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Released by FDA: 3/16/01. Posted by FDA: 3/28/01
Lifecycle Ventures
c/o
Mark J. Scheineson, Esq.
Reed Smith, L.L.P
1301 K Street, N.W.
Washington, DC 20005
RE: NDA#50-605
Ceftin Tablets(cefuroxime
axetil tablets)
MACMIS ID# 9811
Dear Mr. Scheineson:
As a part of the Division of Drug Marketing, Advertising, and
Commumications’ (DDMAC) routine surveillance, we have reviewed
promotional materials for Ceflin (cefuroxime axetil) from Lifecycle
Ventures submission of FDA form 2253 dated January 01, 2001. The
submission contained promotional sales aids for Ceftin (e.g. CEF-0006-A,
CEF-0006-P, CEF-0008-P, and CEF-0008-A). We find the sales aids in
violation of the Federal Food, Drug, and Cosmetic Act and its applicable
regulations. Specifically, we object to the following:
Unapproved Use
 | Ceftin is not approved to treat drug-resistant infections, such as
resistant streptococcus pneumonia (PRSP) and resistant haemophilus
influenzae. In your sales aids, you promote Ceftin for
resistant bacteria with the taglines, “First-line in an era of
bacterial resistance,” and “In an era of drug- resistant streptococcus
pneumoniae.” These taglines are misleading because they
are placed directly in conjunction with treatment and susceptibility
information for Acute Otitis Media (AOM), sinusitis, and bronchitis
and imply that Ceftin is approved for all listed pathogens, including
resistant organisms. The efficacy of Ceftin for the treatment of
PRSP arid resistant haemophilus influenzae has not been
demonstrated by substantial evidence. Therefore, we find the
sales aids to be violative. |
Misleading Economic Claims
 | In your sales aids you present “cost-comparisons” between Ceftin
and numerous antibiotic regimens for sinusitis, bronchitis, and AOM
based on price differences taken from the 2000 Red Book Update
(October 2000). You make claims such as, ‘cost-effective”
“Ceftin savings,” “manage the expense of treatment,” and “cost
of therapy.” These claims are misleading because they are not
supported by adequate evidence. These claims imply that all
costs associated with therapy have been evaluated, riot simply the
acquisition price of the drug. In addition, your graph
entitled, “Ceftin savings: A better way to manage the expense
of treatment in sinusitis,” is misleading because it implies
economic superiority based on the assumption that the outcomes of the
different therapies are the same. |
Requested Action
You should immediately cease distribution of the sales aids and other
similar promotional materials for Ceftin that contain the same or similar
claims or presentations. You should submit a written response on or before
March 30, 2001 describing your intent and plans to comply with the
above. Your letter should include a list of materials discontinued
and the date on which these materials were discontinued.
You should direct your response to the undersigned by facsimile by at
(301)594-677l, or to the Food and Drug Administration, Division of Drug
Marketing, Advertising, arid Communications, HFD-42, Rm l7-B-20, 5600
Fishers Lane, Rockville, MD 20857. We remind you that only written
communications are considered official.
In all future correspondence regarding this particular mailer, please
refer to MACMIS ID #9811 in addition to the NDA number.
Sincerely,
James R. Rogers. Pharm.D.
Regulatory Review Officer
Division of Drug Marketing,
Advertising, and Communications
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