K Number
K172889
Device Name
Infrared Thermometer
Date Cleared
2018-05-25

(246 days)

Product Code
Regulation Number
880.2910
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Infrared thermometer Model PC868 can measure body temperature from the forehead of infants and adults without contact to the human body, it can be used by consumers in household environment and by doctors in the clinic.
Device Description
All objects above absolute zero temperature emits certain percentage of infrared radiation energy based on its temperature. The amount of the radiation energy and the distribution of the wavelength have very closely relationship. When human forehead's temperature in 36-37°C, it emits wavelength 9-13um of infrared radiation. Based on this principle, according to the relationship between surface forehead temperature, we are able to measure the human forehead's actual temperature through measuring surface forehead temperature. Therefore, the subject device is able to measure the temperature of a person by the energy the person emits. The predicate device KI-8280, use the same detection principle to measure the patient's temperature. These thermometers are a kind of measurement device that utilize infrared radiation to measure forehead and object temperature. The Infrared Thermometers main function as following: - Forehead and object temperature measure functions - Have wide range of temperature readings: from 32.0°Cto 42.9°C - The big LCD display can clear showing the measure result. - Have memory function - Low battery indicator - Have backlight function - Have ambient temperature detection function The power supply of Infrared Thermometer is DC 3.0 V, which is offered by two AAA batteries. This thermometer uses thermopile as the temperature sensor. The enclosure cover is made of ABS plastic material. The thermometer mainly includes the following components: MCU, PCB, LCD, Infrared Sensor, Probe, Batteries, Buzzer, Backlight and Enclosure Cover. There are only one patient contacting materials: ABS plastic. The material also meet the test requirements of ISO10993-5 (In vitro cytotoxicity) and ISO10993-10 (Irritation and delayedtype hypersensitivity). The subject device of PC868 also use the focusing design to collect the infrared emitted from nearby area of object surface. This mechanism make the subject device have the ability to detect the object surface temperature. The compact, small and light-weight design, the Shenzhen Pacom Medical Instruments Co., Ltd. Infrared Thermometer, model PC868, enables to provide safe and reliable result and offers a very good clinical accuracy for human body temperature measurements.
More Information

Not Found

No
The device description details a standard infrared thermometer using a thermopile sensor and basic electronic components (MCU, PCB, LCD, etc.) to measure temperature based on infrared radiation. There is no mention of AI, ML, or any complex algorithms beyond basic signal processing for temperature calculation. The performance studies are based on standard accuracy and repeatability metrics, not AI/ML performance metrics.

No.
The device is an infrared thermometer used for measuring body temperature, which is a diagnostic function, not a therapeutic one.

No

The device is an infrared thermometer used to measure body temperature. While temperature can be a symptom of various conditions, the device itself provides only a measurement, not a diagnosis of a disease or condition. Its function is to measure a physiological parameter, not to identify or determine the nature of a disease.

No

The device description explicitly lists hardware components such as MCU, PCB, LCD, Infrared Sensor, Probe, Batteries, Buzzer, Backlight, and Enclosure Cover, indicating it is a physical device, not software-only.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to provide information for diagnosis, monitoring, or screening.
  • Device Function: The Infrared thermometer Model PC868 measures body temperature by detecting infrared radiation emitted from the forehead. This is a non-invasive measurement taken directly from the body's surface.
  • Lack of Sample Analysis: The device does not analyze any biological samples taken from the patient.

Therefore, since the device measures a physical parameter directly from the body without analyzing a biological sample, it falls outside the definition of an In Vitro Diagnostic device. It is a medical device used for physiological measurement.

N/A

Intended Use / Indications for Use

The Infrared thermometer Model PC868 can measure body temperature from the forehead of infants and adults without contact to the human body, it can be used by consumers in household environment and by doctors in the clinic.

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

FLL

Device Description

All objects above absolute zero temperature emits certain percentage of infrared radiation energy based on its temperature. The amount of the radiation energy and the distribution of the wavelength have very closely relationship. When human forehead's temperature in 36-37°C, it emits wavelength 9-13um of infrared radiation. Based on this principle, according to the relationship between surface forehead temperature, we are able to measure the human forehead's actual temperature through measuring surface forehead temperature. Therefore, the subject device is able to measure the temperature of a person by the energy the person emits. The predicate device KI-8280, use the same detection principle to measure the patient's temperature.

