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Study 329 was a
clinical trial Clinical trials are prospective biomedical or behavioral research studies on human participants designed to answer specific questions about biomedical or behavioral interventions, including new treatments (such as novel vaccines, drugs, dietar ...
which was conducted in North America from 1994 to 1998 to study the efficacy of
paroxetine Paroxetine, sold under the brand names Paxil and Seroxat among others, is an antidepressant of the selective serotonin reuptake inhibitor (SSRI) class. It is used to treat major depressive disorder, obsessive-compulsive disorder, panic disorder ...
, an SSRI anti-depressant, in treating 12- to 18-year-olds diagnosed with
major depressive disorder Major depressive disorder (MDD), also known as clinical depression, is a mental disorder characterized by at least two weeks of pervasive low mood, low self-esteem, and loss of interest or pleasure in normally enjoyable activities. Introdu ...
. Led by Martin Keller, then professor of psychiatry at
Brown University Brown University is a private research university in Providence, Rhode Island. Brown is the seventh-oldest institution of higher education in the United States, founded in 1764 as the College in the English Colony of Rhode Island and Providenc ...
, and funded by the British pharmaceutical company SmithKline Beecham—known since 2000 as
GlaxoSmithKline GSK plc, formerly GlaxoSmithKline plc, is a British multinational pharmaceutical and biotechnology company with global headquarters in London, England. Established in 2000 by a merger of Glaxo Wellcome and SmithKline Beecham. GSK is the ten ...
(GSK)—the study compared paroxetine with
imipramine Imipramine, sold under the brand name Tofranil, among others, is a tricyclic antidepressant (TCA) mainly used in the treatment of depression. It is also effective in treating anxiety and panic disorder. The drug is also used to treat bedwetting. ...
, a
tricyclic antidepressant Tricyclic antidepressants (TCAs) are a class of medications that are used primarily as antidepressants, which is important for the management of depression. They are second-line drugs next to SSRIs. TCAs were discovered in the early 1950s and wer ...
, and
placebo A placebo ( ) is a substance or treatment which is designed to have no therapeutic value. Common placebos include inert tablets (like sugar pills), inert injections (like Saline (medicine), saline), sham surgery, and other procedures. In general ...
(an inert pill). SmithKline Beecham had released paroxetine in 1991, marketing it as Paxil in North America and Seroxat in the UK. The drug attracted sales of $11.7 billion in the United States alone from 1997 to 2006, including $2.12 billion in 2002, the year before it lost its
patent A patent is a type of intellectual property that gives its owner the legal right to exclude others from making, using, or selling an invention for a limited period of time in exchange for publishing an enabling disclosure of the invention."A p ...
. Published in July 2001 in the ''
Journal of the American Academy of Child and Adolescent Psychiatry The ''Journal of the American Academy of Child and Adolescent Psychiatry'' is a peer-reviewed medical journal covering pediatric psychiatry. It is published by Elsevier and is the official journal of the American Academy of Child and Adolescent ...
'' (''JAACAP''), which listed Keller and 21 other researchers as co-authors, study 329 became controversial when it was discovered that the article had been
ghostwritten ''Ghostwritten'' is the first novel published by English author David Mitchell. Published in 1999, it won the John Llewellyn Rhys Prize and was widely acclaimed. The story takes place mainly around East Asia, but also moves through Russia, B ...
by a PR firm hired by SmithKline Beecham, had made inappropriate claims about the drug's efficacy, and had downplayed safety concerns. The controversy led to several lawsuits and strengthened calls for drug companies to disclose all their clinical research data. ''
New Scientist ''New Scientist'' is a magazine covering all aspects of science and technology. Based in London, it publishes weekly English-language editions in the United Kingdom, the United States and Australia. An editorially separate organisation publishe ...
'' wrote in 2015: "You may never have heard of it, but Study 329 changed medicine." SmithKline Beecham acknowledged internally in 1998 that the study had failed to show efficacy for paroxetine in adolescent depression. In addition, more patients in the group taking paroxetine had experienced
suicidal thinking Suicidal ideation, or suicidal thoughts, means having thoughts, ideas, or ruminations about the possibility of ending one's own life.World Health Organization, ''ICD-11 for Mortality and Morbidity Statistics'', ver. 09/2020MB26.A Suicidal ideatio ...
and behaviour. Although the ''JAACAP'' article included these negative results, it did not account for them in its conclusion; on the contrary, it concluded that paroxetine was "generally well tolerated and effective for major depression in adolescents". The company relied on the ''JAACAP'' article to promote paroxetine for off-label use in teenagers. In 2003 Britain's
Medicines and Healthcare products Regulatory Agency The Medicines and Healthcare products Regulatory Agency (MHRA) is an executive agency of the Department of Health and Social Care in the United Kingdom which is responsible for ensuring that medicines and medical devices work and are acceptably ...
(MHRA) analysed study 329 and other GSK studies of paroxetine, concluding that, while there was no evidence of paroxetine's efficacy in children and adolescents, there was "robust evidence" of a causal link between the drug and suicidal behaviour. The following month the MHRA and US
Food and Drug Administration The United States Food and Drug Administration (FDA or US FDA) is a List of United States federal agencies, federal agency of the United States Department of Health and Human Services, Department of Health and Human Services. The FDA is respon ...
(FDA) advised doctors not to prescribe paroxetine to the under-18s."FDA statement regarding the anti-depressant Paxil for pediatric population"
Food and Drug Administration, 19 June 2003, courtesy of the
Drug Industry Documents Archive The Drug Industry Documents Archive (DIDA) is a digital archive of pharmaceutical industry documents created and maintained by the University of California, San Francisco, Library and Center for Knowledge Management. DIDA is a part of the larger UC ...
, University of California, San Francisco.
The MHRA launched a criminal inquiry into GSK's conduct, but announced in 2008 that there would be no charges. In 2004 New York State Attorney
Eliot Spitzer Eliot Laurence Spitzer (born June 10, 1959) is an American politician and attorney. A member of the Democratic Party (United States), Democratic Party, he was the 54th governor of New York from 2007 until his resignation in 2008. Spitzer was b ...
sued GSK for having withheld data, and in 2012 the
United States Department of Justice The United States Department of Justice (DOJ), also known as the Justice Department, is a federal executive department of the United States government tasked with the enforcement of federal law and administration of justice in the United State ...
fined the company $3 billion, including a sum for withholding data on paroxetine, unlawfully promoting it for the under-18s, and preparing a misleading article on study 329. The company denied that it had withheld data, and said it was only when data from its nine paediatric trials on paroxetine were analysed together that "an increased rate of suicidal thinking or attempted suicide asrevealed". The ''JAACAP'' article on study 329 was never retracted.Heck, Isabel (2 April 2014)
"Controversial Paxil paper still under fire 13 years later"
''The Brown Daily Herald''.
The journal's editors say the negative findings are included in a table, and that therefore there are no grounds to withdraw the article., p. 1246. In September 2015 the ''BMJ'' published a re-analysis of the study. This concluded that neither paroxetine nor imipramine had differed in efficacy from placebo in treating depression, that the paroxetine group had experienced more suicidal ideation and behaviour, and that the imipramine group had experienced more cardiovascular problems.Le Noury, Joanna, et al. (16 September 2015)
"Restoring Study 329: efficacy and harms of paroxetine and imipramine in treatment of major depression in adolescence"
''BMJ'', 351.
Godlee, Fiona (17 September 2015)
"Study 329"
''BMJ'', 351, 17 September 2015.
Doshi, Peter (16 September 2015)
"No correction, no retraction, no apology, no comment: paroxetine trial reanalysis raises questions about institutional responsibility"
''BMJ'', 351.
Henry, David; Fitzpatrick, Tiffany (16 September 2015))
"Liberating the data from clinical trials"
''BMJ'', 351.
Boseley, Sarah (16 September 2015)
"Seroxat study under-reported harmful effects on young people, say scientists"
''The Guardian''.


