Another Second-Generation GalNAc-RNAi Rocked by Off-Target Concerns

With the approval of ONPATTRO and the current overall clinical picture, in particular the highly encouraging safety profile seen with PCSK9-targeting Inclisiran in well over a 1000 subjects (à The Medicines Company and Alnylam), the RNAi mechanism can be considered a clinically validated  new drug modality. 

Liver enzyme elevations, however, have been seen across a few clinical programs.  This includes ALN-AAT for alpha-1 antitrypsin-related liver disease, ALN-AT3 for hemophilia, and now also Givosiran (ALN-AS1).  The most likelyreason for these observations is that the minimization of off-targeting had been neglected for these ‘2^nd-generation GalNAc-RNAi triggers’, thereby raising the risk that the relatively high off-target noise (dozens of off-targets) can be detrimental to target cell health. 

To wit, the spectrum of off-target genes varies tremendously from RNAi trigger sequence to RNAi trigger sequence and affects biologically unrelated genes.  This makes it very hard to predict whether the off-target noise will have adverse effects or will be just irrelevant noise to the cell.  Not helping is the fact that lab animals due to their genome sequence differences cannot model the safety around off-targeting.  The hope is that perhaps organ explants or mice with humanized organs (e.g. humanized mouse livers) will be better predictors since the target cell is almost the same as in the clinical setting.

Marked liver enzyme elevation in Givosiran pivotal trial

This week, Alnylam provided an interim read-out from the ENVISION trial, the registrational study with GalNAc-siRNA Givosiran for acute hepatic porphyria (AHP).  AHP is a rare disease caused by defects in heme synthesis.  This results in the accumulation of toxic intermediates such as PBG and ALA which can cause a range of symptoms, including severe pain attacks.

The study envisioned an interim biomarker read-out in a first cohort of patients that had been treated for at least 3 months with study drug.  It had been agreed before with the FDA that if lowering of ALA could be found in this read-out, it might form the basis for an accelerated approval.

Unsurprisingly, urinary ALA levels were reported to be statistically significantly lower in patients treated with Givosiran compared to placebo- in-line with the phase I/II experience (p<0 .001="" span="" style="mso-spacerun: yes;"> 

Unfortunately, there were numerically more than twice as many Givosiran-treated sujects (5/23) that experienced a serious adverse event (SAE) than in the placebo group (2/20).  One of the Givosiran-treated subjects had to discontinue treatment due to liver enzyme levels above the pre-specified threshold (>8x upper limit of normal).  While no liver enzyme elevations had been reported in a similar number of patients in the earlier-stage studies, I wished the company could have talked more about the presence of other liver enzyme increases of less than 8x ULN to get a better sense of the magnitude of the problem and whether such incidence would be compatible with giving the drugs in a chronic fashion.

Having said that, with 5 SAEs in 23 subjects treated a little more than 3 months on average (on top of a case of drug-related anaphylaxis in the phase I/II open-label extension study), SAEs that might be drug-related, would already seem to invalidate Givosiran being used in those with the same genetic condition, but not necessarily with recurrent pain attacks.  This would have tremendously extended the market opportunity of Givosiran.   

In the same vein, with the present safety questions, an accelerated approval that would shave off a few months before the full dataset will be available in early 2019, can now be ruled out with high certainty.

To add insult to injury, Akcea reported earlier this week that a GalNAc-version of the competitive RNaseH antisense technology did not suffer from thrombocytopenia as unconjugated ASOs typically do, thus putting ASOs back in the race for liver targets.  Still, in the long-term and in particular with the more specific new GalNAc-RNAi trigger chemistries, RNAi should win for most liver targets, but for some targets where either RNAi has inherent difficulties achieving high potencies or in cases where off-targeting toxicity still strikes (albeit at a much lower rate), RNaseH ASOs may emerge victorious.

Disclosure: long ALNY, but have taken some off the table following these data and questions around cardiac issues with ONPATTRO; it is important now for Inclisiran to re-instill confidence in the safety of RNAi Therapeutics; short AKCA as I do not believe that their current TTR and triglyceride-lowering drugs TEGSEDI and WAYLIVRA, respectively, can be commercially successful drugs and its artificially bloated market cap is a result of the low float and short interest in this stock and not a reflection of the value that the market sees in Akcea.