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510(k) Data Aggregation

    K Number
    K252745

    Validate with FDA (Live)

    Date Cleared
    2025-12-12

    (105 days)

    Product Code
    Regulation Number
    878.4810
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Halo Sterile Single-use Radial Fibers are indicated for use in all surgical specialties in which compatible laser systems with operational wavelengths between 500nm - 2200nm have received regulatory clearance. Halo Sterile Single-use Radial Fibers are intended for use with any cleared surgical laser with an SMA 905 connector.

    Device Description

    The Halo Sterile Single - use Radial Fibers (Model: Halo - R - 0.40 - 2.5/Halo - R - 0.60 - 2.5/Novo-R-0.60-1.8/Novo-R-0.40-1.8), as surgical laser fibers, are suitable for use in combination with commercially available diode laser systems with a wavelength ranging from500nm to 2200nm and equipped with SMA905 connectors. The output power should not exceed 30 W. This device is single use only and sterilized by EO gas.The Halo Sterile Single - use Radial Fibers are intended for general surgical operations such as incision, excision, vaporization, ablation, hemostasis or coagulation of soft tissues in either contact or non - contact mode. In particular, they are designed for endovascular coagulation of blood vessels.The Fiber is radial-typed fiber. The shape of distal end of fiber is conical to radiate laser radially.

    AI/ML Overview

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    K Number
    K252762

    Validate with FDA (Live)

    Device Name
    HALO AP Dx
    Manufacturer
    Date Cleared
    2025-11-25

    (88 days)

    Product Code
    Regulation Number
    864.3700
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HALO AP Dx is a software only device intended as an aid to the pathologist to review, interpret and manage digital images of scanned surgical pathology slides prepared from formalin-fixed paraffin embedded (FFPE) tissue for the purposes of pathology primary diagnosis. HALO AP Dx is not intended for use with frozen section, cytology, or non-FFPE hematopathology specimens.

    It is the responsibility of a qualified pathologist to employ appropriate procedures and safeguards to assure the quality of the images obtained and, where necessary, use conventional light microscopy review when making a diagnostic decision. HALO AP Dx is intended for use with the interoperable components specified in the Table below.

    Device Description

    HALO AP Dx, version 2.4 (abbreviated as v2.4), is a browser-based software-only device intended to aid pathology professionals in viewing, manipulating, management, and interpretation of digital pathology whole slide images (WSI) of glass slides obtained from the Hamamatsu Photonics K.K. NanoZoomer S360MD scanner or the Leica Biosystems Imaging, Inc. Aperio GT 450 DX.

    HALO AP Dx is typically operated as follows:

    1. Image acquisition is performed using the predicate device. The operator performs quality control of the digital slides per the instructions of the predicate device and lab specifications to determine if re-scans are necessary.

    2. Once image acquisition is complete, according to its Instructions for Use, the unaltered image is saved in an external image storage location. HALO AP Dx ingests the image, and a copy of image metadata is stored in the subject device's database to improve viewing response times.

    3. Depending upon a laboratory's workflow, the scanned images may first be reviewed by histotechnicians to confirm image quality and initiate any re-scans. After review, the histotechnician may modify the case status and make it available to the pathologist.

    4. The reading pathologist selects a patient case from a selected worklist within HALO AP Dx whereby the subject device fetches the associated images from external image storage.

    5. The reading pathologist uses the subject device to view the images and can perform the following actions, as needed:
      a. Zoom and pan the image.
      b. Measure distances and areas in the image.
      c. Annotate images.
      d. View multiple images side by side in a synchronized fashion.

    6. The above steps are repeated as necessary.

    After viewing all images belonging to a particular case (patient), the pathologist will make a diagnosis which is documented in another system, such as a Laboratory Information System.

    HALO AP Dx operates and is validated for use with the FDA cleared components listed in the intended use statement table above.

    AI/ML Overview

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    K Number
    K232833

    Validate with FDA (Live)

    Device Name
    HALO AP Dx
    Manufacturer
    Date Cleared
    2024-05-07

    (237 days)

    Product Code
    Regulation Number
    864.3700
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    For In Vitro Diagnostic Use

    HALO AP Dx is a software only device intended as an aid to the pathologist to review, interpret and manage digital images of scanned surgical pathology slides prepared from formalin-fixed paraffin embedded (FFPE) tissue for the purposes of pathology primary diagnosis. HALO AP Dx is not intended for use with frozen section, cytology, or non-FFPE hematopathology specimens.

    It is the responsibility of a qualified pathologist to employ appropriate procedures and safeguards to assure the quality of the images obtained and, where necessary, use conventional light microscopy review when making a diagnostic decision. HALO AP Dx is intended for use with the Hamamatsu NanoZoomer S360MD Slide scanner and the JVC Kenwood JD-C240BN01A display.

    Device Description

    HALO AP Dx, version 2.1 is a browser-based software-only device intended to aid pathology professionals in viewing, manipulating, management and interpretation of digital pathology whole slide images (WSI) of glass slides obtained from the Hamamatsu Photonics K.K. NanoZoomer S360MD scanner and viewed on the JVC Kenwood JD-C240BN01A display.

    HALO AP Dx is typically operated as follows:

    1. Image acquisition is performed using the predicate device, NanoZoomer S360MD Slide scanner according to its Instructions for Use. The operator performs quality control of the digital slides per the instructions of the NanoZoomer and lab specifications to determine if re-scans are necessary.
    2. Once image acquisition is complete, the unaltered image is saved by the scanner's software to an image storage location. HALO AP Dx ingests the image, and a copy of image metadata is stored in the subject device's database to improve viewing response times.
    3. Scanned images are reviewed by scanning personnel such as histotechnicians to confirm image quality and initiate any re-scans before making it available to the pathologist.
    4. The reading pathologist selects a patient case from a selected worklist within HALO AP Dx whereby the subject device fetches the associated images from external image storage.
    5. The reading pathologist uses the subject device to view the images and can perform the following actions, as needed:
      a. Zoom and pan the image.
      b. Measure distances and areas in the image.
      c. Annotate images.
      d. View multiple images side by side in a synchronized fashion.