Clinical trial


Overview

Funded by SmithKline Beecham, the acute phase of study 329 was an eight-week, double-blind, randomized clinical trial conducted in 12 university or hospital psychiatric departments in the United States and Canada between 1994 and 1997. The study compared paroxetine, a selective serotonin reuptake inhibitor marketed as Paxil and Seroxat, with
imipramine Imipramine, sold under the brand name Tofranil, among others, is a tricyclic antidepressant (TCA) mainly used in the treatment of depression. It is also effective in treating anxiety and panic disorder. The drug is also used to treat bedwetting. ...
, a
tricyclic antidepressant Tricyclic antidepressants (TCAs) are a class of medications that are used primarily as antidepressants, which is important for the management of depression. They are second-line drugs next to SSRIs. TCAs were discovered in the early 1950s and wer ...
marketed as Tofranil, in teenagers aged 12–18 with a diagnosis of
major depressive disorder Major depressive disorder (MDD), also known as clinical depression, is a mental disorder characterized by at least two weeks of pervasive low mood, low self-esteem, and loss of interest or pleasure in normally enjoyable activities. Introdu ...
of at least eight weeks duration. Martin Keller, then professor of psychiatry at
Brown University Brown University is a private research university in Providence, Rhode Island. Brown is the seventh-oldest institution of higher education in the United States, founded in 1764 as the College in the English Colony of Rhode Island and Providenc ...
, had proposed the trial to the company in 1992 as the largest study until then to examine the efficacy of SSRIs in children. After a screening phase from April 1994, 275 male and female patients were randomly assigned paroxetine, imipramine or
placebo A placebo ( ) is a substance or treatment which is designed to have no therapeutic value. Common placebos include inert tablets (like sugar pills), inert injections (like Saline (medicine), saline), sham surgery, and other procedures. In general ...
(an inert pill). Of the 275, 93 were given paroxetine, 95 imipramine and 89 placebo. The paroxetine group were given 20 mg daily for four weeks, rising to 30 mg at week five and 40 mg at week six if the clinician thought it appropriate. The last study visit was in May 1997, and the blind was broken in October.


Efficacy

The trial's protocol had described two primary and six secondary outcomes by which it would measure efficacy."Study drug: BRL29060/Paroxetine (Paxil)"
SmithKline Beecham, 20 August 1993, amended 24 March 1994.
The data showed that, according to those eight outcomes, paroxetine was no more effective than placebo. According to Melanie Newman, writing for the ''
BMJ ''The BMJ'' is a weekly peer-reviewed medical trade journal, published by the trade union the British Medical Association (BMA). ''The BMJ'' has editorial freedom from the BMA. It is one of the world's oldest general medical journals. Origina ...
'', " e drug only produced a positive result when four new secondary outcome measures, which were introduced following the initial data analysis, were used instead. Fifteen other new secondary outcome measures failed to throw up positive results."


