K Number
K150365
Device Name
Cloud9 System
Date Cleared
2015-07-21

(159 days)

Product Code
Regulation Number
868.5905
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Cloud9® System is indicated for use by adults to reduce or eliminate simple snoring. The Cloud9® System maintains a continuous, positive low-pressure in the airway. The device is designed for prescription home use.
Device Description
The Cloud9® System is a device for delivery of low levels of continuous positive airway pressure (CPAP) that can be used by people who wish to reduce or eliminate their snoring. lts main components include the airflow unit (AFU) and custom nasal mask interface, called the NiteCap™. The Cloud9® System delivers CPAP at low pressures ranging from 2 to 4 cmH₂O, via a nasal interface. The blower generating the airstream is controlled continuously based on pressure measurements at the nasal interface to maintain the pressure at the nose of the user constant ("CPAP"). Its performance is similar to currently used CPAP devices.
More Information

No
The device description explicitly states the blower is controlled continuously based on pressure measurements to maintain constant pressure, which is a standard feedback control loop, not AI/ML. There are no mentions of AI, ML, DNN, or training/test sets.

Yes
The device is indicated for use by adults to reduce or eliminate simple snoring, which is a medical condition. It delivers continuous positive airway pressure (CPAP), a known therapeutic intervention, and its performance is described as similar to currently used CPAP devices.

No

The device is described as a medical device for delivering continuous positive airway pressure (CPAP) to reduce or eliminate simple snoring, which is a therapeutic function, not a diagnostic one. Its purpose is to treat snoring, not to diagnose a condition.

No

The device description explicitly states that the system includes physical components: an airflow unit (AFU) and a custom nasal mask interface (NiteCap™). These are hardware components, not software.

Based on the provided information, the Cloud9® System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use is to "reduce or eliminate simple snoring" by maintaining positive airway pressure. This is a therapeutic intervention, not a diagnostic test performed on biological samples.
  • Device Description: The device delivers continuous positive airway pressure (CPAP) via a nasal interface. This is a physical treatment method.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or screening.

The Cloud9® System is a therapeutic device used to treat a condition (snoring) by applying physical pressure to the airway.

N/A

Intended Use / Indications for Use

The Cloud9® System is indicated for use by adults to reduce or eliminate simple snoring. The Cloud9 System maintains a continuous, positive low-pressure in the airway. The device is designed for prescription home use.

Product codes

BZD

Device Description

The Cloud9® System is a device for delivery of low levels of continuous positive airway pressure (CPAP) that can be used by people who wish to reduce or eliminate their snoring. Its main components include the airflow unit (AFU) and custom nasal mask interface, called the NiteCap™. The Cloud9® System delivers CPAP at low pressures ranging from 2 to 4 cmH₂O, via a nasal interface. The blower generating the airstream is controlled continuously based on pressure measurements at the nasal interface to maintain the pressure at the nose of the user constant ("CPAP"). Its performance is similar to currently used CPAP devices.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Airway

Indicated Patient Age Range

Adults

Intended User / Care Setting

Prescription home use.

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

Not Found

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

A clinical study was conducted to evaluate safety and efficacy of the Cloud9® System to reduce or eliminate simple snoring. The study was a prospective, interventional study of habitual simple snorers with subjects serving as their own controls. The overall design involved four subject visits as follows:

    1. Baseline assessment of snoring and sleep parameters by PSG
    1. Titration study to determine the lowest effective level of CPAP within the range of 2 to 6 cm H₂O
  • Full treatment night at the previously determined CPAP level (Visit 2) 3.
    1. Second control night off CPAP to assess and change from baseline over the course of the trial.

Device safety was assessed by the occurrence of adverse events (nasal or skin irritation, epistaxis and sleep disruption) noted during device use (Visits 2 and 3).

A total of 24 subjects were evaluated at three centers.

Study Endpoints, Results, and Conclusions:

Primary Endpoint: Reduction in the number of all snores or reduction in loud snores as percent of sleep time with the device (Visits #2 and #3). Success criteria: 50% reduction in all snores OR at least a 90% reduction in loud snores as a percent of sleep time.
Result: There was an average of 86% reduction in loud snoring and 67% reduction in all snoring.
Conclusion: The Cloud9 System is effective for its indication to reduce or eliminate simple snoring. The primary endpoint was met with a greater than 50% reduction in all snores.

