K Number
K070676
Manufacturer
Date Cleared
2007-04-18

(37 days)

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

The Korebalance™ device is intended for use in balance therapy, only by health care professionals with experience in balance therapy. Patient suitability must be judged by the health professional on a case by case basis.

Device Description

The updated Korebalance™ Kinesthetic Ability Trainer device has the same intended use and incorporates the same balance board (platform) and bladder design technology as the originally cleared device. The modifications are primarily software based and allow:

    1. Creation of a patient specific electronic record of patient information via a touchscreen GUI.
  • Quantitative measurement of patient balance performance while the patient 2. executes a preprogrammed set of maneuvers or protocols with the board. The GUI provides instructions and visual feedback to the patient with regard to the maneuvers to be made and the success in executing the maneuver. The patient results are scored and saved (the information is not a clinical measurement but provides a reproducible quantitative measurement that the therapist can use to plan and monitor therapy) along with the bladder pressure measurement for use by the therapist, in conjunction with the therapist's observations, to assess patient progress over the course of multiple therapy sessions. Specific protocols are provided for vestibular training, orthopedic therapy, and falls prevention. These protocols are similar to those used with the previously cleared device.
    1. Patients to play "games" displayed on the GUI that involve performing various maneuvers on the balance platform. Performance is scored. The games provide an additional means for the therapist to provide rehabilitation that is fun and challenging for patients.
AI/ML Overview

The Korebalance™ Kinesthetic Ability Trainer is a device intended for use in balance therapy by health care professionals. This Special 510(k) submission (K070676) is for modifications to the previously cleared K.A.T. 1000 device (K911795), primarily software-based updates.

Here's an analysis of the acceptance criteria and the study that proves the device meets them:

1. Table of Acceptance Criteria and Reported Device Performance:

Acceptance Criteria CategorySpecific CriteriaReported Device PerformanceComments
Safety and EffectivenessMaintain fundamental safety and effectiveness of the predicate device.The modifications "do not materially alter the intended use or fundamental technology of the device, but serve to facilitate the provision of therapy, data collection and management."This implies that since the core technology and intended use are unchanged, and the modifications are primarily software-based to improve user interaction and data handling, the device is considered as safe and effective as the predicate.
Intended UseSame intended use as the predicate device (K.A.T. 1000)."It has the same intended use."The device continues to be intended for balance therapy, to be used by healthcare professionals for assessing and improving patient balance.
Fundamental TechnologyIncorporates the same balance board and bladder design technology as the predicate device."It incorporates the same balance board and bladder design technology."The core hardware component (balance platform) remains identical, ensuring consistent physical interaction and measurement principles.
Performance MeasurementAbility to provide quantitative measure of performance."The device provides a quantitative measure of performance."This functionality is inherent to both the predicate and the modified device, as it's a key aspect of balance assessment and therapy monitoring.
AdjustabilityDegree of difficulty is adjustable."The degree of difficulty is adjustable."This feature is retained from the predicate, allowing therapists to customize therapy to individual patient needs.
New Features FunctionalitySoftware modifications (touchscreen GUI, patient specific electronic record, preprogrammed tests, scoring, saving data, "games") function as intended."The modifications are primarily software based and allow: 1. Creation of a patient specific electronic record... 2. Quantitative measurement... 3. Patients to play "games"... Performance is scored."The submission implicitly asserts that these new software features function as described and enhance the device's usability and therapeutic capabilities.
Regulatory ComplianceModifications made in accordance with design control provisions and applicable guidance documents."The modifications to the existing device were made in accordance with the design control provisions of the quality system regulation and applicable guidance documents to show that the modified device is as safe, as effective, and performs as well as or better than the original device."This statement confirms adherence to regulatory requirements for design changes, which is the primary "study" or justification for a Special 510(k).

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

  • Sample Size: Not applicable. This is a Special 510(k) based on design modifications to a previously cleared device, not a de novo submission requiring extensive new clinical testing with a specific test set of patient data.
  • Data Provenance: Not applicable. The submission focuses on demonstrating that the modifications themselves do not alter the fundamental safety or effectiveness of the already cleared device. There isn't a "test set" of patient data in the traditional sense for evaluating algorithm performance. The basis for acceptance is regulatory compliance with design controls and a comparison to the predicate device.

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

  • Not applicable. There was no "test set" requiring expert ground truth establishment for this type of submission.

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

  • Not applicable. No adjudication method was used as there was no test set of patient data requiring such.

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. An MRMC study was not done. The Korebalance Kinesthetic Ability Trainer is a physical balance assessment and training device, not an AI-assisted diagnostic imaging or interpretation tool that would involve "human readers" in that context. The modifications are to its software interface and data management, not its core measurement methodology in a way that would necessitate comparing human interpretation.

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

  • Not applicable. This device is not an algorithm-only diagnostic tool. It requires human interaction (patient on the board, therapist overseeing). While it has software and algorithms for measurement and scoring, it's not a standalone AI product in the sense of making independent diagnostic or treatment recommendations without human oversight. Its "performance" is tied to its functional accuracy as a balance measurement device, which is considered equivalent to the predicate.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

  • Not applicable. The "ground truth" for this Special 510(k) is effectively the established safety and effectiveness of the predicate device (K.A.T. 1000) and the demonstration that the new modifications uphold this standard through adherence to design controls and functional verification. There isn't an external clinical "ground truth" in the typical sense for algorithm validation.

