K Number
K191739
Device Name
Sterile LeadConfirm
Date Cleared
2020-01-02

(188 days)

Product Code
Regulation Number
882.1330
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Alpha Omega Disposable Sterile LeadConfirm for MER is intended to be used in neurosurgery for connecting a compatible DBS Lead to a compatible recording and stimulation device. The Alpha Omega Disposable Sterile LeadConfirm for MER is indicated for assisting Neurosurgeons, in the operating room during functional neurosurgery, to aid in the placement of a compatible DBS Lead. The Alpha Omega Disposable Sterile LeadConfirm should only be used to connect a compatible DBS Lead to a compatible recording and stimulation device.
Device Description
Alpha Omega's Sterile LeadConfirm cable and adaptor connects the DBS lead to Alpha Omega's approved physiological navigation systems for recording and stimulation system: Neuro Omega (K171581) and NeuroSmart (K172042). The purpose of the submission is to introduce the Sterile LeadConfirm Cable and Adaptor, the subject devices are sterile Hardware only. There are three types of the subject device, Alpha Omega's Sterile LeadConfirm Cables: - 1) Sterile LeadConfirm M Cable that connects to Medtronic Lead P960009 (3389, 3387) - 2) Sterile LeadConfirm B Cable that connects to Boston Scientific Lead P150031 (BSC-DB-2201, BSC-DB-2202) - 3) Sterile LeadConfirm A Cable that connects to Abbott Lead P140009 (6170/ 6171/ 6172/ 6173/ 6178/ 6170/ 6180/ 6181) In addition, there are two types of Sterile LeadConfirm Adaptors: - 1) Sterile LeadConfirm M Adaptor - 2) Sterile LeadConfirm A Adaptor AOE (Alpha Omega Engineering) stimulation with LeadConfirm cable and adaptor is identical to IPG/ test stimulator, with the following parameters: - a) Pulse shape: Square wave, Lili pulse - b) Amplitude up to 12mA - c) Duration up to 500uSec
More Information

Neuro Omega (K171581), NeuroSmart (K172042)

No
The device description and summary of performance studies indicate that the device is a sterile cable and adaptor for connecting existing devices, with no mention of AI/ML capabilities or data processing beyond basic electrical signals.

No.
The device is a cable and adaptor used to connect a DBS lead to recording and stimulation devices during neurosurgery for assistance in lead placement, not for direct therapeutic treatment itself.

No

The device is a cable and adaptor system used to connect a DBS lead to a recording and stimulation device, aiding in the placement of the DBS lead, but it does not independently diagnose. The diagnostic function is performed by the connected recording and stimulation device (Neuro Omega, NeuroSmart), to which this device only provides the connection.

No

The device description explicitly states that the subject devices are "sterile Hardware only" and describes cables and adaptors.

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

Here's why:

  • Intended Use: The intended use is to connect a DBS lead to a recording and stimulation device during neurosurgery to aid in lead placement. This is a surgical tool used in vivo (within the body) to facilitate a procedure.
  • Device Description: The device is described as sterile hardware (cables and adaptors) that connect existing medical devices (DBS leads and recording/stimulation systems). It's a physical connector, not a device that analyzes biological samples.
  • Lack of IVD Characteristics: IVD devices are designed to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. This device does not interact with or analyze such specimens.

The device's function is to enable the electrical connection between components used in a surgical procedure, which falls under the category of surgical accessories or components, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

The Alpha Omega Disposable Sterile LeadConfirm for MER is intended to be used in neurosurgery for connecting a compatible DBS Lead to a compatible recording and stimulation device.

The Alpha Omega Disposable Sterile LeadConfirm for MER is indicated for assisting Neurosurgeons, in the operating room during functional neurosurgery, to aid in the placement of a compatible DBS Lead.

The Alpha Omega Disposable Sterile LeadConfirm should only be used to connect a compatible DBS Lead to a compatible recording and stimulation device.

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

GZL

Device Description

Alpha Omega's Sterile LeadConfirm cable and adaptor connects the DBS lead to Alpha Omega's approved physiological navigation systems for recording and stimulation system: Neuro Omega (K171581) and NeuroSmart (K172042).

