K Number
K223542
Device Name
TubaVent Balloon Dilatation System
Date Cleared
2023-08-03

(251 days)

Product Code
Regulation Number
874.4180
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The TubaVent balloon dilatation system is intended to dilate the cartilaginous portion of the Eustachian tube for treatment of persistent obstructive Eustachian tube dysfunction in patients 18 years and older.
Device Description
The TubaVent balloon dilatation system is an Eustachian Tube Balloon Dilatation System consisting of the balloon catheter, the Tubalnsert insertion device and the inflation device. It is used for dilation of the cartilaginous portion of the Eustachian tube in persistent obstructive Eustachian tube dysfunction. The balloon catheter TubaVent is available in two versions where the balloon diameter is different: 3 and 4.5 mm. The insertion device Tubalnsert has an angle of 45° at the distal end.
More Information

None

No
The summary describes a mechanical balloon dilatation system and does not mention any AI or ML components or functionalities.

Yes
The device is intended to treat a medical condition (persistent obstructive Eustachian tube dysfunction) by dilating the Eustachian tube.

No

Explanation: The device is intended to dilate the Eustachian tube for treatment of a medical condition, which is a therapeutic rather than a diagnostic function.

No

The device description explicitly lists physical components: a balloon catheter, an insertion device, and an inflation device. These are hardware components, not software.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • Device Function: The TubaVent balloon dilatation system is a surgical device used to physically dilate the Eustachian tube within the patient's body. It does not analyze any specimens taken from the body.
  • Intended Use: The intended use is to treat a condition by physically modifying a part of the body, not to diagnose or monitor a condition through laboratory analysis.

Therefore, based on the provided information, the TubaVent balloon dilatation system is a surgical device, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The TubaVent balloon dilatation system is intended to dilate the cartilaginous portion of the Eustachiant of persistent obstructive Eustachian tube dysfunction in patients 18 years and older.

Product codes

PNZ

Device Description

The TubaVent balloon dilatation system is an Eustachian Tube Balloon Dilation System consisting of the balloon catheter, the Tubalnsert insertion device and the inflation device. It is used for dilation of the cartilaginous portion of the Eustachian tube in persistent obstructive Eustachian tube dysfunction. The balloon catheter TubaVent is available in two versions where the balloon diameter is different: 3 and 4.5 mm. The insertion device Tubalnsert has an angle of 45° at the distal end.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Eustachian tube

Indicated Patient Age Range

18 years and older.

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Non-clinical Tests: Bench
Biocompatibility: All tests (ISO 10993-5:2009 (Cytotoxicity), ISO 10993-10: 2010 (Sensitization & Irritation), ISO 10993-11: 2017 (acute systemic toxicity), ISO 10993-23: 2021 (sensitization)) were passed. The TubaVent balloon dilatation system fulfils all applicable biocompatibility requirements. The material used for this device is not cytotoxic. It does not cause sensitization, irritation or intracutaneous reactivity nor does it cause acute systemic toxicity.

Performance: All performance tests have demonstrated that the TubaVent balloon dilatation system performs as intended. Tests include dimensional verification, deflation time, balloon burst pressure, tensile strength, torque and fatigue tests. Simulation studies in a head model and in an animal cadaver model (sheep head) have ensured that the TubaVent balloon dilatation system functions in accordance with its design specifications and intended use. A human cadaver study was executed in order to fulfil the special control of 874.4180(b)(iv)(6). TubaVent balloon dilatation system. This human factors validation testing demonstrated that the device can be used by the intended users without serious use errors or problems, for the intended uses and under the expected use conditions. The results confirm that the TubaVent balloon dilatation system is safe and performs as intended.

Shelf life: Accelerated aging tests as well as real time aging tests have demonstrated that the TubaVent has a shelf life of 3 years, if stored under the recommended conditions. The insertion device Tubalnsert, has a shelf life of 5 years, the Tuba inflation devices a shelf life of 3 years.

Sterilization: Validation of the sterilization procedure and parameters has demonstrated that the TubaVent, Tubalnsert and the Inflation device reach the sterility assurance level (SAL) of 10-6.

