K Number
K090461
Device Name
IMAGE-ARENA 4.0 AND IA APPLICATIONS 2D CARDIAC PERFORMANCE ANALYSIS 1.0
Date Cleared
2009-05-22

(88 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Image-Arena Platform Software is intended to serve as a data management platform for clinical application packages. It provides information that is used for clinical diagnosis purposes. The software is suited for stand-alone workstations as well as for networked multisystem installations and therefore is an image management system for research and routine use in both physician practices and hospitals. It is intended as a general purpose digital medical image processing tool for cardiology. As the Image-Arena Applications software tool package is modular structured, clinical applications packages with different indications for use can be connected. Echo-Com software is intended to serve as a versatile solution for Stress Echo examinations in patients who may not be receiving enough blood or oxygen because of blocked arteries. Image-Com software is intended for reviewing, measuring and reporting of DICOM data of the cardiac modalities US and XA. It can be driven by Image-Arena or other third party platforms and is intended to launch other clinical applications. The clinical application package 2D Cardiac Performance Analysis is indicated for cardiac quantification based on echocardiographic data. It provides measurements of myocardial function (displacement, velocity and strain) that is used for clinical diagnosis purposes of patients with suspected heart disease.
Device Description
The hardware requirements are based on an Intel Pentium high performance computer system and Microsoft® Windows XP Professional™ or Microsoft® Vista™ Operating System standards. Image-Arena is suited as stand-alone workstation as well as networked multisystem installations. Image Arena is developed as a common interface platform for TomTec and 3rd party clinical application packages that can be connected to Image-Arena through the 300 party Interface. The different application packages have all access to the central database and can be enabled on a modular basis thus allowing custom tailored solutions of Image-Arena. The Image-Arena Application is a software tool package designed for analysis, documentation and archiving of ultrasound studies in multiple dimensions and X-ray angiography studies. The Image-Arena Application software tools are modular structured and consist of different software modules. The different modules can be combined on the demand of the users to fulfil the requirements of a clinical researcher or routine oriented physician. The Image-Arena Application offers features to import different digital 2D, 3D and 4D (dynamic 3D) image formats based on defined file format standards (DICOM-, HPSONOS-, GE-,TomTec-file formats) in one system, thus making image analysis independent of the ultrasound-device or other imaging devices used. Offline measurements, documentation in standard report forms, the possibility to implement user-defined report templates and instant access to the stored data through digital archiving make it a flexible tool for image analysis and storage of different imaging modalities data including 2D. M-Mode. Pulsed (PW) Doppler Mode, Continuous (CW) wave Doppler Mode, Power Amplitude Doppler Mode, Color Doppler Mode, Doppler Tissue Imaging and 3D/4D imaging modes. 2D Cardiac Performance Analysis 1.0 is an additional clinical application package for high performance PC platforms based on Microsoft Windows™ operating system standards. 2D Cardiac Performance Analysis 1.0 is a software for the analysis, storage and retrieval of digitized ultrasound B-mode images. The data can be acquired by ultrasound machines that are able to acquire and store 2D ultrasound datasets. The digital 2D data can be used for comprehensive functional assessment of the myocardial function. 2D Cardiac Performance Analysis 1.0 is designed to run with a TomTec Data Management Platform for offline analysis. The TomTec Data Management Platform enhances the workflow by providing the database, import, export and other advanced high-level research functionalities. All analyzed data and images will be transferred to the platform for reporting and statistical quantification purposes. 2D Cardiac Performance Analysis 1.0 is designed for the 2-dimensional functional analysis of myocardial function. Based on two dimensional datasets a speckle tracking algorithm supports the calculation of a 2D contour model that represents the endocardial and epicardial border. From that contours the corresponding velocities, displacement and strain can be derived. The 2D Cardiac Performance Analysis 1.0 application is a visual and quantitative method for assessing cardiac mechanics and the dynamics of cardiac motion.
More Information

Not Found

No
The document describes a speckle tracking algorithm for cardiac analysis, which is a traditional image processing technique and does not inherently indicate the use of AI or ML. There are no mentions of AI, ML, or related concepts like neural networks or training data.

