(113 days)
No
The summary describes a standard electrosurgical device for sealing and cutting tissue using bipolar RF energy and a mechanical blade. There is no mention of AI, ML, image processing, or any data-driven decision-making components. The performance studies focus on mechanical and electrical properties, not algorithmic performance.
Yes
The device is described as an electrosurgical instrument used in surgical procedures (e.g., general, gynecologic, urologic, vascular, thoracic) to ligate vessels, cut tissue, and perform dissection. These are therapeutic actions in a medical context.
No
The device is described as a surgical instrument for vessel ligation and tissue division, not for diagnosing medical conditions.
No
The device description clearly states it is a physical instrument ("seal and cut devices which are provided as sterile, single use devices") that uses bipolar electrical RF energy and a cutting blade, indicating it is a hardware 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 medical devices used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information for diagnosis, monitoring, or screening.
- Device Function: The Caiman Seal and Cut Technology is a surgical instrument used during surgical procedures to seal and cut blood vessels and tissue within the body. It directly interacts with the patient's anatomy.
- Intended Use: The intended use clearly describes its application in general and gynecologic surgical procedures for vessel ligation, tissue grasping, and dissection. This is an in vivo (within the living body) application, not in vitro (in glass or outside the living body).
- Device Description: The description reinforces its use as a surgical tool for vessel sealing, blunt dissection, grasping, and dividing tissue during open and laparoscopic procedures.
The device's function and intended use are entirely focused on surgical intervention within the body, which is the opposite of an In Vitro Diagnostic device.
N/A
Intended Use / Indications for Use
Caiman Seal and Cut Technology consists of dedicated bipolar electrosurgical instruments intended for use in general surgery and gynecologic surgical procedures where ligation of vessels is desired. The instruments create a seal by the application of bipolar electrosurgical RF energy (coagulation) to vascular structure (vessels) interposed between the jaws of the device. A cutting blade is actuated for the division of tissue.
Instruments 12.5 cm, 17 cm, and 24 cm in length are indicated for open procedures and instruments 36 cm and 44 cm in length are indicated for laparoscopic procedures. The include general surgical procedures, (including urologic, vascular, thoracic, and thoracoscopic), and gynecological procedures where ligation of vessels is performed. These procedures include: vaginal hysterectomies, Nissen fundoplication, adhesiolysis, bowel resection, and oophorectomy etc., or any procedure where vessel ligation (seal and cut), tissue grasping, and dissection is performed. The devices up to and including 7mm and bundles as large as will fit in the jaws of the instrument.
Caiman Seal and Cut Technology has not be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the system for these procedures.
Product codes (comma separated list FDA assigned to the subject device)
GEI
Device Description
The Caiman® 5 Maryland instruments are seal and cut devices which are provided as sterile, single use devices. These devices are capable of vessel sealing, blunt dissection, grasping and dividing tissue enclosed within its jaws during open and laparoscopic procedures. The devices are designed to be used with the dedicated Lektrafuse RF Generator and create vesselligation by the application of bipolar electrical RF energy and tissue division with a cutting blade.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
vessels
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Not Found
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)
Design verification studies were performed:
- Tissue-related performance test for arteries: Provide evidence of several technical requirements and a user need. Intended to verify the tissue-related requirements and demonstrate the life cycle for typical applications. Result: Pass.
- Burst Pressure testing for veins: Generate burst pressure data for veins of all relevant diameters. Result: Pass.
- Jaw Tissue stress test: Demonstrate that under load up to and beyond the load limit, the durability of the Maryland instruments is comparable to that of the predicate devices. Result: Pass.
- Validation of usability: Validate user needs related to usability through a user survey in order to document the usability, and thus to ensure that the product under investigation meets the requirements for usability in accordance with the applicable standards. Result: Pass.
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.
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.
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
§ 878.4400 Electrosurgical cutting and coagulation device and accessories.
(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.
0
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 & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. Underneath the square are the words "U.S. FOOD & DRUG ADMINISTRATION" in a smaller font.