    The above steps are repeated as necessary.

    After viewing all images belonging to a particular case (patient), the pathologist will make a diagnosis which is documented in another system, such as a Laboratory Information System (LIS).

    The interoperable components of HALO AP Dx are provided in table 1 below:

    Table 1. Interoperable Components for Use with HALO AP Dx

    ComponentsManufacturerModel
    ScannerHamamatsuNanoZoomer S360MD Slide scanner
    DisplayJVCJD-C240BN01A
    AI/ML Overview

    This FDA 510(k) clearance letter pertains to HALO AP Dx, a software-only device for digital pathology image review. The documentation indicates that the device has been deemed substantially equivalent to a predicate device, the Hamamatsu NanoZoomer S360MD Slide scanner system (K213883).

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document defines the performance data points primarily through "Performance Data" and "Summary of Studies" sections, focusing on comparisons to the predicate device and usability. There are no explicit quantitative "acceptance criteria" presented as specific thresholds, but rather statements of adequacy and similarity to the predicate.

    Acceptance Criterion (Implicit)Reported Device Performance
    Image Reproduction Quality (Color Accuracy)Criteria: Identical image reproduction compared to the predicate device (NZViewMD viewer), specifically regarding pixel-wise color accuracy.Performance: Pixel-level comparisons demonstrated that the 95th percentile CIEDE2000 values across all Regions of Interest (ROIs) from varied tissue types and diagnoses were less than 3 ΔE00. This was determined to be "identical image reproduction."
    Turnaround Time (Image Loading - Case Selection)Criteria: "When selecting a case, it should not take longer than 4 seconds until the image is fully loaded."Performance: Determined to be "adequate for the intended use of the subject device." (No specific value reported, but implies <= 4 seconds).
    Turnaround Time (Image Loading - Panning)Criteria: "When panning the image, it should not take longer than 3 seconds until the image is fully loaded."Performance: Determined to be "adequate for the intended use of the subject device." (No specific value reported, but implies <= 3 seconds).
    Measurement AccuracyCriteria: Ability to perform accurate measurements (distance and area).Performance: "The subject device has been found to perform accurate measurements with respect to its intended use." (Verified using a test image with known sizes).
    System Responsiveness under LoadCriteria: Maintain responsiveness under constant utilization.Performance: "Concurrent multi-user load testing confirms HALO AP Dx performance remains responsive under constant utilization over a long time period."
    Human Factors/Usability (Safety and Effectiveness for Users)Criteria: User interface is intuitive, safe, and effective for intended users.Performance: "Task-based usability tests verified the HALO AP Dx user interface to be intuitive, safe, and effective for the range of intended users." (Conducted per FDA's Guidance on Applying Human Factors and Usability Engineering to Medical Devices (2016)).

    2. Sample Size Used for the Test Set and Data Provenance

    • Test Set Sample Size: The document does not explicitly state the numerical sample size for the test set (e.g., number of whole slide images). It mentions "multiple tiles at multiple magnification levels" and "all ROIs taken from images with varied tissue types and diagnoses" for image reproduction testing, and "a test image containing objects with known sizes" for measurement accuracy. This suggests a varied, though unspecified, set of images or data points were used for testing.
    • Data Provenance: Not explicitly stated regarding country of origin. The study appears to be an internal non-clinical performance evaluation. The type of tissue used for image reproduction testing is "varied tissue types and diagnoses," implying real FFPE tissue samples, but it doesn't specify if they were retrospective or prospectively collected for the study.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    • The document describes non-clinical performance testing (e.g., pixel-wise comparison, turnaround times, measurement accuracy, human factors testing). These tests typically rely on predefined objective metrics or reference standards rather than expert consensus on diagnostic interpretation.
    • For the human factors/usability testing, the study "verified the HALO AP Dx user interface to be intuitive, safe, and effective for the range of intended users." This implies involvement of intended users (pathologists or similar professionals), but neither the specific number nor their qualifications are detailed.

    4. Adjudication Method for the Test Set

    • Adjudication methods (e.g., 2+1, 3+1) are typically relevant for studies where a "ground truth" is established by multiple human readers for diagnostic accuracy.
    • Since this document focuses on technical performance and usability, rather than diagnostic accuracy (which would involve human pathologists making diagnoses with and without AI assistance), traditional adjudication methods were not applicable or described. The "ground truth" in these tests consists of objective technical parameters or usability feedback.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No MRMC comparative effectiveness study was described. The study primarily focuses on showing the technical performance of HALO AP Dx is substantially equivalent to the viewing software component of the predicate device (NZViewMD), not on improving human reader performance or diagnostic accuracy with AI assistance.
    • The device is a "viewer" intended to "aid the pathologist," not an AI-powered diagnostic algorithm. Therefore, an MRMC study comparing human readers with and without AI assistance to measure effect size is not relevant to this submission, which focuses on the viewing platform itself.

    6. Standalone (Algorithm Only) Performance

    • This device, HALO AP Dx, is a standalone software-only device in the sense that it functions as a digital pathology image viewer.
    • However, it does not involve a diagnostic AI algorithm where "standalone performance" (e.g., sensitivity/specificity of the AI itself) would be measured. Its "performance" is about accurate image reproduction, speed, and usability of the viewing functions.