Secondary Endpoint: Reduction in overall nightly noise exposure below the WHO limit of 45 dBA. Success criteria: 50% reduction in snoring time > 45 dBA.
Result: Loud snoring was reduced from 34% of sleep time to 5% of sleep time with the Cloud9™ and the total time spent in loud snoring was reduced from 148 minutes to 18 minutes, a greater than 50% reduction.
Conclusion: The Cloud9 System is effective for its indication to reduce or eliminate simple snoring. The secondary endpoint was met with a greater than 50% reduction in snoring time ≥ 45 dBA (loud snoring).

Safety Endpoint: No adverse events (nasal or skin irritation, epistaxis and sleep disruption) noted.
Result: No adverse events occurred during this study.
Conclusion: The safety endpoint was met.

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

Primary Endpoint: 86% reduction in loud snoring, 67% reduction in all snoring.
Secondary Endpoint: Loud snoring reduced from 34% of sleep time to 5% of sleep time. Total loud snoring time reduced from 148 minutes to 18 minutes.

Predicate Device(s)

K100121, K132013

Reference Device(s)

K120665, K071689

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 868.5905 Noncontinuous ventilator (IPPB).

(a)
Identification. A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.(b)
Classification. Class II (performance standards).

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Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center -WO66-G609 Silver Spring, MD 20993-002

July 21, 2015

inSleep Technologies, LLC (inSleep Health) C/O Ms. Adrienne Lenz Senior Consultant, Quality Assurance and Regulatory Affairs Emergo Group 816 Congress Avenue, Suite 1400 Austin, TX 78701

Re: K150365

Trade/Device Name: Cloud 9® System Regulation Number: 21 CFR 868.5905 Regulation Name: Non-Continuous Ventilator (IPPB) Regulatory Class: Class II Product Code: BZD Dated: June 15, 2015 Received: June 22, 2015

Dear Ms. Lenz:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

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.

1

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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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 Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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 (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Tejashri Purohit-Sheth, M.D.

Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR

Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K150365

Device Name Cloud9® System

Indications for Use (Describe)

The Cloud9® System is indicated for use by adults to reduce or eliminate simple snoring. The Cloud9® System maintains a continuous, positive low-pressure in the airway. The device is designed for prescription home use.

Type of Use (Select one or both, as applicable):
✓ Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

for

Cloud9® System

K150365

1. Submission Sponsor

inSleep Health 12100 Singletree Lane Suite 183 Eden Prairie, MN 55344 USA Phone: (952) 746-1324 Fax: (954) 888-9600 Contact: Marty Kerber, SVP, Engineering and Manufacturing

2. Submission Correspondent

Emergo Group 816 Congress Avenue, Suite 1400 Austin, TX 78701 Cell Phone: PHONE Office Phone: (512) 327.9997 Fax: (512) 327.9998 Contact: Adrienne Lenz, Senior Consultant, Quality Assurance and Regulatory Affairs Email: project.management@emergogroup.com

3. Date Prepared

June 12, 2015

4. Device Identification

Trade/Proprietary Name:Cloud9® System
Common/Usual Name:Continuous positive airway pressure (CPAP)
Classification Name:Noncontinuous ventilator (IPPB)
Classification Regulation:868.5905
Product Code:BZD, ventilator, non-continuous (respirator)
Device Class:Class II
Classification Panel:Anesthesiology

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5. Legally Marketed Predicate Device(s)

Main Predicate K100121 AEIOMED Model 300157 CPAP System (now marketed by Somnetics as Transcend)

K132013 Resmed Swift Air (now marketed as AirFit P10).

6. Device Description

The Cloud9® System is a device for delivery of low levels of continuous positive airway pressure (CPAP) that can be used by people who wish to reduce or eliminate their snoring. lts main components include the airflow unit (AFU) and custom nasal mask interface, called the NiteCap™. The Cloud9® System delivers CPAP at low pressures ranging from 2 to 4 cmH₂O, via a nasal interface. The blower generating the airstream is controlled continuously based on pressure measurements at the nasal interface to maintain the pressure at the nose of the user constant ("CPAP"). Its performance is similar to currently used CPAP devices.

7. Indication for Use Statement

The Cloud9® System is indicated for use by adults to reduce or eliminate simple snoring. The Cloud9 System maintains a continuous, positive low-pressure in the airway. The device is designed for prescription home use.

