Replimune · RP1 · Apr 2026

What did the FDA's second letter object to?

A unanimous finding that the data were insufficient, three deficiencies in the single-arm trial, and early Phase 3 data the FDA called insufficient.

EphemerisX Research · Published · 2 source documents · 1 min read

Short answer

The FDA's second letter concluded the data were insufficient to show effectiveness, and set out three deficiencies in the RPL-001-16 trial.

What the evidence shows

The review team, supervisory leadership and Oncology Center of Excellence experts unanimously determined data presented are insufficient to conclude substantial evidence of effectiveness FDA · Apr 10, 2026 · p. 1.

The letter gives three deficiencies in RPL-001-16. Response rate and duration of response were not reliably assessed, could be artifactually increased, and may not be reproducible FDA · Apr 10, 2026 · p. 5; comparing response rates cross-trial is challenging due to the heterogeneity of the patient populations FDA · Apr 10, 2026 · p. 5; and it remains unclear whether the observed responses in RPL-001-16 are due to nivolumab alone FDA · Apr 10, 2026 · p. 6. The early Phase 3 data submitted with the resubmission were insufficient to support an efficacy claim FDA · Apr 10, 2026 · p. 4.

To address them, the company must conduct and provide the results from adequate and well-controlled clinical trial(s) FDA · Apr 10, 2026 · p. 6. Its 8-K: Replimune disagrees with the FDA about whether the data set, upon which breakthrough therapy designation was awarded, is sufficient 8-K · Apr 13, 2026.

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This investigation connects to

The documents, by date

FDA Complete Response Letter, April 10, 2026FDA letter · Apr 10, 2026Replimune Form 8-K, filed April 13, 20268-K · Apr 13, 2026

The passages quoted

FDA Complete Response Letter, April 10, 2026 · page 1

This BLA resubmission primary clinical review team, supervisory leadership in the Office of Therapeutic Products, and subject matter experts from Oncology Center of Excellence unanimously determined data presented are insufficient to conclude substantial evidence of effectiveness of vusolimogene oderparepvec for treatment of unresectable advanced cutaneous melanoma.
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FDA Complete Response Letter, April 10, 2026 · page 4

This data is insufficient to support an efficacy claim.
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FDA Complete Response Letter, April 10, 2026 · page 5

However, comparing response rates cross-trial from RPL-001-16 to historical controls is challenging due to the heterogeneity of the patient populations in RPL-001-16 and the historical controls (e.g., the type of prior therapy received, such as single agent anti-PD-1 or combination checkpoint inhibitor, duration of prior therapy, setting of prior anti-PD-1 therapy [adjuvant vs. advanced/metastatic setting], extent of disease at baseline).
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FDA Complete Response Letter, April 10, 2026 · page 5

Given these issues, the reported response rate and duration of response from RPL-001-16 were not reliably assessed, could be artifactually increased, and may not be reproducible.
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FDA Complete Response Letter, April 10, 2026 · page 6

Thus, it remains unclear whether the observed responses in RPL-001-16 are due to nivolumab alone.
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FDA Complete Response Letter, April 10, 2026 · page 6

To address these deficiencies, you must conduct and provide the results from adequate and well-controlled clinical trial(s) which demonstrate substantial evidence of effectiveness.
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Replimune Form 8-K, filed April 13, 2026

Replimune disagrees with the FDA about whether the data set, upon which breakthrough therapy designation was awarded, is sufficient to allow this promising medicine to be made available to advanced cancer patients.
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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 →