K Number
K212149
Device Name
MyndMove 2.0
Manufacturer
Date Cleared
2022-03-03

(237 days)

Product Code
Regulation Number
882.5810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
MYNDMOVE is an electrical stimulation device indicated for the following uses: Functional Electrical Stimulation (FES) Improvement of ann and hand functions and active range of motion in patients with hemplegia due to stroke or upper limb paralysis due to C3-T1 spinal cord injury. NeuroMuscular Electrical Stimulation (NMES) · Maintenance and/or increase of arm and hand range of motion - · Prevention and/or retardation of disuse atrophy - · Increase in local blood circulation - · Reduction of muscle spasm · Re-education of muscles. Myddlove therapy can only be administered by Occupational or Physical Therapy professionals that have completed MyndMove training by Mynd Tec on the use of the MyndMove System.
Device Description
The MyndMove 2.0 System is a neuromodulation device that delivers short electrical pulses to stimulate muscle contractions and enhance motor recovery following Stroke or Spinal Cord Injury. The MyndMove system comprises the Stimulator device, stimulation electrodes and cables, hand and foot switches, and integrated software. The MyndMove 2.0 Functional Electrical Stimulator is an eight-channel device with a touch screen user interface (UI). The Stimulator software allows the User to choose from a number of pre-programmed stimulation protocols, to customize the stimulation intensities for each patient, and to document the treatments provided. Each MyndMove Stimulator is connected, via an IEEE 802.11 a/b/q/n wireless radio adapter, to a cloud-based backend data management system. The primary function of the backend is to manage the various elements of the MyndMove ecosystem including but not limited to patient unique IDs and prescriptions, therapist profiles and stimulation protocols. MyndMove 2.0 Therapy can only be administered by trained MyndMove Therapy professionals (TMMT) with assigned Therapist Log-In IDs. TMMTs are Occupational or Physical Therapy professionals that have completed MyndMove training by MyndTec on the use of the MyndMove system. MyndMove 2.0 uses surface electrical stimulation to produce muscle contractions in different combinations to achieve a wide range of reaching and grasping functions. To achieve these movements, the single use electrodes are placed in various combinations on the surface of muscles in the arm and hand. MyndMove 2.0 is based on advanced functional electrical stimulation (FES) principles designed to promote neuroplasticity by influencing the efferent and afferent pathways. Proper sequencing of the muscle contractions as per the MyndMove 2.0 protocols achieve a wide range of reaching and grasping functions. During the delivery of MyndMove 2.0 therapy, the patient executes functional tasks with assistance from the therapist and the MyndMove 2.0 device. The patient attempts to perform the movement and is then assisted to complete the movement when the therapist activates the MyndMove 2.0 stimulation protocol, which generates bursts of short electrical pulses, using surface electrodes, to produce muscle contraction. In this manner, the patient gets both efferent and afferent input as they are actively attempting move and as the arm and/or hand is moved into the instructed position. Non-damaged pathways can be activated and non-damaged areas of the central nervous system can be trained to substitute for injured areas.
More Information

Not Found

No
The summary describes a device that delivers electrical stimulation based on pre-programmed protocols and user input, without mentioning any adaptive or learning capabilities.

Yes

Explanation: The device is explicitly described as an "electrical stimulation device" that delivers short electrical pulses to stimulate muscle contractions and enhance motor recovery, which aligns with the definition and purpose of a therapeutic device. Its stated "Indications for Use" directly relate to treating medical conditions and improving patient function.

No

Explanation: The device is described as an electrical stimulation device for therapy and motor recovery, not for diagnosing conditions. Its intended use is to improve functions and motion, prevent atrophy, increase circulation, and reduce muscle spasm through electrical stimulation, all of which are therapeutic actions.

No

The device description explicitly states that the MyndMove system comprises the Stimulator device, stimulation electrodes and cables, hand and foot switches, and integrated software. This indicates the presence of significant hardware components beyond just software.

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

Here's why:

  • Intended Use: The intended use clearly states that MyndMove is an electrical stimulation device used for therapeutic purposes (Functional Electrical Stimulation and NeuroMuscular Electrical Stimulation) to improve motor function and address issues like paralysis, disuse atrophy, muscle spasm, and range of motion. This is a therapeutic application, not a diagnostic one.
  • Device Description: The description details a device that delivers electrical pulses to stimulate muscle contractions. This is consistent with a therapeutic device, not a device that analyzes biological samples to diagnose conditions.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting analytes, or providing diagnostic information about a patient's condition based on in vitro testing.