8. Substantial Equivalence Discussion

The following table compares the Cloud9® System to the predicate devices with respect to indications for use, intended use, technological characteristics and principles of operation, providing more detailed information regarding the basis for the determination of substantial equivalence.

| Manufacturer | inSleep Health | Somnetics (cleared
by AEIOMED) | Resmed | SIGNIFICANT
DIFFERENCES |
|----------------------|------------------------------------|---------------------------------------------------------------|----------------------------------------------|----------------------------|
| Trade Name | Cloud9® System | Model 300157 CPAP
System (now
marketed as
Transcend) | Swift Air (now
marketed as AirFit
P10) | |
| 510(k) Number | This submission | K100121 | K132013 | None |
| Product Code | BZD | BZD | BZD | None |
| Regulation
Number | 868.5905 | 868.5905 | 868.5905 | None |
| Regulation
Name | Noncontinuous
ventilator (IPPB) | Noncontinuous
ventilator (IPPB) | Noncontinuous
ventilator (IPPB) | None |

Table 5A – Comparison of Characteristics
--------------------------------------------

5

| Manufacturer | inSleep Health | Somnetics (cleared
by AEIOMED) | Resmed | SIGNIFICANT
DIFFERENCES |
|---------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | Cloud9® System | Model 300157 CPAP
System (now
marketed as
Transcend) | Swift Air (now
marketed as AirFit
P10) | DIFFERENCES |
| Indications for
Use | The Cloud9®
System is indicated
for use by adults to
reduce or
eliminate simple
snoring. The
Cloud9® device
maintains a
continuous,
positive low-
pressure in the
airway. The device
is designed for
prescription home
use. | The Model 300157
CPAP System is a
single patient
reusable device. The
Model 300157 CPAP
System provides
continuous positive
airway pressure
(CPAP) to support
treatment of adults
(over 30 kg) with
Obstructive Sleep
Apnea. | The Swift Air
channels airflow
noninvasively to a
patient from a
positive airway
pressure (PAP)
device such as a
continuous positive
airway pressure
(CPAP) or bilevel
device.
The Swift Air is:

  • to be used by
    patients (> 66 lb/30
    kg) for whom
    positive airway
    pressure has been
    prescribed
  • intended for
    single-patient re-use
    in the home
    environment and
    multipatient re-use
    in the
    hospital/institutiona
    l environment. | The Cloud9®
    System's
    indication is
    similar to the
    Invent (K120665)
    which provides
    expiratory
    positive airway
    pressure to
    reduce or
    eliminate
    snoring. |
    | Mechanism of
    Action | Continuous
    Positive Airway
    Pressure (CPAP) | Continuous Positive
    Airway Pressure
    (CPAP) | Continuous Positive
    Airway Pressure
    (CPAP) or BiLevel
    Positive Airway
    Pressure (BiPAP) | None |
    | Technology | Blower
    Nasal mask held in
    place with
    adjustable
    headgear that
    straps the mask to
    the face. | Blower
    Nasal mask held in
    place with
    adjustable headgear
    that straps the mask
    to the face. | Nasal mask held in
    place with
    adjustable headgear
    that straps the mask
    to the face. | None |
    | Manufacturer | inSleep Health | Somnetics (cleared
    by AEIOMED) | Resmed | SIGNIFICANT
    DIFFERENCES |
    | Trade Name | Cloud9® System | Model 300157 CPAP
    System (now
    marketed as
    Transcend) | Swift Air (now
    marketed as AirFit
    P10) | |
    | CPAP Type | User adjustable
    fixed CPAP
    pressure | Auto CPAP | NA - channels
    airflow
    noninvasively to a
    patient from a PAP
    device such as a
    CPAP or bilevel
    device. | A prescribed
    pressure is not
    required for this
    indication and
    therefore users
    can select the
    pressure that
    works best to
    reduce or
    eliminate their
    snoring. |
    | Patient Circuit
    Connection | Custom connector
    (15 mm ID) that
    includes the
    measurement
    lumen in one single
    connector | Air outlet connector
    port: 19-mm
    diameter
    proprietary
    connector
    Universal Adapter
    Port Dimensions 22-
    mm diameter
    connector | Conical connectors
    (ref. ISO 5356-
    1:2004). | The
    Cloud9®System's
    circuit includes a
    second small
    lumen to
    measure
    pressure at the
    nose and a
    custom
    connector
    prevents
    patients from
    using another,
    not approved
    circuit with the
    Air Flow Unit. |
    | Pressure Range | 2 to 4 cm H2O | 4 to 20 cm H2O | 4 to 20 cm H2O | Lower maximum
    pressure (4 cm
    H2O) for the
    treatment of
    snoring. Other
    CPAP devices,
    such as DeVilbiss
    Intellipap
    (K071689) also
    use lower
    pressures, down
    to 3 cmH2O. |
    | Pressure Stability
    (cmH2O) as
    measured by ISO
    17510-1 | Less than +/-1 cm
    H2O at all pressure
    levels | Not specified | Not applicable to
    interface | Cloud9 meets
    requirements of
    ISO 17510-1 like
    other CPAP
    devices. |
    | Manufacturer | inSleep Health | Somnetics (cleared
    by AEIOMED) | Resmed | SIGNIFICANT
    DIFFERENCES |
    | Trade Name | Cloud9® System | Model 300157 CPAP
    System (now
    marketed as
    Transcend) | Swift Air (now
    marketed as AirFit
    P10) | |
    | Maximum Flow
    (LPM) | 71 L/min for all
    pressure settings | 71 L/min at
    4cmH₂O, 75 L/min
    at 8cmH₂O | Not applicable to
    interface | Cloud9 meets
    requirements of
    ISO 17510-1 like
    other CPAP
    devices. |
    | Maximum
    System
    Shutdown
    Pressure | 30 cm H₂O | 30 cm H₂O | Not applicable to
    interface | None |
    | Mask Sizes | InSleep nasal
    interface (the
    Butterfly) is
    available in Small,
    Medium, Large and
    Extra Large (S, M, L
    & XL) | K100121 includes a
    patient interface,
    but details are not
    publically available. | AirFit P10 XS, S,M, L
    AirFit P10 for Her
    XS, S, M,L | Both are
    available in
    various sizes to
    fit different
    users. |
    | Mask Dead space | Less than 52 ml | Seal dead space
    Less than 301 cc | Large pillows 123
    mL. | The Cloud9®
    System dead
    space is lower
    and thus better
    than the
    predicate device |
    | Resistance/ Drop
    in pressure as
    measured
    according to
    17510-2 | at 50 L/min: 5.7 cm
    H₂O
    at 100 L/min: 21.1
    cm H₂O | At 50 l/min 0.140
    cm H₂O
    At 100 l/min 0.278
    cm H₂O | at 50 L/min: 0.4 cm
    H₂O
    at 100 L/min: 1.4 cm
    H₂O | The Cloud9®
    System is
    working with
    smaller hoses
    which increases
    the resistance.
    The Cloud9®
    mask and
    interface can
    therefore only
    be used with the
    Cloud9® AFU,
    that is
    specifically
    designed to
    work with the
    higher resistance
    mask. |

