Replimune · RP1 · 2021 – 2026

When did injected lesions become an FDA concern?

The second letter traces it to a 2021 meeting. The first letter does not mention it. In 2026 the second letter's first numbered deficiency opens with it, and the approval's efficacy population is the patients with a non-injected lesion.

EphemerisX Research · Published · 5 source documents · 1 min read

Short answer

The FDA's second letter quotes a 2021 remark about judging responses in injected lesions; the first letter does not mention injected lesions; the second letter's first numbered deficiency opens with them; and the approval 8-K's efficacy population is the 91 patients with at least one non-injected lesion.

What the evidence shows

In 2021, according to the second letter, the FDA said: we consider the interpretation of responses in the setting of the intra-tumoral route of administration to be problematic in the lesions which have been injected FDA · Apr 10, 2026 · p. 3.

Letter 1 does not mention injected lesions, RECIST, surgery, biopsies or duration of response. FDA · searched

The second letter: almost half (49%) of the patients with objective response had all their target lesions injected FDA · Apr 10, 2026 · p. 4; counting two responders with no target lesions at baseline, over half (53%) of patients with objective response did not have noninjected target lesions FDA · Apr 10, 2026 · p. 4. With those patients excluded, the response rate decreases markedly FDA · Apr 10, 2026 · p. 4. It adds that pathology results may reflect local treatment effects at the injection site rather than systemic effects of the investigational therapy FDA · Apr 10, 2026 · p. 5.

The company's resubmission included analyses of response in patients who had both injected and non-injected tumors FDA · Apr 10, 2026 · p. 2; its 8-K says they showed no material difference in response rates between injected and non-injected lesions 8-K · Apr 13, 2026.

The advisory committee discussed whether the observed responses are indicative of systemic antitumor activity attributable to RP1 8-K · Jul 31, 2026. The approval 8-K reports 91 patients with at least one non-injected lesion included in the efficacy-evaluable population 8-K · Aug 7, 2026, with an objective response rate (ORR) of 24.2% 8-K · Aug 7, 2026.

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This investigation connects to

The documents, by date

FDA Complete Response Letter, July 21, 2025FDA letter · Jul 21, 2025FDA Complete Response Letter, April 10, 2026FDA letter · Apr 10, 2026Replimune Form 8-K, filed April 13, 20268-K · Apr 13, 2026Replimune Form 8-K, filed July 31, 20268-K · Jul 31, 2026Replimune Form 8-K, filed August 7, 20268-K · Aug 7, 2026

The passages quoted

FDA Complete Response Letter, July 21, 2025

Letter 1 does not mention injected lesions, RECIST, surgery, biopsies or duration of response.

Searched the whole document for: inject, RECIST, surg, biops, duration of response. None found.

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FDA Complete Response Letter, April 10, 2026 · page 2

You also provided results from additional exploratory analyses of RPL-001-16, including analyses of patients who had a response to immediate prior anti-PD1 therapy and their subsequent response to the combination of vusolimogene oderparepvec and nivolumab, of progression-free survival, and of response in patients who had both injected and non-injected tumors.
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FDA Complete Response Letter, April 10, 2026 · page 3

Finally, we noted that “we consider the interpretation of responses in the setting of the intra-tumoral route of administration to be problematic in the lesions which have been injected.”
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FDA Complete Response Letter, April 10, 2026 · page 4

FDA review identified that almost half (49%) of the patients with objective response had all their target lesions injected with vusolimogene oderparepvec. Furthermore, FDA review identified two additional patients deemed responders who did not have any target lesions per independent review at baseline.
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FDA Complete Response Letter, April 10, 2026 · page 4

Thus, over half (53%) of patients with objective response did not have noninjected target lesions to assess systemic anti-tumor activity.
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FDA Complete Response Letter, April 10, 2026 · page 4

When these patients are excluded from the analysis of the primary endpoint of ORR, the resulting response rate decreases markedly from your reported response rate in RPL-001-16.
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FDA Complete Response Letter, April 10, 2026 · page 5

Histopathologic assessments were used to assess response, and in some cases, these results changed the radiologic response assessment of best overall response. In RPL-001-16, these histology specimens were not centrally reviewed, there is a potential for sampling bias with respect to biopsy specimens, and it is unclear whether a determination of tumor response based on pathology reflects local treatment effects at the injection site rather than systemic effects of the investigational therapy.
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Replimune Form 8-K, filed April 13, 2026

In addition, the company provided detailed analyses showing no material difference in response rates between injected and non-injected lesions.
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Replimune Form 8-K, filed July 31, 2026

The committee discussed two topics: (1) whether the single-arm IGNYTE study, as designed and conducted, allows for a reliable determination of the expected response rate and durability of response in the proposed population; and (2) the clinical meaningfulness of the response rate and duration of response reported in IGNYTE, and whether the observed responses are indicative of systemic antitumor activity attributable to RP1.
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Replimune Form 8-K, filed August 7, 2026

The IGNYTE trial enrolled 140 patients with 91 patients with at least one non-injected lesion included in the efficacy-evaluable population. In this population, TUDRIQEV plus nivolumab achieved an objective response rate (ORR) of 24.2%, with a median duration of response of 14.1 months.
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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 →