No
The device is described as a "digital medical image processing tool" and "image management system" that provides "information that is used for clinical diagnosis purposes." It is designed for reviewing, measuring, and reporting DICOM data, and for cardiac quantification and analysis of myocardial function. It does not actively treat or intervene in a patient's condition.

Yes

The device, specifically the "2D Cardiac Performance Analysis" component, provides measurements (displacement, velocity, and strain) and its output is explicitly stated as being "used for clinical diagnosis purposes of patients with suspected heart disease." Additionally, the "Image-Arena Platform Software" is intended to provide "information that is used for clinical diagnosis purposes."

No

The device description explicitly mentions hardware requirements based on an Intel Pentium high performance computer system and Microsoft® Windows XP Professional™ or Microsoft® Vista™ Operating System standards. While the core functionality is software, it is designed to run on specific hardware and is not presented as a purely software-only solution independent of a defined hardware platform.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for diagnostic purposes.
  • Device Function: The description clearly states that this device is a software platform for managing and processing medical images (US and XA) of the heart. It analyzes existing image data to provide measurements and information for clinical diagnosis.
  • No Specimen Handling: There is no mention of the device being used to collect, prepare, or examine specimens from the human body. Its input is image data, not biological samples.

While the software provides information used for clinical diagnosis, it does so by analyzing medical images, which falls under the category of medical imaging software, not In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The Image-Arena Platform Software is intended to serve as a data management platform for clinical application packages. It provides information that is used for clinical diagnosis purposes.
The software is suited for stand-alone workstations as well as for networked multisystem installations and therefore is an image management system for research and routine use in both physician practices and hospitals. It is intended as a general purpose digital medical image processing tool for cardiology.
As the Image-Arena Applications software tool package is modular structured, clinical applications packages with different indications for use can be connected.
Echo-Com software is intended to serve as a versatile solution for Stress Echo examinations in patients who may not be receiving enough blood or oxygen because of blocked arteries.
Image-Com software is intended for reviewing, measuring and reporting of DICOM data of the cardiac modalities US and XA. It can be driven by Image-Arena or other third party platforms and is intended to launch other clinical applications.
The clinical application package 2D Cardiac Performance Analysis is indicated for cardiac quantification based on echocardiographic data. It provides measurements of myocardial function (displacement, velocity and strain) that is used for clinical diagnosis purposes of patients with suspected heart disease.

Product codes (comma separated list FDA assigned to the subject device)

LLZ, DQK

Device Description

The hardware requirements are based on an Intel Pentium high performance computer system and Microsoft® Windows XP Professional™ or Microsoft® Vista™ Operating System standards.

Image-Arena is suited as stand-alone workstation as well as networked multisystem installations. Image Arena is developed as a common interface platform for TomTec and 3rd party clinical application packages that can be connected to Image-Arena through the 300 party Interface. The different application packages have all access to the central database and can be enabled on a modular basis thus allowing custom tailored solutions of Image-Arena.

The Image-Arena Application is a software tool package designed for analysis, documentation and archiving of ultrasound studies in multiple dimensions and X-ray angiography studies.

The Image-Arena Application software tools are modular structured and consist of different software modules. The different modules can be combined on the demand of the users to fulfil the requirements of a clinical researcher or routine oriented physician.

The Image-Arena Application offers features to import different digital 2D, 3D and 4D (dynamic 3D) image formats based on defined file format standards (DICOM-, HPSONOS-, GE-,TomTec-file formats) in one system, thus making image analysis independent of the ultrasound-device or other imaging devices used.

Offline measurements, documentation in standard report forms, the possibility to implement user-defined report templates and instant access to the stored data through digital archiving make it a flexible tool for image analysis and storage of different imaging modalities data including 2D. M-Mode. Pulsed (PW) Doppler Mode, Continuous (CW) wave Doppler Mode, Power Amplitude Doppler Mode, Color Doppler Mode, Doppler Tissue Imaging and 3D/4D imaging modes.

2D Cardiac Performance Analysis 1.0 is an additional clinical application package for high performance PC platforms based on Microsoft Windows™ operating system standards. 2D Cardiac Performance Analysis 1.0 is a software for the analysis, storage and retrieval of digitized ultrasound B-mode images. The data can be acquired by ultrasound machines that are able to acquire and store 2D ultrasound datasets. The digital 2D data can be used for comprehensive functional assessment of the myocardial function.