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7

8

| Manufacturer | inSleep Health | Somnetics (cleared
by AEIOMED) | Resmed | SIGNIFICANT
DIFFERENCES |
|--------------|----------------------------|---------------------------------------------------------------|----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | Cloud9® System | Model 300157 CPAP
System (now
marketed as
Transcend) | Swift Air (now
marketed as AirFit
P10) | |
| AC Powered | 100 – 240VAC
50-60hz | Input
100-240 VAC, 50-
60Hz
Output
19VDC, 2.6 Amp | Not applicable to
interface | The Cloud9®
System meets
the same
standards for
electrical safety
and
electromagnetic
compatibility as
its predicate
devices. |
| Materials | Comply with ISO
10993-1 | Comply with ISO
10993-1 | Comply with ISO
10993-1 | None |

9. Non-Clinical Performance Data

As part of demonstrating safety and effectiveness of Cloud9® System and in showing substantial equivalence to the predicate devices, inSleep Health completed a risk analysis and a number of tests. The Cloud9® System meets all the requirements for overall design, cleaning, biocompatibility, electrical safety and software and test results confirm that the output meets the design inputs and specifications. The Cloud9® System passed all testing as shown by the acceptable results obtained.

The Cloud9® System complies with the applicable voluntary standards for biocompatibility, electrical safety, usability and CPAP performance. The device passed all the testing in accordance with the following international standards.

  • ISO 10993-1: 2009, Biological Evaluation of Medical Devices Part 1: Evaluation and . Testing
  • IEC 60601-1: 2005, Medical Electrical Equipment - Part 1: General Requirements for Safety
  • IEC 60601-1-2: 2007. Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility - Requirements and tests
  • IEC 60601-1-11:2010, Medical electrical equipment - Part 1-11: General requirements for basic safety and essential performance - Collateral standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment
  • ISO 17510-2: 2007: Sleep apnoea breathing therapy -Part 2: Masks and application accessories
  • . ISO 17510-1: 2007: Sleep Apnoea Breathing Therapy. Part 1: Sleep Apnoea Breathing Therapy Equipment.
  • IEC 62366: 2007 Medical devices - Application of usability engineering to medical devices

9

  • IEC 60601-1-6: 2010 Medical electrical equipment -- Part 1-6: General requirements for basic safety and essential performance -- Collateral Standard: Usability
  • . IEC 62304: 2006, Medical device software - Software life cycle processes
  • . ISO 14971: 2007, Medical devices -- Application of risk management to medical devices

Table 5B summarizes the biocompatibility testing performed.

