4.1.4        What efficacy and safety information contributes to the assessment of clinical pharmacology and biopharmaceutics study data (e.g., can disparate efficacy measurements or adverse events reports to be attributed to intrinsic or extrinsic factors that alter drug exposure/response relationships in patients)?

 

The present submission did not include clinical efficacy trials.  Exposure-related adverse effects include seizures, with a 10-fold increase in seizure incidence compared to 300 mg per day at doses between 450 and 600 mg per day of the immediate-release formulation of bupropion, according to information provided in the label of WELLBUTRIN SR.  The present submission did not evaluate dose-dependence of adverse effects.  The studies were conducted in healthy volunteers without clinically significant impairment in factors that could alter exposure-response relations (such as renal or hepatic impairment, congestive heart failure, age, or concomitant medications).

 

4.2         General Clinical Pharmacology

 

4.2.1  What is the basis for selecting the response endpoints, i.e., clinical or surrogate endpoints, or biomarkers (also called pharmacodynamics, PD) and how are they measured in clinical pharmacology and clinical studies.

 

The present submission did not include studies evaluating pharmacodynamic response to WELLBUTRIN XL.

 

Although the mechanism of action of bupropion as an antidepressant is unknown, it inhibits dopamine uptake and this could be due to occupancy of the dopamine transporter.  The present submission included a positron emission tomography (PET) study (OHB10001) to evaluate relationship between dopamine transporter occupancy and bupropion and metabolites concentration at steady state following administration of bupropion given as 150 mg WELLBUTRIN SR twice daily for 8 days in 6 healthy male volunteers, mean age 30.7 (23-39) years of age.  This is a clinically relevant dose.  The full study report can be found in the Appendix, Section 6.2.1.  PET studies demonstrated approximately 26% occupancy of the dopamine transporter in the striatum up to 24 hours following the last dose of bupropion.  Future efforts would be required to characterize he relationship between occupancy and clinical effort, in order to provide a link between dose, pharmacokinetics, and effect as well as to further characterize the mechanism for the effect.

 

4.2.2        Are the active moieties in the plasma (or other biological fluid) appropriately identified and measured to assess pharmacokinetic parameters and exposure response relationships?

 

Bupropion and its active metabolites hydroxybupropion, threohydrobupropion, and erthyrohydrobupropion [erythrohydrobupropion] were appropriately identified and measured in the plasma.  Please refer to the Bioanalytical Section (4.6).  In addition to evaluating the PK of bupropion and its metabolites, the Pharmacological Activity-Weighted Composite (PAWC) of bupropion and its metabolites were determined and evaluated.  Bupropion and its metabolites were previously used in approval of WELLBUTRIN SR tables since approximately 90% of systemic exposure is due

 

 

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