The Columbia Scientific, Inc. cutaneous electrotherapy and recording electrodes are intended to be used to apply electrical stimulation current to the patient's skin or record physiological signals.

Example electrical stimulation current applications of these electrodes are:

a) Transcutaneous Electrical Nerve Stimulation (TENS) for pain relief.
b) Electrical muscle stimulation (EMS) for neck muscle stimulation
c) Functional electrical stimulation (FES).
d) Galvanic stimulation.
e) Microcurrent electrical nerve stimulation (MENS).
f) Interferential stimulation.
g) Neuromuscular electrical stimulation (NMES).

Device Description

Single patient use cutaneous electrodes for the application of electrical stimulation are intended to be used to apply electrical stimulation current to the patient's skin or record physiological signals.

The Leadwire is attached to the electrode and is designed to be connected to a transcutaneous external muscle stimulator.

The cutaneous electrodes are single patient /multiple application use and are composed of materials commonly used in this application:

First Layer- Tricot/polyester fabric, coated with biocompatible adhesive.

Second layer- Electrically conductive Activated Carbon Mesh material.

Third layer- Biocompatible conductive Hydrogel coupling media that has been tested for biocompatibility. Test report T1262-809 NAMSA CA. Division

The electrode has one type of connection point that can be used to connect to the stimulation device (For e.g. VitalStim NMES model 5900 or 5905). The lead wire assembly is 60" with .080 inch diameter recessed female socket that is in compliance with IEC 601-1(plus amendments) and section 56.3 of 21 CFR 898.12 Performance Standard and connects to the electrode and the electrical stimulation devices.

AI/ML Overview

The Columbia 600 Electrode and Columbia 06 Leadwire, as described in K080386, is a device designed for applying electrical stimulation current to a patient's skin or recording physiological signals. The submission details a comparison to a predicate device (Pepin Manufacturing Inc. Cutaneous Electrodes, K070807) to establish substantial equivalence, primarily focusing on performance through impedance testing.

1. Acceptance Criteria and Reported Device Performance

Acceptance Criteria (Implied)	Reported Device Performance (Columbia 600 Electrode)
Impedance Level: Not explicitly stated as a numerical criterion, but the device must demonstrate impedance levels that are "less than" or at least comparable to the predicate device to prove effectiveness.	Impedance values were "less than the other predicate devices impedance values."
All other key characteristics: To be "as safe and effective as the predicate devices and do not pose new questions of safety and effectiveness," implying equivalence in:	The device is "SAME" as the predicate for:
- Indications for use	- Indications for use (e.g., TENS, EMS, FES, galvanic, microcurrent, inferential, NMES)
- Where used	- Where used (Hospitals and Clinics)
- Basic features (Size, adhesive, packaging)	- Basic features (25 mm diameter, non sterile, single patient use, self-adhesive, 4 electrodes in sealed pouch)
- Standard met	- Standard met (Conformance to 21CFR 898.12 standard)

Note: The submission for K080386 does not provide specific numerical acceptance criteria for impedance but rather a comparative statement. The primary "study" is this comparison.

2. Sample Size and Data Provenance for the Test Set

Sample Size Used for the Test Set: Not explicitly stated. The document mentions "impedance testing" was performed, but the number of electrodes or tests conducted is not detailed.
Data Provenance: Not explicitly stated. Given that the manufacturer is based in Portland, Oregon (Columbia Scientific Development, LLC), it's reasonable to infer the testing was conducted in the US, but this is not confirmed. The study appears to be retrospective in the sense that the test was conducted on the final device for comparison.

3. Number of Experts and Qualifications for Ground Truth

Number of Experts: Not applicable. The ground truth for the performance test (impedance) was based on objective measurement rather than expert consensus on medical images or diagnoses.
Qualifications of Experts: Not applicable.

4. Adjudication Method for the Test Set

Adjudication Method: Not applicable. The test was an objective measurement of impedance, not an assessment requiring adjudication by experts.

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

MRMC Study: No. This device is a passive electrode and leadwire, not an AI-powered diagnostic or assistive tool for human readers. Therefore, an MRMC comparative effectiveness study involving human readers improving with or without AI assistance is not relevant to this device.

6. Standalone (Algorithm Only) Performance Study

Standalone Study: Yes, in a broad sense. The impedance testing was performed on the device itself (algorithm only, if one considers the inherent electrical properties of the device as its "algorithm") without human intervention affecting the measurement outcome. However, given the nature of the device (a passive electrode), this isn't an "algorithm" in the typical software sense.

7. Type of Ground Truth Used

Type of Ground Truth: Objective physical measurement. The ground truth for performance was the measured electrical impedance of the electrode, compared against the measured impedance of the legally marketed predicate device.

8. Sample Size for the Training Set

Sample Size for Training Set: Not applicable. This device does not use machine learning or AI that requires a "training set." The device's design and material properties are determined by engineering and manufacturing processes, not by training on a dataset.

9. How Ground Truth for the Training Set Was Established

How Ground Truth for Training Set Was Established: Not applicable, as there is no training set for this type of device.

