K Number
K190887
Device Name
Leksell Vantage Stereotactic System
Date Cleared
2019-08-01

(119 days)

Product Code
Regulation Number
882.4560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Intended Purpose of Leksell® Vantage™ Stereotactic System is target localization and fixation of the patient head in a coordinate system in order to perform stereotactic neurosurgical procedures, for example; deep brain stimulation, lesioning, biopsies, targeted injections, aspirations and minimal invasive tumor treatments.
Device Description
The Leksell® Vantage™ Stereotactic System is a device used for minimally invasive neurosurgical procedures. It enables coordinate referencing and fixation of the patient's skull and brain during image acquisition and treatment. The coordinate referencing enables target localization and accurate stereotactic treatment of brain targets; for example for aspirations and biopsies, electrode placements, injections of cells & drugs, heamatoma evacuations as well as lesioning using a number of methodologies. The system consists of a head frame that is fixated to the patient skull by minimally invasive disposable fixation pins and a number of accessories for frame application and imaging as well as a stereotactic arc and operating room accessories for the sterile surgical procedure. The system is based on the established Leksell center-of-arc principle, which allows guidance of compatible interventional instruments at any trajectory angle to the brain target. Compatible interventional instruments are based on the Leksell principle of an active working length of 190 mm (as the arc radius) and use the correct mechanical interfacing of the Arc instrument stop and guide holders. Various instruments, such as biopsy needles, cannulas, and electrodes can be used with the system to perform biopsies, hematoma evacuation and injections of radioactive nuclides and cytostatic agents, puncture of cysts, positioning electrodes for stimulation/ recording or lesioning and stereotactic endoscope guidance.
More Information

No
The description focuses on mechanical components and established stereotactic principles for target localization and fixation. There is no mention of AI or ML in the device description, intended use, or performance studies.

No.
The device itself is a stereotactic system for target localization and fixation during neurosurgical procedures, not for providing therapy directly. It enables therapeutic procedures like deep brain stimulation or tumor treatments, but it is a navigational and fixation tool.

No

This device is used for target localization, fixation, and guidance during neurosurgical procedures, but it does not perform a diagnostic function of identifying or characterizing a disease or condition. It is a surgical tool.

No

The device description explicitly states the system consists of a head frame, fixation pins, accessories for frame application and imaging, a stereotactic arc, and operating room accessories, all of which are hardware components.

Based on the provided information, the Leksell® Vantage™ Stereotactic System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use clearly states "target localization and fixation of the patient head in a coordinate system in order to perform stereotactic neurosurgical procedures". This describes a device used on the patient for surgical guidance and intervention, not a device used to examine specimens from the patient outside the body.
  • Device Description: The description details a system for fixing the patient's skull and brain, enabling coordinate referencing for surgical procedures. It mentions instruments like biopsy needles and cannulas, but these are used in vivo (within the living body) for procedures, not for in vitro (in glass/outside the body) diagnostic testing.
  • Lack of IVD Characteristics: The description does not mention any components or functions related to analyzing biological samples (blood, tissue, etc.) or performing diagnostic tests on them.

IVD devices are specifically designed to examine specimens derived from the human body to provide information for diagnostic purposes. The Leksell® Vantage™ Stereotactic System is a surgical guidance and fixation system used directly on the patient during neurosurgical procedures.

N/A

Intended Use / Indications for Use

The Intended Purpose of Leksell® Vantage™ Stereotactic System is target localization and fixation of the patient head in a coordinate system in order to perform stereotactic neurosurgical procedures, for example; deep brain stimulation, lesioning, biopsies, targeted injections, aspirations and minimal invasive tumor treatments.

Product codes

HAW

Device Description

The Leksell® Vantage™ Stereotactic System is a device used for minimally invasive neurosurgical procedures. It enables coordinate referencing and fixation of the patient's skull and brain during image acquisition and treatment. The coordinate referencing enables target localization and accurate stereotactic treatment of brain targets; for example for aspirations and biopsies, electrode placements, injections of cells & drugs, heamatoma evacuations as well as lesioning using a number of methodologies.

