Daily viral sample collection and self-exam
  • Biweekly clinic visit for review of diary, clinical genital exam, and additional viral studies
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Viral Shedding Substudy Results
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Background
Safety
  • WARNINGS: TTP/HUS and death occurred in patients with advanced HIV disease and allogeneic BMT and renal transplant recipients receiving valacyclovir 8 grams per day
  • Frequently reported adverse events include nausea, headache, vomiting, dizziness, and abdominal pain
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Safety Summary
  • No deaths
  • No reports of TTP/HUS
  • 14 valacyclovir and 12 placebo patients developed serious adverse events
  • 12 valacyclovir and 5 placebo patients discontinued treatment due to AE
  • 8 valacyclovir and 8 placebo patients became pregnant
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Serious Adverse Events
(None associated with study medications)
  • Valacyclovir (14)
  • Glomerulonephritis (Discontinued)
  • Breast cancer
  • Intestinal obstruction
  • Spontaneous abortion, uterine fibroid
  • Appendicitis, localized infection, lymphadenitis, meningitis
  • Arthralgia, disk herniation, osteoarthritis
  • Syncope, vasovagal attack


  • Placebo (12)
  • Coronary artery disease (Discontinued)
  • Anal canal cancer
  • Spontaneous abortion (3), Bartholin’s cyst, ovarian cyst
  • Appendicitis, erysipelas, pancreatitis
  • Disk herniation, lower limb fracture
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STD Guidelines - Background
  • Effect of condoms on reducing the transmission of    HSV-2 from men to women                                            Wald et al. JAMA 2001;285:3100-3106


  • Re-analysis of ineffective HSV-2 vaccine trial,                     528 monogamous HSV-2 discordant couples followed for 18 months


  • HSV-2 transmission occurred in 31 couples (6%)


  • Condom use protective for women (adjusted hazard ratio - 0.085) but not for men
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Condom use reported by susceptible partners at baseline and during the study
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Limitations of Behavioral Data
  • Condom use, oral sex poorly defined
  • No analysis conducted concerning abstinence during outbreaks
  • Limited descriptive data concerning relationships
  • Multinational, multi-lingual
  • Missing diaries
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Summary
  • Valacyclovir appears to reduce clinical HSV-2 outbreaks among source partners and transmission to susceptible partners among monogamous, heterosexual couples


  • The viral shedding substudy results support the use of valacyclovir to reduce HSV-2 transmission among such couples


  • No new safety issues were identified
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Summary (continued)
  • Subjects continued not to use condoms during every sex act, especially oral sex acts, and not to abstain from sex during symptomatic recurrences despite monthly STD counseling


  • Behavioral research to improve STD counseling effectiveness is urgently needed
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Questions for the Advisory Committee
  • 1. Does the information presented by the applicant support the use of valacyclovir to reduce the risk of transmission of genital herpes among monogamous heterosexual couples?


  • If the answer to question #1 is yes, please address the following questions.


  • If the answer to question #1 is no, then what additional studies should be conducted?


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Questions for the Advisory Committee
  • 2. Does the information presented support the use of valacyclovir to reduce the risk of transmission of genital herpes among populations other than monogamous heterosexual couples?


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Questions for the Advisory Committee
  • 3. In study HS2AB3009, over 4,000 couples were screened, but only 1,498 were enrolled.


  •    A large number of couples were excluded because “susceptible” partners were found to be HSV-2 positive without clinical symptoms.


  •    Please discuss the implications of screening susceptible partners for HSV prior to initiating therapy of the source partner with valacyclovir.



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Questions for the Advisory Committee
  • 4. In your opinion, will marketing of valacyclovir for reduction of genital herpes transmission have an impact on use of condoms and abstinence from sex during clinical HSV-2 outbreaks?




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Questions for the Advisory Committee
  • 5. Although patients in the registrational trial were treated for eight months, valacyclovir for suppression of transmission of genital herpes will likely be used for significantly longer periods of time.
  • What additional studies would you suggest to evaluate the potential for longer-term adverse events, including development of resistance to valacyclovir?




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Questions for the Advisory Committee
  • 6. The primary endpoint in HS2AB3009 was the proportion of couples with clinical evidence of a first episode of genital HSV-2 in the susceptible partner.


  •    Would you recommend that primary endpoint in future studies with agents to prevent transmission of HSV-2?


  •    If not, what primary endpoint would you recommend?




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Review Team
  • Anita H. Bigger, Ph.D., Pharmacology
  • Debra Birnkrant, M.D., Division Director
  • Nilambar Biswal, Ph.D., Microbiology
  • Anthony DeCicco, R.Ph., Chief, Project Management
  • Jim Farrelly, Ph.D., Pharmacology Team Leader
  • Stanka Kukich, M.D., Medical Team Leader
  • Ko-Yu Lo, Ph.D., Chemistry
  • Stephen P. Miller, Ph.D., Chemistry Team Leader
  • Jeffrey S. Murray, M.D., M.P.H., Deputy Director
  • Jules O'Rear, Ph.D., Microbiology Team Leader
  • Nitin Patel, R.Ph., Regulatory Project Manager
  • Kellie Reynolds, Pharm.D., Pharmacokinetics Team Leader
  • Greg Soon, Ph.D., Statistical Team Leader