K Number
K183123
Device Name
microTargeting Guideline 4000 5.0 System
Manufacturer
Date Cleared
2018-12-20

(37 days)

Product Code
Regulation Number
882.1330
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The microTargeting™ Guideline 4000 5.0 System is intended to record and stimulate electrophysiological activity, as well as aid in the accurate placement of electrodes and other instruments.
Device Description
The microTargeting™ Guideline 4000™ 5.0 System is an electrophysiological recording and stimulation system designed primarily for functional neurosurgery procedures. The system provides high quality and research-grade recordings on both microelectrodes and macroelectrodes, including low-frequency signals on externalized DBS leads, improved signal quality, decreased noise susceptibility, improved user experience with redesigned software, new intraoperative data analysis options, and an updated user interface to support touch screens and multiple high-resolution monitors. Additionally, it provides simultaneous constant-current and constant-voltage stimulation capabilities that include multiple weighted sources and return paths as well as complex and arbitrary stimulation waveforms. The software provides an intuitive patient management system, as well as advanced visualization and analysis methods for both single-unit recording and low-frequency signals (LFP, SEEG etc.). A fully configured system consists of a Core Module, a notebook PC, an 8-channel UE interface unit, a remote, an optional second 8-channel LF interface and an optional synchronization unit.
More Information

Not Found

No
The summary does not mention AI, ML, or related terms, and the device description focuses on electrophysiological recording, stimulation, and data visualization/analysis without indicating AI/ML capabilities.

No
The device is intended to record and stimulate electrophysiological activity and aid in electrode/instrument placement, not to treat a disease or condition for therapeutic benefit.

Yes

The device is intended to "record and stimulate electrophysiological activity" and aids in "accurate placement of electrodes." It also provides "advanced visualization and analysis methods for both single-unit recording and low-frequency signals," all of which are diagnostic functions.

No

The device description explicitly lists multiple hardware components that constitute a fully configured system, including a Core Module, a notebook PC, interface units, and a remote.

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

Here's why:

  • Intended Use: The intended use is to "record and stimulate electrophysiological activity, as well as aid in the accurate placement of electrodes and other instruments" within the brain and nervous system. This is a direct interaction with the patient's body for diagnostic and therapeutic purposes, not the examination of specimens derived from the human body.
  • Device Description: The description details an electrophysiological recording and stimulation system used during functional neurosurgery procedures. It focuses on measuring electrical signals within the body and applying electrical stimulation.
  • Lack of IVD Characteristics: There is no mention of analyzing biological specimens (blood, urine, tissue, etc.) or providing information about a patient's health status based on such analysis.

IVD devices are specifically designed to examine specimens from the human body to provide information for the diagnosis, monitoring, or treatment of diseases or conditions. This device operates directly on the patient's nervous system.

N/A

Intended Use / Indications for Use

The microTargeting™ Guideline 4000™ 5.0 System is intended to record and stimulate electrophysiological activity, as well as aid in the accurate placement of electrodes and other instruments.

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

GZL

Device Description

The microtargeting™ Guideline 4000™ 5.0 System is an electrophysiological recording and stimulation system designed primarily for functional neurosurgery procedures.

The microtargeting™ Guideline 4000™ 5.0 System provides:

  • High quality and research-grade recordings on both microelectrodes and macroelectrodes, including low-frequency signals on externalized DBS leads
  • Improved signal quality
  • Decreased Noise susceptibility
  • Improved user experience with redesigned software
  • New intraoperative data analysis options
  • Updated user interface to support touch screens and multiple high-resolution monitors

Additionally, Guideline 5 interface provides unprecedented simultaneous constant-current and constant-voltage stimulation capabilities that include multiple weighted sources and return paths as well as complex and arbitrary stimulation waveforms. Together, these capabilities result in the output of advanced stimulation protocols, including current steering. The software provides an intuitive patient management system, as well as advanced visualization and analysis methods for both single-unit recording and low-frequency signals (LFP, SEEG etc.).

The Guideline 5 offers neurosurgical teams a powerful microelectrode recording/stimulating system in a compact, streamlined package. It offers fully integrated stimulation and impedance check capabilities on all channels, in addition to one-click recall of user preferences and side-byside review of all recorded snapshots.

