K Number
K211338
Device Name
EMBOTRAP III Revascularization Device
Manufacturer
Date Cleared
2021-07-30

(88 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The EMBOTRAP™ III Revascularization Device is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
Device Description
The EMBOTRAP™ III Revascularization Device is composed of a retrievable, self-expanding, Nitinol shaped section at the distal end of a tapered Nitinol shaft. It is designed to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke. The EMBOTRAP™ III Revascularization Device is supplied sterile and is intended for single-use only by physicians trained in neuro-interventional catheterization and the treatment of ischemic stroke.
More Information

No
The summary describes a mechanical device for thrombus removal and does not mention any AI/ML components or functionalities.

Yes.
The device is intended to restore blood flow and remove thrombus in patients experiencing ischemic stroke by physically removing the obstruction, aligning with the definition of a therapeutic device that treats a medical condition.

No

Explanation: The device is described as a revascularization device intended to remove thrombus and restore blood flow in patients experiencing ischemic stroke. Its function is to perform a therapeutic procedure (clot removal), not to diagnose a condition.

No

The device description clearly states it is a physical device composed of Nitinol and designed to be inserted into the neurovasculature. The performance studies also detail extensive bench and animal testing of the physical device's properties and performance.

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • EMBOTRAP™ III Function: The EMBOTRAP™ III Revascularization Device is a medical device used inside the body to physically remove a thrombus (blood clot) from the neurovasculature. It is a therapeutic device, not a diagnostic one.
  • Intended Use: The intended use clearly states it's for "restor[ing] blood flow in the neurovasculature by removing thrombus." This is a treatment, not a diagnostic test.
  • Device Description: The description details a physical device designed for insertion into the body to perform a mechanical action.

The information provided describes a device used for a medical procedure performed on the patient, not a test performed on a sample from the patient.

N/A

Intended Use / Indications for Use

The EMBOTRAP™ III Revascularization Device is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

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

NRY

Device Description

The EMBOTRAP™ III Revascularization Device is composed of a retrievable, self-expanding, Nitinol shaped section at the distal end of a tapered Nitinol shaft. It is designed to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke. The EMBOTRAP™ III Revascularization Device is supplied sterile and is intended for single-use only by physicians trained in neuro-interventional catheterization and the treatment of ischemic stroke.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

neurovasculature

Indicated Patient Age Range

Not Found

Intended User / Care Setting

physicians trained in neuro-interventional catheterization and the treatment of ischemic stroke.

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)

Biocompatibility Testing: The biocompatibility evaluation for the EMBOTRAP™ III Revascularization Device was conducted in accordance with International Standard ISO 10993-1 "Biological Evaluation of Medical Devices -Part 1: Evaluation and Testing Within a Risk Management Process" and FDA Biocompatibility Guidance. The device is categorized as an external communicating device with limited exposure (

§ 870.1250 Percutaneous catheter.

(a)
Identification. A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.(b)
Classification. Class II (performance standards).

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July 30, 2021

Neuravi Ltd. Niall Fox Director of Regulatory Affairs Block 3, Ballybrit Business Park Galway H91 K5YD, Ireland

Re: K211338

Trade/Device Name: EMBOTRAP III Revascularization Device Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: April 30, 2021 Received: May 3, 2021

Dear Niall Fox:

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 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,

Naira Muradyan, Ph.D. 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

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Indications for Use

510(k) Number (if known) K211338

Device Name EMBOTRAP III Revascularization Device

Indications for Use (Describe)

The EMBOTRAP™ III Revascularization Device is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

Type of Use (Select one or both, as applicable)
-------------------------------------------------
☑ Recreational Use (Part 21 CFR 201.326 Subject)□ Over-The-Counter Use (21 CFR 201.66 Subject)
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

K211338

l. SUBMITTER:

510(k) Owner: Neuravi Ltd.

Block 3, Ballybrit Business Park, Galway H91 K5YD, Ireland

Contact Person: Niall Fox

Director of Regulatory Affairs

Tel: +353-91-394123

E-mail: nfox5@its.jnj.com

Date Prepared: July 28th, 2021

DEVICE II.

Trade Name of Device: EMBOTRAP™ III Revascularization Device

Common Name of Device: Catheter, Thrombus Retriever

Classification Name: 21 CFR 870.1250 - Class II

Product Code: NRY

PREDICATE DEVICES III.

EmboTrap® II Revascularization Device (K173452)

EMBOTRAP™ III Revascularisation Device (5 x 22 mm and 5 x 37 mm models via K193063)

Solitaire™ Platinum Revascularization Device (K160641)

IV. DEVICE DESCRIPTION

The EMBOTRAP™ III Revascularization Device is composed of a retrievable, self-expanding, Nitinol shaped section at the distal end of a tapered Nitinol shaft. It is designed to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke. The EMBOTRAP™ III Revascularization Device is supplied sterile and is intended for single-use only by physicians trained in neuro-interventional catheterization and the treatment of ischemic stroke.

