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FDA Issues Complete Response Letter for Replimune's RP1 Melanoma Therapy, Citing Trial Design Concerns

5 days ago3 min read

Key Insights

  • The FDA issued a Complete Response Letter rejecting Replimune's biologics license application for RP1 plus nivolumab in advanced melanoma, stating the IGNYTE trial does not provide substantial evidence of effectiveness.

  • The agency cited concerns about patient population heterogeneity in the IGNYTE study and raised design issues with the confirmatory phase 3 trial IGNYTE-3, though no safety concerns were identified.

  • Replimune expressed surprise at the decision, noting that issues raised in the CRL were not flagged during mid- and late-cycle reviews, and plans to request an urgent Type A meeting with the FDA within 30 days.

The US FDA has issued a Complete Response Letter (CRL) to Replimune Group regarding its Biologics License Application for RP1 (vusolimogene oderparepvec) in combination with nivolumab for treating advanced melanoma. The decision represents a significant setback for the clinical-stage biotechnology company and patients with limited therapeutic options in this indication.

FDA's Primary Concerns

The FDA concluded that the IGNYTE trial does not constitute an "adequate and well-controlled" clinical investigation sufficient to demonstrate substantial evidence of effectiveness. The agency specifically cited concerns about the heterogeneity of the patient population in IGNYTE, which complicated interpretation of the trial's results.
Additionally, the CRL raised design issues with the confirmatory phase 3 trial, IGNYTE-3, particularly around evaluating the individual contribution of each treatment component in the combination therapy. Importantly, no safety concerns were identified in the review.

Company Response and Next Steps

"We are surprised by this FDA decision and disappointed for advanced melanoma patients who have limited treatment options as highlighted by the granting of breakthrough status at the time we provided the IGNYTE primary data," said Sushil Patel, PhD, chief executive officer of Replimune.
The company emphasized that the issues highlighted in the CRL were not raised during the mid- and late-cycle reviews, and that they had already aligned with the FDA on the design of the confirmatory study. Replimune plans to request a Type A meeting with the FDA, expected within 30 days, to discuss a path forward.

About RP1 and the Clinical Program

RP1 is Replimune's lead oncolytic immunotherapy candidate, developed from a genetically modified herpes simplex virus engineered to induce direct tumor cell lysis, enhance immunogenicity, and activate systemic anti-tumor responses. The therapy is based on a proprietary strain of herpes simplex virus engineered and genetically armed with a fusogenic protein (GALV-GP R-) and GM-CSF.
The BLA was supported by data from the IGNYTE trial, which evaluated RP1 plus nivolumab in patients with advanced melanoma who failed anti-PD-1 treatment. The FDA had granted the submission Priority Review status and Breakthrough Therapy designation earlier this year, signaling that the therapy might offer meaningful improvements over existing treatments.

Regulatory Context

This CRL comes as the FDA is undertaking a broad initiative to enhance transparency in its drug approval process. The agency recently published over 200 previously confidential CRLs issued between 2020 and 2024, providing public insight into common deficiencies that lead to non-approval.
FDA Commissioner Marty Makary, MD, MPH, stated, "For far too long, drug developers have been playing a guessing game when navigating the FDA… We're one step closer to delivering predictability, with an ultimate goal of bringing cures and meaningful treatments to patients faster."

Implications for Advanced Melanoma Treatment

The decision underscores the complexities of cancer drug development, particularly for patients with advanced melanoma who have progressed after prior checkpoint inhibitor therapy—an area with significant unmet medical need and limited therapeutic alternatives. Replimune noted that without a path forward for timely accelerated approval, the development of RP1 for advanced cancer patients with limited options may not be viable.
The outcome of upcoming FDA interactions will be critical in determining whether RP1 can ultimately fulfill its promise as a novel therapy for patients with advanced melanoma.
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