    7. Type of Ground Truth Used

    The ground truth used for the technical performance evaluations was objective and predefined:

    • For Image Reproduction: A pixel-wise comparison to the predicate device's viewer (NZViewMD) was performed. The "ground truth" was essentially the image rendered by the predicate's software.
    • For Turnaround Times: Time taken for specific actions (loading, panning) against predefined numerical thresholds (4 seconds, 3 seconds).
    • For Measurement Accuracy: A "test image containing objects with known sizes." The known sizes were the ground truth.
    • For Human Factors: User feedback and task completion during usability tests against predefined criteria for intuitiveness, safety, and effectiveness.

    8. Sample Size for the Training Set

    • The document does not mention a "training set" in the context of machine learning. This is because HALO AP Dx is described as a "software only device intended as an aid to the pathologist to review, interpret and manage digital images," not an AI/ML-based diagnostic algorithm that would require a training set.
    • Its core functionality is image display and manipulation, not pattern recognition or classification that would necessitate machine learning.

    9. How the Ground Truth for the Training Set Was Established

    • As no machine learning training set is mentioned or implied for this device's functionality, this question is not applicable.
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    K Number
    K212708

    Validate with FDA (Live)

    Manufacturer
    Date Cleared
    2021-09-23

    (28 days)

    Product Code
    Regulation Number
    870.1340
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Halo One Thin-Walled Guiding Sheath is indicated for use in peripheral arterial and venous procedures requiring percutaneous introduction of intravascular devices. The Halo One Thin-Walled Guiding Sheath is NOT indicated for use in the neurovasculature nor the coronary vasculature.

    Device Description

    The Halo One Thin-Walled Guiding Sheath consists of a thin-walled (Up to 1F reduction in outer diameter compared to standard sheaths of equivalent French size) sheath made from single-lumen tubing, fitted with a female luer hub at the proximal end and a formed atraumatic distal tip. The thin-wall design reduces the thickness of the sheath wall to help facilitate intravascular access from access sites including but not limited to radial, femoral, popliteal, tibial and pedal. A detachable hemostasis valve, employing a crosscut silicone membrane and incorporating a side arm terminating in a 3-way stopcock, is connected to the sheath luer hub. The sheath is supplied with a compatible vessel dilator that snaps securely into the hemostasis valve hub. The sheath has a strain relief feature located at the luer hub and a radiopaque platinum-iridium marker located close to the distal tip. The Halo One Thin-Walled Guiding sheath is supplied in 4F, 5F and 6F compatible sizes and lengths of 90cm. 70cm. 45cm. 25cm and 10 cm. The Halo One Thin-Walled Guiding Sheath 4F, 5F and 6F 25cm and 10cm sheaths will be offered with a 0.018" and 0.035" guide wire compatible dilator option. The Halo One Thin-Walled Guiding Sheath is also offered as an access kit in 4F,5F and 6F 10cm and 25cm lengths incorporating access needle (21G x 4cm or 19G x 7cm option available) and access guidewire in both 0.018" (0.018" x 80cm or 0.018" x 50cm option available) and 0.035" (0.035" x 80cm or 0.035" x 50cm option available) configurations to the existing predicate device product range. All sheath configurations (lengths) are provided with a hydrophilic coating over the distal portion of the sheath to provide a lubricious surface to ease insertion. The shorter sheath configurations (25cm and 10cm) are also provided without the coating.

    AI/ML Overview

    This document is a 510(k) Summary for a medical device called the "Halo One Thin-Walled Guiding Sheath." It is a submission to the FDA to demonstrate substantial equivalence to a legally marketed predicate device.

    The information provided does not describe an AI/ML powered device, nor does it detail a study that proves the device meets specific acceptance criteria related to AI/ML performance. Instead, it describes a conventional medical device (a catheter introducer) and outlines non-clinical performance testing for its physical and functional characteristics.

    Therefore, many of the requested categories for AI/ML device studies cannot be answered from this document.

    Here's an attempt to answer the relevant parts based on the provided text, and identify where the information is not applicable (N/A) for an AI/ML context:

    1. A table of acceptance criteria and the reported device performance

    The document provides a general list of performance criteria that were evaluated for the subject device to demonstrate substantial equivalence to the predicate device. However, it does not present a specific table with detailed quantitative acceptance criteria and their corresponding reported device performance values. It only states that the device "met all predetermined acceptance criteria" and that tests "demonstrate that the technical characteristics and performance criteria... is substantially equivalent to the predicate."

    Here's a summary of the characteristics and performance criteria evaluated:

    Acceptance Criteria CategoryReported Device Performance (as stated in document)
    Visual Inspection of sheath, access guidewire and access needleMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Simulated use of sheath, access guidewire and access needleMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Dimensional Testing of Dilator / SheathMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Compatibility Testing of sheath, access guidewire and access needleMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Penetration Force of Dilator / SheathMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Trackability of Dilator and SheathMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Trackability of device in sheathMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Visual Inspection (Tip-Rollback)Met predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Bend Radius / KinkMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Leak TestingMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Needle Ultrasound visibilityMet predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Packaging Testing (Visual Inspection, Bubble Emission of Pouches, Visual Inspection of Sterile Barrier Packaging Heat Seal, Seal Strength Tensile Method)Met predetermined acceptance criteria; findings demonstrate substantial equivalence.
    Biocompatibility (ISO 10993-1)Met predetermined acceptance criteria; findings demonstrate substantial equivalence.

    2. Sample sized used for the test set and the data provenance

    The document does not specify sample sizes for any of the performance tests. It also does not discuss "data provenance" in terms of country of origin or retrospective/prospective, as these are typically relevant for clinical studies or AI/ML model training data, which is not the focus here. The testing appears to be non-clinical, in-vitro, or bench testing based on FDA guidance and internal risk assessments.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    N/A. This is a non-clinical device performance study, not an AI/ML study requiring expert ground truth for interpretation of medical images or data.