2D Cardiac Performance Analysis 1.0 is designed to run with a TomTec Data Management Platform for offline analysis. The TomTec Data Management Platform enhances the workflow by providing the database, import, export and other advanced high-level research functionalities. All analyzed data and images will be transferred to the platform for reporting and statistical quantification purposes.

2D Cardiac Performance Analysis 1.0 is designed for the 2-dimensional functional analysis of myocardial function. Based on two dimensional datasets a speckle tracking algorithm supports the calculation of a 2D contour model that represents the endocardial and epicardial border. From that contours the corresponding velocities, displacement and strain can be derived.

The 2D Cardiac Performance Analysis 1.0 application is a visual and quantitative method for assessing cardiac mechanics and the dynamics of cardiac motion.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Yes

Input Imaging Modality

Ultrasound (US), X-ray Angiography (XA)

Anatomical Site

Heart / Myocardium

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Physician practices and Hospitals

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Testing was performed according to internal company procedures. Software testing and validation were done at the module and system level according to written test protocols established before testing was conducted. Test results were reviewed by designated technical professionals before software proceeded to release. Please refer to Chapter 16: Software, Verification and Validation Documentation.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Not Found

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K083348, K072090

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 892.2050 Medical image management and processing system.

(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).

0

Image /page/0/Picture/0 description: The image shows the logo for TOMTEC Imaging Systems. The logo is black and white and features the company name in bold, sans-serif font. The word "TOMTEC" is on the top line, and the words "IMAGING SYSTEMS" are on the bottom line in a smaller font. The logo is simple and modern.

Image /page/0/Picture/1 description: The image shows handwritten text that appears to be a document identifier and page number. The text "K090461" is written on the top line, likely serving as a unique identifier for the document. Below that, the text "Pg 1 of 5" indicates that this is page 1 of a 5-page document. The handwriting is clear and legible, suggesting it was written for record-keeping purposes.

Jan 09th, 2008

.

Traditional 510(k) Summary

MAY 22 2009

Image-Arena 4.0 and Image-Arena Applications

4D Echo-Com 4.0

4D Image-Com 4.0

2D Cardiac Performance Analysis 1.0

Owner's Name and Address

TomTec Imaging Systems GmbH Edisonstrasse 6 D-85716 Unterschleissheim

Contact Person

Inge Scheidt QM & RA Officer ++49-89-32175-515 Phone ++49-89-32175-750 Fax

Common, Classification & Proprietary Names

| Common Name: | Various ultrasound Image Analysis System
Software |
|----------------------|----------------------------------------------------------------------------------------------------------------------------|
| Classification Name: | Picture archiving and communications system |
| Proprietary Name(s): | Image-Arena 4.0 and Image-Arena Applications
4D Echo-Com 4.0
4D Image-Com 4.0
2D Cardiac Performance Analysis 1.0 |

Predicate Devices:

Predicate Device 1: K083348 Image-Arena Applications (Image-Arena Platform 4.0/ Server Manager 4.0/ Echo-Com 4.0/ Image-Com 4.0), TomTec Siemens Diagnostic Ultrasound System, Predicate Device 2: K072090 (only Velocity Vector Imaging = VVI

component)

50

summary

1

K090461

Image /page/1/Picture/1 description: The image shows the logo for TOMTEC Imaging Systems. The logo is in black and white, with the word "TOMTEC" in large, bold letters. Below the company name is the phrase "IMAGING SYSTEMS" in smaller letters. The logo is simple and modern.

The Subject Device "Image-Arena 4.0 and Image Arena Applications" is a combination of Predicate Device 1: K083348 Image-Arena Applications (Image-Arena Platform 4.0/ Server Manager 4.0/ Echo-Com 4.0/ Image-Com 4.0), TomTec and Predicate Device 2: K072090 Siemens Diagnostic Ultrasound System, (only Velocity Vector Imaging = VVI-component).

Image /page/1/Figure/3 description: The image shows a diagram of the Image-Arena 4.0 and Image-Arena Applications. The diagram includes predicate devices 1 and 2, with codes K083348 and K072090 respectively. The diagram also includes a generic interface, a database and data management system, and various applications. The subject device is Image-Arena 4.0 and Image-Arena Applications.