Summary

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K080386

Exhibit 2

MAY 30 2008

510 (K) Summary

Company Name: Columbia Scientific Development, LLC 420 NW 11th Ave., Suite 617 Portland, Oregon 97209

Contact: Stephen Shulman Phone: 734-663-0132 Fax: 734-663-1306 www.stevelshul(@aol.com Summary Date: April 9, 2008

Trade Name: Columbia 600 Electrode and Columbia 06 Leadwire

Common Name: Cutaneous electrode for muscle stimulation Leadwire for connection of cutaneous electrode to a battery powered muscle stimulator. Establishment Registration #: Address of manufacturer: TBD Device Class: Class II Product Code: GXY New or Modification: This notification is for a new device. Classification Name: 21 CFR 882.1320 21 CFR 898.12

Classification Panel: Neurology Predicate Device(s): 510(K) Number: K070807, Product Code: GXY Applicant: Pepin Manufacturing Inc. Trade Name: PMI Cutaneous Electrodes

1.0 Description of Electrode/Leadwire

The Leadwire is attached to the electrode and is designed to be connected to a transcutaneous external muscle stimulator.

The cutaneous electrodes are single patient /multiple application use and are composed of materials commonly used in this application:

First Layer- Tricot/polyester fabric, coated with biocompatible adhesive.

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Second layer- Electrically conductive Activated Carbon Mesh material.

Third layer- Biocompatible conductive Hydrogel coupling media that has been tested for biocompatibility. Test report T1262-809 NAMSA CA. Division

2.0 Indication for Use of Electrode/Leadwire

The Columbia Scientific. Inc. cutaneous electrotherapy and recording electrodes are intended to be used to apply electrical stimulation current to the patient's skin or record physiological signals.

Example electrical stimulation current applications of these electrodes are:

a) Transcutaneous Electrical Nerve Stimulation (TENS) for pain relief.
b) Electrical muscle stimulation (EMS) for neck muscle stimulation
c) Functional electrical stimulation (FES).
d) Galvanic stimulation.
e) Microcurrent electrical nerve stimulation (MENS).
f) Interferential stimulation.
g) Neuromuscular electrical stimulation (NMES).

3.0 Substantial Equivalence Comparison

The cutaneous electrotherapy electrode does not contain active electronics, software or firmware and is equivalent to the predicate device. The Columbia 600 electrodes are measured for effectiveness by monitoring the impedance level and comparing the level to previously approved devices. Result's of the impedance testing revealed that the subject device's impedance values were less than the other predicate devices impedance values.

Comparison Areas	Pepin (K070807)	"Columbia 600 Electrode&Columbia 06 Leadwire
Indications for use	The Pepin Manufacturing Inc.cutaneous electrotherapy andrecording electrodes areintended to be used to apply electricalstimulation current to the patient's skinor record physiological signals.	SAME

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Where used	Hospitals and Clinics	SAME
Basic featuresSize, adhesive,packaging	25 mm diameter, non sterile,single patient use, self adhesive, 4electrodes in sealed pouch.	SAME
Standard met	Conformance to 21CFR 898.12standard.	SAME

5. Conclusion

For the above reason's, the Columbia 600 Electrode and Columbia 06 Leadwire are considered to be as safe and effective as the predicate devices and do not pose new questions of safety and effectiveness.

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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES. USA" are arranged in a circular pattern around the eagle. The logo is black and white.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Columbia Scientific Development, LLC % Regulatory Technology Services, LLC Mr. Mark Job Responsible Third Party Official 1394 25th Street, Northwest Buffalo, Minnesota 55313

MAY 3 0 2008

Re: K080386

Trade/Device Name: Columbia 600 Electrode and Columbia 06 Leadwire Regulation Number: 21 CFR 882.1320 Regulation Name: Cutaneous electrode Regulatory Class: II Product Code: GXY Dated: May 15, 2008 Received: May 16, 2008

Dear Mr. Job:

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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Page 2 - Mr. Mark Job

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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number (800) 638-2041 or (240) 276-3150 or Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Mark M. Millman

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known):

Device Name: Columbia 600 Electrode and Columbia 06 Leadwire

The Columbia Scientific, Inc. cutaneous electrotherapy and recording electrodes are intended to be used to apply electrical stimulation current to the patient's skin or record physiological signals.

Example electrical stimulation current applications of these electrodes are:

a) Transcutaneous Electrical Nerve Stimulation (TENS) for pain relief.
b) Electrical muscle stimulation (EMS) for neck muscle stimulation
c) Functional electrical stimulation (FES).

d) Galvanic stimulation.

e) Microcurrent electrical nerve stimulation (MENS).
f) Interferential stimulation.
g) Neuromuscular electrical stimulation (NMES).

Prescription Use	X
	(Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation(QDE)

(Division Sign-Off)

Division of General, Restorative, and Neurological Devices

510(k) Number L080381

Regulation Number and Section

§ 882.1320 Cutaneous electrode.

(a)
Identification. A cutaneous electrode is an electrode that is applied directly to a patient's skin either to record physiological signals (e.g., the electroencephalogram) or to apply electrical stimulation.(b)
Classification. Class II (performance standards).