Safety

Eleven subjects on paroxetine, compared to five on imipramine and two on placebo, experienced
serious adverse event A serious adverse event (SAE) in human drug trials is defined as any untoward medical occurrence that at any dose #Results in death #Is life-threatening #Requires inpatient hospitalization or causes prolongation of existing hospitalization #Results ...
s (SAE), including behavioral problems and emotional lability. The researchers defined an event as an SAE if it resulted in hospitalization, involved suicidal gestures, or was regarded as serious by the subject's doctor. In the 93 taking paroxetine, the SAEs consisted of one subject experiencing headache while tapering off, and 10 experiencing psychiatric problems. Seven of the 10 were hospitalized. Two of the 10 experienced worsening depression; two conduct problems such as aggression; one
euphoria Euphoria ( ) is the experience (or affect) of pleasure or excitement and intense feelings of well-being and happiness. Certain natural rewards and social activities, such as aerobic exercise, laughter, listening to or making music and da ...
; and five emotional lability, including suicidal ideation and behaviour. Of the 95 patients on imipramine and the 89 on placebo, one in each group experienced emotional lability. Yet Keller's article in the ''
Journal of the American Academy of Child and Adolescent Psychiatry The ''Journal of the American Academy of Child and Adolescent Psychiatry'' is a peer-reviewed medical journal covering pediatric psychiatry. It is published by Elsevier and is the official journal of the American Academy of Child and Adolescent ...
'' concluded that, of the 11 patients who had experienced SAEs while taking paroxetine, "only headache (1 patient) was considered by the treating investigator to be related to paroxetine treatment". Keller 2001, p. 769.


1998 SmithKline Beecham position paper

In October 1998 the neurosciences division of SmithKline Beecham's Central Medical Affairs (CMAT) department distributed a position paper, "Seroxat/Paxil Adolescent Depression: Position piece on the phase III clinical studies", that discussed studies 329 and 377."Seroxat/Paxil Adolescent Depression: Position piece on the phase III clinical studies"
SmithKline Beecham, October 1998, courtesy of the
Drug Industry Documents Archive The Drug Industry Documents Archive (DIDA) is a digital archive of pharmaceutical industry documents created and maintained by the University of California, San Francisco, Library and Center for Knowledge Management. DIDA is a part of the larger UC ...
, University of California, San Francisco; also availabl
here
courtesy of the
United States Department of Justice The United States Department of Justice (DOJ), also known as the Justice Department, is a federal executive department of the United States government tasked with the enforcement of federal law and administration of justice in the United State ...
.
The latter was a 12-week trial, comparing paroxetine and placebo in teenagers, conducted from 1995 to 1998. The SmithKline Beecham position paper explained that the company had decided not to submit trial data from studies 329 and 377 to regulators, and discussed how to "effectively manage the dissemination of these data in order to minimise any potential negative commercial impact". An attached memo noted that the results were disappointing and would not support a label claim that paroxetine could be used to treat adolescents: "The best that could have been achieved was a statement that, although safety data was reassuring, efficacy had not been demonstrated." The paper said: "it would be commercially unacceptable to include a statement that efficacy had not been demonstrated, as this would undermine the profile of paroxetine." Study 329 had shown "trends in efficacy in favour of Seroxat/Paxil across all indices of depression ...", according to the paper, " ut hadfailed to demonstrate a statistically significant difference from placebo on the primary efficacy measures". Study 377 had shown a high placebo response rate and had "failed odemonstrate any separation of Seroxat/Paxil from placebo". SmithKline Beecham decided to publish study 329 but not 377, and not to submit either trial to the regulators, because they were "insufficiently robust to support a label change" for adolescent use". The document was leaked during a lawsuit and first published by the '' Canadian Medical Association Journal'' in March 2004. In response a GSK spokesperson said that "the memo draws an inappropriate conclusion and is not consistent with the facts ... GSK abided by all regulatory requirements for submitting safety data. We also communicated safety and efficacy data to physicians through posters, abstracts, and other publications."


''JAACAP'' article


Authorship

Although the ''JAACAP'' article listed its authors as Martin Keller and 21 other physicians or researchers, the article had in fact been
ghostwritten ''Ghostwritten'' is the first novel published by English author David Mitchell. Published in 1999, it won the John Llewellyn Rhys Prize and was widely acclaimed. The story takes place mainly around East Asia, but also moves through Russia, B ...
by Scientific Therapeutics Information (STI), a PR company in Springfield, New Jersey, specializing in communications for the pharmaceutical industry. The ''JAACAP'' article did not mention STI; the only mention of Laden was: "Editorial assistance was provided by Sally K. Laden, M.S." The list of authors included James P. McCafferty of GSK, but the article did not disclose his company affiliation. STI had worked with SmithKline Beecham on its promotion of paroxetine since the early 1990s. In April 1998 Sally K. Laden and John A. Romankiewicz of STI sent SmithKline Beecham an estimate of $17,250 to work on six drafts of the study 329 paper, including the final draft, to cover the period up to March 1999. The sum was payable in installments: $8,500 upon initiation, $5,125 after draft three, and $3,625 upon submission to the journal. The estimate covered all writing, editing, library research, copy editing, art work and coordination with the physicians and others who would be named as authors. Martin Keller would be listed as the main author. The first draft was ready by December 1998. SmithKline Beecham documents show that Laden and STI coordinated the entire publication process, including writing the cover letter to the journal that published the article, ''JAACAP'', which she sent to Keller with the instruction that he transfer it to his own letterhead.


