Aldeyra Therapeutics · reproxalap · Nov 2023 – Apr 2025

Did the FDA agree to the design of Aldeyra's 2024 dry eye chamber trial?

Aldeyra's filings describe FDA feedback, a “SPA - No Agreement letter” and a Type A meeting. The FDA's 2025 letter then called the Study 030 primary efficacy analysis problematic.

EphemerisX Research · Published · 5 source documents · 2 min read

Short answer

Aldeyra's 10-K says the FDA answered its Special Protocol Assessment with a “SPA - No Agreement letter”, that the design was then amended, and that at a Type A meeting the company believes the FDA concurred with the principal aspects of the design. The FDA's April 2025 letter found the primary efficacy analysis of Study 030 problematic.

What the evidence shows

In November 2023 Aldeyra submitted a Special Protocol Assessment for a chamber trial. Its 10-K, filed in February 2026, says: In response to the SPA, the FDA issued a SPA - No Agreement letter which provided feedback to Aldeyra on the proposed chamber trial 10-K · Feb 27, 2026. The company then amended the design and protocol of the chamber trial 10-K · Feb 27, 2026, and at a Type A meeting we believe that the FDA concurred with the principal aspects of the trial design 10-K · Feb 27, 2026. Then two chamber trials were initiated, in addition to one field trial 10-K · Feb 27, 2026.

When the first chamber trial reported in August 2024, the 8-K said that Through the FDA Special Protocol Assessment process and additional comments, the FDA provided feedback on the clinical trial protocol and statistical plan 8-K · Aug 8, 2024. It described the design: patients were administered vehicle (the drug product without the active ingredient) before and during exposure to a dry eye chamber 8-K · Aug 8, 2024; then Qualifying patients were subsequently randomized to receive either reproxalap or vehicle before and during exposure to an additional dry eye chamber 8-K · Aug 8, 2024, with the primary endpoint measured from 80 to 100 minutes in the chamber 8-K · Aug 8, 2024.

The FDA's April 2, 2025 letter discusses Study 030 and the comparison between two visits: You used Visit 2 and Visit 4 DEC results as the dependent variable and performed linear contrasts to obtain treatment differences between Visit 4 and Visit 2 results FDA · Apr 2, 2025 · p. 2. Its conclusion: The Agency finds the Study 030 primary efficacy endpoint analysis problematic, and we do not find the study results to be robust FDA · Apr 2, 2025 · p. 2. Aldeyra's 2026 tables list 030 Chamber Symptoms 8-K · Sep 29, 2026.

For the next study, the letter adds a condition: you should not make changes to the protocol or the statistical analysis plan after the first subject is enrolled in the study without expressed agreement by the FDA FDA · Apr 2, 2025 · p. 2. The April 2025 8-K does not mention the letter's condition on changes to the protocol or statistical analysis plan. 8-K · searched

Not in this record: the SPA letter, the minutes of the Type A meeting, and the 2023 letter itself.

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This investigation connects to

The documents, by date

Aldeyra Therapeutics Form 8-K, filed August 8, 20248-K · Aug 8, 2024FDA Complete Response Letter, April 2, 2025FDA letter · Apr 2, 2025Aldeyra Therapeutics Form 8-K, filed April 3, 20258-K · Apr 3, 2025Aldeyra Therapeutics Form 10-K, filed February 27, 202610-K · Feb 27, 2026Aldeyra Therapeutics Form 8-K, filed September 29, 20268-K · Sep 29, 2026

The passages quoted

Aldeyra Therapeutics Form 8-K, filed August 8, 2024

In the Phase 3 clinical trial, patients were administered vehicle (the drug product without the active ingredient) before and during exposure to a dry eye chamber in a manner that Aldeyra believes is consistent with the FDA’s dry eye disease draft guidance 1 . Qualifying patients were subsequently randomized to receive either reproxalap or vehicle before and during exposure to an additional dry eye chamber. Of the 132 patients randomized, 66 patients received reproxalap and 66 patients received vehicle. The primary endpoint was ocular discomfort, an FDA-accepted symptom of dry eye disease, from 80 to 100 minutes in the chamber.
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Aldeyra Therapeutics Form 8-K, filed August 8, 2024

The dry eye chamber clinical trial was designed to satisfy the FDA’s New Drug Application (NDA) resubmission requirement, identified in the previously received complete response letter, of “at least one additional adequate and well-controlled study to demonstrate a positive effect on the treatment of ocular symptoms of dry eye.” Through the FDA Special Protocol Assessment process and additional comments, the FDA provided feedback on the clinical trial protocol and statistical plan.
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FDA Complete Response Letter, April 2, 2025 · page 2

You used Visit 2 and Visit 4 DEC results as the dependent variable and performed linear contrasts to obtain treatment differences between Visit 4 and Visit 2 results. The Agency finds the Study 030 primary efficacy endpoint analysis problematic, and we do not find the study results to be robust.
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FDA Complete Response Letter, April 2, 2025 · page 2

You should conduct at least one additional adequate and well controlled study to demonstrate a positive effect on the treatment of ocular symptoms of dry eye. In the conduct of this study, you should not make changes to the protocol or the statistical analysis plan after the first subject is enrolled in the study without expressed agreement by the FDA.
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Aldeyra Therapeutics Form 8-K, filed April 3, 2025

The April 2025 8-K does not mention the letter's condition on changes to the protocol or statistical analysis plan.

Searched the whole document for: protocol, statistical analysis plan, expressed agreement, first subject. None found.

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Aldeyra Therapeutics Form 10-K, filed February 27, 2026

On November 16, 2023, Aldeyra submitted to the FDA a Special Protocol Assessment (SPA) for a proposed Phase 3 clinical trial to assess ocular discomfort in a dry eye chamber, which is designed to simulate dry eye exacerbations or flares, potentially the most bothersome aspect of the disease for most dry eye patients. In response to the SPA, the FDA issued a SPA - No Agreement letter which provided feedback to Aldeyra on the proposed chamber trial. Based on the feedback, Aldeyra amended the design and protocol of the chamber trial and, per FDA SPA Guidance, Aldeyra and the FDA held a Type A meeting, during which we believe that the FDA concurred with the principal aspects of the trial design.
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Aldeyra Therapeutics Form 10-K, filed February 27, 2026

Subsequent to the SPA Type A meeting, two chamber trials were initiated, in addition to one field trial, in which patients administered reproxalap or vehicle (placebo) over six weeks and reported ocular discomfort weekly.
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Aldeyra Therapeutics Form 8-K, filed September 29, 2026

Trial Design Endpoint Reproxalap Improvement vs. Vehicle (%) 012 Field Symptoms 204% 012 Field Staining 21% 013 Field Symptoms 62% 019 Chamber Redness 0% 023 Chamber Schirmer Test 417% 023 Chamber Schirmer Response 113% 024 Chamber Redness 63% 024 Chamber Symptoms 11% 024 Chamber Schirmer Test 37% 027 Chamber Redness 34% 027 Chamber Schirmer Test 93% 030 Chamber Symptoms 66% 031 Field Symptoms 34% 032 Chamber Symptoms 102
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Prepared from public FDA letters and SEC filings: every quoted passage is matched to the original document, and every “not in” statement comes from a search of the whole document, before it is published. Questions, summaries and connecting sentences are EphemerisX’s wording. Not investment advice. How this research works → · Ask the FDA and SEC Ephemeris →