These thermometers are a kind of measurement device that utilize infrared radiation to measure forehead and object temperature. The Infrared Thermometers main function as following:

  • Forehead and object temperature measure functions
  • Have wide range of temperature readings: from 32.0°Cto 42.9°C
  • The big LCD display can clear showing the measure result.
  • Have memory function
  • Low battery indicator
  • Have backlight function
  • Have ambient temperature detection function

The power supply of Infrared Thermometer is DC 3.0 V, which is offered by two AAA batteries.

This thermometer uses thermopile as the temperature sensor. The enclosure cover is made of ABS plastic material. The thermometer mainly includes the following components: MCU, PCB, LCD, Infrared Sensor, Probe, Batteries, Buzzer, Backlight and Enclosure Cover.

There are only one patient contacting materials: ABS plastic. The material also meet the test requirements of ISO10993-5 (In vitro cytotoxicity) and ISO10993-10 (Irritation and delayedtype hypersensitivity).

The subject device of PC868 also use the focusing design to collect the infrared emitted from nearby area of object surface. This mechanism make the subject device have the ability to detect the object surface temperature.

The compact, small and light-weight design, the Shenzhen Pacom Medical Instruments Co., Ltd. Infrared Thermometer, model PC868, enables to provide safe and reliable result and offers a very good clinical accuracy for human body temperature measurements.

Power requirements:
d.c.3V,twoAAbatteries,meetstherequirementsofUL544

Sterilization information: Theinfraredthermometerisnotsoldsterile

Temperaturerange: Forforeheadmode: 32.0℃to42.9℃; For surface mode: 0℃ to 100℃

Ambient temperature environment: Temperature: 10°C-40°C; Relative humidity: 15%-85%RH; Atmospheric pressure: 70-106KPa

Storageenvironment: Temperature:0°C-50°C;Relativehumidity:15%-85%RH; Atmospheric pressure:70-106KPa

Accuracyandrepeatability: For forehead mode: ±0.2℃(0.4℃)during35.5℃-42.0℃;(95.9℃-107.6℃) ±0.3℃(0.5℃(0.5℃)otherranges; For surface mode: ±1.0℃(1.80F)during15.0℃-60.0℃(59°F-140°F);

±2.0°C(3.6°F)otherranges;

Othercapabilities:

  • a) LCDdisplaywithcolorchangingbacklight
  • b) ReadstemperatureinFahrenheitorcentigrade
  • Automatic power saving in 15 seconds c)
  • d) Automaticallysaveslast99readings
  • e) BatteryLifespangreaterthan1000reads,replaceablebatteries

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

forehead

Indicated Patient Age Range

infants and adults

Intended User / Care Setting

consumers in household environment and by doctors in the clinic.

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)

The clinical performance test protocol and data analysis is followed the requirements the ASTM E 1965-98. It can conclude that the Thermometer, PC868 is acceptable to measure patient's temperature.

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.

K102947

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

§ 880.2910 Clinical electronic thermometer.

(a)
Identification. A clinical electronic thermometer is a device used to measure the body temperature of a patient by means of a transducer coupled with an electronic signal amplification, conditioning, and display unit. The transducer may be in a detachable probe with or without a disposable cover.(b)
Classification. Class II (performance standards). The device is exempt from the premarket notification procedures in part 807, subpart E of this chapter, subject to the limitations in § 880.9 and the following conditions for exemption:(1) Device is not a clinical thermometer with telethermographic functions;
(2) Device is not a clinical thermometer with continuous temperature measurement functions; and
(3) Appropriate analysis and testing (such as that outlined in the currently FDA-recognized editions, as appropriate, of ISO 80601-2-56, “Medical electrical equipment—Part 2-56: Particular requirements for basic safety and essential performance of clinical thermometers for body temperature measurement,” or ASTM E1965, “Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature,” or ASTM E1112, “Standard Specification for Electronic Thermometer for Intermittent Determination of Patient Temperature,” or ASTM E1104, “Standard Specification for Clinical Thermometer Probe Covers and Sheaths”) must validate specifications and performance of the device.