Design validation: Design validation was performed in a human cadaver study.

Non-clinical Tests: Animal: No animal study was conducted.

Clinical Performance Data: No clinical performance study was conducted for the TubaVent balloon dilatation system.

Key Metrics

Not Found

Predicate Device(s)

K171761

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 874.4180 Eustachian tube balloon dilation system.

(a)
Identification. A Eustachian tube balloon dilation system is a prescription device that includes a flexible catheter attached to an inflatable balloon. The system is intended for use in dilating the cartilaginous portion of the Eustachian tube for treating persistent Eustachian tube dysfunction.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be evaluated:
(i) Mechanical testing, including tensile and flexural testing of catheter joints and materials.
(ii) Durability testing, including fatigue and burst pressure testing of the balloon materials and components.
(iii) Inflation and deflation characterization testing, including time and pressure measurements, and leak testing of the balloon.
(iv) Verification testing of safety features built into the device must be performed, including the characterization of catheter geometries and distal tip insertion limitation mechanisms.
(2) Simulated use testing in a clinically relevant model must demonstrate the reliability of the device to remain mechanically functional throughout the anticipated conditions of use, and validate that the design features limit access to only the cartilaginous portion of the Eustachian tube.
(3) The patient-contacting components of the device must be demonstrated to be biocompatible.
(4) Performance data must demonstrate the sterility of the device.
(5) Performance data must support shelf life by demonstrating continued sterility of the device, package integrity, and device functionality over the identified shelf life.
(6) Training must include simulated use on cadavers to ensure users can follow the instructions for use to allow safe use of the device.
(7) Labeling must include:
(i) Detailed instructions for use.
(ii) A detailed summary of the device technical parameters, including maximum allowed inflation pressure, allowable catheter geometries, and available balloon sizes.
(iii) A shelf life.

0

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August 3, 2023

Spiggle & Theis Medizintechnik GmbH Claudia Winterschladen Head of Regulatory Affairs International Burghof 4 Overath, North Rhime-Westphalia 51491 Germany

Re: K223542

Trade/Device Name: TubaVent Balloon Dilatation System Regulation Number: 21 CFR 874.4180 Regulation Name: Eustachian Tube Balloon Dilation System Regulatory Class: Class II Product Code: PNZ Dated: June 30, 2023 Received: July 3, 2023

Dear Claudia Winterschladen:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/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 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,

Joyce C. Lin -S

for Shu-Chen Peng, Ph.D. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K223542

Device Name TubaVent Balloon Dilatation System

Indications for Use (Describe)

The TubaVent balloon dilatation system is intended to dilate the cartilaginous portion of the Eustachiant of persistent obstructive Eustachian tube dysfunction in patients 18 years and older.

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)

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Section 5 - 510(k) Summary

as required by 21 CFR 807.92(c)

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1. Owner of the 510(k) [807.92(a)(1)]

| Manufacturer / 510(k) Submitter | Spiggle & Theis Medizintechnik GmbH
Burghof 4
51491 Overath / Germany |
|-----------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Establishment Registration Number | 3002858762 |
| Phone / Fax number | +49 2206 9081-65 / +49 2206 9081-13 |
| Contact Person for 510(k) | Claudia Winterschladen
Head of Regulatory Affairs International
Email: c.winterschladen@spiggle-theis.com |
| Date, 510(k) summary was prepared | 2022-11-10 |

2. Device Identification [807.92(a)(2)]

Device Trade NameTubaVent Balloon Dilatation System
Device Common or Usual NameN/A
Classification/Regulation NameEustachian Tube Balloon Dilation System
Device Regulation Number21 CFR 874.4180
Device Classification Product CodePNZ
Device ClassClass II
Regulation Medical Specialty / Review PanelEar, Nose & Throat

3. Predicate Device [807.92(a)(3)]

Manufacturer / 510(k) SubmitterAcclarent Inc.
510(k) No.K171761
Device Trade NameAcclarent Aera®
Device Common or Usual NameN/A
Classification / Regulation NameEustachian Tube Balloon Dilation System
Device Regulation Number21 CFR 874.4180
Device Classification Product CodePNZ
Device ClassClass II
Regulation Medical Specialty / Review PanelEar, Nose & Throat

