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The Life Sciences Report - Winter 2020

USJMF and Wilson Sonsini Host Successful Japan Trade Mission and Roadshow for U.S. Medtech Companies - On November 5-11, 2019, U.S.-Japan Medtech Frontiers (USJMF) and Wilson Sonsini led a group of representatives from 22...more

Court Holds the FDA Cannot Classify an Imaging Agent Medical Device as a Drug

The legal definitions of a drug and a medical device set forth in the Food, Drug, and Cosmetic Act have some important overlapping provisions. Because of the overlapping provisions, theoretically the U.S. Food and Drug...more

A Preliminary Evaluation of the RMAT Designation's Effect on Publicly Traded Company Stock Price

The 21st Century Cures Act created the Regenerative Medicine Advanced Therapy (RMAT) designation in recognition of the growing importance of regenerative medical therapies. An RMAT designation conveys significant regulatory...more

Despite Easy Confirmation, Difficult Issues Lie Ahead for New FDA Commissioner Stephen Hahn

After being confirmed by the Senate in a 72-18 vote on December 12, 2019, the new Commissioner of the Food and Drug Administration (FDA) Dr. Stephen Hahn will be facing a number of critical issues on the immediate horizon...more

FDA Declares CBD Is Not GRAS and Signals That It Will Maintain Its Deliberate Approach

With its recent issuance of additional warning letters and the release of a consumer update, the Food and Drug Administration (FDA) appears to be signaling that it will continue its deliberate approach in determining an...more

Newly Introduced Bill Would Reshape U.S. New Drug Pricing

Recently, Stat+ reported that a group of prominent venture capitalists (VCs) issued a strong warning to Congress. The warning: H.R. 3, the newly introduced Lower Drug Costs Now Act, if enacted, will "severely constrain" the...more

Digital Health Report: Fall 2019

Beware of “Most Favored Nations” Clauses in Commercial Contracts - Imagine that your digital health company has developed a groundbreaking product. You are eager to monetize the product, so you sign non-disclosure...more

FDA Issues Final Guidance on Citizen Petitions and Stay of Action Petitions Subject to FDCA Section 505(q)

Introduction: Citizen Petitions in the News - Citizen petitions and stay of action petitions (collectively, citizen petitions or petitions) are in the news. Formally, citizen petitions are a mechanism for "interested...more

Digital Health Report - Summer 2019

Avoid Potential Pitfalls When Incorporating Third-Party Software into Wearable Products - The global market for wearable devices continues to expand rapidly. Digital health companies that manufacture and sell their own...more

FDA Issues Competitive Generic Therapies (CGTs) Statement and Guidance Regarding CGT Designation, Approval Pathway, and Market...

Recently, the United States Food and Drug Administration (FDA) Commissioner Scott Gottlieb issued a statement (the statement) outlining a new policy to improve access and foster price competition for branded drugs that are...more

FDA Outlines New Efforts to Strengthen and Modernize Its Regulation of Dietary Supplements

Dietary supplements are big business. Three out of four Americans take a dietary supplement, and the rate rises to four out of five among older Americans. Dietary supplements are a $40 billion dollar industry, with between...more

AdvaMed Updates Its "Code of Ethics on Interactions with U.S. Health Care Professionals"

On January 9, 2019, the Advanced Medical Technology Association (AdvaMed) released an updated version of its "Code of Ethics on Interactions with U.S. Health Care Professionals" (HCPs) (the Code), which will take effect on...more

FDA Outlines Considerations for the Development and Labeling of Companion Diagnostics for Use with a Specific Group or Class of...

Recently, the U.S. Food and Drug Administration, or FDA, issued a draft guidance (the guidance) outlining considerations for the development and labeling of in vitro companion diagnostics to support indicated uses for...more

Manufacturers of Instruments Routinely Used in In Vitro Diagnostics Should Carefully Consider FDA's Recent Cybersecurity Guidance

High throughput sequencers, including next generation, or NGS, sequencers; polymerase chain reaction, or PCR, machines; flow cytometers; and other instruments are routinely used in conducting in vitro diagnostic assays. Many...more

FDA Joint Statement Is a Harbinger of Significant Change for the 510(k) Program

Background: The Increasing Regulation of Medical Devices Subject to 510(k) Clearance - The U.S. Food and Drug Administration's (FDA's) 510(k) premarket clearance pathway is the road to commercialization for thousands of...more

Amid Rising Incidence of Allergies and Broad Use of Cosmetics, FDA Proposes Consumer Survey to Assess Allergens in Cosmetics

The U.S. Food and Drug Administration (FDA) recently issued a Federal Register notice (the notice) that the FDA intends to conduct a web-based survey for a "more current understanding of the prevalence of adverse reactions to...more

FDA Updates Cybersecurity Guidance for Medical Device Manufacturers

The U.S. Food and Drug Administration (FDA) recently issued a dense, 24-page draft guidance, titled "Content of Premarket Submissions for Management of Cyber Security in Medical Devices" (the guidance). The guidance notes...more

HHS Proposes New Rule Requiring Drug TV Advertisements to Include the Drug's Retail Price

Prescription drug pricing in the U.S. has received significant and widespread attention lately from the media, consumers, and the government. For example, the Washington Post ran an article that examines the sometimes opaque...more

Digital Health Report - Fall 2018

Evaluating Prospective Partners When Scaling Your Digital Health Company (Part 2) - In Part 1 of this article from our last Digital Health Report, we looked at the opportunities and some of the potential limitations of...more

Selected Favorable Pharmaceutical Intellectual Property Provisions of the USMCA

After more than a year of negotiations, the U.S., Mexico, and Canada recently concluded the United States-Mexico-Canada Agreement (USMCA). The USMCA, when it takes effect, will replace the North American Free Trade Agreement...more

District Court Case Highlights Nuances Associated with Determining If a Generic or Biosimilar Applicant Is Entitled to Protection...

A recent case at the U.S. District Court for the District of Delaware demonstrates how nuanced safe harbor protection under 35 U.S.C. § 271(e)(1) "non-infringement" can be for a pharmaceutical company developing a biosimilar...more

FDA Publishes Biosimilars Action Plan (BAP)

Biologic drug products are used to treat a variety of serious diseases, including cancer, blindness, rheumatoid arthritis, multiple sclerosis, and diabetes. Biologics, which include antibodies and large proteins, tend to be...more

FDA Pulls Back the Veil on Surrogate Endpoints

A surrogate endpoint is a clinical measurement—associated with a specific treatment—that indicates whether the treatment may provide a statistically significant clinical benefit. A possible example of a surrogate endpoint is...more

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