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 2002 citizen petition, defending Mifeprex’s safety and effectiveness as approved in 2000. Second, FDA approved a supplemental new drug application by Danco. That application requested a number of amendments to Mifeprex’s REMS that FDA described as “major” and “interrelated.” FDA Summary Review of 2016 Amendments at 5 (Mar. 29, 2016). Those changes included: Id. at 2, 26. FDA also pointed to a number of studies as evidence that Mifeprex would be safe and effective despite the amendments. Id. at 5–17.
 * Increasing the maximum gestational age from forty-nine days to seventy days;
 * Allowing non-physicians to prescribe mifepristone;
 * Removing the requirement that the administration of misoprostol and the subsequent follow-up appointment be conducted in person;
 * Eliminating prescribers’ obligation to report non-fatal adverse events;
 * Switching the method of administration for misoprostol from oral to buccal; and
 * Changing the dose of mifepristone (600 mg to 200 mg) and misoprostol (400 mcg to 800 mcg).

Several years later, in 2019, the American Association of Pro-Life Obstetricians and Gynecologists and American College of Pediatricians filed a citizen petition challenging the 2016 Amendments. The petition generally requested that FDA restore the restrictions it imposed in 2000. Separately, in April of 2019, FDA approved an “abbreviated new drug application” by GenBioPro, Inc. for a generic version of mifepristone. To assess whether the drug was safe, the agency relied on the same data that it had relied upon for the 2000 Approval and 2016 Amendments regarding Mifeprex.