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4. New Device Description [807.92(a)(4)]

| Description | The TubaVent balloon dilatation system is an Eustachian Tube Balloon
Dilation System consisting of the balloon catheter, the Tubalnsert
insertion device and the inflation device. It is used for dilation of the
cartilaginous portion of the Eustachian tube in persistent obstructive
Eustachian tube dysfunction. The balloon catheter TubaVent is available in
two versions where the balloon diameter is different: 3 and 4.5 mm. The
insertion device Tubalnsert has an angle of 45° at the distal end. |
|--------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| How it functions | The balloon is located at the distal end of the TubaVent and is inflated using
sterile isotonic saline solution NaCl 0.9 % to 10 bar. The inflation is
controlled with help of the pressure gauge on the inflation device. The
balloon pressure is then hold for 2 minutes. Insertion of the TubaVent into
the Eustachian tube (ET) is done with the Tubalnsert via a patient's nostril.
The procedure is usually carried out under general anesthesia. Evidence is
emerging in the scientific literature that the procedure can be done under
local anesthesia, sedation, and analgesia. Real-world clinical data collected
in a pilot feasibility study from 10 patients (5 received bilateral BET)
supports the use of the TubaVent short device under local anesthesia. The
use of local anesthesia for this procedure is evident with appropriate
patient preparation, which may include supplemental medication for
patient management.1 |
| Scientific concept | Eustachian tube dysfunction (ETD) is a common condition resulting from
inadequate opening of the Eustachian tube or the inability to
appropriately equalize pressure between the middle ear and the
environment, respectively. This may lead to hearing loss, chronic otitis
media, tinnitus, and vertigo. The principle of dilatation to open an
obstructed tube has been successfully applied for many years for example
in blood vessels. The marketing of the first Eustachian balloon dilation
catheter was permitted by the FDA in September 2016. The decision was
based on a randomized clinical trial in which 52 % of treated patients had
tympanogram results within a normal functioning range six weeks after
the procedure compared to 14 % of the patients, who were treated with
conventional medical management (nasal spray). |
| Significant physical and
performance | The TubaVent balloon dilatation system is offered with two different
balloon diameters, 3.0 and 4.5 mm. The balloons are both 20 mm long |
| characteristics (design,
material etc.) | and are made of polyamide. The balloon is semi-compliant. The working
length of the catheter is for both variants 236 mm. |

– Luukkainen V, Jero J, Sinkkonen ST. Balloon Eustachian tuboplasty under monitored anaesthesia care with different balloon dilation devices: A pilot feasibility study with 18 patients. Clin Otolaryngol. 2019 Jan;44(1):87-90. doi: 10.11111/coa.13236. Epub 2018 Nov 4. PMID: 30281926.

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5. Intended Use New Device [807.92(a)(5)]

Intended use andThe TubaVent balloon dilatation system is intended to dilate the cartilaginous portion of the Eustachian tube for treatment of persistent obstructive Eustachian tube dysfunction in patients 18 years and older.
patient population

