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The Potential and Possibilities for BioGenerics Thursday, May 28, 2009 Bruce A. Leicher, Sr. VP and General Counsel Momenta Pharmaceuticals, Inc. Momenta Pharmaceuticals, Inc. • Founded 2001 – Cambridge, MA – ~165 Employees • Analytical platform developed at MIT in 1990s • Initial Focus - Characterization Technology Complex Mixture Molecules: Heparins, Peptides, Biologics Complex Generic Drugs Follow on Biologic Drugs Novel Biopharmaceutical Drugs Molecular Diagnostics and Biomarkers 2 Complex Biologic 3 Structural Characterization and control of the Manufacturing Process • Characterization of: each species in the reference product its composition and sequence • Batch-to-batch variability of the reference product determined • “Equivalence Windows” developed Captures inherent variability in manufacturing process • Critical to ensure robust understanding of manufacturing process for complex biopharmaceuticals 4 Structure-Process: Leverage technology to design and control manufacturing process Characterization is critical to design and ensure robust understanding and control of manufacturing process for complex biopharmaceuticals Starting Material Step 1 Step 2 Step 3 Drug Drug Substance Product Integrated Momenta Characterization Analytics Product Starting Material Process Knowledge Process Parameters Product Quality Process Controls Quality-By-Design (QbD) 5 Thorough Characterization Enhances Quality – But is disruptive to the more standard FOBs development approach (Illustrative) Product Knowledge Standard Biosimilar Momenta Follow-on-Biologic Brand Biosimlar Brand Biosimlar+ Brand Biogeneric Same Same Same Same Same Same Different Different Unknown Unknown Different Different Remove uncertainty. Qualify differences. Demonstrate equivalence. • Thorough characterization • Increased POS for approval • Manufacturing Process Design • Reduced (non)clinical requirements • Product Control and Quality • Better commercial differentiation 6 Demonstrating Interchangeability Can Enhance Quality • Quality Improvements Identifying structural variations associated with side effects Enabling greater precision in identifying “contaminants” Facilitating greater understanding of Manufacturing changes Providing greater understanding of Product “drift” • Advances in technology offer the potential for improved manufacturing consistency 7 FDA should balance the level of chemical characterization with need for additional biological and clinical testing 1. Level of process and product knowledge (characterization) provided for the FOB will be key when FDA sets the criteria for Biogeneric and Biosimilar approvals. 2. Biological and Clinical Testing, in the absence of sufficient product knowledge, will be inadequate to qualify structural differences and/or uncertainty between the FOB and the Innovator – to justify interchangeability. Steven Kozlowski, PhD Director, Office of Biotechnology Products, OPS/CDER/FDA 8 Interchangeability with the Innovator drug will be key driver to commercial success in the U.S. BIOSIMILAR BIOSIMILAR+ Therapeutic Alternative Therapeutic Substitution Marketplace FDA / Marketplace FDA Physician / Payor Physician / Payor Pharmacist / Payor Omnitrope® Genotropin® TBD Lovenox® M-Enox Contracting: Retail / Hospital Chains +++ +++ +++ Marketing / Sales +++ ++ + N/A TBD +++ + ++ +++ How Determined Decision Maker Example Direct Substitution Market Share BIOGENERIC Interchangeable Therapeutic Equivalence Illustrative 9 Competition that Allows Extended Brand Sales Drug Price Erosion (Illustrative) 1st Generic Launch $1,200 Limited Entrants $1,000 1 Generic: ~15% Price $800 $600 3 Generics: ~50% Retention of Brand Earning Potential $400 7+ Generics: ~90% $200 $- n Ja r Ap l Ju ct O n Ja r Ap l Ju ct O n Ja r Ap l Ju ct O n Ja r Ap l Ju ct O Markets with limited competition have potential for significant economics 10 Momenta Position – FOB Legislation Clear Regulatory path to Interchangeability No mandatory requirement for Clinical Trials No mandatory requirement for public Guidance Documents FDA to determine regulatory framework and criteria, to be Driven by the Science Appropriate period of Data Exclusivity for innovator Certain and Fair Patent Process pre-Approval – Ensure Incentives for Analytical Innovation – – Ensure Highest Product Quality and Patient Safety – -Encourages Innovative R&D Investment in Unmet Needs- Competition, Investment and Innovation Challenges • Hatch Waxman was pro-competitive and pro-R&D Spurred innovation investment in novel, unmet needs rather than 3rd, 4th and 5th entrants or life cycle management in a class of therapy Provided 5 years of exclusivity + patent term extension Permitted transparency for legal clearance of invalid or unenforceable patents prior to launch of the generic • Today, there is no legal pathway for generic entry of biologics Key incentive for Investment and Innovation • BIO/PhRMA is seeking longer exclusivity as a condition of any new legislation This would impede investment, and entry of competition This is not consistent with the greater number of patents covering the making, using and selling of biologics Drugs have greater competition during their patent lives and less earning potential due to the more limited scope of patent coverage This would reward “less innovative” R&D 12 Patent Clearance Challenges • Hatch-Waxman used the “Orange Book” to identify and facilitate notice of patents that may be challenged as invalid, not infringed or unenforceable • To promote competition, the process must enable initiation of the process early enough to allow for a generic launch when the patents expire or are determined not to block a generic • Biologics are challenging because of the complex array of patent protection and multiple parties Early identification Early right to sue in advance of data exclusivity (following FDA acceptance of filing) 13 Questions? 14