March 12, 2019
Aesculap, Inc. Ms. Jessica Stigliano Regulatory Affairs Associate 3773 Corporate Parkway Center Valley, Pennsylvania 18034
Re: K183180
Trade/Device Name: Caiman 5 Maryland Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: February 8, 2019 Received: February 9, 2019
Dear Ms. Stigliano:
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 medical devices and radiation-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,
Image /page/1/Picture/6 description: The image shows a digital signature. The signature is by Long H. Chen -S. The date of the signature is March 12, 2019, and the time is 13:03:43 -04'00'.
for
Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known) K183180
Device Name Caiman 5 Maryland
Indications for Use (Describe)
Caiman Seal and Cut Technology consists of dedicated bipolar electrosurgical instruments intended for use in general surgery and gynecologic surgical procedures where ligation of vessels is desired. The instruments create a seal by the application of bipolar electrosurgical RF energy (coagulation) to vascular structure (vessels) interposed between the jaws of the device. A cutting blade is actuated for the division of tissue.
Instruments 12.5 cm, 17 cm, and 24 cm in length are indicated for open procedures and instruments 36 cm and 44 cm in length are indicated for laparoscopic procedures. The include general surgical procedures, (including urologic, vascular, thoracic, and thoracoscopic), and gynecological procedures where ligation of vessels is performed. These procedures include: vaginal hysterectomies, Nissen fundoplication, adhesiolysis, bowel resection, and oophorectomy etc., or any procedure where vessel ligation (seal and cut), tissue grasping, and dissection is performed. The devices up to and including 7mm and bundles as large as will fit in the jaws of the instrument.
Caiman Seal and Cut Technology has not be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the system for these procedures.
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)
PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
3
K183180
510(k) SUMMARY (as required by 21 CFR 807.92)
Caiman® 5 Maryland
March 11, 2019
| COMPANY: | Aesculap®®, Inc.
3773 Corporate Parkway
Center Valley, PA 18034
Establishment Registration Number: 2916714 |
|--------------------|---------------------------------------------------------------------------------------------------------------------|
| CONTACT: | Ms. Jessica Stigliano
610-984-9063 (phone)
610-791-6882 (fax)
jessica.stigliano@Aesculapimplants.com |
| TRADE NAME: | Caiman® 5 Maryland |
| COMMON NAME: | Electrosurgical, Cutting & Coagulation & Accessories |
| REGULATION NUMBER: | 21 CFR 878.4400 |
| PRODUCT CODE: | GEI |
| REVIEW PANEL: | General and Plastic Surgery |
PRIMARY PREDICATE
K151696 - Caiman Seal and Cut Technology
REFERENCE DEVICE
K130596 - Caiman Seal and Cut Technology K110824 - Aragon Surgical RF System - 5mm Laparoscopic Instrument
SUBSTANTIAL EQUIVALENCE
Aesculap®, Inc. believes that the Caiman® 5 Maryland is substantially equivalent to the primary predicate, Caiman® Seal and Cut Technology (K151696) and reference devices, Caiman® Seal and Cut Technology (K130596) and Aragon Surgical RF System - 5mm Laparoscopic Instrument (K110824).
DEVICE DESCRIPTION
The Caiman® 5 Maryland instruments are seal and cut devices which are provided as sterile, single use devices. These devices are capable of vessel sealing, blunt dissection, grasping and dividing tissue enclosed within its jaws during open and laparoscopic procedures. The devices
4
K 183180
are designed to be used with the dedicated Lektrafuse RF Generator and create vesselligation by the application of bipolar electrical RF energy and tissue division with a cutting blade.
INDICATIONS FOR USE
Instruments 12.5 cm, 17 cm, and 24 cm in length are indicated for open procedures and instruments 36 cm and 44 cm in length are indicated for laparoscopic procedures. The indications for use include general surgical procedures, (including urologic, vascular, thoracic, and thoracoscopic), and gynecological procedures where ligation and division of vessels is performed. These procedures include: vaginal hysterectomies, Nissen fundoplication, colectomy, adhesiolysis, bowel resection, and oophorectomy etc., or any procedure where vessel ligation (seal and cut), tissue grasping, and dissection is performed. The devices can be used on vessels up to and including 7mm and bundles as large as will fit in the jaws of the instrument.