Part NameContact Type/DurationTests Conducted
Air CircuitSkin - Permanent duration (>30
days) based on cumulative contact
every night.
AND
Airway gas - humidified due to
patient exhalation (considered
external communication with
tissue) permanent duration (>30
days) based on cumulative contact
every night• Cytotoxicity
• Sensitization
• Irritation/intracutaneous
reactivity
• System toxicity (acute)
• Pyrogenicity (as part of
Systemic toxicity)
• Subchronic toxicity (subacute
toxicity)
• Genotoxicity
• Implantation
• Chemical Characterization
(identification of extractable
compounds)
Main HoseSkin - Permanent duration (>30
days) based on cumulative contact
every night.
AND
Airway gas - dry.• Cytotoxicity
• Sensitization
• Irritation/intracutaneous
reactivity
• Chemical Characterization
(identification of particulates
and VOCs)
Air flow unit
internal
componentsAirway gas - dry. No direct patient
contact• Chemical Characterization
(identification of particulates
and VOCs)
NiteCap™
Fit System -
Sport /
AthleticSkin - Permanent duration (>30
days) based on cumulative contact
every night.• Cytotoxicity
• Sensitization
• Irritation/intracutaneous
reactivity
Table 5B - Biocompatibility Testing
-----------------------------------------

Additional verification and validation testing included:

  • Validation of cleaning methods .
  • . Validation to demonstrate that all features of the Cloud9 System were compliant with the system, software and firmware level requirements.
  • Testing of the usability of the Cloud9 System to evaluate the ability of an adult to unpack, assemble, operate and disassemble the Cloud9® System safely and effectively.

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  • Environmental testing to evaluate the use of Cloud9's Air Flow Unit in a variety of environmental conditions.
  • . Testing to determine the 6-month recommended change interval for the Cloud9® System's Filter Assembly.
  • Verification that the cleaning methods do not affect device performance over the ● claimed lifetime or replacement intervals
  • Verification of the maximum pressure under single fault conditions
  • . Verification of the maximum temperature at the patient connection port under normal and single fault conditions

10. Clinical Performance Data

A clinical study was conducted to evaluate safety and efficacy of the Cloud9® System to reduce or eliminate simple snoring. The study was a prospective, interventional study of habitual simple snorers with subjects serving as their own controls. The overall design involved four subject visits as follows:

    1. Baseline assessment of snoring and sleep parameters by PSG
    1. Titration study to determine the lowest effective level of CPAP within the range of 2 to 6 cm H₂O
  • Full treatment night at the previously determined CPAP level (Visit 2) 3.
    1. Second control night off CPAP to assess and change from baseline over the course of the trial.

Device safety was assessed by the occurrence of adverse events (nasal or skin irritation, epistaxis and sleep disruption) noted during device use (Visits 2 and 3).

A total of 24 subjects were evaluated at three centers. Table 5C presents the study endpoints, results and conclusions.

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.
Study EndpointResultConclusion
Primary - Reduction inThere was an average of 86%The Cloud9 System is
the number of all snoresreduction in loud snoring andeffective for its indication
or reduction in loud67% reduction in all snoringto reduce or eliminate
snores as percent of sleepsimple snoring. The
time with the deviceprimary endpoint was met
(Visits #2 and #3).with a greater than 50%
Success criteria: 50%reduction in all snores.
reduction in all snores OR
at least a 90% reduction
in loud snores as a
percent of sleep time
Secondary - Reduction inLoud snoring was reducedThe Cloud9 System is
overall nightly noisefrom 34% of sleep time to 5%effective for its indication
exposure below the WHOof sleep time with theto reduce or eliminate
limit of 45 dBA.Cloud9™ and the total timesimple snoring. The
Success criteria: 50%spent in loud snoring wassecondary endpoint was
reduction in snoring timereduced from 148 minutes tomet with a greater than
> 45 dBA18 minutes, a greater than50% reduction in snoring
50% reduction.time ≥ 45 dBA (loud
snoring).
Safety — No adverseNo adverse events occurredThe safety endpoint was
events (nasal or skinduring this study.met.
irritation, epistaxis and
sleep disruption) noted

Table 5C – Study Results and Conclusions

11. Statement of Substantial Equivalence

It has been shown in this 510(k) submission that the difference between the Cloud9® System and the predicate devices do not raise any questions regarding its safety and effectiveness. The Cloud9® System, as designed and manufactured, is determined to be substantially equivalent to the referenced predicate devices.