Saturday, June 12, 2010
Dan Vorhaus JD on his blog says "The path of least resistance may be to simply agree with the FDA....The viability will depend on how the FDA intends to categorize the specific product...."
I agree, these companies have big choices to make. If it is any indication, Counsyl (full of smart people) and now, Pathway Genomics (full of smart people) have both decided to go the route of Medical test.
Perhaps it is because they think the burden will cost less to investors than fighting the "Man"
Well, in guessing what the FDA will do, it is always best to see what they have done to a "similar" product. In this case, they have a great product that is very similar. That would be the FDA's approval of AmpliChip.
A friend of mine in Canada argues about the holes in this platform, but unfortunately it is the only FDA approved platform.
You can read the letter for the FDA approval here
This was cleared in 2005! I wonder if the DTCG companies ever looked at AmpliChip as a model before?
In the letter it is clear, microarray technology used for drug metabolism prediction is considered a Class II medical device. The letter indicated that this applied not only to AmpliChip, but also to similar devices.
It also does not waive premarket submission.
Both of these are very important points in how the DTCG groups evaluate their future business models and potential market.
The Sherpa Says: Why Conjecture? Just look at what the FDA decided for AmpliChip. It will be a similar template.