Caiman Seal and Cut Technology has not been shown to be effective for tubal sterilization or tubal coagulation for sterilization procedures. Do not use the system for these procedures.
TECHNOLOGICAL CHARACTERISTICS (compared to Predicate(s))
The modifications made to the Caiman instruments do not affect the fundamental scientific technology. The modifications made to these devices do not raise any new issues of safety and effectiveness, as confirmed by the testing and validation activities described in the submission.
5
Attribute | Subject Device | Primary Predicate | Reference Device | Reference Device |
---|---|---|---|---|
Caiman® 5 Maryland | Caiman Seal and Cut | Caiman Seal and Cut | Aragon Surgical RF System | |
Technology (K151696) | Technology (K130596) | Caiman 5 Laparoscopic | ||
Instrument (K110824) | ||||
Indications for | Caiman Seal and Cut | Caiman Seal and Cut | Caiman Seal and Cut Technology | The Aragon Surgical Caiman 5 |
Use | Technology consists of | Technology consists of | consists of dedicated bipolar | Laparoscopic Instrument is a |
dedicated bipolar | dedicated bipolar | electrosurgical instruments | dedicated bipolar electrosurgical | |
electrosurgical instruments | electrosurgical instruments | intended for use in general surgery | instrument intended for use in | |
intended for use in general | intended for use in general | and gynecologic surgical | general surgical and gynecologic | |
surgery and gynecologic | surgery and gynecologic | procedures where ligation and | laparoscopic procedures where | |
surgical procedures where | surgical procedures where | division of vessels is desired. The | ligation and division of vessels is | |
ligation and division of vessels | ligation and division of vessels | instruments create a seal by the | desired. The instrument creates a | |
is desired. The instruments | is desired. The instruments | application of bipolar | seal by the application of bipolar | |
create a seal by the application | create a seal by the application | electrosurgical RF energy | electrosurgical RF energy to | |
of bipolar electrosurgical RF | of bipolar electrosurgical RF | (coagulation) to vascular structure | vascular structures (vessels) | |
energy (coagulation) to vascular | energy (coagulation) to vascular | (vessels) interposed between the | interposed between the jaws of | |
structure (vessels) interposed | structure (vessels) interposed | jaws of the device. A cutting blade | the device. A cutting blade is | |
between the jaws of the device. | between the jaws of the device. | is actuated for the division of | actuated for the division of tissue. | |
A cutting blade is actuated for | A cutting blade is actuated for | tissue. | Indications for use include | |
the division of tissue. | the division of tissue. | The Caiman 12 Plus (44cm) and | general laparoscopic procedures, | |
Instruments 12.5cm, 17 cm, | Instruments 24 cm in length are | the Caiman 5 are indicated for | including urologic, vascular, | |
and 24 cm in length are | indicated for open procedures | laparoscopic procedures and the | thoracic, and thoracoscopic, and | |
indicated for open procedures | and instruments 36 cm and 44 | Caiman 12 Plus (24cm) is | gynecological laparoscopic | |
and instruments 36 cm and 44 | cm in length are indicated for | indicated for open procedures. | procedures where ligation and | |
cm in length are indicated for | laparoscopic procedures. The | The indications for use include | division of vessels is performed. | |
laparoscopic procedures. The | indications for use include | general surgical procedures, | These procedures include: | |
indications for use include | general surgical procedures, | (including urologic, vascular, | laparoscopically assisted vaginal | |
general surgical procedures, | (including urologic, vascular, | thoracic, and thoracoscopic), and | hysterectomies, Nissen | |