C

2

Image /page/2/Picture/1 description: The image shows the logo for TOMTEC Imaging Systems. The logo is in black and white and features the word "TOMTEC" in large, bold letters. Below the word "TOMTEC" is the phrase "IMAGING SYSTEMS" in smaller letters. The logo is simple and modern.

Device Description

The hardware requirements are based on an Intel Pentium high performance computer system and Microsoft® Windows XP Professional™ or Microsoft® Vista™ Operating System standards.

Image-Arena is suited as stand-alone workstation as well as networked multisystem installations. Image Arena is developed as a common interface platform for TomTec and 3rd party clinical application packages that can be connected to Image-Arena through the 300 party Interface. The different application packages have all access to the central database and can be enabled on a modular basis thus allowing custom tailored solutions of Image-Arena.

The Image-Arena Application is a software tool package designed for analysis, documentation and archiving of ultrasound studies in multiple dimensions and X-ray angiography studies.

The Image-Arena Application software tools are modular structured and consist of different software modules. The different modules can be combined on the demand of the users to fulfil the requirements of a clinical researcher or routine oriented physician.

The Image-Arena Application offers features to import different digital 2D, 3D and 4D (dynamic 3D) image formats based on defined file format standards (DICOM-, HPSONOS-, GE-,TomTec-file formats) in one system, thus making image analysis independent of the ultrasound-device or other imaging devices used.

Offline measurements, documentation in standard report forms, the possibility to implement user-defined report templates and instant access to the stored data through digital archiving make it a flexible tool for image analysis and storage of different imaging modalities data including 2D. M-Mode. Pulsed (PW) Doppler Mode, Continuous (CW) wave Doppler Mode, Power Amplitude Doppler Mode, Color Doppler Mode, Doppler Tissue Imaging and 3D/4D imaging modes.

2D Cardiac Performance Analysis 1.0 is an additional clinical application package for high performance PC platforms based on Microsoft Windows™ operating system standards. 2D Cardiac Performance Analysis 1.0 is a software for the analysis, storage and retrieval of digitized ultrasound B-mode images. The data can be acquired by ultrasound machines that are able to acquire and store 2D ultrasound datasets. The digital 2D data can be used for comprehensive functional assessment of the myocardial function.

2D Cardiac Performance Analysis 1.0 is designed to run with a TomTec Data Management Platform for offline analysis. The TomTec Data Management Platform enhances the workflow by providing the database, import, export and

Here is the JSON requested:

summary

3

Image /page/3/Picture/1 description: The image shows the logo for Tomtec Imaging Systems. The logo is in black and white and features the word "Tomtec" in a bold, stylized font. Below the word "Tomtec" is the phrase "Imaging Systems" in a smaller, sans-serif font. The logo is simple and modern, and it is likely used to represent the company's brand.

other advanced high-level research functionalities. All analyzed data and images will be transferred to the platform for reporting and statistical quantification purposes.

2D Cardiac Performance Analysis 1.0 is designed for the 2-dimensional functional analysis of myocardial function. Based on two dimensional datasets a speckle tracking algorithm supports the calculation of a 2D contour model that represents the endocardial and epicardial border. From that contours the corresponding velocities, displacement and strain can be derived.

The 2D Cardiac Performance Analysis 1.0 application is a visual and quantitative method for assessing cardiac mechanics and the dynamics of cardiac motion.

Intended Use

The Image-Arena software tool package is intended to retrieve, store, analyze and report digital ultrasound and XA studies. The Image-Arena platform is based on a SQL - database and is intended as an image management system for images of the modalities US and XA.

The Image-Arena software can import certain digital 2D or 3D image file formats of the modalities US and XA.

The software is suited for stand-alone workstations as well as for networked multi-system installations and therefore is an image management system for research and routine use in both physician practices and hospitals. It is intended as a general purpose digital medical image processing tool for cardiology.

2D Cardiac Performance Analysis 1.0 software is intended for quantification of the myocardial deformation (strain) and movement (displacement / velocity) for 2D echocardiographic data. Possible quantification results are velocity, displacement, strain, time-to-peak and phase.

Prerequisite is to draw a contour (endocard or endocard and epicard) in a 2D dataset. Based on this manual drawn contour, the SW calculates with a tracking algorithm the borders' displacement.

