REGULATORY DEVELOPMENT

A drug-development
program.

Antaeus Biosciences is pursuing bemitil as a drug. The current $1–2M pre-seed round funds preclinical work toward a candidate decision. It does not fund a supplement launch or establish human efficacy.

The route at a glance

Selected: drug development

Preclinical evidence and an IND-led plan

Qualifying clinical development

Safety and efficacy evidence for a defined product and use

505(b)(2)

Assess whether existing findings can support part of an NDA. Reliance and bridging must be justified.

505(b)(1)

A fuller original evidence package when the reliance route does not fit.

The company has selected drug development. The NDA pathway requires a product-specific gap assessment. A supplement launch is outside this plan.

01 / COMPANY DECISION

Drug development is the route

We are pursuing drug development through an IND-led clinical program and an appropriate NDA pathway. We will assess 505(b)(2) reliance on existing evidence with regulatory specialists. No IND or NDA is represented as filed.

02 / DECISION TREE

The drug branch is selected

The selected branch is drug development. After a supported preclinical decision, prepare the quality, safety and clinical package needed for an IND. Then determine whether an NDA can rely in part on existing evidence under 505(b)(2) or needs a fuller applicant-generated package under 505(b)(1). The supplement branch is outside this company plan.

03 / PRESCRIPTION DEVELOPMENT

IND before a qualifying human study

The drug branch begins with authenticated material, manufacturing information, nonclinical safety and a clinical protocol. A US investigational study that requires an IND cannot begin until the IND is in effect and other required approvals are in place. FDA has an initial 30-day review window; a clinical hold can stop the study.

FDA: IND overview ↗Official context or process; not efficacy

04 / 505(b)(2)

A possible evidence-reliance pathway

A 505(b)(2) NDA may rely in part on published studies or certain FDA findings not owned by the applicant. It remains a full approval application. Whether the bemitil literature can support this route, and what bridging work would be required, needs regulatory assessment. Soviet-era use is not a US approval shortcut.

FDA: applications covered by 505(b)(2) ↗Official context or process; not efficacy

05 / 505(b)(1)

A fuller evidence burden

If the available literature cannot support the necessary reliance, an application may need a fuller applicant-generated package under 505(b)(1). Both drug routes require adequate evidence of quality, safety and effectiveness. [REGULATORY GAP ASSESSMENT: fill in].

06 / DIETARY SUPPLEMENT

Why a supplement is outside the plan

We are developing a drug, not selling bemitil as a supplement. NDI means new dietary ingredient notification; NDA means new drug application. NDI eligibility, safety notification and lawful supplement claims are separate requirements. A notification is not a substitute for drug approval.

FDA: NDI background and ingredient eligibility ↗Official context or process; not efficacyFDA: NDI notification procedures ↗Official context or process; not efficacy

07 / TRADEOFFS

Choose a product, then cost its path

Prescription development can support approved treatment claims if evidence earns approval. It requires clinical development, manufacturing controls and further capital. A supplement route cannot substitute for those requirements. The cost and timing of the selected drug route depend on a product-specific legal and scientific assessment.

08 / TARGET TIMELINE

The first 18 months are preclinical

Months 0–3: leadership, authenticated material and locked thresholds. Months 3–9: molecular profiling, functional heat testing and independent confirmation. The month-nine stop rule applies to failed replication or unacceptable safety. [REGULATORY MILESTONE DATE: fill in]. An IND filing date and a market-launch date are not established.

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