    4. Adjudication method for the test set

    N/A. Not applicable to non-clinical device performance testing.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    N/A. This is not an AI/ML powered device, and no MRMC study is detailed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    N/A. This is not an AI/ML powered device.

    7. The type of ground truth used

    For the non-clinical tests, the "ground truth" would be established by physical measurements, standardized test methods, and pre-defined specifications derived from engineering requirements, applicable standards (e.g., ISO), and risk assessments. For biocompatibility, it's adherence to international standards like ISO 10993-1.

    8. The sample size for the training set

    N/A. This is not an AI/ML powered device.

    9. How the ground truth for the training set was established

    N/A. This is not an AI/ML powered device.

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    K Number
    K211788

    Validate with FDA (Live)

    Device Name
    HALO
    Manufacturer
    Date Cleared
    2021-07-08

    (29 days)

    Product Code
    Regulation Number
    892.2080
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HALO is a notification only cloud-based image processing software artificial intelligence algorithms to analyze patient imaging data in parallel to the standard of care imaging interpretation. Its intended use is to identify suggestive imaging patterns of a pre-specified condition and to directly notify an appropriate medical specialist.

    HALO's indication is to facilitate the evaluation of the brain vasculature on patients suspected of stroke by processing and analyzing CT angiograms of the brain acquired in an acute setting. After completion of the data analysis, HALO sends a notification if a pattern suggestive for a suspected intracranial Large Vessel Occlusion (LVO) of the anterior circulation (ICA, M1 or M2) has been identified in an image.

    The intended users of HALO are defined as medical specialists or a team of specialists that are involved in the diagnosis and care of stroke patients at emergency department where stroke patients are administered. The include physicians such as neurologists, radiologists, and/or other emergency department physicians.

    HALO's output should not be used for primary diagnosis or clinical decisions; the final diagnosis is always decided upon by the medical specialist. HALO is indicated for CT scanners from GE Healthcare and Philips.

    Device Description

    HALO is a notification only, cloud-based clinical support tool which identifies image features and communicates the analysis results to a specialist in parallel to the standard of care workflow.

    HALO is designed to process CT angiograms of the brain and facilitate evaluation of these images using artificial intelligence to detect patterns suggestive of an intracranial large vessel occlusion (LVO) of the anterior circulation.

    A copy of the original CTA images is sent to HALO cloud servers for automatic image processing. After analyzing the images, HALO sends a notification regarding a suspected finding to a specialist, recommending review of these images. The specialist can review the results remotely in a compatible DICOM web viewer.

    AI/ML Overview

    Here's a detailed breakdown of the acceptance criteria and study proving the device meets them, based on the provided FDA 510(k) summary for HALO:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Primary Endpoints:
    LVO Detection Sensitivity91.3% (95% CI, 86.6%-94.8%)
    LVO Detection Specificity85.9% (95% CI, 80.6%-90.2%)
    Area Under the Curve (AUC) for LVO Detection0.97
    Secondary Endpoints:
    Median Notification Time for Detected LVOs4 minutes 29 seconds (minimum 3:47, maximum 7:12)

    The document states that "The HALO performance with regard to sensitivity and specificity, and the notification time are both equivalent to that of the selected predicate device." This implies that the reported performance metrics met or exceeded the established criteria for substantial equivalence to the predicate.

    2. Sample Size and Data Provenance

    • Test Set Sample Size: 427 patients after exclusions (originally 434 CTA scans).
    • Data Provenance: Retrospective, multi-center clinical study. Patients were admitted to US comprehensive stroke centers.

    3. Number and Qualifications of Experts for Ground Truth

    • Number of Experts: 3 neuro radiologists.
    • Qualifications: "Expert panel consisting of 3 neuro radiologists." Specific details on years of experience or board certification are not provided in this document.

    4. Adjudication Method for the Test Set

    The document states: "Ground truth was established by an expert panel consisting of 3 neuro radiologists." While it doesn't explicitly detail the adjudication method (e.g., 2+1, 3+1, consensus discussion), the wording suggests a consensus-based approach among the three experts. "Established by" implies a final, agreed-upon determination, not individual readings.

    5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study involving human readers with vs. without AI assistance is mentioned in the provided text for this specific device clearance. The study described focuses on the standalone performance of the AI algorithm.

    6. Standalone (Algorithm Only) Performance

    Yes, a standalone performance study was done. The reported sensitivity, specificity, and AUC are all metrics of the algorithm's performance without human intervention in the diagnosis and notification process. The intended use of HALO is to "directly notify an appropriate medical specialist" if a suspected finding is identified, running "in parallel to the standard of care imaging interpretation." This means its function is to flag cases for specialist review, not to replace it.

    7. Type of Ground Truth Used

    The ground truth used was expert consensus among three neuro radiologists, based on their interpretation of the CTA scans.

    8. Sample Size for the Training Set

    The document does not specify the sample size used for the training set. It only mentions the test set of 427 patients. It alludes to the algorithm using "a database of images" for its AI model but provides no numbers for this database's size or composition regarding training.

    9. How Ground Truth for the Training Set Was Established

    The document does not explicitly state how the ground truth for the training set was established. It only details the ground truth establishment for the test set. It is common practice for training data ground truth to be established through expert labeling or other robust methods, but this information is not provided here.

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    K Number
    K200963

    Validate with FDA (Live)

    Date Cleared
    2021-01-05

    (270 days)

    Product Code
    Regulation Number
    870.5150
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Halo™ Single-Loop Microsnare Kit is intended for use in the retrieval and manipulation of atraumatic foreign bodies located in the coronary and peripheral cardiovascular system and the extra-cranial neurovascular anatomy.