V. INDICATIONS FOR USE

The EMBOTRAP™ III Revascularization Device is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.

COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE VI.

A summary of the technological characteristics of the EMBOTRAP™ III device in comparison to those of the predicate devices is presented below

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CharacteristicsPredicate Devices Referenced in this SubmissionProposed SE Device
EMBOTRAP III
(5 x 22 mm and 5 x 37 mm)EMBOTRAP IISolitaire™ PlatinumEMBOTRAP III
(6.5 x 45 mm)
ManufacturerNeuravi Ltd.Neuravi Ltd.Covidien/MedtronicSame as EMBOTRAP II
510(k) NumberK193063K173452K160641N/A
ClassificationClass II (21CFR 870.1250)Same
Device Classification NameCatheter, Thrombus RetrieverSame
Classification Product CodeNRYSame
Indication for UseThe EMBOTRAP III Revascularization
Device is intended to restore blood
flow in the neurovasculature by
removing thrombus in patients
experiencing ischemic stroke within
8 hours of symptom onset. Patients
who are ineligible for intravenous
tissue plasminogen activator (IV t-
PA) or who fail IV t-PA therapy are
candidates for treatment.The EMBOTRAP II Revascularization
Device is intended to restore blood
flow in the neurovasculature by
removing thrombus in patients
experiencing ischemic stroke within
8 hours of symptom onset. Patients
who are ineligible for intravenous
tissue plasminogen activator (IV t-
PA) or who fail IV t-PA therapy are
candidates for treatment.The Solitaire Platinum Revascularization
Device is intended to restore blood flow
by removing thrombus from a large
intracranial vessel in patients
experiencing ischemic stroke within 8
hours of symptom onset. Patients who
are ineligible for intravenous tissue
plasminogen activator (IV t-PA) or who
fail IV t-PA therapy are candidates for
treatment.Same as EMBOTRAP models
Target PopulationPatients with symptoms of an ischemic stroke within 8 hours of symptom onset, who are ineligible for intravenous
tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatmentSame
Design/Technological
PrinciplesRetrievable, self-expanding Nitinol shaped section
Nitinol guide-wire like shaftSame
Distal End (Retriever) DesignBi-layer tubular design with a tapered
distal end with tip
Image: [5 x 22 mm device]
Image: [5 x 37 mm device]Bi-layer tubular design with a tapered
distal end with tip
Image: [device]Same as EMBOTRAP II
Principal Device Materials
Shaped Section & Shaft WireNitinolNitinolNitinolSame as EMBOTRAP II
Distal Marker/CoilPlatinum/Tungsten CoilPlatinum/Tungsten CoilPlatinum/IridiumSame as EMBOTRAP II
Proximal Marker/CoilPlatinum/Tungsten CoilPlatinum/Tungsten CoilPlatinum/IridiumSame as EMBOTRAP II
Shaft CoatingHydrophobic
PTFE CoatingHydrophobic
PTFE CoatingSame as EMBOTRAP II
Design Characteristics & Technology
Size(s) Offered
(Retriever Diameter ×
Length)5×22mm, 5×37mm,5×21 mm, 5×33 mm6x40 mm6.5x45 mm
Device Length194 cm, 195 cm
(Labeled Overall length)194 cm, 195 cm
(Labeled Overall length)180 cm
(Labeled Push Wire Length)196 cm
(Labeled Overall length)
Minimum Microcatheter ID0.021"-0.027"0.021"0.027" (6 mm diameter size)0.021"-0.027"
Key Principles of OperationThe device is used in the neurovasculature to restore blood flow in patients experiencing ischemic strokeSame

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No. of passes/device IFU3 / Device & Vessel3 / Device & Vessel3 / Device & VesselSame
Additional Characteristics
How suppliedSterile/Single UseSterile/Single UseSterile/Single UseSame
Sterilization MethodEthylene OxideEthylene OxideEthylene OxideSame

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VII. PERFORMANCE DATA

Biocompatibility Testing:

The biocompatibility evaluation for the EMBOTRAP™ III Revascularization Device was conducted in accordance with International Standard ISO 10993-1 "Biological Evaluation of Medical Devices -Part 1: Evaluation and Testing Within a Risk Management Process" as recognized by FDA (Recognition Number 2-156) and FDA Biocompatibility Guidance (Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process", June 16, 2016).

Per ISO 10993-1, the EMBOTRAP™ III device is categorized as an external communicating device with limited exposure, i.e. whose contact with circulating blood is less than 24 hours.