The system consists of a head frame that is fixated to the patient skull by minimally invasive disposable fixation pins and a number of accessories for frame application and imaging as well as a stereotactic arc and operating room accessories for the sterile surgical procedure.

The system is based on the established Leksell center-of-arc principle, which allows guidance of compatible interventional instruments at any trajectory angle to the brain target. Compatible interventional instruments are based on the Leksell principle of an active working length of 190 mm (as the arc radius) and use the correct mechanical interfacing of the Arc instrument stop and guide holders. Various instruments, such as biopsy needles, cannulas, and electrodes can be used with the system to perform biopsies, hematoma evacuation and injections of radioactive nuclides and cytostatic agents, puncture of cysts, positioning electrodes for stimulation/ recording or lesioning and stereotactic endoscope guidance.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CT and MR

Anatomical Site

Brain

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Used for the same clinical interventions and/or treatments
Intended for use by the same health care professionals

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)

Clinical testing was deemed not required to demonstrate substantial equivalence with the predicate devices.

The verification activities have covered requirements at system and subsystem level to show that the design output meet the design input.

Design and usability validation of the system has been performed by competent and professionally qualified personnel to ensure that the product fulfils the intended use and user needs. The design and usability validation was also made to ensure that the risk control measures associated with functions related to safety (FRS) was effective.

Results from verification and validation testing demonstrates that conformance to applicable technical requirement specifications and user needs have been met showing that the system is safe to use and is substantially equivalent to the predicate devices.

Test: Sterilization
Test Method Summary: Sterility validation (EtO) according to ISO 11135:2014 was performed to demonstrate that the device have a sterility assumed level (SAL) of 10-6. The tests were performed on the predicate device Leksell® Vantage™ Stereotactic System (K171123).
Results: Results met pre-established acceptance criteria, demonstrating equivalence to the predicate device in terms of sterility.

Test: MR testing
Test Method Summary: The device was subjected to compliance testing to applicable consensus safety standards, such as: ASTM F2052; ASTM F2119; ASTM F2182, ASTM F2213 and ASTM F2503, and FDA guidance regarding safety and compatibility in the MR environment.
Results: The result demonstrates that the device is compliant to the FDA guidance and applicable consensus standards. This compliance demonstrates substantial equivalence.

Test: Accuracy
Test Method Summary: Accuracy was tested on different levels of the subject device: - Total system accuracy from imaging to treatment. - Total mechanical accuracy of the system - Mechanical accuracy of each component - Handling accuracy of various steps like repeated mounting of parts to each other and scale setting accuracy. - Displacement from load of head when fixed in the frame.
Results: All test cases were passed, demonstrating that the overall system accuracy of the Vantage system when used with the CT accessories is substantial equivalent to the predicate device.

Test: Design and Usability validation
Test Method Summary: Design and usability validation of the system has been performed by trained competent and professionally qualified personnel to ensure that the product fulfils the intended use and user needs.
Results: No unacceptable human factor risks were identified. Residual risks have been weighted against the benefit of the product and are deemed acceptable demonstrating that the Leksell® Vantage™ Stereotactic System used with the CT accessories is substantial equivalent to the predicate device.

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

Mechanical accuracy 0,9 mm

Predicate Device(s)

K171123, K080355

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.4560 Stereotaxic instrument.

(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(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). 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. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

August 1, 2019

Elekta Instrument AB Alf Laurell Regulatory Affairs Engineer Kungstensgatan 18 Stockholm, 10393 SE

Re: K190887

Trade/Device Name: Leksell Vantage Stereotactic System Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: HAW Dated: July 1, 2019 Received: July 3, 2019

Dear Alf Laurell:

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

1

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,

for Matthew Krueger Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K190887

Device Name

Leksell® Vantage™ Stereotactic System

Indications for Use (Describe)

The Intended Purpose of Leksell® Vantage™ Stereotactic System is target localization and fixation of the patient head in a coordinate system in order to perform stereotactic neurosurgical procedures, for example; deep brain stimulation, lesioning, biopsies, targeted injections, aspirations and minimal invasive tumor treatments.

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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Dokumentnamn/Name of document Traditional 510(k)

IssuerRef nr/Dok nr/Ref no/Doc noEdition
Alf Laurell----
RegardingDirectory
CT accessories for Leksell Vantage Stereotactic System--

510(k) Summary

As Required by 21 CFR 807.92(c) 510 (k) Summary

1. Subscribers Name & Address

Elekta Instrument AB Kungstensgatan 18, P.O. Box 7593 SE-103 93 Stockholm, Sweden Tel: (011) 46 8 587 254 00 Fax: (011) 46 8 587 255 00 Official Correspondent: Mats Premfors, QA Manager

Date summary prepared: 2019-07-27

2. Trade Name

Leksell® Vantage™ Stereotactic System

3. Common Name

Stereotaxic instrument

Device Classification 4.

Trade NameProduct CodeClassRegulation Number
Leksell® Vantage™ Stereotactic SystemHAWII21 CFR 882.4560

Classification Panel 5.

Neurology

Predicate Device Identification 6.

Legally marketed devices to which equivalence is being claimed510(k) #
Leksell Stereotactic SystemK080355
Leksell® Vantage™ Stereotactic System (Primary)K171123

7. Other relevant submissions

N/A, no other relevant submissions

8. Device Description

The Leksell® Vantage™ Stereotactic System is a device used for minimally invasive neurosurgical procedures. It enables coordinate referencing and fixation of the patient's skull

4

Dokumentnamn/Name of documentTraditional 510(k)
---------------------------------------------------

Traditional 510(k)

IssuerAlf Laurell
Ref nr/Dok nr/Ref no/Doc no--
Edition--
RegardingCT accessories for Leksell Vantage Stereotactic System
Directory--

and brain during image acquisition and treatment. The coordinate referencing enables target localization and accurate stereotactic treatment of brain targets; for example for aspirations and biopsies, electrode placements, injections of cells & drugs, heamatoma evacuations as well as lesioning using a number of methodologies.

The system consists of a head frame that is fixated to the patient skull by minimally invasive disposable fixation pins and a number of accessories for frame application and imaging as well as a stereotactic arc and operating room accessories for the sterile surgical procedure.

The system is based on the established Leksell center-of-arc principle, which allows guidance of compatible interventional instruments at any trajectory angle to the brain target. Compatible interventional instruments are based on the Leksell principle of an active working length of 190 mm (as the arc radius) and use the correct mechanical interfacing of the Arc instrument stop and guide holders. Various instruments, such as biopsy needles, cannulas, and electrodes can be used with the system to perform biopsies, hematoma evacuation and injections of radioactive nuclides and cytostatic agents, puncture of cysts, positioning electrodes for stimulation/ recording or lesioning and stereotactic endoscope guidance.

9. Summary of clinical testinq

Clinical testing was deemed not required to demonstrate substantial equivalence with the predicate devices.

10. Summary of Non Clinical and Performance testing

The verification activities have covered requirements at system and subsystem level to show that the design output meet the design input.

Design and usability validation of the system has been performed by competent and professionally qualified personnel to ensure that the product fulfils the intended use and user needs. The design and usability validation was also made to ensure that the risk control measures associated with functions related to safety (FRS) was effective.

Results from verification and validation testing demonstrates that conformance to applicable technical requirement specifications and user needs have been met showing that the system is safe to use and is substantially equivalent to the predicate devices.

Testing is summarized in the table below.

5

Dokumentnamn/Name of document Traditional 510(k)

IssuerAlf Laurell
Ref nr/Dok nr/Ref no/Doc no--
Edition--
RegardingCT accessories for Leksell Vantage Stereotactic System
Directory--
TestTest Method SummaryResults
SterilizationSterility validation (EtO) according to
ISO 11135:2014 was performed to
demonstrate that the device have a
sterility assumed level (SAL) of 10-6.

The tests were performed on the
predicate device Leksell® Vantage™
Stereotactic System (K171123). | Results met pre-
established acceptance
criteria, demonstrating
equivalence to the
predicate device in terms
of sterility. |
| MR testing | The device was subjected to
compliance testing to applicable
consensus safety standards, such as:
ASTM F2052; ASTM F2119; ASTM
F2182, ASTM F2213 and ASTM F2503,
and FDA guidance regarding safety and
compatibility in the MR environment. | The result demonstrates
that the device is
compliant to the FDA
guidance and applicable
consensus standards. This
compliance demonstrates
substantial equivalence. |
| Accuracy | Accuracy was tested on different
levels of the subject device:

  • Total system accuracy from
    imaging to treatment.
  • Total mechanical accuracy of
    the system
  • Mechanical accuracy of each
    component
  • Handling accuracy of various
    steps like repeated mounting
    of parts to each other and
    scale setting accuracy.
  • Displacement from load of
    head when fixed in the frame. | All test cases were passed,
    demonstrating that the
    overall system accuracy of
    the Vantage system when
    used with the CT
    accessories is substantial
    equivalent to the predicate
    device. |
    | Design and Usability
    validation | Design and usability validation of the
    system has been performed by trained
    competent and professionally qualified
    personnel to ensure that the product
    fulfils the intended use and user
    needs. | No unacceptable human
    factor risks were identified.
    Residual risks have
    been weighted against the
    benefit of the product and
    are deemed acceptable
    demonstrating that the
    Leksell® Vantage™
    Stereotactic System used |
    | | | with the CT accessories is
    substantial equivalent to
    the predicate device. |

6

Dokumentnamn/Name of document Traditional 510/lz)

Traditional 510(k)

IssuerAlf Laurell
Ref nr/Dok nr/Ref no/Doc no--
Edition--
RegardingCT accessories for Leksell Vantage Stereotactic System
Directory--

11. Intended Use

The Intended Purpose of Leksell® Vantage™ Stereotactic System is target localization and fixation of the patient head in a coordinate system in order to perform stereotactic neurosurgical procedures, for example; deep brain stimulation, lesioning, biopsies, targeted injections, aspirations and minimal invasive tumor treatments.

12. Technological Characteristics

The CT accessories of Leksell® Vantage™ Stereotactic System has equivalent technological characteristics as its predicate device (K080355), for further details see the table below.

Substantial Equivalence 13.

The intended use, the basic functionality and the fundamental technological characteristics of the device Leksell® Vantage™ Stereotactic System remain unchanged with the introduction of the CT accessories and the Leksell Vantage Head Frame Holder.

Leksell® Vantage™ Stereotactic as compared to the predicate devices has:

  • Same mechanical accuracy
  • . Same coordinate system
  • Same Center of Arc Principle
  • Intended for localizing the same intracranial anatomical targets
  • Used for the same clinical interventions and/or treatments
  • Intended for use by the same health care professionals

In addition, the risk evaluation regarding endotoxin testing in routine production for product FirmFix™ 1 -5 has been updated.

The conclusion from verification and validation is that the Leksell® Vantage™ Stereotactic System is substantial equivalent to its predicate devices.

The table below shows a comparison between the Leksell® Vantage™ Stereotactic System and the predicate devices.

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Dokumentnamn/Name of document Traditional 510(k)

IssuerAlf Laurell
Ref nr/Dok nr/Ref no/Doc no--
Edition--
RegardingCT accessories for Leksell Vantage Stereotactic System
Directory--
Subject DevicePredicate Device (K080355)Predicate Device (K171123)
Device NameLeksell® Vantage™ Stereotactic SystemLeksell Stereotactic System® (K080355)Leksell® Vantage™ Stereotactic System (K171123)
Regulation Number21 CFR 882.456021 CFR 882.456021 CFR 882.4560
Product CodeHAWHAWHAW
Product ClassIIIIII
DescriptionHead Frame and semi- circular arc system used for the coordinate referencing of targets in the brain and the guidance of neurosurgical instruments to these brain targets.Head Frame and semi- circular arc system used for the coordinate referencing of targets in the brain and the guidance of neurosurgical instruments to these brain targets.Head Frame and semi- circular arc system used for the coordinate referencing of targets in the brain and the guidance of neurosurgical instruments to these brain targets.
Technical FeaturesCoordinate System: Leksell Coordinate System using Cartesian coordinatesCoordinate System: Leksell Coordinate System using Cartesian coordinatesCoordinate System: Leksell Coordinate System using Cartesian coordinates
Fixation: Head Frame applied to patient skull with four fixation pins.Fixation: Head Frame applied to patient skull with four fixation pins.Fixation: Head Frame applied to patient skull with four fixation pins.
Fixation Pins: Single use Fixation Pins and Inserts that secures the Vantage head frame to the patient skull using Leksell Vantage KeysFixation Pins: Titanium Fixation Pins, Reusable Fixation Pins and Disposable Inserts that secures the Leksell Coordinate Frame G to the patient skull using Instrument Screw DriversFixation Pins: Single use Fixation Pins and Inserts that secures the Vantage head frame to the patient skull using Leksell Vantage Keys
Imaging modalityCT and MRCT and MRMR
Technical characteristicsCT accessories: The Leksell Vantage CT Fiducial Box is used for referencing of the stereotactic coordinate system on the patient's anatomical CT images.CT accessories: The Open CT Indicator Box is used for referencing of the stereotactic coordinate system on the patient's anatomical CT images.CT accessories: N/A
Leksell® Vantage™ Head Frame interface:Leksell® Vantage™ Head Frame interface:Leksell® Vantage™ Head Frame interface:
Subject DevicePredicate Device
(K080355)Predicate Device
(K171123)
Leksell® Vantage™ Frame
Holder is a modified OR
adapter. In addition to
holding the Leksell®
Vantage™ Head Frame in
the operating room, the
Frame Holder is also
interfacing the CT Fiducial
box via one hole on each
side.N/ALeksell® Vantage™ OR
adapter
Principles of UseCenter of the arc
principle using an arc
radius of 190 mm.
Cartesian coordinates
applied to the brain of
the patient by the use of
a head frame fixated to
the skull.
• comprises a headframe
and arc;
• is target centered
• uses Cartesian (x,y,z)
coordinates to
triangulate target
position in frame
• utilizes fiducial markers
that can be registered
to a stereotactic brain
atlas and/or
intracranial image;
• provides support and
accessories for surgical
instruments to the
target;Center of the arc
principle using an arc
radius of 190 mm.
Cartesian coordinates
applied to the brain of
the patient by the use
of a head frame fixated
to the skull.
• comprises a
headframe and arc;
• is target centered
• uses Cartesian (x,y,z)
coordinates to
triangulate target
position in frame
• utilizes fiducial
markers that can be
registered to a
stereotactic brain
atlas and/or
intracranial image;
• provides support and
accessories for
surgical instruments
to the target;Center of the arc
principle using an arc
radius of 190 mm.
Cartesian coordinates
applied to the brain of
the patient by the use
of a head frame fixated
to the skull.
• comprises a
headframe and arc;
• is target centered
• uses Cartesian (x,y,z)
coordinates to
triangulate target
position in frame
• utilizes fiducial
markers that can be
registered to a
stereotactic brain
atlas and/or
intracranial image;
• provides support and
accessories for
surgical instruments
to the target;
MaterialInvasive components:
PEEK with Aluminum tip.Invasive components:
Aluminum or Titanium.Invasive components:
PEEK with Aluminum tip.
Head Frame:
Glass fiber reinforced
EpoxyHead Frame:
Aluminum (with glued
joints for insulation in
MRI)Head Frame:
Glass fiber reinforced
Epoxy
Subject DevicePredicate Device
(K080355)Predicate Device
(K171123)
Arc:
AluminumArc:
AluminumArc:
Aluminum
AccuracyMechanical accuracy 0,9 mmMechanical accuracy 0,9 mmMechanical accuracy 0,9 mm

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Dokumentnamn/Name of document Traditional 510(k)

IssuerAlf Laurell
Ref nr/Dok nr/Ref no/Doc no--
Edition--
RegardingCT accessories for Leksell Vantage Stereotactic System
Directory--

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Dokumentnamn/Name of document Traditional 510/k)

Traditional 510(k)

IssuerAlf Laurell
Ref nr/Dok nr/Ref no/Doc no--
Edition--
RegardingCT accessories for Leksell Vantage Stereotactic System
Directory--

Conclusion:

The conclusion is that the subject device is substantial equivalent to its predicate devices.