    Device Description

    Halo™ Single-Loop Microsnare Kit contains: (1) Microsnare, (1) Microsnare Catheter, (1) Introducer and (1) Torque Handle. The microsnare is constructed of a flexible and radiopaque loop. The pre-formed microsnare loop can be introduced through the microsnare catheter without risk of microsnare deformation because of the snare's super-elastic construction. The microsnare catheter is constructed of flexible tubing and contains a radiopaque marker band.

    AI/ML Overview

    The Halo™ Single-Loop Microsnare Kit underwent a series of non-clinical performance tests to demonstrate substantial equivalence to its predicate devices. No clinical studies were conducted, thus, information regarding human readers or effect sizes with AI assistance is not available.

    1. A table of acceptance criteria and the reported device performance:

    The document indicates that acceptance criteria were determined to demonstrate substantial equivalence, and the device was shown to meet these acceptance criteria. However, specific numerical acceptance criteria and reported performance values for each test are not provided in the given text. Instead, the document lists the types of performance tests conducted.

    Acceptance Criteria CategoryReported Device Performance
    Performance Testing
    Tensile strengthMet acceptance criteria
    Liquid leakageMet acceptance criteria
    Air leakageMet acceptance criteria
    Corrosion ResistanceMet acceptance criteria
    System Tip FlexibilityMet acceptance criteria
    Tip Flexibility Microsnare & Microsnare CatheterMet acceptance criteria
    Snare Flexing & Fracture TestMet acceptance criteria
    Catheter Flexural ModulusMet acceptance criteria
    Catheter Kink TestMet acceptance criteria
    Marker Band Pull TestMet acceptance criteria
    Torque Strength TestMet acceptance criteria
    Simulative UseMet acceptance criteria
    RadiopacityMet acceptance criteria
    ParticulateMet acceptance criteria
    Luer TestingMet acceptance criteria
    Shipping TestMet acceptance criteria
    Biocompatibility Testing
    Cytotoxicity (ISO 10993-5)Met acceptance criteria
    Sensitization (ISO 10993-10)Met acceptance criteria
    Intracutaneous Irritation (ISO 10993-10)Met acceptance criteria
    Acute Systemic Toxicity (ISO 10993-11)Met acceptance criteria
    Material Mediated Pyrogen (ISO 10993-11)Met acceptance criteria
    Hemocompatibility (ISO10993-4)Met acceptance criteria
        o ASTM Hemolysis – Direct and Indirect ContactMet acceptance criteria
        o Complement Activation, SC5b-9Met acceptance criteria
        o Platelet and Leucocyte CountsMet acceptance criteria
        o Partial Thromboplastin Time (PTT)Met acceptance criteria

    2. Sample size used for the test set and the data provenance:

    The document does not specify the sample sizes used for each non-clinical test. The data provenance is non-clinical, meaning it comes from laboratory or bench testing rather than patient data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    This information is not applicable as the studies were non-clinical performance and biocompatibility tests, not studies involving expert assessment of medical images or patient data.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    This information is not applicable as the studies were non-clinical performance and biocompatibility tests.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    No MRMC study was conducted. The device is a medical instrument (microsnare kit), not an AI-powered diagnostic tool. The document focuses on demonstrating the physical and biological characteristics of the device.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    This is not applicable since the device is a medical instrument, not an algorithm. The performance tests evaluate the physical characteristics and biocompatibility of the device itself.

    7. The type of ground truth used:

    For performance testing, the "ground truth" would be established engineering specifications, industry standards, and regulatory requirements against which the device's physical and mechanical properties are measured. For biocompatibility testing, the "ground truth" is established biological responses as defined by ISO standards.

    8. The sample size for the training set:

    This information is not applicable as this is a medical device approval based on non-clinical testing, not a machine learning model requiring a training set.

    9. How the ground truth for the training set was established:

    This information is not applicable as this is a medical device approval based on non-clinical testing, not a machine learning model requiring a training set.

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    K Number
    K200873

    Validate with FDA (Live)

    Device Name
    HALO
    Manufacturer
    Date Cleared
    2020-11-20

    (233 days)

    Product Code
    Regulation Number
    892.2080
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HALO is a notification only cloud-based image processing software artificial intelligence algorithms to analyze patient imaging data in parallel to the standard of care imaging interpretation. Its intended use is to identify suggestive imaging patterns of a pre-specified clinical condition and to directly notify an appropriate medical specialist.

    HALO's indication is to facilitate the evaluation of the brain vasculature on patients suspected of stroke by processing and analyzing contrast enhanced CT angiograms of the brain acquired in an acute setting. After completion of the data analysis. HALO sends a notification if a pattern suggestive for a suspected intracranial Large Vessel Occlusion (LVO) of the anterior circulation (ICA, M1 or M2) has been identified in an image.

    The intended users of HALO are defined as appropriate medical specialists that are involved in the diagnosis and care of stroke patients at emergency department where stroke patients are administered. They include physicians such as neurologists, and/or other emergency department physicians.

    HALO's output should not be used for primary diagnosis or clinical decisions; the final diagnosis is always decided upon by the medical specialist. HALO is indicated for CT scanners from GE Healthcare.

    Device Description

    HALO is a notification only, cloud-based clinical support tool which identifies image features and communicates the analysis results to a specialist in parallel to the standard of care workflow.

    HALO is designed to process CT angiograms of the brain and facilitate evaluation of these images using artificial intelligence to detect patterns suggestive of an intracranial large vessel occlusion (LVO) of the anterior circulation.

