K Number
K181154
Device Name
Med-link Wrist Digital Blood Pressure Monitor, Med-link Upper Arm Digital Blood Pressure Monitor
Date Cleared
2019-08-02

(458 days)

Product Code
Regulation Number
870.1130
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Med-link Wrist Digital Blood Pressure Monitor is non-invasive blood measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood presures and pulse rate through an inflatable cuff wrapped around the wrist. It can be used by medical professionals or at home. The cuff circumference is limited to 13.5-19.5 cm. Med-link Upper Arm Digital Blood Pressure Monitor is non-invasive measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood presures and pulse rate through an inflatable cuff wrapped around the upper arm. It can be used by medical professionals or at home. The cuff circumference is limited to 22-32cm.
Device Description
The proposed devices are battery driven automatic non-invasive blood pressure Monitor. It is used for automatically conduct the inflation, deflation and measurement, which can measure systolic and diastolic blood pressure as well as the pulse rate of adult at wrist or upper arm within its claimed range and accuracy by oscillometry technique. Devices are consisted of three main parts: external hardwares (such as cuff), analog circuit, and MCU. The devices have the data storage function in order for data reviewing, including the systolic pressure, diastolic pressure, pulse rate and measurement time. The proposed devices are intended to be used in medical facilities or at home and provided non-sterile. The proposed devices have 2 models: Med-link Wrist Digital Blood Pressure Monitor Model:ESM101 Med-link Upper Arm Digital Blood Pressure Monitor Model:ESM201
More Information

Not Found

No
The description focuses on standard oscillometry techniques and hardware components (cuff, analog circuit, MCU) without mentioning any AI/ML algorithms or capabilities. The performance studies listed are standard tests for blood pressure monitors.

No.
The device is a diagnostic tool for measuring blood pressure and pulse rate, not for directly treating a medical condition.

Yes

Explanation: The device is intended to measure blood pressure and pulse rate, which are physiological parameters used to assess a patient's health status and aid in the diagnosis of conditions such as hypertension.

No

The device description explicitly states it consists of "external hardwares (such as cuff), analog circuit, and MCU," indicating it includes physical hardware components beyond just software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health. This testing is done outside of the body (in vitro).
  • Device function: The Med-link Blood Pressure Monitor measures blood pressure and pulse rate directly on the patient's body using a cuff. It does not analyze any specimens taken from the body.

The device described is a non-invasive medical device used for physiological measurement.

N/A

Intended Use / Indications for Use

Med-link Wrist Digital Blood Pressure Monitor is non-invasive blood measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood presures and pulse rate through an inflatable cuff wrapped around the wrist. It can be used by medical professionals or at home. The cuff circumference is limited to 13.5-19.5 cm.

Med-link Upper Arm Digital Blood Pressure Monitor is non-invasive measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood presures and pulse rate through an inflatable cuff wrapped around the upper arm. It can be used by medical professionals or at home. The cuff circumference is limited to 22-32cm.

Product codes

DXN

Device Description

The proposed devices are battery driven automatic non-invasive blood pressure Monitor. It is used for automatically conduct the inflation, deflation and measurement, which can measure systolic and diastolic blood pressure as well as the pulse rate of adult at wrist or upper arm within its claimed range and accuracy by oscillometry technique. Devices are consisted of three main parts: external hardwares (such as cuff), analog circuit, and MCU. The devices have the data storage function in order for data reviewing, including the systolic pressure, diastolic pressure, pulse rate and measurement time.

The proposed devices are intended to be used in medical facilities or at home and provided non-sterile. The proposed devices have 2 models:

Med-link Wrist Digital Blood Pressure Monitor Model:ESM101
Med-link Upper Arm Digital Blood Pressure Monitor Model:ESM201

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Wrist, Upper Arm

Indicated Patient Age Range

Adult

Intended User / Care Setting

medical professionals or at home

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 series of safety, essential performance and biocompatibility tests were performed to assess the safety and effectiveness of Med-link Digital Blood Pressure Monitor. The tests listed below were conducted in accordance with

IEC 60601-1 Medical electrical equipment-Part 1:General requirements for basic safety, and essential performance.

IEC 60601-1-2, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests

IEC 80601-2-30, Medical electrical equipment - Part 2-30: Particular requirements for the basic safety and essential performance of automated noninvasive sphygmomanometers

ISO 81060-2 Non-Invasive Sphygmomanometers - Part 2: Clinical Validation Of Automated Measurement Type

ISO 10993-1 Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process

ISO 10993-5 Biological Evaluation of medical devices-Part 5: Test for in vitro cytotoxicity

ISO 10993-10 Biological evaluation of medical devices- Part 10: Tests For Irritation And Skin Sensitization

  • . Cytotoxicity Test
  • Skin irritation Test ●
  • Skin Sensitization Test .

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

Pressure: ±3mmHg
Pulse: ±5%

Predicate Device(s)

K130564, K123882

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1130 Noninvasive blood pressure measurement system.

(a)
Identification. A noninvasive blood pressure measurement system is a device that provides a signal from which systolic, diastolic, mean, or any combination of the three pressures can be derived through the use of tranducers placed on the surface of the body.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA name and title on the right. The symbol on the left is a stylized representation of a human figure, while the text on the right reads "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue letters.

August 2, 2019

Shenzhen Med-link Electronics Tech Co, Ltd. Baihan Feng Regulatory Affairs Specialist 4th Fl, Bldg A, Yingtailong Industrial Prk, Dalang South Road, Longhua District Shenzhen. 518109 CHINA

Re: K181154

Trade/Device Name: Med-link Wrist Digital Blood Pressure Monitor Model: ESM101, Med-link Upper Arm Digital Blood Pressure Monitor Model: ESM201 Regulation Number: 21 CFR 870.1130 Regulation Name: Noninvasive Blood Pressure Measurement System Regulatory Class: Class II Product Code: DXN Dated: June 28, 2019 Received: July 1, 2019

Dear Baihan Feng:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Stephen Browning Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K181154

Device Name

Med-link Wrist Digital Blood Pressure Monitor Model:ESM101 Med-link Upper Arm Digital Blood Pressure Monitor Model:ESM201

Indications for Use (Describe)

Med-link Wrist Digital Blood Pressure Monitor is non-invasive blood measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood presures and pulse rate through an inflatable cuff wrapped around the wrist. It can be used by medical professionals or at home. The cuff circumference is limited to 13.5-19.5 cm.

Med-link Upper Arm Digital Blood Pressure Monitor is non-invasive measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood presures and pulse rate through an inflatable cuff wrapped around the upper arm. It can be used by medical professionals or at home. The cuff circumference is limited to 22-32cm.

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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Image /page/3/Picture/1 description: The image shows the logo for MEDLINKET. The logo consists of the word "MED" in red, with a blue arc extending from the bottom of the "M" to the top of the "D". A red circle is placed to the right of "MED", and the word "LINKET" is written in blue to the right of the circle. The letters "TM" are written in a smaller font size above the "T" in "LINKET".

510(k) Summary

This 510(k) summary is being submitted in accordance with the requirements of 21 CFR 807.92. Type of submission: Traditional

The assigned 510(k) number is:

1. Submitter information

Manufacturer Name: Shenzhen Med-link Electronics Tech Co., Ltd. Address: 4th Fl, Bldg A, Yingtailong Industrial Park, Dalang South Road, Longhua District, Shenzhen, Guangdong, CHINA, 518109 Tel: 0086-755-61568825 Fax: 0086-755-61120055 Establishment Registration Number: 3006636961

2. Contact Person

Baihan Feng (Primary Contact) E-mail: MDL001@medlinket.com

Fei Liu E-mail: USER22@med-linket.com

    1. Data of Submission
      28th , Jun., 2019

4. Identification of the Device

Trade Name: Med-link Wrist Digital Blood Pressure Monitor Model:ESM101

Med-link Upper Arm Digital Blood Pressure Monitor Model:ESM201

Common Name: Non-invasive blood pressure measurement system

Classification Regulation: 21 CFR 870.1130

Product Code: DXN

Identification of the Predicate Device 5.

Table 1 Predicate Device Information

No.Device NameCommonManufactureClassificaClassifi510(k)
---------------------------------------------------------------------

4

Image /page/4/Picture/1 description: The image shows the logo for MEDLINKET. The logo has the word "MED" in red, with a blue arc underneath it. To the right of the arc is a red circle, followed by the word "LINKET" in blue. The letters "TM" are in superscript to the right of the word "LINKET".

| | | Name | | tion and
Code | cation
regulati
on | number | |
|--|---|------------------------------------------------------------------------|-------------------------------------------------------------|-----------------------------------|--------------------------|------------------------|---------|
| | 1 | Full
Automatic(NIBP)
Blood Pressure
Monitor, Model
HL158LA | Blood
Pressure
Monitor | Health & Life
Co.,Ltd. | Class II,
DXN | 21 CFR
870.113
0 | K130564 |
| | 2 | AGE Automatic
Upper Arm Blood
Pressure Monitor | Noninvasi
ve blood
pressure
measurem
ent system | Ageless Health
Industrial Ltd. | Class II,
DXN | 21 CFR
870.113
0 | K123882 |

6. Indications for Use of the Subject device

Med-link Wrist Digital Blood Pressure Monitor is non-invasive blood measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood pressures and pulse rate through an inflatable cuff wrapped around the wrist. It can be used by medical professionals or at home. The cuff circumference is limited to 13.5-19.5 cm.

Med-link Upper Arm Digital Blood Pressure Monitor is non-invasive measurement of arterial blood pressure values in adults. It is intended to measure the diastolic, systolic blood pressures and pulse rate through an inflatable cuff wrapped around the upper arm. It can be used by medical professionals or at home. The cuff circumference is limited to 22-32cm.

7. Device Description

The proposed devices are battery driven automatic non-invasive blood pressure Monitor. It is used for automatically conduct the inflation, deflation and measurement, which can measure systolic and diastolic blood pressure as well as the pulse rate of adult at wrist or upper arm within its claimed range and accuracy by oscillometry technique. Devices are consisted of three main parts: external hardwares (such as cuff), analog circuit, and MCU. The devices have the data storage function in order for data reviewing, including the systolic pressure, diastolic pressure, pulse rate and measurement time.

The proposed devices are intended to be used in medical facilities or at home and provided non-sterile. The proposed devices have 2 models:

Med-link Wrist Digital Blood Pressure Monitor Model:ESM101

5

Image /page/5/Picture/1 description: The image shows the logo for MED LINKET. The logo has the word "MED" in red, with a blue swoosh underneath it. To the right of the word "MED" is a red circle, followed by the word "LINKET" in blue.

Med-link Upper Arm Digital Blood Pressure Monitor Model:ESM201

8. Test Summary

A series of safety, essential performance and biocompatibility tests were performed to assess the safety and effectiveness of Med-link Digital Blood Pressure Monitor. The tests listed below were conducted in accordance with

IEC 60601-1 Medical electrical equipment-Part 1:General requirements for basic safety, and essential performance.

IEC 60601-1-2, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests

IEC 80601-2-30, Medical electrical equipment - Part 2-30: Particular requirements for the basic safety and essential performance of automated noninvasive sphygmomanometers

ISO 81060-2 Non-Invasive Sphygmomanometers - Part 2: Clinical Validation Of Automated Measurement Type

ISO 10993-1 Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process

ISO 10993-5 Biological Evaluation of medical devices-Part 5: Test for in vitro cytotoxicity

ISO 10993-10 Biological evaluation of medical devices- Part 10: Tests For Irritation And Skin Sensitization

  • . Cytotoxicity Test
  • Skin irritation Test ●
  • Skin Sensitization Test .

9. Substantial Equivalence Determination

ItemProposed DevicePrimary Predicate Device
Trade nameMed-link Wrist Digital Blood
Pressure MonitorFull Automatic(NIBP) Blood
Pressure Monitor, Model
HL158LA
510(K) SubmitterShenzhen Med-link Electronics
Tech Co., Ltd.Health & Life Co.,Ltd.
510(K) NumberK130564
Classification
Regulation21CRF 870.113021CRF 870.1130
ItemProposed DevicePrimary Predicate Device
Classification
and CodeClass II,
DXNClass II,
DXN
Common nameNoninvasive blood pressure
measurement systemBlood
Pressure
Monitor
Type of UseOTCOTC
Indications for
UseMed-link Wrist Digital Blood
Pressure Monitor is non-invasive
blood measurement of arterial
blood pressure values in adults. It
is intended to measure the
diastolic, systolic blood pressures
and pulse rate through an
inflatable cuff wrapped around the
wrist. It can be used by medical
professionals or at home. The cuff
circumference is limited to
13.5-19.5 cm.HL158LA automatically
measures human' s Systolic,
Diastolic blood pressure and
heart rate by using the
oscillometric method. All
values can be read out in one
LCD panel. Measurement
position is at human being' s
wrist. The intended use of
this over-the-counter device
is for use by people over the
age of 18 with wrist
circumference ranging from
approx. 5.3 to 7.7
inches(13.5 cm to 19.5 cm)
and for home use.
Patient
populationsAdultAdult
Method of
MeasurementOscillometricOscillometric
Measurement
SiteWristWrist
Measurement
RangePressure: 0~280 mmHg
Pulse: 40~199 beats/minutePressure: 0~280 mmHg
Pulse: 40~199 beats/minute
AccuracyPressure: ±3mmHg
Pulse: ±5%Pressure: ±3mmHg
Pulse: ±5%
ItemProposed DevicePrimary Predicate Device
Inflation and
DeflationAutomaticAutomatic
DisplayLCDLCD
Memory2x90 sets4x30 sets
Cuff Size13.5cm~19.5cm13.5cm~19.5cm
Voice broadcastYesNot-provided
Power SupplyDC 3.0V (2xAAA alkaline
battery)DC 3.0V (2xAAA alkaline
battery)
Operation
EnvironmentTemperature: +5° C~+40° C;
Humidity: 15%~85%RH,Temperature: +5° C~+40°
C;
Humidity: 15%~93%RH
Storage
EnvironmentTemperature: -20° C~+55° C
Humidity: ≤95%RH,
non-condensingTemperature: -25° C~+70°
C
Humidity: ≤95%RH,
Electrical SafetyComply with IEC 60601-1Comply with IEC 60601-1,
IEC 60601-1-11
EMCComply with IEC 60601-1-2Comply with IEC 60601-1-2
PerformanceISO 80601-2-30 and ISO 81060-2AAMI SP10
Biocompatibility
EvaluationAll the patient contracting
materials are evaluated by the
biocompatibility standard ISO
10993-1, -5, -10.All the patient contracting
materials are evaluated by
the
biocompatibility standard
ISO 10993-1, -5, -10.

Table 2 Comparison Table for Med-link Wrist Digital Blood Pressure Monitor ESM101

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Image /page/6/Picture/1 description: The image shows the logo for MEDLINKET. The logo features the word "MED" in red, with a blue arc underneath it. To the right of "MED" is a red circle, followed by the word "LINKET" in blue, with the trademark symbol above it.

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Image /page/7/Picture/1 description: The image shows the logo for MEDLINKET. The logo consists of the word "MED" in red, with a blue arc underneath it. To the right of the arc is a red circle, followed by the word "LINKET" in blue. The letters "TM" are in superscript to the right of the word "LINKET".

Table 3 Comparison Table for Med-link Upper Arm Digital Blood Pressure Monitor ESM201

ItemProposed DevicePrimary Predicate Device
Trade nameMed-link Upper Arm Digital
Blood Pressure MonitorAGE Automatic Upper Arm
Blood Pressure Monitor
510(K) SubmitterShenzhen Med-link Electronics
Tech Co., Ltd.Ageless Health Industrial
Ltd.
510(K) NumberK123882
Classification
Regulation21CRF 870.113021CRF 870.1130
ItemProposed DevicePrimary Predicate Device
Classification
and CodeClass II,
DXNClass II,
DXN
Common nameNoninvasive blood pressure
measurement systemNoninvasive blood pressure
measurement system
Type of UseOTCOTC
Indications for
UseMed-link Upper Arm Digital
Blood Pressure Monitor is
non-invasive measurement of
arterial blood pressure values in
adults. It is intended to measure
the diastolic, systolic blood
pressures and pulse rate through
an inflatable cuff wrapped around
the upper arm. It can be used by
medical professionals or at home.
The cuff circumference is limited
to 22-32cm.AGE Automatic Upper Arm
Blood Pressure Monitor is
for use by medical
professionals or at home and
is a non-invasive blood
pressure measurement
system intended to measure
the diastolic and systolic
blood pressures and pulse
rate of an adult individual by
using a non-invasive
technique in which an
inflatable cuff is wrapped
around the upper arm. The
cuff circumference is limited
to 24-34cm.
Patient
populationsAdultAdult
Method of
MeasurementOscillometricOscillometric
Measurement
SiteUpper ArmUpper Arm
Measurement
RangePressure: 0~280 mmHg
Pulse: 40~199 beats/minutePressure: 0~280 mmHg
Pulse: 40~199 beats/minute
AccuracyPressure: ±3mmHg
Pulse: ±5%Pressure: ±3mmHg
Pulse: ±5%
Inflation and
DeflationAutomaticAutomatic
ItemProposed DevicePrimary Predicate Device
DisplayLCDLCD
Memory2x90 sets2x90 sets
Cuff Size22cm~32cm24cm~34cm
Voice broadcastYesYes
Power SupplyDC 6.0V (4xAA alkaline battery)DC 6.0V (4xAA alkaline battery)
Operation
EnvironmentTemperature: +5°C~+40°C;
Humidity: 15%~85%RH,Temperature: +5°C~+40°C;
Humidity: 10%~95%RH
Storage
EnvironmentTemperature: -20°C~+55°C
Humidity: ≤95%RHTemperature: -20°C~+65°C
Humidity: 10%~95%RH
Electrical SafetyComply
with IEC 60601-1Comply with IEC 60601-1
EMCComply with IEC 60601-1-2Comply with IEC 60601-1-2
PerformanceISO 80601-2-30 and ISO 81060-2AAMI SP10
Biocompatibility
EvaluationAll the patient contracting
materials are evaluated by the
biocompatibility standard ISO
10993-1, -5, -10.All the patient contracting
materials are evaluated by the
biocompatibility standard ISO
10993-1, -5, -10.

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Image /page/8/Picture/1 description: The image shows the logo for MED LINKET. The logo has the word "MED" in red, with a blue swoosh underneath it. To the right of "MED" is a red circle, and then the word "LINKET" in blue. There is a small "TM" in the upper right corner of the word "LINKET".

9

Image /page/9/Picture/1 description: The image shows the logo for MED Linket. The logo has the letters "MED" in red, with a blue swoosh underneath. To the right of the letters is a red circle, and then the word "LINKET" in blue. There is a small "TM" symbol in the upper right corner of the word "LINKET".

The proposed device and its predicate devices have the identical indented use, principle and performance. The differences between the proposed device and the predicate device do not raise any question regarding its safety and effectiveness.

10. Conclusion

Based on the comparison and analysis in this submission, it can be concluded that: Med-link Upper Digital Blood Pressure Monitors are substantially equivalent to the predicate devices in regard to safety and effectiveness.