Publication

STI first submitted the article to the ''
Journal of the American Medical Association ''The Journal of the American Medical Association'' (''JAMA'') is a peer-reviewed medical journal published 48 times a year by the American Medical Association. It publishes original research, reviews, and editorials covering all aspects of bio ...
'' (''JAMA''), which rejected it in November 1999. Concerns cited by ''JAMA'' reviewers included that "the main finding of the study is the high placebo response rate". They also suggested that the named authors confirm they had been "granted full access to the data set to verify the accuracy of the report". Early drafts of the paper for ''JAMA'' did not mention the
serious adverse event A serious adverse event (SAE) in human drug trials is defined as any untoward medical occurrence that at any dose #Results in death #Is life-threatening #Requires inpatient hospitalization or causes prolongation of existing hospitalization #Results ...
s (SAEs). A SmithKline Beecham scientist, James McCafferty, added a paragraph about these in July 1999, adding that 11 patients on paroxetine had experienced SAEs, against two on placebo: "worsening depression, emotional lability, headache, and hostility were considered related or possibly related to treatment." Jureidini et al. 2008, p. 77. This was changed in the final draft to: "Of the 11 patients, only headache (1 patient) was considered by the treating investigator to be related to paroxetine treatment." In December 1999 Laden submitted the rewritten paper to ''JAACAP'', led at the time by Mina K. Dulcan, editor-in-chief. According to Melanie Newman in the ''BMJ'', ''JAACAP's'' reviewers wrote that the results did not "clearly demonstrate efficacy for paroxetine", and asked whether, because of the high placebo response rate, SSRIs should be regarded as first-line therapy. Newman 2010, p. 1247. ''JAACAP'' accepted the article in January 2001, and published it in July. The article concluded: "Paroxetine is generally well tolerated and effective for major depression in adolescents." McCafferty's paragraph about worsening depression and emotional lability possibly being related to the treatment had been removed. The only SAE attributed to paroxetine in the ''JAACAP'' article was in one patient who had reported headache. The article continued: "Because these serious adverse events were judged by the investigator to be related to treatment in only 4 patients (paroxetine, 1; imipramine, 2; placebo, 1), causality cannot be determined conclusively." It concluded: "The findings of this study provide evidence of the efficacy and safety of the SSRI, paroxetine, in the treatment of adolescent depression." Keller 2001, pp. 770–771.


2001 GlaxoSmithKline sales memo, off-label use

GSK used the ''JAACAP'' article to promote paroxetine to doctors for use in their teenage patients. The drug had not been approved for use in children and adolescents. Drug companies are prohibited from promoting drugs for unapproved uses, but doctors are permitted to prescribe drugs for what is known as off-label use. In the UK 32,000 prescriptions of paroxetine were written for children and adolescents in 1999, and in the US that figure rose to 2.1 million in 2002, earning GSK $55 million.''The People of the State of New York against GlaxoSmithKline''
2 June 2004, p. 2, para. 3.
On 7 August 2001 Sally Laden of STI, apparently the main author of the ''JAACAP'' article, arranged for GSK to buy 500 reprints of the article—300 for Keller and 200 for Zachary Hawkins of GSK's Paxil Product Management team—to be distributed to the company's neuroscience sales force. On 16 August 2001 Zachary Hawkins sent a memo about study 329 to "All Sales Representatives Selling ''Paxil''", calling study 329 a "cutting-edge,' landmark study", the first to compare efficacy of a selective serotonin reuptake inhibitor and a
tricyclic antidepressant Tricyclic antidepressants (TCAs) are a class of medications that are used primarily as antidepressants, which is important for the management of depression. They are second-line drugs next to SSRIs. TCAs were discovered in the early 1950s and wer ...
with placebo in the treatment of depressed adolescents. "''Paxil'' demonstrates REMARKABLE Efficacy and Safety in the treatment of adolescent depression," he wrote. The memo continued that paroxetine was "significantly more effective than placebo" on certain outcomes: "''Paxil'' was generally well tolerated in this adolescent population and most adverse events were not serious. The most common adverse events occurred at rates that were similar to rates in the placebo group." It ended with:
In conclusion, the findings of this study provide evidence of the efficacy and safety of ''Paxil'' in the treatment of adolescent depression. Here's another example of GlaxoSmithKline's commitment to Psychiatry by bringing forth 'cutting edge' scientific data. ''Paxil'' is truly a REMARKABLE product that continues to demonstrate efficacy, even in this understudied population."


Inquiries in the United Kingdom


BBC ''Panorama'', MHRA

Scottish reporter Shelley Jofre presented four investigative programmes on paroxetine for BBC ''
Panorama A panorama (formed from Greek πᾶν "all" + ὅραμα "view") is any wide-angle view or representation of a physical space, whether in painting, drawing, photography, film, seismic images, or 3D modeling. The word was originally coined in ...
'' between 2002 and 2007, including one devoted to study 329, "Secrets of the Drug Trials", in January 2007."The Secrets of Seroxat"
BBC ''Panorama'', 13 October 2002
transcript
.
"Emails from the edge"
BBC ''Panorama'', 11 May 2003
transcript
.
"Taken on Trust"
BBC ''Panorama'', 3 October 2004
transcript
.
"Secrets of the drugs trials"
BBC ''Panorama'', 29 January 2007
transcript