    A copy of the original CTA images is sent to HALO cloud servers for automatic image processing. After analyzing the images, HALO sends a notification regarding a suspected finding to a specialist, recommending review of these images. The specialist can review the results remotely in a compatible DICOM web viewer.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study details for the HALO device, based on the provided FDA 510(k) summary:

    HALO Device Acceptance Criteria and Study Details

    1. Table of Acceptance Criteria and Reported Device Performance

    MetricAcceptance Criteria (Implicit)Reported Device Performance (HALO)
    SensitivitySufficiently high for LVO detection (comparable to predicate)91.1% (95% CI, 86.0%-94.8%)
    SpecificitySufficiently high for LVO detection (comparable to predicate)87.0% (95% CI, 81.2%-91.5%)
    AUCHigh (indicative of good discriminative power)0.97
    Notification TimeFast enough for acute stroke setting (comparable to predicate)Median: 4 minutes 31 seconds. Range: 3:47 to 7:12
    Substantial EquivalenceEquivalent to predicate device ContaCT in terms of indications for use, technological characteristics, and safety and effectiveness.Concluded to be substantially equivalent.

    2. Sample Size and Data Provenance for Test Set

    • Sample Size: 348 CTA scans were initially collected, with 364 patients included for further analysis after exclusion. It's unclear if the "348 CTA scans" and "364 patients" refer to the same dataset or if some patients had multiple scans or if there was an expansion of the dataset. Assuming 364 cases (patients with at least one scan) were used.
    • Data Provenance: Retrospective evaluation in a consecutive patient cohort. Data was collected from US comprehensive stroke centers.

    3. Number and Qualifications of Experts for Ground Truth

    • Number of Experts: 3 neuro radiologists.
    • Qualifications: "Neuro radiologists" implies specialized training and experience in interpreting neurological imaging, which is appropriate for stroke diagnosis. Specific years of experience are not mentioned.

    4. Adjudication Method for Test Set

    The adjudication method is not explicitly stated. It says "Ground truth was established by an expert panel consisting of 3 neuro radiologists," which suggests a consensus-based approach, but the specific rule (e.g., majority vote, unanimous agreement, review by a lead expert if disagreement) is not provided.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, an MRMC comparative effectiveness study involving human readers with and without AI assistance was not explicitly mentioned or conducted as detailed in the summary. The study focused on the standalone performance of the HALO algorithm.

    6. Standalone Performance (Algorithm Only)

    Yes, a standalone study was performed. The clinical study retrospectively evaluated the performance of the HALO clinical decision support algorithm for LVO detection using the collected CTA scans. The reported sensitivity, specificity, AUC, and notification time are all measures of the algorithm's standalone performance.

    7. Type of Ground Truth Used

    Expert Consensus. The ground truth for the test set was established by an expert panel consisting of 3 neuro radiologists.

    8. Sample Size for Training Set

    The sample size for the training set is not explicitly mentioned in the provided document. The document only covers the evaluation of the algorithm.

    9. How Ground Truth for Training Set was Established

    How the ground truth was established for the training set is not explicitly mentioned in the provided document. ("database of images" is stated for the core algorithm, but not how ground truth was applied to them).

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    K Number
    K201208

    Validate with FDA (Live)

    Manufacturer
    Date Cleared
    2020-09-23

    (141 days)

    Product Code
    Regulation Number
    870.2920
    Age Range
    All
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The LIVMOR Halo AF Detection SystemTM is indicated for use by patients who have been diagnosed with or are susceptible to developing atrial fibrillation and who would like to monitor and record their pulse rhythms on an intermittent basis so that their physician can be alerted irregular heart rhythms.

    The LIVMOR Halo AF Detection System is intended for use in conjunction with the LIVMOR Halo+ Home Monitoring SystemTM, and is not validated for use with other pulse monitoring systems.

    Device Description

    The LIVMOR Halo AF Detection System™ consists of an algorithm to filter and detect irregular pulse rhythm that may be suggestive of atrial fibrillation (AF) from photoplethysmograph (PPG) data, a patient user interface to notify the patient of data collection, and a physician user interface to alert the physician when irregular pulse rhythm suggestive of AF is detected. This medical device software interfaces with the LIVMOR Halo+ Home Monitoring System™ and compatible smartwatch to capture PPG data and sync to servers.

    The LIVMOR Halo AF Detection System is designed to intermittently monitor for irregular heart rhythm using the LIVMOR Halo+ Home Monitoring System while the user is at rest at night. Photoplethysmograph (PPG) signals recorded by the Halo Watch are then analyzed by the Halo AF Detection System when WiFi connectivity is available. The signal is first analyzed for quality before performing the analysis. The complete set of data from the recording session is analyzed. When a signal is suggestive of AF, the rhythm is flagged for physician review through the LIVMOR Heatt View physician portal.

    AI/ML Overview

    The LIVMOR Halo AF Detection System's acceptance criteria and the study proving it meets these criteria are detailed as follows:

    1. Table of Acceptance Criteria and Reported Device Performance

    MetricAcceptance Criteria (Implicit from Predicate/Study Results)Reported Device Performance (LIVMOR Halo AF Detection System)
    Per Subject (n=92)
    SensitivityComparable to or better than FibriCheck (95.6%)100.0%
    SpecificityComparable to FibriCheck (96.55%)93.0%
    Positive Predictive ValueNot explicitly stated as acceptance, but reported89.7%
    Negative Predictive ValueNot explicitly stated as acceptance, but reported100.0%
    AccuracyNot explicitly stated as acceptance, but reported95.7%
    Per Measurement (n=1834)
    SensitivityNot explicitly stated as acceptance, but reported for predicate93.3%
    SpecificityNot explicitly stated as acceptance, but reported for predicate99.1%

    Note: The document implicitly sets the predicate device's performance as a benchmark for substantial equivalence. While direct acceptance criteria are not explicitly listed in a "criteria" column, the demonstrated performance statistics are presented as meeting "performance goals."