0

May 25, 2018

Shenzhen Pacom Medical Instruments Co., Ltd. Liangzhou Zhong Manager 8 Floor, B District, B Building, No. 5 Industry Five Road, Jianbian Community Songgang, Shenzhen, 518105 CHINA

Re: K172889

Trade/Device Name: Infrared Thermometer Regulation Number: 21 CFR 880.2910 Regulation Name: Clinical Electronic Thermometer Regulatory Class: Class II Product Code: FLL Dated: April 16, 2018 Received: April 16, 2018

Dear Liangzhou Zhong:

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. Iisting 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 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.

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.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Tina Kiang
-s

Tina Kiang, Ph.D. Acting 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): _K172889

Device Name: Infrared Thermometer, Model: PC868

Indications for Use:

The Infrared thermometer Model PC868 can measure body temperature from the forehead of infants and adults without contact to the human body, it can be used by consumers in household environment and by doctors in the clinic.

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)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Page 1 of 1

3

510(k) Summary

This summary of 510(K) information is being submitted in accordance with the requirements of SMDA and 21 CFR §807.92.

The assigned 510(k) number is: K172889

1.0 Information of Submitter and Correspondent

Submitter's information:

Shenzhen Pacom Medical Instruments Co., Ltd. Address: On the 8tt floor of B District, B Building, No.5, Industry five road, Jianbian Community, Songgang, Shenzhen 518105, China. Phone:+86-755-32920339 Fax: +86-755-32920339 Contact Person: Mr.Zhong E-mail: reanny@reanny.com

Submission contact information:

Shenzhen Reanny Medical Devices Management Consulting Co., Ltd

Address: Room 2012#, Gebu commercial building, Hongxing community, Songgang street, Baoan district, Shenzhen 518000, China

Contact Person: Reanny Wang; E-mail: reanny@reanny.com

2.0 Device Information

Type of 510(k) submission:Traditional
Trade Name:Infrared Thermometer, Model: PC868
Model:PC868
Classification name:thermometer, electronic, clinical General
Review Panel:Hospital
Product Code:FLL
Device Class:II
Regulation Number:880.2910

4

3.1 Predicate Device Information

Sponsor:K-jump Health Co., Ltd.
Device:Non-contact Infrared Thermometer, model KI-8280
510(K) Number:K102947

4.0 Device Description

All objects above absolute zero temperature emits certain percentage of infrared radiation energy based on its temperature. The amount of the radiation energy and the distribution of the wavelength have very closely relationship. When human forehead's temperature in 36-37°C, it emits wavelength 9-13um of infrared radiation. Based on this principle, according to the relationship between surface forehead temperature, we are able to measure the human forehead's actual temperature through measuring surface forehead temperature. Therefore, the subject device is able to measure the temperature of a person by the energy the person emits. The predicate device KI-8280, use the same detection principle to measure the patient's temperature.

These thermometers are a kind of measurement device that utilize infrared radiation to measure forehead and object temperature. The Infrared Thermometers main function as following:

  • Forehead and object temperature measure functions
  • Have wide range of temperature readings: from 32.0°Cto 42.9°C
  • The big LCD display can clear showing the measure result.
  • Have memory function
  • Low battery indicator
  • Have backlight function ロ
  • Have ambient temperature detection function

The power supply of Infrared Thermometer is DC 3.0 V, which is offered by two AAA batteries.

This thermometer uses thermopile as the temperature sensor. The enclosure cover is made of ABS plastic material. The thermometer mainly includes the following components: MCU, PCB, LCD, Infrared Sensor, Probe, Batteries, Buzzer, Backlight and Enclosure Cover.

5

There are only one patient contacting materials: ABS plastic. The material also meet the test requirements of ISO10993-5 (In vitro cytotoxicity) and ISO10993-10 (Irritation and delayedtype hypersensitivity).

The subject device of PC868 also use the focusing design to collect the infrared emitted from nearby area of object surface. This mechanism make the subject device have the ability to detect the object surface temperature.

The compact, small and light-weight design, the Shenzhen Pacom Medical Instruments Co., Ltd. Infrared Thermometer, model PC868, enables to provide safe and reliable result and offers a very good clinical accuracy for human body temperature measurements.