"Company hid suicide link"
BBC News, 29 January 2007
"Seroxat: Statement from GlaxoSmithKline"
BBC ''Panorama'', 29 January 2007.
The 2007 programme was based on thousands of internal company documents produced during lawsuits pursued against GSK by patients and families. Jofre's interest in paroxetine was triggered by the July 2001 case of ''Timothy J. Tobin v. SmithKline Beecham Pharmaceuticals'' in the United States. The family of 60-year-old Donald Schell sued the company after Schell shot and killed his wife, daughter and baby granddaughter, then committed suicide, 48 hours after starting a course of paroxetine in 1998. A Wyoming jury awarded the plaintiffs $6.4 million. The first of Jofre's programmes, "The Secrets of Seroxat", aired on 13 October 2002, and covered the Schell case, study 329, and GSK's efforts to market the drug for use in children. (At the time the Summary of Product Characteristics for paroxetine in Europe said that its use in children was "not recommended as safety and efficacy have not been established in this population".) Discussing study 329 and the paediatric use of paroxetine, Alistair Benbow, head of European psychiatry for GlaxoSmithKline, told Jofre that, during study 329, paroxetine had been "generally well tolerated by this difficult to treat population". To examine the issues that ''Panorama'' had raised, Britain's
Medicines and Healthcare products Regulatory Agency The Medicines and Healthcare products Regulatory Agency (MHRA) is an executive agency of the Department of Health and Social Care in the United Kingdom which is responsible for ensuring that medicines and medical devices work and are acceptably ...
(MHRA) set up an ad hoc group of experts, which held a meeting with GSK on 14 November 2002. The MHRA asked GSK about its clinical trials in children. GSK was planning to apply for pediatric indications for paroxetine. According to the MHRA, "GSK did not raise any concern about lack of efficacy or adverse reactions in the clinical trials in the paediatric population at that meeting." MHRA, 6 March 2008(a), p. 3, para. 7. Jofre's second ''Panorama'' programme on paroxetine, "Emails from the edge" (11 May 2003) focused on the 67,000 calls and 1,400 e-mails the BBC received, after the first programme, from people taking the drug. They reported withdrawal symptoms, as well as acts of violence and self-harm that they believed were attributable to paroxetine. During this programme, Benbow told Jofre: "We have been asked by the regulatory authorities to provide all our information related to suicides and I can tell you the data that we provide to them clearly shows no link between Seroxat and an increased risk of suicide—no link."


May 2003 GlaxoSmithKline briefing paper

In February 2003 the MHRA's
Committee on the Safety of Medicines The Committee on Safety of Medicines (CSM) was an independent advisory committee that advised the UK Licensing Authority on the quality, efficacy, and safety of medicines. Following the thalidomide tragedy of 1957 to 1961, in 1963 the government ...
(CSM) set up an Expert Working Group to investigate SSRIs and safety. In preparation for its first meeting, the MHRA met GSK on 21 May 2003 to make sure that GSK had supplied all information relevant to paroxetine and safety, and to discuss Jofre's second ''Panorama'' programme. Toward the end of the meeting, GSK handed over a 79-page briefing paper, "Paroxetine: Critical evaluation of paroxetine hydrochloride for the treatment of Paediatric Obsessive Compulsive Disorder and Social Anxiety Disorder in children and adolescents", dated 20 May 2003. MHRA, 6 March 2008(a), p. 4, para. 11. The paper included data from nine clinical trials GSK had conducted on paroxetine and children between April 1994 and September 2002: GSK briefing paper, 20 May 2003, p. 9, table 1. The briefing paper concluded that "analysis of the safety data demonstrates that paroxetine is generally well tolerated by paediatric patients ...," but suggested a label change to the effect that efficacy had not been established in children with major depressive disorder, and that adverse reactions could include hyperkinesia, hostility, emotional lability and agitation. The paper said these had occurred around twice as much in the paroxetine group than in those taking placebo. By "emotional lability", the paper alluded in particular to suicidal thoughts and behaviour. Of 20 reports of adverse events in the paroxetine groups, 12 had been suidical thoughts or suicide attempts (none successful), three self-mutilation and five general emotional lability. There had been eight adverse events in the patients taking placebo, of which four were suicidal thoughts or behaviour, one self-mutilation and three emotional lability. The paper suggested a label change regarding withdrawal symptoms, which it said had occurred with paroxetine at roughly twice the rate of placebo. MHRA, 22 May 2003. For twice that of placebo, section 5.2.5, p. 27. For the rest, section 5.4, p. 32.


MHRA response

Alasdair Breckenridge, then-chair of the MHRA, told ''Panorama'' that the GSK briefing document caused "a very dramatic change in our thinking about Seroxat and children". The MHRA asked GSK to submit the full clinical data, which they did on 27 May 2003. The data provided "robust evidence" of a causal link between paroxetine and suicidality, and no evidence that paroxetine was effective in treating depression in children. MHRA, 6 March 2008(a), p. 5, para. 12. The MHRA wrote:
On examination of the full clinical trial data in children submitted by GSK urgently on 27 May 2003 in response to requests from the Agency, it became clear that the evidence base for the safety concern of an increased risk of suicidal behaviour was derived from pooled analysis of all the trials (a meta-analysis). It was only when the trials were analysed together that the safety issue became apparent. These trials had been conducted over a number of years and some had been published in part, however the publications gave an incomplete and partial picture of the full data. Importantly, the trials conducted in a range of conditions in children and adolescents failed to demonstrate that Seroxat was effective in the treatment of depressive illness.
The analysis suggested an increased rate of suicidal thinking and behaviour of 3.4 percent on paroxetine versus 1.2 percent on placebo.Carrey, Normand; Pharm, Adil Virani (November 2003). "Suicidal Ideation Reports From Pediatric Trials for Paroxetine and Venlafaxine", ''The Canadian Child and Adolescent Psychiatry Review'', 12(4), pp. 101–102. The committee concluded that the risks outweighed the benefits, MHRA, 4 June 2003, p. 16. and on 10 June 2003 issued an advisory to physicians not to prescribe paroxetine to the under-18s.Duff, Gordon (10 June 2010)
"Safety of Seroxat (paroxetine) in children and adolescents under 18 years—contradindication in the treatment of depressive illness"
Committee on Safety of Medicines, Scottish Executive.
The US Food and Drug Administration followed suit nine days later.