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set:
      • Per Subject Analysis: 92 subjects.
      • Per Measurement Analysis: 1834 measurements (derived from these subjects).
    • Data Provenance: The document does not specify the country of origin. It indicates the data was collected through a "clinical study" involving "simultaneously collected ECG data with a Holter monitor," suggesting it was prospective in nature for the purpose of this validation study.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    The document states that the ground truth was "established by physician review of simultaneously collected ECG data with a Holter monitor." It does not specify:

    • The exact number of physicians (experts) involved.
    • Their specific qualifications (e.g., years of experience, subspecialty).

    4. Adjudication Method for the Test Set

    The document does not explicitly state the adjudication method used for establishing the ground truth (e.g., 2+1, 3+1 consensus). It only mentions "physician review."

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. The document describes a study to validate the standalone performance of the LIVMOR Halo AF Detection System against a ground truth established by physician-reviewed Holter ECGs. It does not mention a comparative effectiveness study involving human readers with and without AI assistance (i.e., an MRMC study to show human reader improvement).

    6. Standalone Performance (Algorithm Only without Human-in-the-Loop Performance)

    Yes. The study described is a standalone performance study. The device's algorithm generated results (AF detection), which were then compared directly against the ground truth established by physician review of Holter ECGs. The performance metrics (sensitivity, specificity, etc.) are reported for the device itself.

    7. Type of Ground Truth Used

    The ground truth used was "expert consensus" in the form of "physician review of simultaneously collected ECG data with a Holter monitor." This implies that the Holter ECGs provided the definitive physiological data, and physicians interpreted this data to determine the presence or absence of AF, serving as the gold standard for comparison.

    8. Sample Size for the Training Set

    The document does not provide information about the sample size of the training set used for the development of the LIVMOR Halo AF Detection System's algorithm. The provided data relates specifically to the validation/test set.

    9. How the Ground Truth for the Training Set Was Established

    Since the document does not mention the training set size, it also does not elaborate on how the ground truth for any potential training set was established. The clinical performance data provided solely pertains to the evaluation of the finished device on a test set.

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    K Number
    K200641

    Validate with FDA (Live)

    Date Cleared
    2020-09-03

    (176 days)

    Product Code
    Regulation Number
    N/A
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HaloGUARD™ Protective Disc with CHG is intended to cover insertion sites on adult patients. Common applications include IV catheters, central venous lines, epidural catheters, PICCs, hemodialysis catheters, orthopedic pins, other intravascular catheters and percutaneous devices.

    Device Description

    HaloGUARD™ Protective Disc with CHG is a sterile, single use disposable disc infused with the antibacterial agent chlorhexidine gluconate (CHG).

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the "HaloGUARD™ Protective Disc with CHG", which is a medical device intended to cover insertion sites on adult patients. The submission argues for substantial equivalence to a predicate device, the "BIOPATCH Protective Disk with CHG".

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The FDA clearance for K200641, the HaloGUARD™ Protective Disc with CHG, is based on a determination of substantial equivalence to a predicate device (BIOPATCH Protective Disk with CHG). Therefore, the "acceptance criteria" are primarily a demonstration that the subject device is as safe and effective as the predicate, without raising new questions of safety or effectiveness. The device performance is assessed through various non-clinical tests rather than specific clinical outcome metrics against predefined numerical targets.

    Acceptance Criteria CategorySpecific Criteria / Demonstrated Performance
    Indications for UseHaloGUARD™ Protective Disc with CHG is intended to cover insertion sites on adult patients. Common applications include: IV catheters, central venous lines, epidural catheters, PICCs, hemodialysis catheters, orthopedic pins, other intravascular catheters, and percutaneous devices. This is substantially equivalent to the predicate's use for absorbing exudate and covering wounds caused by various percutaneous medical devices.
    MaterialMedical grade foam impregnated with CHG with a film backing. Substantially equivalent to predicate.
    Antibacterial AgentChlorhexidine gluconate (CHG). Substantially equivalent to predicate.
    Sterilization MethodE-beam Radiation (35 kGy). Predicate uses Ethylene Oxide. This is a difference but deemed acceptable through testing.
    Sterility Assurance Level10⁻⁶. Substantially equivalent to predicate.
    Shelf LifeSix (6) months. Predicate has two (2) years. This is a difference but a shorter shelf life is often acceptable if supported by data.
    BiocompatibilityHaloGUARD™ Protective Disc with CHG is safe and effective for prolonged contact ( > 24 hours up to 30 days) with breached or compromised surfaces. Evaluated endpoints: Cytotoxicity, Irritation, Material-Mediated Pyrogenicity, Sensitization, Subacute Systemic Toxicity. Results demonstrate substantial equivalence.
    Performance (Bench)Met functional requirements. Evaluated aspects: Absorbency Factor, Antimicrobial Efficacy (4 log reduction and 7-day study) (USP <51>), Appearance, CHG Concentration Determination. Demonstrates substantial equivalence.
    Wound HealingDoes not delay the natural wound healing response. Evaluated via an animal study (ISO 10993-6). Results demonstrate substantial equivalence.
    Safety and EffectivenessOverall conclusion that the device is substantially equivalent to the predicate, sharing similar design, indications, and technology, and raising no new questions of safety or effectiveness.

    2. Sample Size Used for the Test Set and Data Provenance

    • The document primarily describes non-clinical (bench and animal) testing. It does not mention a "test set" in the context of human patient data.
    • For bench testing: The phrase "representative finished, sterilized devices" is used. No specific numerical sample size is provided for these tests (Absorbency Factor, Antimicrobial Efficacy, Appearance, CHG Concentration Determination).
    • For biocompatibility testing: The phrase "representative finished, sterilized devices" is used. No specific numerical sample size is provided.
    • For animal study: "representative finished, sterilized devices" were used for the wound healing study. No specific numerical sample size (number of animals) is provided, nor is the country of origin of the study. This would be a prospective study on animals.
    • The document states: "Clinical testing was not required to support substantial equivalence." This means no human patient data (test set) was used.