8. The sample size for the training set:

  • Not applicable. This device does not use machine learning algorithms that require a "training set" of data in the common sense. The software modifications are functional enhancements rather than AI models being trained on large datasets.

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

  • Not applicable, as there was no training set in the machine learning context.

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K070676

Special 510k Korebalance Kinesthetic Ability Trainer SportKAT, LLC

510k Summary

APR 1 8 2007

510k Owner: SPORTKAT, LLC 1497 Poinsettia Avenue, Suite 157 Vista. CA 92083 FDA Registration #: 2031091

Contact:

Mr. Damon Lawson Cell (812) 212-2020 Phone: (858) 866-3393 FAX: (858) 866-3933

Summary Date: March 6, 2007

Device Trade Name: Korebalance™ Kinesthetic Ability Trainer Common or Usual Name: Apparatus, Vestibular Analysis (Computerized Postural Pressure Platform) Classification: Unclassified Product Code: LXV

Predicate Device: This Special 510k is for changes to the previously cleared K.A.T. 1000 device (K911795)

Device Description: The updated Korebalance™ Kinesthetic Ability Trainer device has the same intended use and incorporates the same balance board (platform) and bladder design technology as the originally cleared device. The modifications are primarily software based and allow:

    1. Creation of a patient specific electronic record of patient information via a touchscreen GUI.
  • Quantitative measurement of patient balance performance while the patient 2. executes a preprogrammed set of maneuvers or protocols with the board. The GUI provides instructions and visual feedback to the patient with regard to the maneuvers to be made and the success in executing the maneuver. The patient results are scored and saved (the information is not a clinical measurement but provides a reproducible quantitative measurement that the therapist can use to plan and monitor therapy) along with the bladder pressure measurement for use by the therapist, in conjunction with the therapist's observations, to assess patient progress over the course of multiple therapy sessions. Specific protocols are provided for vestibular training, orthopedic therapy, and falls prevention. These protocols are similar to those used with the previously cleared device.

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Special 510k Korebalance Kinesthetic Ability Trainer SportKAT, LLC

    1. Patients to play "games" displayed on the GUI that involve performing various maneuvers on the balance platform. Performance is scored. The games provide an additional means for the therapist to provide rehabilitation that is fun and challenging for patients.
      Indications for Use: The Korebalance™ device is intended for use in balance therapy, only by health care professionals with experience in balance therapy. Patient suitability must be judged by the health professional on a case by case basis.

Substantial Equivalence: The modified device has the following similarities to the original previously cleared device:

  • It has the same intended use .
  • . It incorporates the same balance board and bladder design technology
  • . The degree of difficulty is adjustable
  • The device provides a quantitative measure of performance .

Modifications include the addition of a GUI, and a computer with software that allows the entry of patient specific information, the selection of static and dynamic preprogrammed tests, test selection and the measurement and the optional storage of patient performance information. The addition of modern 3-D games provides a means for patients to increase their balance board skills under the therapist's guidance in an enjoyable manner. The changes do not materially alter the intended use or fundamental technology of the device, but serve to facilitate the provision of therapy. data collection and management.

Testing: The modifications to the existing device were made in accordance with the design control provisions of the quality system regulation and applicable guidance documents to show that the modified device is as safe, as effective, and performs as well as or better than the original device .

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Image /page/2/Picture/1 description: The image is a black and white seal for the Department of Health & Human Services-USA. The seal is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA" arranged around the top half of the circle. In the center of the seal is a stylized image of three abstract human figures, possibly representing people or a family. The figures are connected and appear to be reaching upwards.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

APR 1 8 2007

SPORTKAT, LLC c/o Damon R. Lawson 1497 Poinsettia Avenue, Suite 157 Vista, CA 92083

Re: K070676

Trade/Device Name: Korebalance Kinesthetic Ability Trainer Regulation Name: Vestibular Analysis Apparatus Regulatory Class: Unclassified Product Code: LXV Dated: March 5, 2007 Received: March 19, 2007

Dear Mr. Lawson:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrib/industry/support/index.html.

Sincerely yours,

M.B. Egelman S. M.D.

Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Special 510k Korebalance Kinesthetic Ability Trainer SportKAT, LLC

Indications for Use

K070676 510(k) Number (if known):

Device Name: Korebalance™ (Kinesthetic Ability Trainer)

Indications for Use: The Korebalance™ device is intended for use in balance therapy, only by health care professionals with experience in balance therapy. Patient suitability must be judged by the health professional on a case by case basis.

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use (Per 21 CFR 801. 109). OR

Over-The-Counter

X Prescription Use _ (Per 21 CFR 801.109)

Blvision Sign-Off) Division of Ophthalmic Ear, Nose and Throat Devis

Use

510(k) Number

Appendix 2 - Page 2 of 2

N/A