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The FDA's initial refusal to even review Moderna's mRNA flu vaccine was a regulatory disaster. Moderna ran a 43,000-person trial under an FDA-approved design, proved superiority over both standard-dose and high-dose comparators, and still got stonewalled. The EU, Canada and Australia are moving forward with reviews while American innovation gets left behind. Unpredictable regulation doesn't protect the public; it just drives vaccine development offshore.
Moderna compared its mRNA flu vaccine to the weakest available flu shot, not the high-dose formulation that's been the evidence-based benchmark for older adults for nearly a decade, thereby setting an easy target. Regulatory predictability matters, but so does comparator integrity; clearing a low bar doesn't mean a product is actually better. Real innovation means proving superiority over the best available option, not the most beatable one.