    3. Number of Experts Used to Establish Ground Truth and Qualifications of Experts

    • Not applicable as no clinical testing with human subjects or expert review of clinical cases was performed. The "ground truth" for the non-clinical tests is established by the respective test methodologies and standards (e.g., USP <51>, ISO standards).

    4. Adjudication Method for the Test Set

    • Not applicable as no clinical testing with human subjects or expert review of clinical cases was performed.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No MRMC comparative effectiveness study was done. Clinical testing was not required.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    • Not applicable. This device is a physical medical disc, not an algorithm or AI-based product.

    7. Type of Ground Truth Used

    • For biocompatibility: Ground truth is established by the specified ISO and USP standards (e.g., ISO 10993-5 for cytotoxicity, ISO 10993-10 for irritation).
    • For performance bench testing: Ground truth is established by internal test methods and USP <51> for antimicrobial efficacy (measuring log reduction).
    • For animal study (wound healing): Ground truth is established by ISO 10993-6 (Tests for Local Effects After Implantation).

    8. Sample Size for the Training Set

    • Not applicable as this is not an AI/ML device that requires a training set. The device is a physical product.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable as this is not an AI/ML device.
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    K Number
    K200268

    Validate with FDA (Live)

    Date Cleared
    2020-06-03

    (121 days)

    Product Code
    Regulation Number
    870.5150
    Age Range
    All
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticPediatricDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Halo™ Single-Loop Snare Kit is intended for use in the cardiovascular system or hollow viscous to retrieve and manipulate foreign objects.

    Device Description

    Halo™ Single-Loop Snare Kit contains: (1) Snare, (1) Snare Catheter, (1) Introducer and (1) Torque Handle. The snare is constructed of a flexible and radiopaque loop. The pre-formed snare loop can be introduced through the snare catheter without risk of snare deformation because of the snare's super-elastic construction. The snare catheter is constructed of flexible tubing and contains a radiopaque marker band.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the Halo™ Single-Loop Snare Kit. This documentation is for a medical device (a snare kit), not an AI device or software. Therefore, the questions related to AI device performance, such as sample size for test/training sets, experts for ground truth, MRMC studies, standalone algorithm performance, and training set ground truth establishment, are not applicable to this submission.

    The document discusses non-clinical performance tests conducted to demonstrate substantial equivalence to predicate devices. These tests are focused on the physical and material properties of the snare kit.

    Here's an analysis based on the provided text, focusing on what is available:

    Acceptance Criteria and Reported Device Performance (Non-Clinical):

    The document states that "A series of testing was conducted in accordance with protocols based on requirements outlined in guidances and industry standards and the below were shown to meet the acceptance criteria that were determined to demonstrate substantial equivalence."

    While specific numerical acceptance criteria and exact performance results are not provided in a table format, the document lists the types of tests performed and indicates that the device met the acceptance criteria for each.

    Acceptance Criteria (Test Category)Reported Device Performance (Met/Not Met)
    Tensile strengthMet Acceptance Criteria
    Liquid leakageMet Acceptance Criteria
    Air leakageMet Acceptance Criteria
    Corrosion ResistanceMet Acceptance Criteria
    System Tip FlexibilityMet Acceptance Criteria
    Tip Flexibility – Snare & CatheterMet Acceptance Criteria
    Snare Flexing & Fracture TestMet Acceptance Criteria
    Catheter Flexural ModulusMet Acceptance Criteria
    Catheter Kink TestMet Acceptance Criteria
    Marker Band Pull TestMet Acceptance Criteria
    Torque Strength TestMet Acceptance Criteria
    Simulative UseMet Acceptance Criteria
    RadiopacityMet Acceptance Criteria
    ParticulateMet Acceptance Criteria
    Luer TestingMet Acceptance Criteria
    Shipping TestMet Acceptance Criteria
    Cytotoxicity (ISO 10993-5)Met Acceptance Criteria
    Sensitization (ISO 10993-10)Met Acceptance Criteria
    Intracutaneous Irritation (ISO 10993-10)Met Acceptance Criteria
    Acute Systemic Toxicity (ISO 10993-11)Met Acceptance Criteria
    Material Mediated Pyrogen (ISO 10993-11)Met Acceptance Criteria
    Hemocompatibility (ISO10993-4)Met Acceptance Criteria
    - ASTM Hemolysis Direct and Indirect ContactMet Acceptance Criteria
    - Complement Activation, SC5b-9Met Acceptance Criteria
    - Platelet and Leucocyte CountsMet Acceptance Criteria
    - Partial Thromboplastin Time (PTT)Met Acceptance Criteria

    Regarding the AI-specific questions:

    The questions provided pertain to the evaluation of an Artificial Intelligence/Machine Learning (AI/ML) powered medical device. The document describes a Halo™ Single-Loop Snare Kit, which is a physical device used for retrieving and manipulating foreign objects in the cardiovascular system or hollow viscous. This is a traditional medical device, not an AI/ML software or algorithm.

    Therefore, the following questions are not applicable to this specific FDA submission:

    1. Sample sized used for the test set and the data provenance: Not applicable. This is for a physical device, not an AI model.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for an AI model is not relevant here.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. Adjudication of expert annotations is for AI model ground truth.
    4. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: Not applicable. MRMC studies are for evaluating AI's impact on human readers.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. There is no algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc): Not applicable. Ground truth for an AI model is not relevant here.
    7. The sample size for the training set: Not applicable. There is no AI model to train.
    8. How the ground truth for the training set was established: Not applicable. There is no AI model to train.

    In summary, the provided FDA document is for a traditional physical medical device, not an AI-powered one, hence most of the detailed questions regarding AI study methodology are not relevant to this specific submission. The performance assessment relied on non-clinical (bench and material) testing to demonstrate substantial equivalence.

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