
A Kugler Reconciliation Case for a floor of GPS mOS of 39 (3-Yr OS of 51%), a Ceiling of BAT IRM 16, 3-Yr OS near 26.8% (Higher Than I Expected), resulting in P(sim) 82%, and Why I Think if we end up having a Higher BAT (16 IRM ceiling) in REGAL, that is Bullish for CR1 Indication/Revenue
Hey everyone, pretty excited to share this as I feel like I had a lightbulb moment and now have a great sense of clarity on relationship between IRM/median OS, esc. rate, ELN mix, for what BAT 3-Yr OS has to land at (meaning required to without any other option) if IRM was XYZ, i.e. for instance, 16, meaning there is a joint relationship. This was a real light-bulb moment for me when I was reconciling 3-Yr OS numbers from Kugler's KM curves through pixel tracing.
If transplant rate in REGAL is 10% to 18%, and IRM is 16 for instance, then at that combo, BAT 3-Yr OS has to be 26.8% to 27%, there isn't another way around that (for context in Kugler, LIT+Ven 3-Yr OS was 32.5% and whole-LIT was 29.5%). I'll go over this in detail.
First if IRM is truly fixed at at a certain amount, for instance, 16 months, and the component shapes come from Kugler (median OS by ELN mix, 3-Yr OS by fav/int/adv, etc.), the mixture math mechanically forces 3-year OS. The two are connected in order for the actual median to end up at the fixed amount, whatever IRM that is, in this example/instance, 16.
And what you'll find as I walk through this, is even after CR1 to CR2 discounting of 3-Yr OS form Kugler to land at 16, BAT 3-Yr OS essentially has to be 27% to land an IRM of 16 to work when modeling/ran to the actual fits, after transplant rates are taken into account.
First, to begin, Kugler provides the ELN 2024 mix for the whole LIT cohort: 48% favorable / 28% intermediate / 24% adverse (n = 123/71/63 = 257, from the Fig 3B at-risk table in Kugler)
Venetoclax penetration in LIT is 77% (198/257) (I feel this is great that it lands at 77%, since 25% of REGAL based on the EU protol may be observation, so it is a great comparator)
I used two methods to arrive at the 3-Yr OS for LIT+Ven in Kugler. Explained simply, first is by using the published medians for fav/int/adv, and second, through pixel tracing on the KM curves/figures.
First is my LIT+Ven bucket set (41.9 fav/31.2 int/17.2 adv), from derived medians 27.3/19.1/11.6, is entirely a construction, a 1.09x uplift I applied to the published whole-LIT ELN medians. That gives 32.9% 3-year OS at the natural ELN mix against the 32.5% I traced off Figure 2B. The ELN shape within LIT+Ven is unverifiable from this paper, but the whole-LIT ELN 3-Yr from the two approaches is very close (32.5% and 32.9%).
Now, for the ELN mix, REGAL opened in early 2021, with the protocol written in 2018-2020. ELN 2024 did not exist. ELN 2022 was the contemporary standard, and the protocol may even reference the older ELN 2017 or a pure cytogenetic-risk scheme. Either way, the trial is almost certainly not using ELN 2024 for stratification or reporting. So anchoring REGAL's mix to ELN 2024 labels doesn't work.
Why this is important is because under ELN 2022, 20 fav/50 int/30 adv essentially with a .877 of Kugler's 3-Yr OS numbers for fav/int/adv for LIT, lands at an IRM of 16. But that is ELN 2022. Under ELN 2024, the amount of favorable would be higher, and 38% fav/ 27% int/ 35% adv with a .846 discount also lands at an IRM of 16.
So, even though the ELN 2022 numbers and ELN 2024 numbers/mixes are different, these both arrive at an IRM of 16.
This just context for how ELN 2022 vs ELN 2024 mix changes land at the same IRM, in this case 16, after applying a CR1 to CR2 discount, which are required to actually land at 16.
There are no assumptions here for the discount, it's just the discounts it has to be on Kugler's 3-Yr OS numbers (for fav/int/adv) to arrive at a BAT IRM of 16.