Therefore, MyndMove is a therapeutic medical device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

MYNDMOVE is an electrical stimulation device indicated for the following uses:

Functional Electrical Stimulation (FES)

Improvement of ann and hand functions and active range of motion in patients with hemplegia due to stroke or upper limb paralysis due to C3-T1 spinal cord injury.

NeuroMuscular Electrical Stimulation (NMES)

· Maintenance and/or increase of arm and hand range of motion

  • · Prevention and/or retardation of disuse atrophy
  • · Increase in local blood circulation
  • · Reduction of muscle spasm
    · Re-education of muscles.

Myddlove therapy can only be administered by Occupational or Physical Therapy professionals that have completed MyndMove training by Mynd Tec on the use of the MyndMove System.

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

GZI, IPF

Device Description

The MyndMove 2.0 System is a neuromodulation device that delivers short electrical pulses to stimulate muscle contractions and enhance motor recovery following Stroke or Spinal Cord Injury. The MyndMove system comprises the Stimulator device, stimulation electrodes and cables, hand and foot switches, and integrated software. The MyndMove 2.0 Functional Electrical Stimulator is an eight-channel device with a touch screen user interface (UI). The Stimulator software allows the User to choose from a number of pre-programmed stimulation protocols, to customize the stimulation intensities for each patient, and to document the treatments provided.

Each MyndMove Stimulator is connected, via an IEEE 802.11 a/b/q/n wireless radio adapter, to a cloud-based backend data management system. The primary function of the backend is to manage the various elements of the MyndMove ecosystem including but not limited to patient unique IDs and prescriptions, therapist profiles and stimulation protocols. MyndMove 2.0 Therapy can only be administered by trained MyndMove Therapy professionals (TMMT) with assigned Therapist Log-In IDs. TMMTs are Occupational or Physical Therapy professionals that have completed MyndMove training by MyndTec on the use of the MyndMove system.

MyndMove 2.0 uses surface electrical stimulation to produce muscle contractions in different combinations to achieve a wide range of reaching and grasping functions. To achieve these movements, the single use electrodes are placed in various combinations on the surface of muscles in the arm and hand.

MyndMove 2.0 is based on advanced functional electrical stimulation (FES) principles designed to promote neuroplasticity by influencing the efferent and afferent pathways. Proper sequencing of the muscle contractions as per the MyndMove 2.0 protocols achieve a wide range of reaching and grasping functions. During the delivery of MyndMove 2.0 therapy, the patient executes functional tasks with assistance from the therapist and the MyndMove 2.0 device. The patient attempts to perform the movement and is then assisted to complete the movement when the therapist activates the MyndMove 2.0 stimulation protocol, which generates bursts of short electrical pulses, using surface electrodes, to produce muscle contraction. In this manner, the patient gets both efferent and afferent input as they are actively attempting move and as the arm and/or hand is moved into the instructed position. Non-damaged pathways can be activated and non-damaged areas of the central nervous system can be trained to substitute for injured areas.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Improvement of arm and hand functions and active range of motion in patients with hemiplegea due to stroke or upper limb paralysis due to C3-T1 spinal cord injury.

The MyndMove System stimulates the following Muscles:
Extensor Digitorum, Extensor Carpi Radialis & Extensor Carpi Ulnaris
Thenar Eminence (Opponens Pollicis Brevis, Flexor Pollicis Brevis & Abductor Pollicis Brevis)
Flexor Digitorum Superficialis and Flexor Digitorum Profundus
Biceps
Triceps
Posterior Deltoid, Middle Deltoid, and Anterior Deltoid
Pectoralis Major
1st, 2nd, and 3rd Lumbricals
2nd Dorsal Interosseous
Serratus Anterior, Lower Trapezius, Upper Trapezius (Scapula).

Indicated Patient Age Range

Not Found

Intended User / Care Setting

MyndMove 2.0 Therapy can only be administered by trained MyndMove Therapy professionals (TMMT) with assigned Therapist Log-In IDs. TMMTs are Occupational or Physical Therapy professionals that have completed MyndMove training by MyndTec on the use of the MyndMove system.

Used for therapy sessions in a clinical setting and for home use by a qualified user.