The purpose of the submission is to introduce the Sterile LeadConfirm Cable and Adaptor, the subject devices are sterile Hardware only.

There are three types of the subject device, Alpha Omega's Sterile LeadConfirm Cables:

  1. Sterile LeadConfirm M Cable that connects to Medtronic Lead P960009 (3389, 3387)
  2. Sterile LeadConfirm B Cable that connects to Boston Scientific Lead P150031 (BSC-DB-2201, BSC-DB-2202)
  3. Sterile LeadConfirm A Cable that connects to Abbott Lead P140009 (6170/ 6171/ 6172/ 6173/ 6178/ 6170/ 6180/ 6181)

In addition, there are two types of Sterile LeadConfirm Adaptors:

  1. Sterile LeadConfirm M Adaptor
  2. Sterile LeadConfirm A Adaptor

AOE (Alpha Omega Engineering) stimulation with LeadConfirm cable and adaptor is identical to IPG/ test stimulator, with the following parameters:

a) Pulse shape: Square wave, Lili pulse
b) Amplitude up to 12mA
c) Duration up to 500uSec

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Neurosurgeons, in the operating room

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)

Verification and validation bench tests were performed, to demonstrate the safety and effectiveness of the proposed Sterile LeadConfirm devices.

The purposes of the design verification & validation processes were to verify the Device specifications and to verify the proper function of all device components and options.

After comparing the predicate device to the subject device, results show that with the above intended use, the device is equivalent in safety and effectiveness.

Performance Tests:

  • Test: Verification and Validation
    • Test Method Summary: This verification performed on complete Sterile LeadConfirm devices, the subject devices, and checked that the design output meets the design input
    • Results: Sterile LeadConfirm devices have been verified under a complete verification plan traceable to Sterile LeadConfirm design input. All samples passed the acceptance criteria which determines the effectiveness of Sterile LeadConfirm devices.
  • Test: Sterilization Validation LeadConfirm Adaptors final Report
    • Test Method Summary: This Sterilization validation performed on complete Sterile LeadConfirm Adaptors
    • Results: The purpose of the study was to validate the effectiveness of the Gamma Radiation Sterilization for Alpha Omega Engineering Ltd. LeadConfirm adaptors, according to VDmax Method. According to the test results (section 13), the gamma radiation sterilization process of LeadConfirm Adaptors Cat. No. STR-000071-00, STR-000072-00 and STR-000073-00, at a sterilization dose of 20kGy, was sustained. This dose gave a SAL of 6 magnitudes as requested by the standards
  • Test: Sterilization Validation LeadConfirm B Cable final Report
    • Test Method Summary: This Sterilization validation performed on complete Sterile LeadConfirm B Cable
    • Results: The purpose of the study was to validate the effectiveness of the Gamma Radiation Sterilization for LeadConfirm B Cable, according to Vdmax Method. According to the test results (Section 13), the gamma radiation sterilization process of Electrodes lead cable, at a sterilization dose of 20kGy, was sustained. This dose gave a SAL of 6 magnitudes as requested by the standards
  • Test: Sterilization Validation LeadConfirm M & A Cables final Report
    • Test Method Summary: This Sterilization validation performed on complete Sterile LeadConfirm M & A Cables
    • Results: The purpose of the study was to validate the effectiveness of the Gamma Radiation Sterilization for LeadConfirm M & A Cables, according to Vdmax Method. According to the test results (Section 13), the gamma radiation sterilization process of Electrodes lead cable, at a sterilization dose of 20kGy, was sustained. This dose gave a SAL of 6 magnitudes as requested by the standards

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.

K120098

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.

Neuro Omega (K171581), NeuroSmart (K172042)

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).

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a symbol representing the Department of Health & Human Services - USA. To the right of this symbol, there is a blue square with the letters "FDA" in white. Next to the blue square, the words "U.S. FOOD & DRUG ADMINISTRATION" are written in blue.

Alpha Omega Engineering Ltd. Maysana Mousa QA RA Manager Nazareth Industrial Park, Mount Precipice, St. 2015 Nazareth 1612102. Israel

Re: K191739

Trade/Device Name: Sterile LeadConfirm Regulation Number: 21 CFR 882.1330 Regulation Name: Depth Electrode Regulatory Class: Class II Product Code: GZL Dated: November 25, 2019 Received: December 2, 2019

Dear Mrs. Maysana Mousa:

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 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for

1

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 (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.

Jay Gupta Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K191739

Device Name Sterile LeadConfirm

Indications for Use (Describe)

The Alpha Omega Disposable Sterile LeadConfirm for MER is intended to be used in neurosurgery for connecting a compatible DBS Lead to a compatible recording and stimulation device.

The Alpha Omega Disposable Sterile LeadConfirm for MER is indicated for assisting Neurosurgeons, in the operating room during functional neurosurgery, to aid in the placement of a compatible DBS Lead.

The Alpha Omega Disposable Sterile LeadConfirm should only be used to connect a compatible DBS Lead to a compatible recording and stimulation device.

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.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

Image /page/3/Picture/0 description: The image shows the logo for Alpha Omega. The logo consists of a stylized letter "A" in maroon color, with a gray bridge-like structure at the bottom. To the right of the "A" is the word "omega" in gray. Below the logo is the text "Defining Neuroscience Technology" in maroon color.

510(k) Summary

This 510(k) summary of safety and effectiveness information is submitted in accordance with the requirements of the Safe Medical Devices Act (SMDA) of 1990. The contents of the 510(k) summary have been provided in conformance with 21 CFR §807.92

Submitter Information

Alpha Omega Engineering Ltd. Hamerkava St. 6 Tsiporit Industrial Zone Nof Hagalil (Nazareth Elite) 1789062, Israel Tel:+972-4-6563-327 Fax:+972-4-6574-075

Submission contact person:

Mrs. Maysana Mousa Tel:+972-4-6563-327 Fax:+972-4-6574-075 Mobile: +972-54-9043303

Device Classification

Proprietary Device Name:Sterile LeadConfirm
Common name:Intraoperative neurophysiological recording and stimulating device
Product Code:GZL
Classification Name:Depth Electrode
Classification Regulation:21 CFR 882.1330
Regulatory Class:II
Predicate Devices

Sterile Disposable Recording Cables K120098

Page 1 of 10

4

Image /page/4/Picture/0 description: The image is a logo for Alpha Omega. The logo features the Greek letters alpha and omega, with the word "ALPHA" in red and the word "omega" in gray. The words "Defining Neuroscience Technology" are written in smaller font below the logo. The alpha and omega symbols are stylized, with the alpha symbol resembling a triangle and the omega symbol resembling a semicircle.

Device Description

Alpha Omega's Sterile LeadConfirm cable and adaptor connects the DBS lead to Alpha Omega's approved physiological navigation systems for recording and stimulation system: Neuro Omega (K171581) and NeuroSmart (K172042).

The purpose of the submission is to introduce the Sterile LeadConfirm Cable and Adaptor, the subject devices are sterile Hardware only.

There are three types of the subject device, Alpha Omega's Sterile LeadConfirm Cables:

    1. Sterile LeadConfirm M Cable that connects to Medtronic Lead P960009 (3389, 3387)
    1. Sterile LeadConfirm B Cable that connects to Boston Scientific Lead P150031 (BSC-DB-2201, BSC-DB-2202)
    1. Sterile LeadConfirm A Cable that connects to Abbott Lead P140009 (6170/ 6171/ 6172/ 6173/ 6178/ 6170/ 6180/ 6181)

In addition, there are two types of Sterile LeadConfirm Adaptors:

    1. Sterile LeadConfirm M Adaptor
    1. Sterile LeadConfirm A Adaptor

AOE (Alpha Omega Engineering) stimulation with LeadConfirm cable and adaptor is identical to IPG/ test stimulator, with the following parameters:

  • a) Pulse shape: Square wave, Lili pulse
  • b) Amplitude up to 12mA
  • c) Duration up to 500uSec

Indications for Use Statement

The Alpha Omega Disposable Sterile LeadConfirm for MER is intended to be used in neurosurgery for connecting a compatible DBS Lead to a compatible recording and stimulation device.

The Alpha Omega Disposable Sterile LeadConfirm for MER is indicated for assisting Neurosurgeons, in the operating room during functional neurosurgery, to aid in the placement of a compatible DBS Lead.

Page 2 of 10

Alpha Omega Engineering Ltd. Hamerkava St. 6 Tsiporit Industrial Zone Nof Hagalil 1789062, Israel Tel:+972-4-6563-327 Fax:+972-4-6574-075 info@alphaomega-eng.com www.alphaomega-eng.com

5

Image /page/5/Picture/0 description: The image is a logo for Alpha Omega. The logo has the letters Alpha and Omega in it. The word Alpha is in a dark red color, and the word Omega is in a gray color.

-Defining Neuroscience Technology

The Alpha Omega Disposable Sterile LeadConfirm should only be used to connect a compatible DBS Lead to a compatible recording and stimulation device

Page 3 of 10

6

Image /page/6/Picture/0 description: The image is a logo for Alpha Omega, a company that defines neuroscience technology. The logo features the letters "A" and "O" in a stylized font, with the "A" in maroon and the "O" in gray. Above the letters "ALPHA" is a maroon line that resembles a heartbeat. Below the logo is the tagline "Defining Neuroscience Technology" in a simple, sans-serif font.

Safety & Effectiveness

The Sterile LeadConfirm devices have been compared to the predicate device, Sterile Disposable Recording Cables (under K12008), in terms of intended use, indications for use, components, principles of operation, technological characteristics and safety features.

Intended Use Comparison .

| # | Comparison
parameter | Subject device:
Sterile LeadConfirm | Predicate device:
Sterile Disposable Recording
Cables | Substantial Equivalent discussion |
|---|---------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------|
| 1 | Legally
distribution
clearance No. | Subject device | K120098 | |
| 2 | Owner | Alpha Omega Engineering
Ltd. | Alpha Omega Engineering
Ltd. | |
| 3 | Intended use and
indications for
use. | The Alpha Omega Disposable
Sterile LeadConfirm for MER
is intended to be used in
neurosurgery for connecting a
compatible DBS Lead to a
compatible recording and
stimulation device.

The Alpha Omega Disposable
Sterile LeadConfirm for MER
is indicated for assisting | Alpha Omega's Sterile
Disposable Recording Cables
for MER are intended to be
used in neurosurgery for
connecting NeuroProbes to
recording and stimulation
device. | Similarities:
Similar
Differences:
None |
| # | Comparison
parameter | Subject device:
Sterile LeadConfirm | Predicate device:
Sterile Disposable Recording | Substantial Equivalent discussion |
| | | | Cables | |
| | | Neurosurgeons, in the
operating room during
functional neurosurgery, to aid
in the placement of a
compatible DBS Lead.
The Alpha Omega Disposable
Sterile LeadConfirm should
only be used to connect a
compatible DBS Lead to a
compatible recording and
stimulation device | | |
| 4 | indications for
use and
environment | Alpha Omega's Disposable
Sterile LeadConfirm for MER
is indicated for assisting
Neurosurgeons, in the
operation room during
functional neurosurgery, to aid
in placement of Lead. | Alpha Omega's Sterile
Disposable Recording Cables
for MER are indicated for
assisting Neurosurgeons, in the
operation room during
functional neurosurgery, to aid
in placement of depth
electrodes. | Similarities:
Similar
Differences:
None |
| 5 | Device code and
regulation | Product Code:
GZL
Regulation #: 21CFR882.1330 | Product Code:
GZL
Regulation #: 21CFR882.1330 | Similarities:
Identical
Differences:
None |
| # | Comparison
parameter | Subject device:
Sterile LeadConfirm | Predicate device:
Sterile Disposable Recording
Cables | Substantial Equivalent discussion |
| 1 | Legally
distribution
clearance No. | Subject device | K120098 | |
| 2 | Owner | Alpha Omega Engineering
Ltd. | Alpha Omega Engineering
Ltd. | |
| 3 | Target treatment
Population | All patients that need
functional neurosurgery | All patients that need
functional neurosurgery | Similarities:
Identical
Differences:
None |
| 4 | Human Factors | Used by professional
Neurosurgeons | Used by professional
Neurosurgeons | Similarities:
Identical
Differences:
None |
| 5 | Use environment | Operating Room | Operating Room | Similarities:
Identical
Differences:
None |

Page 4 of 10

Alpha Omega Engineering Ltd. Hamerkava St. 6 Tsiporit Industrial Zone Nof Hagalil 1789062, Israel Tel:+972-4-6563-327 Fax:+972-4-6574-075 info@alphaomega-eng.com www.alphaomega-eng.com

7

Image /page/7/Picture/0 description: The image shows a logo with the words "ALPHA" and "omega". The word "ALPHA" is in a dark red color and has a line going through it. The word "omega" is in gray and is located below the word "ALPHA".

Defining Neuroscience Technology

Page 5 of 10

8

Image /page/8/Picture/0 description: The image is a logo for Alpha Omega, a company that defines neuroscience technology. The logo features the letters "Alpha" and "Omega" in a stylized font. The word "Alpha" is in red, and the word "Omega" is in gray. The tagline "Defining Neuroscience Technology" is below the logo.

Performance Comparison .

Page 6 of 10

Alpha Omega Engineering Ltd. Hamerkava St. 6 Tsiporit Industrial Zone Nof Hagalil 1789062, Israel Tel:+972-4-6563-327 Fax:+972-4-6574-075 info@alphaomega-eng.com www.alphaomega-eng.com

9

Image /page/9/Picture/0 description: The image shows the logo for Alpha Omega. The logo consists of the Greek letters alpha and omega, with the word "ALPHA" written in a stylized font above the word "omega". The alpha symbol is red, while the omega symbol is gray. The word "ALPHA" is also red, and the word "omega" is gray.

Defining Neuroscience Technology

| # | Comparison
parameter | Subject device:
Sterile LeadConfirm | Predicate device:
Sterile Disposable Recording
Cables | Substantial Equivalent discussion |
|---|-----------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------|----------------------------------------------------|
| 6 | Integrity of
materials and
functionality
after sterilization | Functionality and materials
stability, including packaging
verified, after irradiation
sterilization. | Functionality and materials
stability, including packaging
verified, after irradiation
sterilization. | Similarities:
Identical
Differences:
None |
| 7 | Sterility
achievement
method | Sterilized by Alpha omega
using irradiation sterilization
and delivered sterile, validated
process | Sterilized by Alpha omega
using irradiation sterilization
and delivered sterile. | Similarities:
Identical
Differences:
None |

Page 7 of 10

Alpha Omega Engineering Ltd. Hamerkava St. 6 Tsiporit Industrial Zone Nof Hagalil 1789062, Israel Tel:+972-4-6563-327 Fax:+972-4-6574-075 info@alphaomega-eng.com www.alphaomega-eng.com

10

Image /page/10/Picture/0 description: The image is a logo for Alpha Omega. The logo features the letters "Alpha" and "Omega" in a stylized font. The word "Alpha" is in a dark red color, while the word "Omega" is in gray. Below the words is the phrase "Defining Neuroscience Technology" in a smaller font and dark red color.

Based on the performance results provided in this submission (including test results) and the analysis of similarities and differences presented above, Alpha Omega Technologies Ltd. believes that the proposed device is substantially equivalent to the predicate device without raising new safety and/or effectiveness issues.

Rational for Substantial Equivalency

The proposed Sterile LeadConfirm devices have been compared to the predicate and reference device in terms of intended use, indications for use, components, principles of operation, technological characteristics and safety features.

Based on the performance results provided in this submission (including test results and clinical data) and the analysis of similarities and differences presented above, Alpha Omega believes that the proposed device is substantially equivalent to the predicate device without raising new safety and/or effectiveness issues.