Criminal inquiry

The MHRA launched a criminal inquiry in October 2003 into GSK's conduct. This was based on two concerns: (a) the length of time between the end of the trials and GSK's passing the safety concerns to the MHRA; and (b) the manner in which the material had been handed over. Rather than alerting the MHRA of a risk, GSK had supplied the data in relation to an application to extend the indications of paroxetine to children. The MHRA deemed this inappropriate for an urgent safety concern because of the length of time such applications can take. Medical ethicists Linsey McGoey and Emily Jackson argued that the 1998 SmithKline Beecham position paper, in which the company said it had decided not to show studies 329 and 377 to regulators, represented a ''prima facie'' breach of the '' Medicines Act 1968'' and ''Medicines for Human Use Regulations'', which required pharmaceutical companies to pass to the regulator trial data that had safety and efficacy implications. Jackson 2012, p. 109. The MHRA reviewed around one million pages of documentation in the course of the inquiry. After a four-year investigation, independent counsel instructed by the MHRA advised, according to an MHRA report, that "no offence ha been committed contrary to the 1994 Regulations 'Medicines for Human Use (Marketing Authorisations Etc.) Regulations 1994'', because GSK's clinical trials and alleged failure to provide data from them "most likely did not fall within the regime implemented by those Regulations". If the 1994 Regulations did apply, the report said, the "relevant provisions were not sufficiently clear so as to permit a criminal sanction for their breach". The MHRA announced in March 2008 that there would be no prosecution. In October 2008 the 1994 Regulations were amended to prevent a repetition of the case.


Inquiries in the United States


''The Boston Globe''

In November 1995
Alison Bass Alison Bass is an American journalist and author of three books: her memoir, ''Brassy Broad: How one Journalist helped pave the way to #MeToo'' (2021); ''Getting Screwed: Sex Workers and the Law'' and ''Side Effects: A Prosecutor, A Whistleblower ...
of ''
The Boston Globe ''The Boston Globe'' is an American daily newspaper founded and based in Boston, Massachusetts. The newspaper has won a total of 27 Pulitzer Prizes, and has a total circulation of close to 300,000 print and digital subscribers. ''The Boston Glob ...
'' began investigating
Brown University Brown University is a private research university in Providence, Rhode Island. Brown is the seventh-oldest institution of higher education in the United States, founded in 1764 as the College in the English Colony of Rhode Island and Providenc ...
's psychiatry department, chaired by Martin Keller, who led Study 329. There were allegations that the department had taken $218,000 of government funds for research that apparently had not been conducted. In October 1999 she reported Keller's financial relationship with the pharmaceutical industry, which included receipt of $500,000 in consulting fees the previous year. Bass's work developed into a book about GlaxoSmithKline, paroxetine, and Study 329, '' Side Effects: A Prosecutor, a Whistleblower, and a Bestselling Antidepressant on Trial'' (2008).


FDA-mandated review

In March 2004 the FDA mandated that drug companies review the use of their SSRIs in children. In 2006 GSK researchers published a review of five of their trials involving paroxetine and adolescents or children, including study 329 and the unpublished study 377. They wrote that suicidal ideation or behaviour had occurred in 22 of 642 patients on paroxetine (3.4 percent) against five of 549 on placebo (0.9 percent). The article concluded: "Adolescents treated with paroxetine showed an increased risk of suicide-related events. ... The presence of uncontrolled suicide risk factors, the relatively low incidence of these events, and their predominance in adolescents with MDD make it difficult to identify a single cause for suicidality in these pediatric patients.


''People v. GlaxoSmithKline''

In June 2004 New York State Attorney
Eliot Spitzer Eliot Laurence Spitzer (born June 10, 1959) is an American politician and attorney. A member of the Democratic Party (United States), Democratic Party, he was the 54th governor of New York from 2007 until his resignation in 2008. Spitzer was b ...
filed a lawsuit against GSK in the New York State Supreme Court for having withheld clinical trial data about paroxetine, including from study 329. GSK denied any wrongdoing and said it had disclosed the data to regulators, and to physicians at medical conventions and in other ways. GSK settled the case in August 2004, agreeing to pay $2.5 million, make its trial data about paroxetine and children available on its website, and establish a clinical trial register that would host summaries of all company-sponsored trials going back to 27 December 2000. By October 2004 other drug companies, including
Pfizer Pfizer Inc. ( ) is an American multinational pharmaceutical and biotechnology corporation headquartered on 42nd Street in Manhattan, New York City. The company was established in 1849 in New York by two German entrepreneurs, Charles Pfizer ...
, Eli Lilly and
Merck Merck refers primarily to the German Merck family and three companies founded by the family, including: * the Merck Group, a German chemical, pharmaceutical and life sciences company founded in 1668 ** Merck Serono (known as EMD Serono in the Unite ...
, had agreed to create their own registers. In 2013 GSK joined
AllTrials AllTrials (sometimes called All Trials or AllTrials.net) is a project advocating that clinical research adopt the principles of open research. The project summarizes itself as "All trials registered, all results reported": that is, all clinical tr ...
, a British campaign to have all clinical trials registered and the results reported.


Other lawsuits

By 2009 GSK had paid almost $1 billion to settle paroxetine-related lawsuits related to 450 suicides, withholding data, as well as addiction, antitrust and other claims. An additional 600 unsettled claims related to birth defects.Feeley, Jeff; Fisk, Margaret Cronin (14 December 2009)
"Glaxo Said to Have Paid $1 Billion in Paxil Suits (Update2)"
''Bloomberg''.
The lawsuits produced thousands of internal company documents, some of which entered the public domain. These formed the basis of some of Alison Bass's work and that of Shelley Jofre for the BBC.