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)

Scapula protocols were subject to planned validation testing on 3 healthy volunteers. The objective was to test each protocol on each subject to ensure that the induced motions achieve the desired motions per the described use cases presented in section. Shoulder range of motion (flexion and abduction) under stimulation was collected using a goniometer.

Testing was performed at a clinical site called Lyndhurst and the Toronto Rehabilitation Institute of the University Health Network of the University of Toronto. All verification and validation was successfully performed per the design and development plans and under REB decision at the Toronto Rehabilitation Institute.

Third party testing on the addition of features to meet home use requirements of 60601-1-11 concluded that MyndMove 2.0 is safe for home use within the same indications for use of the predicate device.

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.

K170564

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 882.5810 External functional neuromuscular stimulator.

(a)
Identification. An external functional neuromuscular stimulator is an electrical stimulator that uses external electrodes for stimulating muscles in the leg and ankle of partially paralyzed patients (e.g., after stroke) to provide flexion of the foot and thus improve the patient's gait.(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.

March 03, 2022

MyndTec Inc. Yesmil Pena Quality Assurance Manager 1900 Minnesota Court Suite 122 Mississauga, Ontario Canada

Re: K212149

Trade/Device Name: MyndMove 2.0 Regulation Number: 21 CFR 882.5810 Regulation Name: External Functional Neuromuscular Stimulator Regulatory Class: Class II Product Code: GZI, IPF Dated: January 18, 2022 Received: January 20, 2022

Dear Yesmil Pena:

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

1

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 (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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-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,

Amber Ballard, PhD Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Form Approved: OMB No. 0910-0120 Expiration Date: 08/30/2023 See PRA Statement below.

Indications for Use

510(k) Number (if known) K212149

Device Name

MyndMove 2.0

Indications for Use (Describe)

MYNDMOVE is an electrical stimulation device indicated for the following uses:

Functional Electrical Stimulation (FES)

Improvement of ann and hand functions and active range of motion in patients with hemplegia due to stroke or upper limb paralysis due to C3-T1 spinal cord injury.

NeuroMuscular Electrical Stimulation (NMES)

· Maintenance and/or increase of arm and hand range of motion

  • · Prevention and/or retardation of disuse atrophy
  • · Increase in local blood circulation
  • · Reduction of muscle spasm

· Re-education of muscles.

Myddlove therapy can only be administered by Occupational or Physical Therapy professionals that have completed MyndMove training by Mynd Tec on the use of the MyndMove System.

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."

FORM FDA 3881 (6/20)

PSC Publishing Services (201) 443-6740 EF

3

510(k) Summary

Submitter / Owner Information

MyndTec Inc. 1900 Minnesota Court, Suite 122 Mississauga, Ontario Canada, L5N 3C9

Contact Person

Yesmil Pena Telephone:: 905-363-0564 ext. 225 Toll Free: 1-888-363-0581 Fax: 1-877-796-4624 yesmil.pena@myndtec.com

Date Prepared:

March 02, 2022

Device Identification

| A. Name of Device | MyndMove System and MyndMove Functional
Electrical Stimulator |
|--------------------------|-------------------------------------------------------------------------------------------------------|
| B. Classification Name | External Functional Neuromuscular Stimulator and
Powered Muscle Stimulator |
| C. Proprietary Name | MyndMove 2.0 |
| D. Device Classification | Class II |
| E. Panel | Neurology |
| F. Device Product Code | GZI and IPF |
| G. Regulation Number | 882.5810 External functional neuromuscular
stimulators, and
890.5850 Powered Muscle stimulators |
| H. Previous FDA Status | no prior FDA Status |
| I. Basis for Submission | Modified Device |

Identification of Predicate Device

DeviceApplicant510(k) No.Date Cleared
MyndMoveMyndTec Inc.K170564August 30, 2017

Device Description

The purpose of this Traditional 510(k) is to obtain clearance for MyndMove 2.0, a modified version of the MyndMove device (K170564) functional electrical and neuromuscular

4

stimulation device. The MyndMove device (K170564) has undergone minor modifications resulting in the MyndMove 2.0 version. The modifications are a change of the stimulator tablet material due to availability, the removal of the internal battery from the design of the MyndMove 2.0, the addition of IP22 rated ingress protection and the addition of an optional cart to facilitate mobility in the clinical environment. A slight change in the final paragraph after the indications for use to add Physiotherapist Assistants (PTAs) and Occupational Therapy Assistants (OTAs) in addition to Physiotherapists (PTs) and Occupational Therapists (OTs) as authorized users of the MyndMove 2.0 upon training and licensing by State Law, in alignment with Medicare and TRICARE policies.