As shown below, a fully configured system consists of a Core Module, a notebook PC, an 8channel UE interface unit, a remote, an optional second 8-channel LF interface and an optional synchronization unit.

Individual components which comprise the Guideline 5 system are listed in the table below:

Main Processing Unit, Catalog Number C0215, Description Guideline 5 Main Unit, Classification Core Component
Guideline PC, Catalog Number C0216, Description Guideline 5 Notebook, Classification Core Component
Ethernet Cable, Catalog Number C0234, Description Ethernet Cable, Classification Core Component
UE Interface, Catalog Number C0219, Description Microelectrode head-stage, Classification Core Component
LF Interface, Catalog Number C0220, Description Low Frequency Signal head-stage, Classification Accessory
Software, Catalog Number C0217, Description Guideline 5 Software Application, Classification Core Component
Secondary Interface Processing Card, Catalog Number C0218, Description Interface Processing Card (factory or field installed), Classification Variant (internal)
Interface Digital Cable, Catalog Number C0221, Description 3m Interface Cable, Classification Core Component
Motor, Catalog Number C0235, Description microTargeting Power Assist Unit (existing medical device, not within the scope of these design inputs), Classification Accessory
mT Controller Card, Catalog Number C0223, Description Integrated microTargeting Controller, Classification Variant (internal)
Remote Control, Catalog Number C0222, Description Guideline 5 Remote Control, Classification Core Component
Breakout Box, Catalog Number C0224, Description Synchronization Unit, Classification Accessory
HD Digital Cable, Catalog Number C0225, Description 1m Synchronization Unit Cable, Classification Accessory
3m Patient Lead, Catalog Number C0230, Description 3m UE Cable, Classification Consumable
1.5m Patient Lead, Catalog Number C0231, Description 1.5m UE Cable, Classification Consumable
Interface pole mount, Catalog Number C0233, Description Interface Pole Mounting Bracket, Classification Accessory
Speaker, Catalog Number C0237, Description High Performance Speaker, Classification Core Component

The Guideline 5 has full featured multi-source stimulation capabilities. Stimulation modes of constant voltage or constant current mode are available with a compliance voltage of ±14V. The UE Interface is capable of microstimulation (±100µA max) through the microelectrode as well as macrostimulation (±10mA max) through the macro-contact. During stimulation, the voltage applied to the electrode is monitored and displayed constantly. The LF provides macro-stimulation. Every channel has its own stimulation circuit, allowing the Guideline 5 to perform the complex simultaneous multi-channel, multireturn stimulation protocols required for current shaping and steering. Channels not involved in the stimulation continue to record activity while an adaptive suppressor minimizes stimulus artifacts.

Integrated Impedance Check functionality for microelectrodes, macro-contacts and LF electrodes can be performed easily for monitoring the state of all connected electrodes. Measurement frequency and duration are user adjustable. The low measurement current of 1μApp minimizes any effect of the measurement on microelectrode properties. Simultaneous measurement of all channels provides quicker results. An automated power on self-test verifies proper operation and calibration of all stimulation and impedance check circuitry prior to every use of the Guideline 5 system.

The Guideline 5 is capable of recording any or all activity on an event-by-event basis or continuously. Recorded waveforms can be reviewed and analyzed intraoperatively or post-operatively. Sample Matlab™ scripts provided allow for more advanced analyses of electrode and auxiliary data suitable for research applications.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

brain and nervous system

Indicated Patient Age Range

Not Found

Intended User / Care Setting

neurosurgeon, neurologist or clinical neurophysiologist

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)

Performance data of the microTargeting™ Guideline 4000™ 5.0 System is documented in the verification and validation reports. Electrical Safety Test, Mechanical Integrity test, Macrostimulation test, Microstimulation test and Software regression test results show the system to be the equivalent to the predicate system.

Test: Electrical Safety
Test Method Summary: Electrical Safety consistent with IEC 60601 (Class 1 ME Equipment). Internal Testing based on IEC 60601 protocols. 60601-1 Electrical Safety Testing Performed Externally by 3rd Party entity.
Results: Both internally and externally performed electrical safety testing on subject device per standard IEC 60601 passed the acceptance criteria necessary for establishing basic safety. The subject and predicate device were both exposed to the same 60601-1 electrical safety testing therefore a substantive equivalence is established.

Test: Mechanical Integrity
Test Method Summary: Mechanical Strength and Integrity testing consistent with standard IEC 60601 Internal Testing based on IEC 60601 protocols. 60601-1 Mechanical Strength Testing Performed Externally by 3rd Party entity.
Results: Both internally and externally performed mechanical strength testing on subject device per standard IEC 60601 passed the acceptance criteria necessary for establishing basic safety. The subject and predicate device were both exposed to the same 60601-1 mechanical strength testing therefore a substantive equivalence is established.

Test: Macro Stimulation
Test Method Summary: The test method employed is an internally generated protocol in which the subject device is assessed on three key parameters relevant to the safe and effective delivery of therapeutic electrical stimulus. These parameters include: -Accurate output frequency -Accurate pulse duration -Accurate stimulus amplitude. Each parameter is adjusted via the software user interface. Each parameter is then measured using a NIST traceable oscilloscope with the subject device's output terminated with precision resistive loads which act as microelectrode analogs.
Results: The subject devices met the acceptance criteria necessary for establishing accuracy of stimulator outputs to within ±10% of the User Interface set point for frequency, pulse duration, and amplitude. Given the predicate device provides the same accuracy, a substantive equivalence is established.

Test: Micro Stimulation
Test Method Summary: The test protocol used for Macro Stimulation mode also applies to Micro stimulation with the exception of the latter outputs an order of magnitude lower stimulus amplitude.
Results: The subject devices met the acceptance criteria necessary for establishing accuracy of stimulator outputs to within ±10% of the User Interface set point for frequency, pulse duration, and amplitude. Given the predicate device provides the same accuracy, a substantive equivalence is established.

Test: Software regression testing
Test Method Summary: The internally created software regression test protocol is based on the workflow established in the Usability specification of the predicate device. It is performed iteratively at each software release per IEC 62304. All major and minor software functions were tested iteratively prior to each release of a new software revision. Additionally, bugs fixed since the previous round of regression testing were assessed for effectiveness and risk.
Results: All major areas of software functionality were confirmed for the subject device. No remaining bugs had a risk level of greater than Acceptable as defined by risk management plan. Over the course of its life-cycle, the predicate device received similar treatment with respect to bug fixes, bug risk acceptance, software releases, and regression testing. As such, substantive equivalence is established.

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.

K071364

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

§ 882.1330 Depth electrode.

(a)
Identification. A depth electrode is an electrode used for temporary stimulation of, or recording electrical signals at, subsurface levels of the brain.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 20, 2018

FHC. Inc. Kelly Moeykens Quality Systems Officer 1201 Main Street Bowdoin, Maine 04287

Re: K183123

Trade/Device Name: microTargeting Guideline 4000 5.0 System Regulation Number: 21 CFR 882.1330 Regulation Name: Depth Electrode Regulatory Class: Class II Product Code: GZL Dated: November 6, 2018 Received: November 13, 2018

Dear Kelly Moeykens:

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.

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

1

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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

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,

Jay R. Gupta -S

For Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K183123

Device Name

microTargeting™ Guideline 4000 5.0 System

Indications for Use (Describe)

The microTargeting™ Guideline 4000 5.0 System is intended to record and stimulate electrophysiological activity, as well as aid in the accurate placement of electrodes and other instruments.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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3

Image /page/3/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo features a stylized image of a neuron on the left, followed by the letters "FHC" in a bold, sans-serif font. Below the letters, the tagline "Neural microTargeting™ Worldwide" is written in a smaller font.

SPECIAL 510(k) SUMMARY

    1. Submitter's name, address, telephone number, a contact person, and the date the summary was prepared:
      FHC, Inc. 1201 Main Street Bowdoin, ME-04287

Tel: 207-666-5651 Fax: 207-666-8292

Contact: Kelly Moeykens Date:11/01/18

2. Name(s) of the Device:

Proprietary/Trade Name:microtargeting™ Guideline 4000™ 5.0 System
Common Name:Guideline 5 or GL5 or Guideline 4000™ 5.0TM or MT-LPP
or Intraoperative neurophysiological recording and
stimulating device
Classification Name:Depth Electrode
Regulation #21 CFR 882.1330
Regulatory Class:II
Product Code:GZL

3. Legally Marked Predicate Device to which the submitter claims substantial equivalence:

The microtargeting™ Guideline 4000™ 5.0 System is substantially equivalent to FHC, Inc.'s microTargeting" Guideline 4000 (K071364); decision date: July 25th 2007, product code: GZL.

FHC Corporate & Manufacturing 1201 Main Street Bowdoin, ME 04287-7302 USA www.fh-co.com

Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl Bucharest 020281 Sector 2 Romania

4

Image /page/4/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo features a stylized blue neuron graphic on the left, followed by the large, blue letters "FHC". Below the letters is the text "Neural microTargeting™ Worldwide" in a smaller font. The overall design is clean and professional, conveying a sense of scientific expertise and global reach.

4. Description of device:

The microtargeting™ Guideline 4000™ 5.0 System is an electrophysiological recording and stimulation system designed primarily for functional neurosurgery procedures.

The microtargeting™ Guideline 4000™ 5.0 System provides:

  • . High quality and research-grade recordings on both microelectrodes and macroelectrodes, including low-frequency signals on externalized DBS leads
  • . Improved signal quality
  • Decreased Noise susceptibility
  • Improved user experience with redesigned software
  • . New intraoperative data analysis options
  • Updated user interface to support touch screens and multiple high-resolution monitors

Additionally, Guideline 5 interface provides unprecedented simultaneous constant-current and constant-voltage stimulation capabilities that include multiple weighted sources and return paths as well as complex and arbitrary stimulation waveforms. Together, these capabilities result in the output of advanced stimulation protocols, including current steering. The software provides an intuitive patient management system, as well as advanced visualization and analysis methods for both single-unit recording and low-frequency signals (LFP, SEEG etc.).

The Guideline 5 offers neurosurgical teams a powerful microelectrode recording/stimulating system in a compact, streamlined package. It offers fully integrated stimulation and impedance check capabilities on all channels, in addition to one-click recall of user preferences and side-byside review of all recorded snapshots.

As shown below, a fully configured system consists of a Core Module, a notebook PC, an 8channel UE interface unit, a remote, an optional second 8-channel LF interface and an optional synchronization unit.

FHC Corporate & Manufacturing 1201 Main Street Bowdoin. ME 04287-7302 USA www.fh-co.com

Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl Bucharest 020281 Sector 2 Romania

5

FHC
UE Interface
Optional LF Interface
Optional Sync Unit
Bif Burdoch
IntraOp
Guideline 5
Core module and Notebook PC & external speaker
remote

Figure 1 : A fully configured Guideline 5 system.

Individual components which comprise the Guideline 5 system are listed in the table below:

| Component Name | Catalog
Number | Description | Classification |
|----------------------------------------|-------------------|---------------------------------------------------------------------------------------------------------------|--------------------|
| Main Processing Unit | C0215 | Guideline 5 Main Unit | Core Component |
| Guideline PC | C0216 | Guideline 5 Notebook | Core Component |
| Ethernet Cable | C0234 | Ethernet Cable | Core Component |
| UE Interface | C0219 | Microelectrode head-stage | Core Component |
| LF Interface | C0220 | Low Frequency Signal head-stage | Accessory |
| Software | C0217 | Guideline 5 Software Application | Core Component |
| Secondary Interface
Processing Card | C0218 | Interface Processing Card (factory or field installed) | Variant (internal) |
| Interface Digital Cable | C0221 | 3m Interface Cable | Core Component |
| Motor | C0235 | microTargeting Power Assist Unit
(existing medical device, not within
the scope of these design inputs) | Accessory |

Table 1: List of components of Guideline 5 system
---------------------------------------------------------

FHC Corporate & Manufacturing
1201 Main Street Bowdoin, ME 04287-7302 USA www.fh-co.com

Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl Bucharest 020281 Sector 2 Romania

6

Image /page/6/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo features a stylized blue neuron graphic on the left, followed by the letters "FHC" in a bold, sans-serif font. Below the letters, the tagline "Neural microTargeting™ Worldwide" is written in a smaller font.

| mT Controller Card | C0223 | Integrated microTargeting
Controller | Variant (internal) |
|----------------------|-------|-----------------------------------------|--------------------|
| Remote Control | C0222 | Guideline 5 Remote Control | Core Component |
| Breakout Box | C0224 | Synchronization Unit | Accessory |
| HD Digital Cable | C0225 | 1m Synchronization Unit Cable | Accessory |
| 3m Patient Lead | C0230 | 3m UE Cable | Consumable |
| 1.5m Patient Lead | C0231 | 1.5m UE Cable | Consumable |
| Interface pole mount | C0233 | Interface Pole Mounting Bracket | Accessory |
| Speaker | C0237 | High Performance Speaker | Core Component |

The Guideline 5 has full featured multi-source stimulation capabilities. Stimulation modes of constant voltage or constant current mode are available with a compliance voltage of ±14V. The UE Interface is capable of microstimulation (±100µA max) through the microelectrode as well as macrostimulation (±10mA max) through the macro-contact. During stimulation, the voltage applied to the electrode is monitored and displayed constantly. The LF provides macro-stimulation. Every channel has its own stimulation circuit, allowing the Guideline 5 to perform the complex simultaneous multi-channel, multireturn stimulation protocols required for current shaping and steering. Channels not involved in the stimulation continue to record activity while an adaptive suppressor minimizes stimulus artifacts.

Integrated Impedance Check functionality for microelectrodes, macro-contacts and LF electrodes can be performed easily for monitoring the state of all connected electrodes. Measurement frequency and duration are user adjustable. The low measurement current of 1μApp minimizes any effect of the measurement on microelectrode properties. Simultaneous measurement of all channels provides quicker results. An automated power on self-test verifies proper operation and calibration of all stimulation and impedance check circuitry prior to every use of the Guideline 5 system.

The Guideline 5 is capable of recording any or all activity on an event-by-event basis or continuously. Recorded waveforms can be reviewed and analyzed intraoperatively or post-operatively. Sample Matlab™ scripts provided allow for more advanced analyses of electrode and auxiliary data suitable for research applications.

5. Statement of Intended Use:

The microtargeting™ Guideline 4000™ 5.0 System is intended to be used by a neurosurgeon, neurologist or clinical neurophysiologist to accurately position depth electrodes during functional neurosurgical procedures. In addition, when external devices such as EMGs or accelerometers are connected to the Guideline 4000™ 5.0, the system is capable of displaying and recording the activity from these external devices. The Guideline 4000™ 5.0 is also intended to be used in functional neurosurgical procedures for physiological mapping of the brain and nervous system; thereby aiding in the accurate placement of electrodes or other instruments.

Statement of Indications for Use: The Guideline 4000™ 5.0 is intended to record and stimulate electrophysiological activity, as well as aid in the accurate placement of electrodes and other instruments.

    1. Comparison of Technological Characteristics to Predicate Device:

7

The technological characteristics of the Guideline 4000™ 5.0 are the same as those in the predicate device. There is no new technology, materials or method of manufacture introduced. A summary of similarities in the specifications between the Guideline 4000™ 5.0 and its predecessor is provided below.

ComponentSectionFeatureGuideline 4000Guideline 4000™ 5.0
Signal
AmplifierSignal
ConditionerGain
High Pass/Low
Pass Filters28.3 - 3764x
(Analog)
Continuous; 0-
1,000/3,000-
20,000UE: 5.9 - 214x (+3x
optional), LF:
1,2,4,6,12,24x (Analog)
Continuous: 0-10,000Hz
Stimulation
circuitIsolatedYesYes
Stimulator TypeConstant
Current &
Voltage
SettingsSame
Settings controlcontrolled via
hardware and
software.
Activation still
only a hardware
function.Same
Waveform
Displayed?NoSame
Waveform TypeArbitrary,
Unipolar or
Bipolar Square
WaveSame
Stimulation
ModesMicroYesSame
MacroYesSame
Stimulus
ControlsMax Micro Stim
Amplitude100 uASame
Max Macro Stim
Amplitude10 mA10mA
FrequencyUp to 300 HzUp to 300Hz
Pulse Duration.05, .1, .2, .5, 1
msContinuous up to 3.0
mS (50% duty cycle
max)
Train DurationManual, 0.5 to
20 sManual, 0.5s - 60 s
Adaptive
Noise FilterAvailableYesSame
Data
AcquisitionPipelineUSB 2.0TCP/IP
Pre-ampBuilt in gain28.3 xN/A
Max Distance
to patient3 mSame
Max # of Channels108(16 with two
interfaces)
Impedance
CheckActivation controlled bySoftwareSame
Waveform usedSinewaveComposite Waveform,
Sine @ 200Hz and sine @ 1000Hz
Measurement Range10kOhms to
10MOhms100 Ohms - 5MOhms
Resolution2 significant
digitsSame
RemoteAvailableYesSame
Stimulation ActivationYesSame
Stimulus Amplitude
SelectorYesSame
MicrophoneYesSame
Impedance Check
ActivationYesSame
Action
IndicatorsGeneral FaultVisual AlarmSame
Stimulation ErrorVisual and Audio
AlarmSame
Stimulation
ActivatedVisual and Audio
AlarmSame
Impedance
OverageVisual AlarmSame
Audio AmpSourceUn-conditioned
SignalNoYes
Conditioned SignalYesYes
AudioBaseline
SuppressorYesSame
Bass ControlYesSame
Treble ControlYesSame
Graphic EqualizerNoSame
VolumeHeadphone
ControlNo, not
applicableYes
Speaker ControlYesSame
System MuteYesSame
InputsMicrophoneYesSame
OutputsHeadphone
SpeakersNoYes
Aux Input
UnitMax number of
channels4 analog, 2
digital2 analog, 2 high speed
digital, 2 byte digital
Computer
SystemCPU SpeedAt least 1.0 GHz2 GHz dual coreIntel, Core I7 (min)
RAMAt least 256 MB2 GB8GB
MonitorAt least 17" wwide screen 17"
UXGA15.6" diag, 1920x1080
resolution
TouchscreenYes (option)NoMultipoint
CD-RWYesYesNo
Storage DriveYes, SizeNoYes (1TB min)
Recording
SoftwareData TagsVoice TagsYesSame
Custom Text TagsYesSame
Preloaded Test
TagsNoSame
Drive DepthYesSame
Waveform
DisplayFast (Spike) -
Allows user to
focus on single
event if needed
Slow (Continuous)
  • default
    waveform | Yes | Same |
    | | | displayed for each
    channel. | Yes | Same |
    | | | Spectrogram | No | Yes |
    | | Spike
    Discrimination | Window | Yes | Same |
    | | | Level | Yes | Same |

Table 2: Similarities between Guideline 4000 and Guideline 4000™ 5.0

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Image /page/8/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo features a stylized blue neuron graphic on the left, followed by the letters "FHC" in a bold, sans-serif blue font. Below the letters, the tagline "Neural microTargeting™ Worldwide" is written in a smaller, lighter font.

Tel: +1-207-666-8190 US & Canada: 800-326-2905
Fax: +1-207-666-8292 FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3ª Fl Bucharest 020281 Sector 2 Romania

9

Image /page/9/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo consists of a stylized image of a brain cell on the left, followed by the letters "FHC" in a large, sans-serif font. Below the letters, the tagline "Neural microTargeting™ Worldwide" is written in a smaller font.

Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl Bucharest 020281 Sector 2 Romania

10

Image /page/10/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo consists of a stylized image of a brain cell on the left, followed by the letters "FHC" in a bold, sans-serif font. Below the letters, the tagline "Neural microTargeting™ Worldwide" is written in a smaller font.

Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl
Bucharest 020281 Sector 2 Romania

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Image /page/11/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo features a stylized image of a neuron on the left, followed by the letters "FHC" in a bold, sans-serif font. Below the letters, the tagline "Neural microTargeting™ Worldwide" is written in a smaller font. The overall design is clean and professional, conveying a sense of expertise and innovation in the field of neuroscience.


Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl Bucharest 020281 Sector 2 Romania

FHC Latin America Carrera 43 A # 1sur 31 Ed. BBVA oficina 401

Medellín-Colombia

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Image /page/12/Picture/0 description: The image shows the logo for FHC, a company specializing in neural microtargeting worldwide. The logo features a stylized blue brain cell graphic to the left of the letters "FHC" in a bold, sans-serif font, also in blue. Below the letters is the tagline "Neural microTargeting™ Worldwide" in a smaller, lighter font.

Tel: +1-207-666-8190 US & Canada: 800-326-2905 Fax: +1-207-666-8292

FHC Europe (TERMOBIT PROD srl) 42A Barbu Vacarescu Str, 3rd Fl Bucharest 020281 Sector 2 Romania

FHC Latin America Carrera 43 A # 1sur 31 Ed. BBVA oficina 401

Medellín-Colombia

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Image /page/13/Figure/0 description: The image shows a table with the words "Waveform analysis", "Template Matching", "Yes", and "No" written in it. The words "Waveform analysis" and "Template Matching" are in the first row, while "Yes" and "No" are in the second row. The image also contains the logo for Neural microTargeting.

7. Nonclinical performance Data:

Performance data of the microTargeting™ Guideline 4000™ 5.0 System is documented in the verification and validation reports. Electrical Safety Test, Mechanical Integrity test, Macrostimulation test, Microstimulation test and Software regression test results show the system to be the equivalent to the predicate system.

TestTest Method SummaryResults
Electrical
SafetyElectrical Safety consistent
with IEC 60601 (Class 1 ME
Equipment)
Internal Testing based on IEC
60601 protocols.
60601-1 Electrical Safety
Testing Performed Externally
by 3rd Party entity.Both internally and externally
performed electrical safety testing on
subject device per standard IEC
60601 passed the acceptance criteria
necessary for establishing basic
safety. The subject and predicate
device were both exposed to the
same 60601-1 electrical safety testing
therefore a substantive equivalence is
established.
Mechanical
IntegrityMechanical Strength and
Integrity testing consistent
with standard IEC 60601
Internal Testing based on IEC
60601 protocols.
60601-1 Mechanical Strength
Testing Performed Externally
by 3rd Party entity.Both internally and externally
performed mechanical strength
testing on subject device per
standard IEC 60601 passed the
acceptance criteria necessary for
establishing basic safety. The subject
and predicate device were both
exposed to the same 60601-1
mechanical strength testing therefore
a substantive equivalence is
established.
Macro
StimulationThe test method employed is
an internally generated
protocol in which the subject
device is assessed on three
key parameters relevant to the
safe and effective delivery of
therapeutic electrical stimulus.
These parameters include:
-Accurate output frequency
-Accurate pulse duration
-Accurate stimulus amplitudeThe subject devices met the
acceptance criteria necessary for
establishing accuracy of stimulator
outputs to within ±10% of the User
Interface set point for frequency,
pulse duration, and amplitude. Given
the predicate device provides the
same accuracy, a substantive
equivalence is established.
Each parameter is adjusted via
the software user interface.
Each parameter is then
measured using a NIST
traceable oscilloscope with the
subject device's output
terminated with precision
resistive loads which act as
microelectrode analogs.
Micro
StimulationThe test protocol used for
Macro Stimulation mode also
applies to Micro stimulation
with the exception of the
latter outputs an order of
magnitude lower stimulus
amplitude.The subject devices met the
acceptance criteria necessary for
establishing accuracy of stimulator
outputs to within ±10% of the User
Interface set point for frequency,
pulse duration, and amplitude. Given
the predicate device provides the
same accuracy, a substantive
equivalence is established.
Software
regression
testingThe internally created
software regression test
protocol is based on the
workflow established in the
Usability specification of the
predicate device. It is
performed iteratively at each
software release per IEC

All major and minor software
functions were tested
iteratively prior to each
release of a new software
revision. Additionally, bugs
fixed since the previous round
of regression testing were
assessed for effectiveness and
risk. | All major areas of software
functionality were confirmed for the
subject device. No remaining bugs
had a risk level of greater than
Acceptable as defined by risk
management plan.
Over the course of its life-cycle, the
predicate device received similar
treatment with respect to bug fixes,
bug risk acceptance, software
releases, and regression testing. As
such, substantive equivalence is
established. |

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8. Substantial Equivalence statement:

The microTargeting™ Guideline 4000™ 5.0 System is substantially equivalent in design, construction, materials, intended use and performance characteristics to its predicative devices, FHC, Inc.'s microTargeting "Guideline 4000 System (K071364), which was cleared under 510(k) K071364, July 25th, 2007.