Technological Characteristics Comparison

For detailed comparison of all software functionalities of the subject device and the predicate devices refer to Chapt.12: Substantial Equivalent discussion.

Discussion according non-clinical performance data testing

summary

4

Image /page/4/Picture/0 description: The image contains a sequence of handwritten characters, specifically "K09046". The characters are written in a simple, clear style, making them easily readable. The numbers are well-formed and evenly spaced.

Image /page/4/Picture/1 description: The image shows the logo for Tomtec Imaging Systems. The logo is in black and white and features the word "Tomtec" in large, bold letters. Below the word "Tomtec" is the phrase "Imaging Systems" in smaller letters. The logo is simple and modern.

Testing was performed according to internal company procedures. Software testing and validation were done at the module and system level according to written test protocols established before testing was conducted. Test results were reviewed by designated technical professionals before software proceeded to release. Please refer to Chapter 16: Software, Verification and Validation Documentation.

Discussion according clinical performance data testing

The overall product concept was clinically accepted and the clinical test results support the conclusion that the subject device is as safe as effective, and performs as well as the predicate devices. Please refer to Chapter 16: Software, Verification and Validation Documentation.

Test Conclusions of non-clinical and clinical performance data

Test results support the conclusion, that the subject device is as safe as effective, and performs as well as or better than the predicate devices. Please refer to Chapter 16: Software, Verification and Validation Documentation.

Munich, Jan 09th, 2009

summary

J. Silver Clt

Inge Scheidt QM & RA Officer

Image /page/4/Picture/10 description: The image shows a series of chevron shapes arranged in a curved line. The chevrons are all oriented in the same direction, with the open end of the chevron facing to the left. The chevrons are black and the background is white. There are about 10 chevrons in the image.

page 5 of 5

5

Public Health Service

Image /page/5/Picture/2 description: The image is a black and white logo for the Department of Health & Human Services - USA. The logo features a stylized eagle with its wings spread, and its head turned to the left. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle.

MAY 22 2009

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

TomTec Imaging Systems, GmbH C/O Ms. Inge Scheidt Edisonstrasse 6 Unterschleissheim Germany D-85716

Re: K090461

Trade/Device Name: Image-Arena 4.0 and Image-Arena Applications Regulation Number: 21 CFR 892.2050 Regulation Name: Picture Archiving and Communications System Regulatory Class: Class II Product Codes: LLZ, DQK Dated: May 11, 2009 Received: May 12, 2009

Dear Ms. Scheidt:

.

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 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

6

Page 2 - Ms. Inge Scheidt

CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.

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 the reporting of adverse events under the MDR regulation (21 CFR Part 803), please contact the CDRH/Office of Surveillance and Biometrics/Division of Postmarket Surveillance at 240-276-3464. For more information regarding the reporting of adverse events, please go to http://www.fda.gov/cdrh/mdr/.

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/cdrh/industry/support/index.html.

Sincerely yours,

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

7

Indications for Use

Ko90461 510(k) Number (if known):

Device Name:

Image-Arena 4.0 and Image-Arena Applications

Echo-Com 4.0 Image-Com 4.0 2D Cardiac Performance Analysis 1.0

Indications for Use:

The Image-Arena Platform Software is intended to serve as a data management platform for clinical application packages. It provides information that is used for clinical diagnosis purposes.

The software is suited for stand-alone workstations as well as for networked multisystem installations and therefore is an image management system for research and routine use in both physician practices and hospitals. It is intended as a general purpose digital medical image processing tool for cardiology.

As the Image-Arena Applications software tool package is modular structured, clinical applications packages with different indications for use can be connected.

Echo-Com software is intended to serve as a versatile solution for Stress Echo examinations in patients who may not be receiving enough blood or oxygen because of blocked arteries.

Image-Com software is intended for reviewing, measuring and reporting of DICOM data of the cardiac modalities US and XA. It can be driven by Image-Arena or other third party platforms and is intended to launch other clinical applications.

The clinical application package 2D Cardiac Performance Analysis is indicated for cardiac quantification based on echocardiographic data. It provides measurements of myocardial function (displacement, velocity and strain) that is used for clinical diagnosis purposes of patients with suspected heart disease.

Prescription Use (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)

H, Office of Device Evaluation (ODE)

ovascular Devices

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