The MyndMove 2.0 System is a neuromodulation device that delivers short electrical pulses to stimulate muscle contractions and enhance motor recovery following Stroke or Spinal Cord Injury. The MyndMove system comprises the Stimulator device, stimulation electrodes and cables, hand and foot switches, and integrated software. The MyndMove 2.0 Functional Electrical Stimulator is an eight-channel device with a touch screen user interface (UI). The Stimulator software allows the User to choose from a number of pre-programmed stimulation protocols, to customize the stimulation intensities for each patient, and to document the treatments provided.

Each MyndMove Stimulator is connected, via an IEEE 802.11 a/b/q/n wireless radio adapter, to a cloud-based backend data management system. The primary function of the backend is to manage the various elements of the MyndMove ecosystem including but not limited to patient unique IDs and prescriptions, therapist profiles and stimulation protocols. MyndMove 2.0 Therapy can only be administered by trained MyndMove Therapy professionals (TMMT) with assigned Therapist Log-In IDs. TMMTs are Occupational or Physical Therapy professionals that have completed MyndMove training by MyndTec on the use of the MyndMove system.

MyndMove 2.0 uses surface electrical stimulation to produce muscle contractions in different combinations to achieve a wide range of reaching and grasping functions. To achieve these movements, the single use electrodes are placed in various combinations on the surface of muscles in the arm and hand.

MyndMove 2.0 is based on advanced functional electrical stimulation (FES) principles designed to promote neuroplasticity by influencing the efferent and afferent pathways. Proper sequencing of the muscle contractions as per the MyndMove 2.0 protocols achieve a wide range of reaching and grasping functions. During the delivery of MyndMove 2.0 therapy, the patient executes functional tasks with assistance from the therapist and the MyndMove 2.0 device. The patient attempts to perform the movement and is then assisted to complete the movement when the therapist activates the MyndMove 2.0 stimulation protocol, which generates bursts of short electrical pulses, using surface electrodes, to produce muscle contraction. In this manner, the patient gets both efferent and afferent input as they are actively attempting move and as the arm and/or hand is moved into the instructed position. Non-damaged pathways can be activated and non-damaged areas of the central nervous system can be trained to substitute for injured areas.

Indications for Use

MYNDMOVE 2.0 is an electrical stimulation device indicated for the following uses:

Functional Electrical Stimulation (FES)

5

Improvement of arm and hand functions and active range of motion in patients with hemiplegia due to stroke or upperlimb paralysis due to C3-T1 spinal cord injury.

NeuroMuscular Electrical Stimulation (NMES)

  • . Maintenance and/or increase of arm and hand range of motion
  • Prevention and/or retardation of disuse atrophy
  • . Increase in local blood circulation
  • . Reduction of muscle spasm
  • . Re-education of muscles.

MyndMove therapy can only be administered by Occupational or Physical Therapy professionals that have completed MyndMove training by MyndTec on the use of the MyndMove System.

Type of Use

Prescription Use (Rx)

Performance Standards

MyndMove 2.0 complies with the current medical electrical equipment electromagnetic compatibility basic safety and performance, and software standards listed below, as verified upon Third Party testing for compliance with 60601-2-10 Edition 2.1 2016-04, ( basic safety and essential performance of nerve and muscle stimulators), ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (basic safety and essential performance); 60601-1-2 Edition 4.0 2014-02 ( basic safety and essential performance for Electromagnetic disturbances); 60601-1-11 Edition 2.0 2015-01( basic safety and essential performance requirements for medical electrical equipment a used in the home healthcare environment). MyndMove also complies with IEC 62304:2006 Medical device software - Software life cycle processes and 60601-1-6:2010 Third Edition + A1:2013 (basic safety and essential performance for usability). No additional usability testing to the original cleared device was required. There was no change to the hardware or

software design. Performance testing was performed also internally against the same specifications of the cleared device.