6. Summary technological characteristics compared to predicate [807.92(a)(6)]

CharacteristicsNew devicePredicate deviceCorrespondence
Catheter
Catheter
Total Length [mm]270327Different: The TubaVent
balloon dilatation
system is shorter thus
perfectly adapted to the
insertion instrument
TubaInsert, which
prevents the catheter
from being pushed too
far into the Tuba
Eustachii.
Catheter
Working Length [mm]236Not knownSee explanation in
previous line.
Distal shaft end
(balloon)flexibleflexibleIdentical
Proximal shaft endHypotube made of
stainless steelHypotube, rigidIdentical: In both
devices the proximal
shaft is a rigid hypotube
Insertion / Shaft markerNo, because the
protruding length of the
TubaVent Balloon out of
the TubaInsert is fixed by
design features.YesDifferent: The length of
the TubaVent
protruding from the
TubaInsert is fixed. After
the proximal end of the
TubaVent has come into
contact with the
CharacteristicsNew devicePredicate deviceCorrespondence
proximal end of the
Tubalnsert, further
advancement out of the
Tubalnsert is not
possible and therefore
no shaft marker is
required. Therefore, this
difference does not
cause any new issue of
safety or effectiveness
of the new device.
ActuatorNoYesDifferent: The function
of the actuator of the
predicate device is to
facilitate single-handed
advancement and
retraction of balloon
catheter, if required.
The balloon catheter of
the predicate device can
also be moved forward
with two hands.
Furthermore, the
usability study
confirmed that the two
hand procedure of the
new device does not
cause new safety issues
as the movement of the
catheter is done under
endoscopic control.
Balloon catheter designDual lumen tubing: outer
lumen is used to expand
the balloonDual lumen tubingIdentical
Inflation connectionLuer connectorLuer connectorIdentical
Balloon
Length x Diameter
[mm] at working
pressure- Short: 3.28 x 20.0
  • Short wide: 4.94 x 20.0 | 6.0 x 16.0 | Similar: The TubaVent
    balloon has a smaller
    diameter and is 4 mm
    longer than the |
    | Characteristics | New device | Predicate device | Correspondence |
    | | | | diameter is less
    traumatic and a longer
    balloon ensures that a
    longer part of the
    cartilaginous part of the
    ET (approx. 24 mm long)
    is dilated. |
    | Type | Semi-compliant | Non-compliant | Different: Semi-
    compliant balloons
    provide more
    compliance than a non-
    compliant balloon and
    more flexibility to ease
    delivery than a non-
    compliant balloon.
    Schubert et al.
    published a comparison
    of the balloons in 20182,
    which shows that the
    Acclarent Aera balloon
    also behaves like a
    semi-compliant balloon.
    Thus, both balloons are
    equivalent, although
    Acclarent describes its
    balloon as non-
    compliant. |
    | Material | PA (Polylauryllactam;
    nylon) | PET (Polyethylene
    terephthalate;
    polyester) | Similar, as both
    materials are
    thermoplastic and
    chemically inert or
    chemically resistant,
    respectively. |
    | Catheter tip | | | |
    | Characteristics | New device | Predicate device | Correspondence |
    | Design | Olive-shaped; 1.2 mm in diameter; atraumatic
    Image: Catheter | Ball-shaped; 2.4 mm in diameter; atraumatic | Similar: Both designs prevent catheter travel into the isthmus |
    | Material | Pebax | Nylon | Similar: Both materials are soft and therefore atraumatic. |
    | Insertion Device | | | |
    | Separate | Yes: Tubalnsert | Yes | Identical |
    | Rigid shaft | Yes, hypotube | Yes, hypotube | Identical |
    | Angled tip | Yes | Yes | Identical |
    | Atraumatic tip | Yes | Yes | Identical |
    | Distal angled tip | Yes | Yes | Identical |
    | Inflation device | | | |
    | Name | Inflation device | Acclarent Balloon Inflation device | N/A |
    | Photo | Image: Inflation device | Image: Acclarent Balloon Inflation device | Similar in design and shape |
    | Indications for use | The inflation device (...) is intended to inflate, deflate and monitor pressure in the TubaVent. | The ACCLARENT® Balloon Inflation Device is used to inflate the balloon. | Similar wording with identical meaning |
    | Syringe volume | 30 cc | 20 cc | Different |
    | Pressure gauge | Atm and PSI | Atm and PSI | Identical |
    | Length (Plunger not extended) | 23.9 cm | 8.1" [ $ ≤ $ 20.575 cm] | Different due to the greater volume of the subject device. |
    | Characteristics | New device | Predicate device | Correspondence |
    | Length (Plunger
    extended) | 34.9 cm | 11.3" [ $\triangleq$ 28.702
    cm] | Different due to the
    greater volume of the
    subject device. |

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2 Schubert J, Wilfling T, Schümann K, Paasche G, Grabow N, Schmidt W. Investigation of balloon dilatation devices for treatment of Eustachian tube dysfunction. Current Directions in Biomedical Engineering 4(1): 529-533, 2018.