''United States v. GlaxoSmithKline''

In October 2011 the
United States Department of Justice The United States Department of Justice (DOJ), also known as the Justice Department, is a federal executive department of the United States government tasked with the enforcement of federal law and administration of justice in the United State ...
filed a lawsuit under the False Claims Act accusing GSK of promoting drugs for unapproved uses, failing to report safety data, reporting false prices to
Medicaid Medicaid in the United States is a federal and state program that helps with healthcare costs for some people with limited income and resources. Medicaid also offers benefits not normally covered by Medicare, including nursing home care and pers ...
, and paying kickbacks to physicians in the form of gifts, trips and sham consultancy fees. The complaint included preparing the ''JAACAP'' article about study 329, exaggerating paroxetine's efficacy while downplaying the risks, and using the article to promote the drug for adolescent use, which was not approved by the FDA. GSK pleaded guilty in 2012 and paid a $3 billion settlement, including a criminal fine of $1 billion. The fine included an amount for "preparing, publishing and distributing a misleading medical journal article that misreported that a clinical trial of Paxil demonstrated efficacy in the treatment of depression in patients under age 18, when the study failed to demonstrate efficacy"."GlaxoSmithKline to Plead Guilty and Pay $3 Billion to Resolve Fraud Allegations and Failure to Report Safety Data"
United States Department of Justice, 2 July 2012
"GSK's off-label marketing of Paxil"
''United States v. GlaxoSmithKline''], United States District Court for the District of Massachusetts, 26 October 2011, pp. 3–19
''United States v. GlaxoSmithKline''
United States District Court for the District of Massachusetts, 26 October 2011 (for paroxetine, pp. 3–19). Thomas, Katie; Schmidt, Michael S. (2 July 2012)

''The New York Times''.


Calls for retraction

Child psychiatrist Jon Jureidini of the
Women's and Children's Hospital The Women's and Children's Hospital is located on King William Road in North Adelaide, Australia. It is one of the major hospitals in Adelaide and is a teaching hospital of the University of Adelaide, the University of South Australia and Flin ...
in Adelaide and Ann Tonkin of the
University of Adelaide The University of Adelaide (informally Adelaide University) is a public research university located in Adelaide, South Australia. Established in 1874, it is the third-oldest university in Australia. The university's main campus is located on N ...
asked ''JAACAP'' in 2003 to retract the study 329 paper.Jureidini, Jon; Tonkin, Ann (May 2003)
"Paroxetine in major depression"
''Journal of the American Academy of Child and Adolescent Psychiatry'', 42(5), p. 514.
In 2005 the philosopher
Leemon McHenry Leemon McHenry is a bioethicist and Emeritus Professor of Philosophy at California State University, Northridge, in the United States. He has taught philosophy at the University of Edinburgh, Old Dominion University, Davidson College, Central M ...
complained to ''JAACAP's'' editor, Mina Dulcan, that Keller and some of the other researchers named as authors had worked for GSK but had not declared their
conflict of interest A conflict of interest (COI) is a situation in which a person or organization is involved in multiple interests, financial or otherwise, and serving one interest could involve working against another. Typically, this relates to situations i ...
and had violated the journal's policy regarding authorship. Keller had acted as a consultant for several drug companies. ''
The Boston Globe ''The Boston Globe'' is an American daily newspaper founded and based in Boston, Massachusetts. The newspaper has won a total of 27 Pulitzer Prizes, and has a total circulation of close to 300,000 print and digital subscribers. ''The Boston Glob ...
'' reported in 1999 that he had earned $500,000 the previous year from consultancy work, which, the newspaper said, he did not disclose to the journals that published his work or to the
American Psychiatric Association The American Psychiatric Association (APA) is the main professional organization of psychiatrists and trainee psychiatrists in the United States, and the largest psychiatric organization in the world. It has more than 37,000 members are involve ...
. Dulcan replied to McHenry that "unless there is a specific accusation of research fraud, it is not the role of scientific journals to police authorship." Jureidini and McHenry called again for the paper's retraction in 2009. Editor-in-chief Andrés Martin replied that there was no justification for retraction, and that the journal had "conformed to the best publication practices prevailing at the time". Newman 2010, p. 1247. In April 2013 Jureidini asked GSK's CEO
Andrew Witty Sir Andrew Philip Witty (born 22 August 1964) is a British business executive, who is the current chief executive officer (CEO) of UnitedHealth Group. He was also the CEO of GlaxoSmithKline between 2008 and 2017. He formerly held the role of chan ...
to request retraction.Jureidini, Jon. (26 April 2013)
Letter to Andrew Witty, CEO, GlaxoSmithKline
courtesy of ''BMJ''.
Peter Doshi, "Putting GlaxoSmithKline to the test over paroxetine," ''BMJ'', 12 November 2013.


RIAT re-analysis of study 329

In July 2013 Jureidini announced his intention to produce a new write-up of study 329 in accordance with the RIAT initiative (restoring invisible and abandoned trials). The RIAT researchers—Joanna Le Noury, John M. Nardo, David Healy, Jon Jureidini, Melissa Raven, Catalin Tufanaru, and Elia Abi-Jaoude—published their re-analysis in the ''BMJ'' in September 2015. They concluded that " e efficacy of paroxetine and imipramine was not statistically or clinically significantly different from placebo for any prespecified primary or secondary efficacy outcome," and that there were "clinically significant increases in ... suicidal ideation and behaviour and other serious adverse events in the paroxetine group and cardiovascular problems in the imipramine group."