As part of performance testing, six oscilloscope tracings were generated for 500 ohm, 2k ohm and 10k ohms and include output mode, amplitude baseline, load resistance, pulse width, and electrode surface area with the corresponding maximum power density and average current density per surface area. The maximum net charge per pulse and phase charge for the modified device MyndMove 2.0 are identical to those of the cleared device MyndMove. The net charge per pulse for both the modified and cleared devices is 1.85 µC, and the maximum phase charge is 9.02 uC.

FDA Recognition No.Standard Title
17-16IEC 60601-2-10 Edition 2.1 2016-04. Medical electrical equipment - Part 2-10:
Particular requirements for the basic safety and essential performance of nerve
and muscle stimulators.
19-4ANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and
A2:2010/(R)2012 (Consolidated Text): Medical electrical equipment - Part 1:
General requirements for basic safety and essential performance (IEC 60601-
1:2005, MOD).

6

| 19-8 | IEC 60601-1-2 Edition 4.0 2014-02: Medical electrical equipment - Part 1-2:
General requirements for basic safety and essential performance - Collateral
Standard: Electromagnetic disturbances - Requirements and tests. |
|-------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 19-14 | IEC 60601-1-11 Edition 2.0 2015-01: Medical electrical equipment - Part 1-11:
General requirements for basic safety and essential performance - Collateral
Standard: Requirements for medical electrical equipment and medical electrica
systems used in the home healthcare environment. |

Basis for Substantial Equivalence

MyndTec Inc.'s MyndMove and MyndMove 2.0 are similar in design, function and technical specifications. Both devices have the same intended use and deliver functional electrical and neuromuscular stimulation using coded therapeutic algorithmic protocols using an eightchannel stimulator with a maximum 20 mA output current for all 9cm x 5cm, 5cm, 2.5cm diameter and 1cm x 3cm sinqle use electrodes. Both the cleared and modified device have almost identical technical specifications as illustrated in the table below.

MyndMove 2.0 is the result of the removal of the battery, an upgrade of the tablet PC and other modifications to meet home use requirements, maximum current equal to all electrodes, the addition of scapula protocols, and the addition of an optional cart. The predicate device MyndMove has maximum outputs for electrodes depending on size, ranging from 5mA for a 3cm2 electrode, the smallest size, to 20mA for a 45cm2 electrode, the largest size. The modified MyndMove 2.0 applies a maximum 20 mA output current for all electrodes regardless of electrode size to enable the therapist to select the peak currents to generate full muscle recruitment with any electrode size, particularly with denervated muscles. In both the predicate and modified devices, peak current values for all electrode sizes fall under the 2mA/cm maximum allowed by IEC 60601-2-10. Scapula protocols were added to the existing deltoid anatomical sites to optimize patient objectives. An analysis of the performance testing results and all similarities and differences listed in the table below

leads to determine that the modified MyndMove 2.0 has the same technical characteristics the cleared MyndMove. The differences do not raise any concerns regarding safety and effectiveness. Therefore, MyndMove 2.0 is substantially equivalent to the predicate device, the cleared MyndMove.