Power requirements:

d.c.3V,twoAAbatteries,meetstherequirementsofUL544

Sterilization information: Theinfraredthermometerisnotsoldsterile

Temperaturerange: Forforeheadmode: 32.0℃to42.9℃; For surface mode: 0℃ to 100℃

Ambient temperature environment: Temperature: 10°C-40°C; Relative humidity: 15%-85%RH; Atmospheric pressure: 70-106KPa

Storageenvironment: Temperature:0°C-50°C;Relativehumidity:15%-85%RH; Atmospheric pressure:70-106KPa

Accuracyandrepeatability: For forehead mode: ±0.2℃(0.4℃)during35.5℃-42.0℃;(95.9℃-107.6℃) ±0.3℃(0.5℃(0.5℃)otherranges; For surface mode: ±1.0℃(1.80F)during15.0℃-60.0℃(59°F-140°F);

6

Sponsor: Shenzhen Pacom Medical Instruments Co., Ltd.

Infrared Thermometer, model: PC868 Subject Device:

±2.0°C(3.6°F)otherranges;

Othercapabilities:

  • a) LCDdisplaywithcolorchangingbacklight
  • b) ReadstemperatureinFahrenheitorcentigrade
  • Automatic power saving in 15 seconds c)
  • d) Automaticallysaveslast99readings
  • e) BatteryLifespangreaterthan1000reads,replaceablebatteries

5.0 Intended Use

The Infrared thermometer Model PC868 can measure body temperature from the forehead ofinfantsand adultswithoutcontacttothehumanbody.itcanbeusedbyconsumersin householdenvironmentandbydoctorsin theclinic.

6.0 Performance Summary

The devices conform to applicable standards as follow table:

| Item | Description | FDA recognized
consensus
standards | Justification |
|--------------------------------|----------------------------------|------------------------------------------|---------------|
| Safety | IEC 60601-1 | Yes | Conform |
| EMC | IEC 60601-1-2 | Yes | Conform |
| Home healthcare
environment | IEC 60601-1-11 | Yes | Conform |
| Performance | ASTM E 1965-98
ISO 80601-2-56 | Yes | Conform |
| Biocompatibility
evaluation | ISO 10993-1 | Yes | Conform |
| Biocompatibility test | ISO 10993-5
ISO 10993-10 | Yes | Conform |
| Software | IEC 62304 | Yes | Conform |
| Risk management | ISO 14971 | Yes | Conform |

7

Subject Device: Infrared Thermometer, model: PC868

7.0 Comparison to predicate device and conclusion

The subject device is substantially equivalent to predicate devices, K102947, KI-8280. The substantial equivalence chart is provided as follows:

| Elements of

ComparisonPredicate DeviceSubject DeviceJudgment
ModelsKI-8280PC868--
CompanyK-jump Health Co., Ltd.Shenzhen Pacom Medical
Instruments Co., Ltd.--
Device NameNon-Contact Infrared
ThermometerInfrared Thermometer--
510(k) NumberK102947Pending--
Intended useThe non-contact infrared
thermometer, Model KI-
8280, can measure body
temperature for infants and
adults without contact to
human body, it can be used
by consumers in household
environment and doctor in
clinic as reference.The thermometers are intended
to measure forehead temperature
without contact at home or
hospital, including anyone, such
as infants, children and adults.Similar
SensorInfrared SensorInfrared SensorSame
Measurement
methodInfrared radiation detectionInfrared radiation detectionSame
Measurement
modeForehead and surface
measure modeForehead and surface measure
modeSame
Measurement
rangeForehead mode:
32.2°C-43.3°C (90.0°F-
109.9°F);
Surface mode:
0.0°C-100°C (32°F -212°F);For forehead mode:
32.0°C to 42.9°C (89.6°F-107.9°F);
For surface mode:
0°C to 100°C (32°F-212°F)Similar
Note 1
Measuring
accuracyForehead mode:
±0.2°C(0.4°F);
Surface mode:
±1°C(1.8°F)For forehead mode:
± 0.2 °C (0.4°F) during 35.5 °C -
42.0°C; (95.9°F-107.6°F)
±0.3°C (0.5°F) other ranges;
For surface mode:
± 1.0°C (1.8°F) during 15.0 °C -
60.0°C (59°F-140°F);
±2.0°C(3.6°F) other ranges;Similar
Note 2
Elements of
ComparisonPredicate DeviceSubject DeviceJudgment
ModelsKI-8280PC868--
Display
resolution0.1°C/0.1°F0.1°C/0.1°FSame
Response Time1 second1 secondSame
Signal output
and displayLCD, BuzzerLCD, BuzzerSame
C/F switchableYesYesSame
Measurement
distance3-8cm3-5cmSimilar
Note 3
Memory10 sets99setsSimilar
Note 4
Power supplyTwo 1.5V AAA batteriesTwo 1.5V AAA batteriesSame
Low battery
indicationYesYesSame
WaterproofNoIP22Similar
Note 5
High
temperature
hintHigher than 38°C(100.4°F)Higher than 38°C(100.4°F)Same
Operation
environmentTemperature:
10.0°C40°C (50.0°F104.0°F)
Humidity:
95%RH or belowTemperature:
10.0°C40°C (50.0°F104.0°F)
Humidity:
15%-85%RH or belowSimilar
Note 6
Storage
environmentTemperature:
-25.0°C~55.0°C
(-13.0°F~131.0°F)
Humidity: 95%RH or belowTemperature: 0°C-50°C(32.0°F~122.0°F);
Relative humidity: 15%-85%RH;Similar
Note 6
Dimension138×90×45mm149×95×45mmSimilar
Weight125g (including batteries)140g (including batteries)Similar
PerformanceCompliance with ASTM E
1965-98Compliance with ASTM E
1965- 98Same
BiocompatibilityAll the patient contacting
materials are compliance
with ISO 10993-1/-5/-10All the patient contacting
materials are compliance
with ISO 10993-1/-5/-10Same
Electrical SafetyCompliance with IEC
60601-1Compliance with IEC 60601-1Same
EMCCompliance with IECCompliance with IEC 60601-1-2Same
Elements of
ComparisonPredicate DeviceSubject DeviceJudgme
nt
ModelsKI-8280PC868--
60601-1-2

Chapter 9, Page 5 of 8

8

Shenzhen Pacom Medical Instruments Co., Ltd. Sponsor:

Infrared Thermometer, model: PC868 Subject Device:

Chapter 9, Page 6 of 8

9

Shenzhen Pacom Medical Instruments Co., Ltd. Sponsor:

Subject Device: Infrared Thermometer, model: PC868

Note 1 and note2 :

Although the measurement range and measuring accuracy of subject devices are different from predicate device, they both comply with the ASTM E 1965 standard, so the difference will not raise different safety or effectiveness issue.

Note2 :

Although the measurement distance of subject devices is different than predicate device, they both comply with the ASTM E 1965 standard and clinical test, so the difference will notraise different safety or effectiveness questions.

Note 3:

Although the measurement distance of subject devices is different than predicate device, they both comply with the ASTM E 1965 standard and clinical test, so the difference will not raise different safety or effectiveness questions.

Note 4:

The memory of subject devices is less than predicate device, but they both comply with the ASTME 1965 standard, so the difference will not raise different safety or effectiveness questions.

Note 5:

The Waterproof of subject devices is IP22 and this have pass the IEC60601-1 test, will notraise different safety or effectiveness questions.

Note 6:

The Storage environment of subject devices is less than predicate device, but they both comply with the ASTM E 1965 and IEC 60601-1 standard, so the difference will not raise different safety or effectiveness questions.

Final Conclusion:

10

The subject devices have all features of the predicate device. The few differences do not affect the substantial equivalence of the subject devices.

Thus, the subject devices are substantially equivalent to the predicate device.

8.0 Discussion of Clinical Tests Performed

The clinical performance test protocol and data analysis is followed the requirements the ASTM E 1965-98. It can conclude that the Thermometer, PC868 is acceptable to measure patient's temperature.

9.0 Conclusions

Infrared Thermometer, Model PC868 has the same intended use and similar characteristics as the predicate device. Moreover, the subject device demonstrates product safety by successful completion of testing to the IEC 60601-1 standard and electromagnetic standard IEC 60601-1-2. The performance test demonstrates the PC868 meets the ASTM E 1965-98 and concludes that any differences in their characteristics does not raise different questions of safety and effectiveness.

Form the above information we conclude the subject device. PC868 is substantially equivalent to the predicate devices.

10.0 Summary prepared date

May 10, 2018