(including urologic, vascular, | thoracic, and thoracoscopic), | gynecological procedures where | fundoplication, colectomy, | |
thoracic, and thoracoscopic), | and gynecological procedures | ligation and division of vessels is | adhesiolysis, oophorectomy etc. | |
and gynecological procedures | where ligation and division of | performed. These procedures | The Aragon Surgical Caiman 5 | |
where ligation and division of | vessels is performed. These | include: vaginal hysterectomies, | Laparoscopic Instrument can be | |
vessels is performed. These | procedures include: vaginal | Nissen fundoplication, colectomy, | used on vessels up to and | |
procedures include: vaginal | hysterectomies, Nissen | adhesiolysis, bowel resection, and | including 7mm, and tissue | |
hysterectomies, Nissen | fundoplication, colectomy, | oophorectomy etc., or any | bundles as large as will fit in the | |
fundoplication, colectomy, | adhesiolysis, bowel resection, | procedure where vessel ligation | jaws of the instrument. | |
adhesiolysis, bowel resection, | ||||
and oophorectomy etc., or any | ||||
procedure where vessel ligation | ||||
(seal and cut), tissue grasping, | ||||
and dissection is performed. | ||||
The devices can be used on | ||||
vessels up to and including | ||||
7mm and bundles as large as | ||||
will fit in the jaws of the | ||||
instrument. | ||||
Caiman Seal and Cut | ||||
Technology has not been shown | ||||
to be effective for tubal | ||||
sterilization or tubal | ||||
coagulation for sterilization | ||||
procedures. Do not use the | ||||
system for these procedures. | and oophorectomy etc., or any | |||
procedure where vessel ligation | ||||
(seal and cut), tissue grasping, | ||||
and dissection is performed. | ||||
The devices can be used on | ||||
vessels up to and including | ||||
7mm and bundles as large as | ||||
will fit in the jaws of the | ||||
instrument. | ||||
Caiman Seal and Cut | ||||
Technology has not been shown | ||||
to be effective for tubal | ||||
sterilization or tubal | ||||
coagulation for sterilization | ||||
procedures. Do not use the | ||||
system for these procedures. | (seal and cut), tissue grasping, and | |||
dissection is performed. The | ||||
devices can be used on vessels up | ||||
to and including 7mm and bundles | ||||
as large as will fit in the jaws of | ||||
the instrument. | ||||
Caiman Seal and Cut Technology | ||||
has not been shown to be effective | ||||
for tubal sterilization or tubal | ||||
coagulation for sterilization | ||||
procedures. Do not use the system | ||||
for these procedures. | The Aragon Surgical Lektrafuse | |||
RF System has not been shown to | ||||
be effective for tubal sterilization | ||||
or tubal coagulation for | ||||
sterilization procedures and | ||||
should not be used for these | ||||
procedures. | ||||
Material | ||||
Composition | Handle - molded thermoplastic | |||
Shaft - stainless steel | ||||
Insulation - polyester tube | ||||
(Caiman 5) | ||||
ETFE (Caiman 5 Articulating) | ||||
Dissection clip - PEEK | Handle - molded thermoplastic | |||
Shaft - stainless steel | ||||
Insulation - polyester tube | ||||
(Caiman 5) | ||||
EFTE (Caiman 5 Articulating) | ||||
Dissection clip - Valox HX 420 | ||||
HP | Handle - molded thermoplastic | |||
Shaft - stainless steel | ||||
Insulation - polyester tube | ||||
(Caiman 5) | ||||
Dissection clip – PEEK (Caiman |
-
| Molded thermoplastic handle,
stainless steel shaft |
| Functional Use | Grasping Ligation and
Coagulation (unchanged) | Grasping Ligation and
Coagulation | Grasping Ligation and Coagulation | Grasping Ligation and
Coagulation |
| Surgical
Approach | 125mm and 170mm – Open
360mm and 440mm –
Laparoscopic (unchanged) | 240mm - Open
360 and 440mm - Laparoscopic | Caiman 12 Plus (44cm)-
Laparoscopic
Caiman 12 Plus (24cm)- Open
Caiman 5- Laparoscopic | Laparoscopic |
| Length | 125mm
170mm