TestResultsConclusions
Cytotoxicity StudyThe test article extract showed no
evidence of causing cell lysis or
toxicity. The test article extract
met the requirements of the test.
Based on the percentage viability
values for the test article extract
dilutions, the device is non-
cytotoxic.Device is non-cytotoxic per the
Cytotoxicity Studies conducted
ISO Guinea Pig Maximization
Sensitization TestTest article extracts showed no
evidence of causing delayed
dermal contact sensitization in the
guinea pig.Device is not considered a
sensitizer per the Guinea Pig
Maximization Test
ISO Intracutaneous Study in
RabbitsThe difference between the test
extract overall mean score and the
corresponding control overall
mean score was 1.0 or less.Device is not an irritant when
injected intracutaneously per the
ISO Intracutaneous Study in
Rabbits
ISO Systemic Toxicity Study in
MiceThere was no mortality or evidence
of systemic toxicity from the
extracts injected into mice. Each
test article extract met the
requirements of the study.Device is non-toxic per the ISO
Systemic Toxicity Study in Mice

The biocompatibility evaluation included the following tests:

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TestResultsConclusions
USP Rabbit Pyrogen Study,
Material MediatedNo individual rabbit showed a rise
in temperature of ≥ 0.5°C above its
baseline temperature and the total
maximum temperature rise of all
three animals was within
acceptable USP limits.

The total rise of rabbit
temperatures during the 3-hour
observation period was within
acceptable USP requirements. The
test article met the requirements
for the absence of pyrogens. | Device is non-pyrogenic per the
Material Mediated Rabbit Pyrogen
Study |
| ASTM Hemolysis | Both the test article in direct
contact with blood and the test
article extract were non-hemolytic. | Device is non-hemolytic per the
ASTM Hemolysis Test |
| Complement Activation Assay
Studies
SC5b-9 Complement Activation
Assay Study | The C3a and SC5b-9
concentrations of the test article
samples were acceptable. All test
method acceptance criteria were
met. | Levels of C3a and SC5b-9 were
acceptable. |
| In Vivo Thromboresistance Study
in Sheep – Jugular Vein, Acute
(Thrombogenicity) | The implantation procedure was
routine and there were no
difficulties encountered with
insertion or placement of the test
device. There was no evidence of
bleeding or complications during
the post-operative implant period.

Minimal thrombus formation was
associated with the control article
and minimal to slight thrombus
formation was associated with the
test article. | Under the conditions of this study,
both test and control articles were
considered thromboresistant. |

All biocompatibility tests completed met the pre-assigned acceptance criteria as specified in the test protocol and in accordance with the requirements of the applicable standards.

Sterilization and Shelf Life:

The EMBOTRAP™ III device is labelled as a single-use, sterile device, with a shelf life of 3 years. The sterilization process for the EMBOTRAP™ III device has been successfully validated and process monitoring controls are in place to assure that the device is EO-sterilized to achieve a minimum SAL of 10-6.

Shelf life studies have been conducted for the EMBOTRAP™ III device and establish that the product and packaging remain functional and sterile for the shelf life period of 3 years.

In Vitro (Bench) Testing:

The results of design verification and validation testing conducted on the EMBOTRAP™ III device demonstrate that it performs as designed, fulfils all pre-determined product performance

8

specification requirements, and is suitable for its intended use. The verification and validation test results demonstrate that EMBOTRAP™ III is substantially equivalent to the predicate devices.

Characteristic/TestMethodConclusions
System DimensionsA range of device dimensions were measured using specified measurement tools to verify that the required dimensional specifications were met for the subject device models.All required specifications were met.
Device dimensions are comparable to legally-marketed mechanical thrombectomy devices. The subject device includes a longer overall length and larger diameter.
Radial Force TestingRadial force of the subject device models was measured within a range of lumen diameters applicable to the intended vasculature to verify that the device performance specifications have been met.All required specifications were met.
Radial force performance of the subject device is comparable to that of the predicate device.
Outer Cage RecoveryExpansion characteristics of the self-expanding portion of a representative (worst-case) device model were evaluated by measurement post-multiple loading and deployment cycles.All required specifications were met.
Outer cage recovery performance is comparable to that of the predicate.
Durability TestingDamage was evaluated after delivery and withdrawal of the subject device models beyond the recommended number of passes and re-sheathings recommended in the instructions for use.All required specifications were met.
Durability performance of the subject device is comparable to that of the predicate device.
Full Unit (System) Tensile TestingThe system (full unit) tensile strength of the proximal/distal sections of the device was evaluated post-simulated use.All required specifications were met.
The system tensile strength of the subject device is comparable to that of the predicate device.
Marker Push Out ForceEvaluated the force required to dislodge riveted markers from a representative device model post-simulated use (all marker locations and push-out directions were assessed).All required specifications were met.
Flexibility & Kink ResistanceKink resistance of the entire device (shaft and shaped section) was evaluated using a representative worst-case device model, which was wrapped around a series of mandrels of decreasing radii until permanent deformation was observed or until the smallest radius was used.All required specifications were met.
Kink resistance of the subject device is comparable to that of the predicate device.
Coating IntegrityCoating integrity of the subject device was evaluated on a representative (worst-case) device model by examining the shaft coatingAll required specifications were met.
Coating integrity of the subject device is comparable to that of the predicate
Torque Durability
(Strength)The effects of torquing the subject
device were evaluated using a
representative (worst-case) device
model post-simulated use with the
device positioned as follows (distal
end constrained): (a) within the
microcatheter in a simulated vessel;
and (b) with the shaped section of
the device deployed in a simulated
vessel following retraction of the
microcatheter.All required specifications were met.
Torque durability of the subject device
is comparable to that of the predicate
device.
Corrosion ResistanceRepresentative (worst-case) device
models were subjected to corrosion
testing to determine resistance to
corrosion.All required specifications were met.
Corrosion resistance of the subject
device is comparable to that of the
predicate device.
Tip FlexibilityTip flexibility was evaluated by
measuring the deflection force of the
device tip when advanced through a
microcatheter past its tip and
deflected against contact plates at
pre-specified angles.All required specifications were met.
Tip flexibility of the subject device is
comparable to that of the predicate
device.
Re-sheathing ForceA representative (worst-case) device
model was evaluated in a 0.021"
microcatheter to determine the force
required to re-sheath the device.All required specifications were met.
Re-sheathing force is comparable to
those recorded for the predicate
devices.
Deliverability ForceA representative (worst-case) device
model was evaluated in a tortuous
track model to determine the force
required to deliver the subject device
in a 0.021" microcatheter.All required specifications were met.
RadiopacityThe worst-case subject device (least
number of radiopaque markers) was
evaluated in a skull phantom model
using fluoroscopy.All required specifications were met.
Radiopacity of the subject device is
equivalent to, or better than, that of
the predicate devices tested.
Clot retrieval and
performance
(Simulated Use/Ease of
Use)Device performance and ease of use
attributes (including clot retrieval
performance) were evaluated in
simulated anatomy for the subject
devices in relation to the key steps
involved in the clinical procedure.All required ease of use performance
specifications were met.
The subject device effectively
retrieved clot and restored flow in the
test model.
Performance of the subject device
(including loading, delivery,
deployment and retrieval) was
comparable to that of the predicate
devices tested in an in vitro tortuous
path anatomical model.
Physician Usability StudyDevice performance and ease of use
attributes were evaluated in
simulated anatomy for the worst-
case (largest) subject device model in
relation to the key steps involved in
the clinical procedure.
Performance was compared with the
predicate device.The physician usability study
demonstrated that the subject device
met user needs.

Device performance was comparable
to that of the predicate device. |
| Delivery and re-sheathing
force during simulated
use
(in a clinically-
representative, full-length
anatomical model) | Delivery and re-sheathing forces
were measured during simulated use
of a representative (worst-case)
device model device in a full-length
anatomical model and compared
with the forces measured for one or
more predicate devices. | Delivery and re-sheathing
performance of the subject device are
comparable to that of the predicate
device. |
| Kink Resistance –
Deployed Shaped Section | Kink resistance of the deployed
shaped section of a representative
(worst-case) device model was
evaluated in a series of bend radii
within a range of vessel lumen
diameters. | Kink resistance of the deployed
shaped section was comparable to
that of the predicate device. |

Specifically, the following in vitro bench tests were performed on the subject device:

simulated use.

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In Vivo (Animal) Studies:

Acute and chronic animal studies have been performed to assess the usability, effectiveness and safety of the EMBOTRAP™ III device compared to the predicate devices in the swine model. Acute performance evaluated on Day 0 showed that the usability and performance of the EMBOTRAP™ III device was equivalent to that of the predicate device tested. Histological evaluation performed on treated vessels after 3 and 28 days demonstrated that the local and end organ tissue response was comparable between the EMBOTRAP™ III device and the predicate devices tested.

Clinical Studies:

No clinical study was performed as there is no change to the indications for use or the fundamental scientific technology for the subject device. Substantial equivalence of the subject device has been established to the predicate device through the results of bench and animal testing.

CONCLUSIONS

Non-clinical studies demonstrate that the EMBOTRAP™ III Revascularization Device is substantially equivalent to the predicate devices.