So now with that understand of where Kugler's 3-Yr OS comes from and the relationship between ELN mix and BAT IRM, I wanted to go over visually why ELN mix and BAT IRM have a direct relationship with 3-Yr OS.
First is the published medians for fav/int/adv in Kugler, and this is from the published results and also from pixel tracing, so you can see how close they are.
| Curve | Traced Median | Published | Delta |
|---|---|---|---|
| LIT+Ven | 16.9 | 16.6 | 0.3 |
| LIT no-Ven | 12.8 | 12.5 | 0.3 |
| LIT favorable | 25.3 | 25.1 | 0.2 |
| LIT intermediate | 17.4 | 17.5 | 0.1 |
| LIT adverse | 10.7 | 10.6 | 0.1 |
| IT+Ven | 30.8 | 30.3 | 0.5 |
| IT adverse | 18.7 | 19 | 0.3 |
| IT favorable | NR | NR | N/A since Not Reached |
And then for Kugler's 3-Yr OS Numbers:
| Cohort | n | 3-Yr OS (traced) | At risk at 36 mo |
|---|---|---|---|
| Overall | 362 | 35.4% | - |
| LIT + Ven | 198 | 32.50% | 34/198 |
| Whole LIT | 257 | 29.5% | - |
| LIT without Ven | 59 | 18.50% | 7/59 |
| IT (all) | 105 | 49-51% | - |
And Kugler's 3-Yr OS Numbers by ELN 2024 within LIT (traced):
| ELN 2024 (LIT) | n | Traced 3-yr OS |
|---|---|---|
| Favorable | 123 | 43.60% |
| Intermediate | 71 | 28.90% |
| Adverse | 63 | 4.10% |
Now, that the Kugler published and traced data is clear for LIT + Ven and Whole LIT medians and 3-Yr OS, now we can look at what ELN mixes actually build up to 16.
For context on the logic, the model never computes the mixture median. The ELN buildup produces exactly one number, the 3-Yr OS. The model then imposes median = 16 and back-solves the Weibull shape k so a single curve passes through both. Which is two constraints, one free parameter.
| Bucket set | Implied component medians (fav/int/adv) | Mixture median @ 38/27/35 | vs IRM 16 | Mixture 3-Yr OS | Solved k |
|---|---|---|---|---|---|
| Kugler whole-LIT | 25.0 / 17.5 / 10.6 | 16.5 | 0.5 | 26.30% | 0.81 |
| whole-LIT x 0.9 | 22.2 / 16.0 / 10.0 | 15.2 | -0.8 | 23.70% | 0.903 |
| whole-LIT x 0.8 | 19.7 / 14.7 / 9.4 | 13.9 | -2.1 | 21.00% | 1 |
| Kugler LIT+Ven | 27.3 / 19.1 / 11.6 | 18.1 | 2.1 | 30.40% | 0.668 |
| LIT+Ven x 0.9 | 23.7 / 17.2 / 10.8 | 16.3 | 0.3 | 27.30% | 0.773 |
| LIT+Ven x 0.8838 | 23.2 / 16.9 / 10.6 | 16 | 0 | 26.80% | 0.79 |
| LIT+Ven x 0.8 | 20.7 / 15.4 / 10.0 | 14.7 | -1.3 | 24.30% | 0.88 |
| Traced empirical curves | 25.2 / 17.3 / 10.7 | 14.2 | -1.8 | 25.80% | - |
You can see Kugler whole-LIT undiscounted gives 16.5, and LIT+Ven x 0.9 gives 16.3. Both within rounding of 16. And what lands exactly at 16, is a Kugler LIT+Ven discount of .8838.
The exact-16 IRM buckets are 37.03% 3-Yr OS fav / 27.57% 3-Yr OS int / 15.20% 3-Yr OS adv.
And when I show the full view of the actual fits, you will see that when transplant rate is anywhere from 10% to 18% (and single digits to 13% is likely), 3-Yr OS at that specific ELN mix has to be 26.8% in order to land exactly at a BAT IRM of 16.
Meaning they are connected. If transplant rate in BAT/control in REGAL is 10% to 18%, then 3-Yr OS has to be 27%, in order to arrive at IRM of 16.
So, with that understanding, it was important to look what the actual fits show at the likely ELN mix (38 fav, 27 int, 35 adv) using Kugler's 3-Yr OS numbers, discounted from CR1 to CR2 not just cause, but as required for IRM to land at 16, which results in a 3-Yr OS of 26.8%/27%, and what the results would be, because if BAT IRM is 16 in REGAL, that is what the results would be if transplant rate was 10% to 18%, it would be at a 27% 3-Yr OS.
And as I was looking at these, it honestly was one of the most reasonable/rational fits that covers every single question/objection I've ever had (and most others have had)
And here is what they are:
Exact-16 IRM solutions, Kugler LIT+Ven discounted, mix 38% fav / 27% int / 35% adv, IRM 16, May-2023 enrollment (t=27.65), 80th = Aug-11-2026, fitted to 60/72/78/80
Escape survivors on base Weibull shape
| esc | disc | buckets (fav/int/adv) | pre-esc med | post-esc med | fav | BAT2y | BAT3y | BAT4y | BAT5y | k | cureC | psi | HR@IA | HR@80 | Pana | simHR | Psim | Psnh | GPSd@IA | BATd@IA | GPSa@IA | BATa@IA | GPSa@80 | BATa@80 | RESID | GPSmOS | GPS3y | GPS4y | GPS5y | uncRAW | uncMOS | BAT3yS | HR80S | PsimS | PsimSd | Pnostop | PnsCons | PsimIW |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 10% | x0.827 | 34.64 / 25.79 / 14.22 | 15.1 | 16 | 38% | 39% | 27% | 20% | 14% | 0.78 | 0.37 | 1.11 | 0.556 | 0.483 | 82% | 0.463 | 82% | 80% | 23.6 | 35.2 | 39.4 | 27.8 | 31.6 | 15.4 | 1.14 | 40 | 52% | 47% | 44% | 11.2 | 14 | 23% | 0.369 | 97% | 62% | 50% | 77% | 63 |
| 14% | x0.800 | 33.53 / 24.97 / 13.77 | 14.6 | 16 | 38% | 39% | 27% | 20% | 14% | 0.78 | 0.36 | 1.09 | 0.556 | 0.486 | 82% | 0.467 | 81% | 80% | 23.7 | 35.2 | 39.3 | 27.8 | 31.5 | 15.4 | 1.15 | 40 | 52% | 47% | 44% | 11.4 | 14.4 | 23% | 0.371 | 97% | 62% | 50% | 77% | 62 |
| 18% | x0.772 | 32.33 / 24.07 / 13.27 | 14.2 | 16 | 38% | 39% | 27% | 20% | 15% | 0.77 | 0.35 | 1.06 | 0.557 | 0.49 | 81% | 0.471 | 81% | 79% | 23.7 | 35.2 | 39.3 | 27.8 | 31.3 | 15.6 | 1.15 | 39 | 51% | 47% | 43% | 11.5 | 14.8 | 23% | 0.373 | 97% | 61% | 50% | 77% | 62 |
You can see the pre-esc (pre-transplant) IRM and post-transplant IRM, and what is interesting is how the pre-esc median is a discount to Kugler's whole-LIT mOS of 16.6 (which we don't know if any of those patients transplanted or not). But the IRM numbers between both are similar.
In addition, you can see the exact discount needed for the 3-Yr Kugler whole-LIT OS numbers for fav/int/adv, to arrive at exactly a BAT IRM of 16. I've done a ton of research on literature, and with REGAL's criteria and randomization uplift, a discount of just .772 to .827 is not unreasonable, that is actually right in line with a floor .8 I came to a conclusion to after a ton of research, so that was helpful to see.
And then this fit is also just spot on with no halt at IA, where it was a coin-flip, and the GPS mOS numbers are what you would expect from continuous dosing. They aren't outrageously high, but an mOS of 39/40 is in line with what you would expect, and the reason I say that, and I'll touch on why this is so bullish in a moment, the enrollment criteria/randomization lift/ELN mix is very close to CR1, just a slight discount essentially (if IRM is indeed 16), so given the patient population is close to CR1 newly diagnosed, with about a .2 discount, having GPS achieve CR1 like mOS numbers with a discount is not unusual as well.
And the GPS dead at IA is also completely reasonable, 23/24 dead, with 35 BAT dead at IA, which makes sense as BAT mOS was set in 2024.
And the 3-Yr OS of 51% is right in line with the HLA decomposition thesis I shared earlier this year.
Link: Why I Now Believe Cure-Fraction is around 50%, and not 62%-68%, and Why That Now Makes It Likely the 80th will Occur by Q3 2026
https://www.reddit.com/r/sellaslifesciences/comments/1sz9eu5/why_i_now_believe_curefraction_is_around_50_and/
In that post, there is a helpful comment thread between Remarkable-Big and I where the conclusion was the likely cure-fraction/3-Yr OS rate in REGAL, for GPS is likely 45% to 50%.
When I shared my first ever Part 1 DD for REGAL, I had capped it at 50%, based on previous GPS studies, but capping it just cause is not right. Nothing about GPS should be an input, it should fall out of the model. And then when I shared my HLA decomposition thesis, it also pointed to 45% to 50%, but I still could not figure out why the actual fits were showing a higher cure-fraction around 62% to 68%. But then after my learnings in the HLA decomposition thesis, when I modeled with multiple-buckets in GPS (3 buckets with the 3rd being extremely-long survivors), it ended up matching very closely with the 78th event update (off by 1 event). And then once I started to model with ELN mix, transplant rate taken into account, etc. and we finally got Kugler data shortly afterwards, it now aligns perfectly with all those previous conclusions and the HLA decomposition thesis as well.
At an IRM of 16, with BAT 3-Yr OS at 27% which is has to be with a transplant rate of 10% to 18%, uncured mOS is 14 to 14.8 (which makes perfect sense), the no halt at IA makes perfect sense, the GPS mOS of 39 to 40 makes perfect sense (not a super-"cure" but extremely long survival), and the 3-Yr OS of 51% makes perfect sense.
Another reddit user also shared their meeting notes with a hematologist that mentioned 3-Yr OS of 25% in CR2, and the 27% concurrently is very close.
P(sim) here is 82%, and HR at .463 to .471, which is incredible.
Now, why this high of an IRM/3-Yr OS for BAT (which is not really high at all, just the wrong expectations were set from older data), is really bullish for the CR1 indication/CR1 revenue, is because if GPS is achieving these results in patients where the population/cytogenetics are all fairly close (just a .8 discount) to CR1, newly diagnosed that didn't transplant, then it can likely achieve these same results or slightly better in CR1.
And we know from Kugler, whole-LIT mOS was 16.6 and all of Kugler was 19, and if GPS in REGAL is getting 39/40 mOS, then when the FDA is looking at this data, they will see it is clear as day that the results in almost the same population will be great in CR1.
I believe an IRM of 16 and 27% 3-Yr OS in REGAL (which have to go together if transplant rate is 10% to 18%) is our ceiling.
Dr. Tsirigotis said these exact words in his correspondence:
"Dear sir
Regarding the median survival of patients with AML in CR2:
the range of median OS without transplant is really wide and depends on many factors, such as cytogenetics, molecular abnormalities, type of previous lines of therapy, etc
In a recent randomized trial i was involved the median OS of patients with AML in CR2 was 16 months, but many patients were on treatment with new agents and not with standard chemotherapy"
There is only one CR2 randomized trial that we know of, and that 16 likely represents the patients he oversees in REGAL. Kugler data is from MD Anderson (the top in the world), but the centers Dr. Tsirigotis oversees are world-class as well, ATTIKON, General University Hospital is a world-class center too.
Thus, it's either 16 IRM is the ceiling, or it comes in lower than 16 IRM, and 3-Yr OS would then not be 27% but would be lower, if transplant rate is 10% to 18%.
Hope this is insightful for everyone, this was a real lightbulb moment for me and I'm feeling really excited for topline results as it all clicks really well now. I'm glad I came across this just before topline, not for any reason specifically, but it is a suitable closing chapter in my REGAL modeling posts (this was unplanned by the way, I just discovered this as I was doing deep-dives into Kugler for 3-Yr OS and decided to test against the actual fits)