360mm
440mm | 240mm
360mm
440mm | Caiman 12 Plus- 44cm
Caiman 12 Plus- 24cm
Caiman 5- 36cm | 36cm |
| Jaw Shape | Curved | Straight | Straight | Straight |
| Diameter | 5mm (unchanged) | 5 mm | Caiman 12 Plus- 12mm | 5 mm |
6
7
Caiman 5- 5mm | ||||
---|---|---|---|---|
Articulation | 125, 170, 360, and 440mm – | |||
non-articulating | ||||
360 and 440 - articulating | 240, 360, and 440mm – no | |||
360mm - yes | Caiman 12 Plus- yes | |||
Caiman 5- no | No | |||
Number of | ||||
Electrodes | ||||
(Pairs) | 1 | 1 | Caiman 12 Plus- 2 | |
Caiman 5- 1 | 1 | |||
Electrode | ||||
Length | 21.5 cm | 2.65 cm | Caiman 12 Plus- 5cm | |
Caiman 5- 2.65cm | 2.65 cm | |||
Electrode | ||||
Width | 1.01- 1.63 mm – varies over the | |||
length of the jaw due to curve | 0.13-0.15 cm | Caiman 12 Plus- 0.25cm | ||
Caiman 5- 0.13-0.15cm | 0.13-0.15cm | |||
Electrode | ||||
Texture | Smooth with conductive (steel) | |||
and non conductive (Alumina | ||||
Titania) stop members on the | ||||
Jaws, to maintain consistent gap | ||||
between electrode surfaces. | Smooth, with PEEK stop at the | |||
distal end of the jaw and Valox | ||||
stop at the proximal end of the | ||||
jaw, to maintain consistent gap | ||||
between electrode surface. | Smooth with PEEK stops to | |||
maintain consistent gap between | ||||
electrode surfaces | Smooth with PEEK stops to | |||
maintain consistent gap between | ||||
electrode surfaces | ||||
Cable | 10ft (unchanged) | 10ft | 10ft | 10ft |
Sterile/ Single | ||||
Use | Yes (unchanged) | Yes | Yes | Yes |
8
PERFORMANCE DATA
Design verification
Test | Test Method Study | Results |
---|---|---|
Tissue-related | ||
performance test for | ||
arteries | Provide evidence of several technical requirements | |
and a user need. Intended to verify the tissue- | ||
related requirements and demonstrate the life cycle | ||
for typical applications. | Pass | |
Burst Pressure testing | ||
for veins | Generate burst pressure data for veins of all | |
relevant diameters | Pass | |
Jaw Tissue stress test | Demonstrate that under load up to and beyond | |
the load limit, the durability of the Maryland | ||
instruments is comparable to that of the | ||
predicate devices. | Pass | |
Validation of usability | Validate user needs related to usability through | |
a user survey in order to document the | ||
usability, and thus to ensure that the product | ||
under investigation meets the requirements for | ||
usability in accordance with the applicable | ||
standards | Pass |
Electrical Safe ty
The Caiman® 5 Maryland instruments conform to the following electrical safety and EMC standards:
- . IEC 60601-2-2 Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories
- IEC 60601-1-2 General requirements for basic safety and essential performance -● Collateral standard Electromagnetic compatibility - Requirements and tests
- IEC 60601-1 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
- . IEC 60601-2-18 Particular requirements for the basic safety and essential performance of endoscopic equipment
Biocompatibility
The Caiman® 5 Maryland instruments continue to confirm to ISO 10993-1, "Biological Evaluation of medical devices – Part 1: Evaluation and testing within a risk management process".
Sterilization
There have been no changes to the sterilization of the Caiman® 5 Maryland instruments since the predicate device has been cleared in K151696. The instruments continue to be provided sterile. Sterilization of the instruments continue to be in accordance with ISO 11137-2 - method 1.
9
CONCLUSION
The purpose of this 510(k) premarket notification is to gain marketing clearance for the new Caiman® 5 Maryland instruments presented in this submission. Aesculap® believes the new instruments are similar in indications, design / features, components offered, dimensional ranges, and fundamental scientific technology when compared to their predicates.