Anti-depressants and suicidality in young people

In 2007 the FDA required that all anti-depressants include a
boxed warning In the United States, a boxed warning (sometimes "black box warning", colloquially) is a type of warning that appears on the package insert for certain prescription drugs, so called because the U.S. Food and Drug Administration specifies that it ...
of an increased risk of suicidal thoughts and behaviour in young adults (18–24 years) during the first one to two months of treatment."Antidepressant Use in Children, Adolescents, and Adults"
Food and Drug Administration, 2 May 2007, courtesy of the
Drug Industry Documents Archive The Drug Industry Documents Archive (DIDA) is a digital archive of pharmaceutical industry documents created and maintained by the University of California, San Francisco, Library and Center for Knowledge Management. DIDA is a part of the larger UC ...
, University of California, San Francisco.
A 2012
Cochrane review Cochrane (previously known as the Cochrane Collaboration) is a British international charitable organisation formed to organise medical research findings to facilitate evidence-based choices about health interventions involving health professi ...
on the use of SSRIs in children and adolescents concluded that there is evidence of an increased suicide risk in patients treated with antidepressants. It added: "However, given the risks of untreated depression in terms of completed suicide and impacts on functioning, if a decision to use medication is agreed, then
fluoxetine Fluoxetine, sold under the brand names Prozac and Sarafem, among others, is an antidepressant of the selective serotonin reuptake inhibitor (SSRI) class. It is used for the treatment of major depressive disorder, obsessive–compulsive disorde ...
might be the medication of first choice given guideline recommendations."


See also

*
AllTrials AllTrials (sometimes called All Trials or AllTrials.net) is a project advocating that clinical research adopt the principles of open research. The project summarizes itself as "All trials registered, all results reported": that is, all clinical tr ...
*
ClinicalTrials.gov ClinicalTrials.gov is a registry of clinical trials. It is run by the United States National Library of Medicine (NLM) at the National Institutes of Health, and is the largest clinical trials database, holding registrations from over 329,000 tri ...
*
Drug Industry Documents Archive The Drug Industry Documents Archive (DIDA) is a digital archive of pharmaceutical industry documents created and maintained by the University of California, San Francisco, Library and Center for Knowledge Management. DIDA is a part of the larger UC ...
*
IFPMA Clinical Trials Portal The International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) is a trade association that represents leading innovative pharmaceutical companies at the international level and in official relations with the United Nations. I ...
*
List of medical ethics cases Some cases have been remarkable for starting broad discussion and for setting precedent in medical ethics Medical ethics is an applied branch of ethics which analyzes the practice of clinical medicine and related scientific research. Medical eth ...
*
Pharmacovigilance Term Given By Tushar Sharma (UPES Batch 2025) Pharmacovigilance (PV, or PhV), also known as drug safety, is the pharmaceutical science relating to the "collection, detection, assessment, monitoring, and prevention" of adverse effects with pharma ...


Notes


References


Further reading


Drug Industry Documents Archive
University of California, San Francisco.
"Tracking switched outcomes in clinical trials"
Compare.
"For my next trick"
''The Economist'', 26 March 2016. * Barber, Sarah; Cipriani, Andrea (1 April 2017)
"Lessons learned from Restoring Study 329: Transparent reporting, open databases and network meta-analyses as the way forward"
''Australian and New Zealand Journal of Psychiatry'', 51(4), pp. 407–409. * Firestone, Chaz and Kelsh, Chaz (24 September 2008)
"Keller's findings on Paxil disputed by doctors, FDA"
''The Brown Daily Herald''. * Fugh-Berman, Adriane (21 April 2005)
"Not in my name"
''The Guardian''. * Healy, David (2012). ''Pharmageddon'', Berkeley: University of California Press, p. 109ff. * Jureidini, Jon (January 2010)
"Paxil Study 329: Paroxetine vs Imipramine vs Placebo in Adolescents"
Healthy Skepticism Healthy Skepticism Inc is an international non-profit organisation whose main aim is to "improve health by reducing harm from misleading drug promotion". Healthy Skepticism was founded in 1983 with the name Medical Lobby for Appropriate Marketi ...
. * McHenry, Leemon (2010)
"Of Sophists and Spin-Doctors: Industry-Sponsored Ghostwriting and the Crisis of Academic Medicine"
''Mens Sana Monographs'', 8(1), pp. 129–145. *Jureidini, Jon and McHenry, Leemon, (2020),''The Illusion of Evidence Based Medicine'', Adelaide: Wakefield Press. Letters *Weintrob, Alex
"Paroxetine in adolescent major depression"
''Journal of the American Academy of Child and Adolescent Psychiatry'', 41(4), April 2002, pp. 363–364. *Parsons, Mitch
"Paroxetine in adolescent major depression"
41(4), April 2002, p. 364. *Keller, Martin; Ryan, Neal D.; Wagner, Karen Dineen
"Paroxetine in adolescent major depression"
41(4), April 2002, p. 364. *Jureidini, Jon; Tonkin, Ann
"Paroxetine in major depression"
42(5), May 2003 p. 514. *Keller, Martin, et al
"Paroxetine in major depression"
42(5), May 2003, pp. 514–515. *Connor, Daniel F
"Paroxetine in major depression"
43(2), February 2004, p. 127.
Jon Jureidini–James Shannon (GSK) correspondence
''BMJ'', 347, 12 November 2013. {{conflict of interest Clinical trials related to depression Clinical trials sponsored by GSK plc GSK plc History of psychiatry Psychiatry controversies Scientific misconduct incidents