Substantial Equivalence Statement

Based on the above, it is Alpha Omega's opinion that the proposed Sterile LeadConfirm devices are substantially equivalent in terms of design principles, performance features and of safety & effectiveness to the predicate legally cleared devices referred to in section 4 of this document.

Non Clinical and Clinical validation data

Verification and validation bench tests were performed, to demonstrate the safety and effectiveness of the proposed Sterile LeadConfirm devices.

The purposes of the design verification & validation processes were to verify the Device specifications and to verify the proper function of all device components and options.

After comparing the predicate device to the subject device, results show that with the above intended use, the device is equivalent in safety and effectiveness.

Therefore, the subject devices of this 510(k) notification, the Sterile LeadConfirm devices, did not clinical studies to to support safety and effectiveness of of the require device.

11

Image /page/11/Picture/0 description: The image shows the logo for Alpha Omega. The logo consists of the Greek letters alpha and omega, with the word "ALPHA" in red and the word "omega" in gray. The alpha symbol is stylized with a red arch above a gray bridge-like structure. A red line extends from the top of the "A" in ALPHA, creating a wave-like pattern above the word.

-Defining Neuroscience Technology Performance Tests

TestTest Method SummaryResults
Verification and
ValidationThis verification performed on
complete Sterile LeadConfirm
devices, the subject devices, and
checked that the design output
meets the design inputSterile LeadConfirm devices have
been verified under a complete
verification plan traceable to Sterile
LeadConfirm design input. All
samples passed the acceptance
criteria which determines the
effectiveness of Sterile
LeadConfirm devices.
Sterilization
Validation
LeadConfirm
Adaptors final
ReportThis Sterilization validation
performed on complete Sterile
LeadConfirm AdaptorsThe purpose of the study was to
validate the effectiveness of the
Gamma Radiation Sterilization for
Alpha Omega Engineering Ltd.
LeadConfirm adaptors, according
to VDmax Method. According to
the test results (section 13), the
gamma radiation sterilization
process of LeadConfirm Adaptors
Cat. No. STR-000071-00, STR-
000072-00 and STR-000073-00, at
a sterilization dose of 20kGy, was
sustained. This dose gave a SAL of
6 magnitudes as requested by the
standards
Sterilization
Validation
LeadConfirm B
Cable final ReportThis Sterilization validation
performed on complete Sterile
LeadConfirm B CableThe purpose of the study was to
validate the effectiveness of the
Gamma Radiation Sterilization for
LeadConfirm B Cable, according to
Vdmax Method. According to the
test results (Section 13), the gamma
radiation sterilization process of
Electrodes lead cable, at a
sterilization dose of 20kGy, was
sustained. This dose gave a SAL of
6 magnitudes as requested by the
standards
Sterilization
ValidationThis Sterilization validation
performed on complete SterileThe purpose of the study was to
validate the effectiveness of the
-Defining Neuroscience Technology
LeadConfirm M &
A Cables final
ReportLeadConfirm M & A CablesGamma Radiation Sterilization for
LeadConfirm M & A Cables,
according to Vdmax Method.
According to the test results
(Section 13), the gamma radiation
sterilization process of Electrodes
lead cable, at a sterilization dose of
20kGy, was sustained. This dose
gave a SAL of 6 magnitudes as
requested by the standards

Page 9 of 10

Alpha Omega Engineering Ltd. Hamerkava St. 6 Tsiporit Industrial Zone Not Hagali 1789062, Israel
Tel:+972-4-6563-327 Fax:+972-4-6574-075 info@alphaomega-eng.com

12

Image /page/12/Picture/0 description: The image shows a logo with the words "ALPHA omega" in a stylized font. The word "ALPHA" is in a dark red color, and the word "omega" is in gray. The "A" in "ALPHA" is stylized with a dark red arch over a gray bridge-like structure. A red line extends from the "A" in "ALPHA" to the "A" in "omega", creating a visual connection between the two words.

Page 10 of 10