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7. Non-clinical Tests: Bench [807.92(b)(1)]

| Biocompatibility | - ISO 10993-5:2009 (Cytotoxicity)

  • ISO 10993-10: 2010 (Sensitization & Irritation)
  • ISO 10993-11: 2017 (acute systemic toxicity)
  • ISO 10993-23: 2021 (sensitization)
    All tests were passed. The TubaVent balloon dilatation system fulfils
    all applicable biocompatibility requirements. The material used for
    this device is not cytotoxic. It does not cause sensitization, irritation
    or intracutaneous reactivity nor does it cause acute systemic
    toxicity. |
    |------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
    | Performance | All performance tests have demonstrated that the TubaVent balloon
    dilatation system performs as intended. Tests include dimensional
    verification, deflation time, balloon burst pressure, tensile strength,
    torque and fatigue tests. Simulation studies in a head model and in
    an animal cadaver model (sheep head) have ensured that the
    TubaVent balloon dilatation system functions in accordance with its
    design specifications and intended use.
    A human cadaver study was executed in order to fulfil the special
    control of 874.4180(b)(iv)(6).
    TubaVent balloon dilatation system. This human factors validation
    testing demonstrated that the device can be used by the intended
    users without serious use errors or problems, for the intended uses
    and under the expected use conditions. The results confirm that the
    TubaVent balloon dilatation system is safe and performs as
    intended. |
    | Shelf life | Accelerated aging tests as well as real time aging tests have
    demonstrated that the TubaVent has a shelf life of 3 years, if stored
    under the recommended conditions. The insertion device
    Tubalnsert, has a shelf life of 5 years, the Tuba inflation devices a
    shelf life of 3 years. |

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| Sterilization | Validation of the sterilization procedure and parameters has
demonstrated that the TubaVent, Tubalnsert and the Inflation
device reach the sterility assurance level (SAL) of 10-6. |
|-------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Design validation | Design validation was performed in a human cadaver study. |

8. Non-clinical Tests: Animal

| NI.
No
o animal study
WAS
conditioner

n will would and the world and the world of the start of the start of the start of
---------------------------------------------------------------------------------------------------------------------------------------------

9. Clinical Performance Data [807.92(b)(2)]

| N/A | No clinical performance study was conducted for the TubaVent
balloon dilatation system. |

-------------------------------------------------------------------------------------------------

Summary non-clinical and clinical tests [807.92(b)(3)] 10.

The TubaVent balloon dilatation system has met all acceptance criteria for attributes like dimensions, balloon burst pressure etc. Biocompatibility testing was performed in accordance to applicable parts of the the ISO 10993 standard. The TubaVent and all components of the system are biocompatible and do not cause sensitization or irritations. The sterilization process and parameters were validated in accordance with ISO 11135:2014. A sterility assurance level (SAL) of 10 · is reached. Packaging shelf life has been proven for 3 years for the TubaVent and the inflation device (5 years for Tubalnsert) via accelerated and/or real time aging. Thus, the performance test results demonstrate, that the TubaVent balloon dilatation system is as safe as the predicate device.

11. Conclusion

Based on the non-clinical performance data, it is concluded that the TubaVent balloon dilatation system is substantially equivalent to the predicate device under the Federal Food, Drug and Cosmetic Act.

Minor differences in design or material of the TubaVent balloon dilatation system compared to the predicate device do not raise any new questions with regard to the safety or performance or effectiveness of the medical device.

The TubaVent balloon dilatation system is identical to its predicate device with respect to the intended use and the indications for use. It uses the same fundamental scientific technology compared to the predicate device, as it has the same operating principle and the same basic design.

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SPIGGLE & THEIS therefore believes that the TubaVent balloon dilatation system is as safe and effective and performs as the predicate device when used as instructed by knowledgeable and trained surgeons.

TubaVent balloon dilatation system is substantial equivalent to the legally marketed predicate device.