Substantial Equivalence discussion for subject device MyndMove 2.0 and predicate device MyndMove.
Cleared Device MyndMoveModified Device MyndMove 2.0SE Comparison
510(k) NumberK170564(To Be Assigned)
Indications for UseMyndMove is an electrical stimulation device
indicated for the following uses:MyndMove is an electrical stimulation device
indicated for the following uses:Identical
Functional electrical stimulation (FES)Functional electrical stimulation (FES)
Improvement of arm and hand function and
active range of motion in patients with hemiplegia
due to stroke or upper limb paralysis due to
C3-T1 spinal cord injury.
NeuroMuscular Electrical Stimulation (NMES)
• maintenance and/or increase of arm and hand
range of motion,
• prevention and/or retardation of disuse atrophy,
• increase in local blood circulation,
• reduction in muscle spasm, and
• re-education of muscles.
MyndMove therapy can only be administered by
Occupational or Physical Therapists that have
completed MyndMove training by MyndTec on the
use of the MyndMove System.Improvement of arm and hand function and
active range of motion in patients with hemiplegia
due to stroke or upper limb paralysis due to
C3-T1 spinal cord injury.
NeuroMuscular Electrical Stimulation (NMES)
• maintenance and/or increase of arm and hand
range of motion,
• prevention and/or retardation of disuse atrophy,
• increase in local blood circulation,
• reduction in muscle spasm, and
• re-education of muscles.
MyndMove therapy can only be administered by
Occupational or Physical Therapy
professionals that have completed MyndMove
training by MyndTec on the use of the
MyndMove System.(There was a minor
change on the last
statement from
'Occupational or
Physical Therapists' to
'Occupational or
Physical Therapy
professionals' to
enable Occupational
or Physical Therapy
Assistants (OTAs or
PTAs) to administer
the MyndMove
therapy with the
appropriate training
and per the
corresponding
jurisdiction laws and
regulations).This
change does not alter
the intended use.
Anatomical Sites
for Stimulation
(Upper Limb)The MyndMove System stimulates the
following Muscles:
Extensor Digitorum, Extensor Carpi Radialis
& Extensor Carpi Ulnaris
Thenar Eminence (Opponens Pollicis Brevis,
Flexor Pollicis Brevis & Abductor Pollicis
Brevis)
Flexor Digitorum Superficialis and FlexorThe MyndMove System stimulates the
following Muscles:
Extensor Digitorum, Extensor Carpi Radialis
& Extensor Carpi Ulnaris
Thenar Eminence (Opponens Pollicis Brevis,
Flexor Pollicis Brevis & Abductor Pollicis
Brevis)
Flexor Digitorum Superficialis and FlexorEquivalent
Please refer to the
Scapula protocol
addition discussion
Digitorum Profundus
Biceps
Triceps
Posterior Deltoid, Middle Deltoid, and
Anterior Deltoid
Pectoralis Major
1st, 2nd, and 3rd Lumbricals
2nd Dorsal InterosseousDigitorum Profundus
Biceps
Triceps
Posterior Deltoid, Middle Deltoid, and
Anterior Deltoid
Pectoralis Major
1st, 2nd, and 3rd Lumbricals
2nd Dorsal Interosseous
Serratus Anterior, Lower Trapezius, Upper
Trapezius (Scapula).below.
Serratus Anterior, Lower Trapezius, Upper
Trapezius (Scapula).
Where UsedUsed for therapy sessions in a clinical setting
only.Used for therapy sessions in a clinical setting
and for home use by a qualified user.Equivalent
MyndMove 2.0 was
designed for and
tested against
60601-
1-11 (home
healthcare)
Regulated current
orCurrent RegulatedCurrent RegulatedIdentical
regulated voltage?
Software/
firmware/
microprocessor
control? (yes/no)YesYesIdentical
Automatic
overload trip?
(yes/no)YesYesIdentical
Automatic no- load
trip? (yes/no)YesYesIdentical
Automatic shut
off? (yes/no)YesYesIdentical
User override
control? (yes/no)YesYesIdentical
Indicator display:YesYesIdentical
- On/off status?
(yes/no)YesYesIdentical
- Low battery?
(yes/no)YesYesIdentical
- Voltage/current
level? (yes/no)YesYesIdentical
Timer range
( minutes )Stimulation time controlled by user.Stimulation time controlled by user.Identical
Max duration of stimulation program = 120
minutes (configurable in the backend)Max duration of stimulation program = 120
minutes (configurable in the backend)
Compliance with
voluntary
standards? (if yes,
specify)IEC 60601-1
IEC 60601-1-2
IEC 60601-2-10ANSI AAMI ES 60601-1
IEC 60601-1-2
IEC 60601-2-10Equivalent
Compliance with
21 CFR 898?
(yes/no)YesYesIdentical
Power SourcesMains OR Rechargeable Li-Ion Battery.

Rechargeable Li-Ion:
14.8 V DC, 2000 mAh

Power Supply Input: 100-240 V AC, 1.2A, 50-
60 Hz
Power Supply Output: 24 V DC, 4.16 A, 100W | AHM100PS24C2-8 manufactured by XP-Power
100-240 V AC, 1.2 A, 50-60 Hz
24 V DC, 4.16 A, 100 W
Tripp Lite P012-006, 1-15P to C7 -10A, 120V, 18
AWG, 6 ft., Black
Sabic, Lexan Polycarbonate
: Sabic, Lexan Polycarbonate
Sabic, Lexan Polycarbonate Covestro, Makrolon
2805 Polycarbonate TPE E4001-40-J02 | Equivalent |
| Method of line
current isolation | Galvanic Isolation (transformer) 4000 VAC | Galvanic Isolation (transformer) 4000 VAC | Identical |
| Normal
condition (uA) | Earth Leakage: