B.     Discussions with the Division about the NDA Submission

On June 11, 2002, the sponsor presented its WELLBUTRIN XL development program to the Division.  The Division agreed with the proposal to submit an NDA for WELLBUTRIN XL that would be based on data demonstrating bioequivalence of the extended-release formulation of bupropion and the immediate-release formulation [NDA 18,64] [NDA 18,644], (similar to the submission which formed the basis for approval of WELLBUTRIN SR ([NDA 20, 358]).  The Division requested that the sponsor use Cmax, AUC, and Cmin as primary parameters for determining steady-state bioequivalence and that these be determined for bupropion, hydroxy-bupropion, threohydro-bupropion, and erythrohydro-bupropion.  In light of the multiplicity of parameters to be used in the assessment of bioequivalence, an additional measure of bioequivalence, the pharmacological activity-weighted composite (PAWC) of bupropion and its metabolites, was recommended by the Division.  This parameter was used for the approval of WELLBUTRIN SR, since > 90% of systemic drug exposure involves metabolites rather than parent drug.  In addition, the PAWC was noted by the Division as being potentially important in evaluating bioequivalence if one of the 12 individual parameters to be evaluated differed slightly from those of the reference product.

 

C.     Foreign Marketing History

No applications for marketing approval of WELLBUTRIN XL have been submitted outside the U.S.

 

III. Clinically Relevant Findings from Chemistry, Biopharmaceutics

These will be analyzed and reported by reviewers from the respective disciplines.

 

IV.  Safety Analysis of WELLBUTRIN XL

A.     Description of Clinical Data and Sources

Safety information reviewed included: 1) individual study reports from the bioavailability studies (2543, 2544, 2548, 2571, and 2526); and 2) case report forms from the 3 ongoing clinical trials using WELLBUTRIN XL.  Two of these trials involve treatment of Seasonal Affective Disorder (AK 130930 & AK 130936), and one involves the treatment of Attention Deficit Hyperactivity Disorder in Adults (AK 130930).

 

 

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