K Number
K223913
Device Name
Socrates Aspiration System
Date Cleared
2023-09-20

(265 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
As part of the Socrates Aspiration System, the Socrates 38 Aspiration Catheter with a compatible suction pump is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral -M1 and M2 segments, basilar, and vertebral arteries) 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. As part of the Socrates Aspiration System, the Socrates Aspiration Tubing is indicated to connect the Socrates 38 Aspiration Catheter to a compatible suction pump.
Device Description
The Scientia Vascular Socrates Aspiration System is composed of two components: the Socrates 38 Aspiration Catheter, designed to aid in accessing vasculature, and the Socrates Aspiration Tubing, designed to connect the aspiration catheter to a compatible suction pump and control flow between them. When used with a compatible vacuum pump, these components facilitate the aspiration and removal of thrombus from the neurovasculature. Both components are supplied sterile for single use only. The Socrates 38 Aspiration Catheter is a single lumen, variable stiffness catheter designed to be advanced over a steerable guidewire. The catheter shaft design includes nitinol, polymers of varying durometer, and an internal lubricious liner. To reduce friction during manipulation, a hydrophilic coating is applied to the distal exterior section of the catheter shaft. A single radiopaque tip marker provides visualization under fluoroscopy. The proximal end of the catheter includes a clear hub with Luer lock and a stainless-steel strain relief. The catheter is supplied sterile, for single use only and is packaged with a rotating hemostasis valve (RHV). The Socrates Aspiration Tubing is designed to connect the Socrates 38 Aspiration Catheter to a compatible vacuum pump and control flow between them. The aspiration tubing consists of tubing attached to a suction connector on one end and a male Luer lock on the other with an intermediate on/off fluid flow control device and is supplied sterile and for single use only.
More Information

Not Found

No
The document describes a mechanical aspiration system for removing blood clots and does not mention any software or algorithms that would utilize AI or ML.

Yes.
The device is used for revascularization and removal of thrombus in patients with acute ischemic stroke, which directly treats a medical condition.

No

The device is indicated for revascularization and removal of thrombus, which are therapeutic actions, not diagnostic ones. Although it uses fluoroscopy for visualization, this is for guiding the therapeutic procedure rather than for diagnosing the condition itself.

No

The device description clearly outlines physical components (catheter, tubing) made of various materials, indicating it is a hardware-based medical device, not software-only.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are tests performed on samples taken from the human body (like blood, urine, or tissue) to detect diseases, conditions, or infections.
  • Device Function: The Socrates Aspiration System is a medical device used directly within the body (intracranially) to physically remove blood clots causing stroke. It is a therapeutic device, not a diagnostic test performed on a sample outside the body.
  • Intended Use: The intended use clearly describes a procedure for revascularization by removing a physical obstruction (thrombus) from blood vessels.
  • Device Description: The description details a catheter and tubing designed for aspiration within the neurovasculature.
  • Performance Studies: The performance studies focus on the physical function of the device in removing clots and its impact on the vessel, not on the accuracy of a diagnostic test.

Therefore, the Socrates Aspiration System falls under the category of a therapeutic medical device, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

As part of the Socrates Aspiration System, the Socrates 38 Aspiration Catheter with a compatible suction pump is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral -M1 and M2 segments, basilar, and vertebral arteries) 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.

As part of the Socrates Aspiration System, the Socrates Aspiration Tubing is indicated to connect the Socrates 38 Aspiration Catheter to a compatible suction pump.

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

NRY

Device Description

The Scientia Vascular Socrates Aspiration System is composed of two components: the Socrates 38 Aspiration Catheter, designed to aid in accessing vasculature, and the Socrates Aspiration Tubing, designed to connect the aspiration catheter to a compatible suction pump and control flow between them. When used with a compatible vacuum pump, these components facilitate the aspiration and removal of thrombus from the neurovasculature. Both components are supplied sterile for single use only.

The Socrates 38 Aspiration Catheter is a single lumen, variable stiffness catheter designed to be advanced over a steerable guidewire. The catheter shaft design includes nitinol, polymers of varying durometer, and an internal lubricious liner. To reduce friction during manipulation, a hydrophilic coating is applied to the distal exterior section of the catheter shaft. A single radiopaque tip marker provides visualization under fluoroscopy. The proximal end of the catheter includes a clear hub with Luer lock and a stainless-steel strain relief. The catheter is supplied sterile, for single use only and is packaged with a rotating hemostasis valve (RHV).

The Socrates Aspiration Tubing is designed to connect the Socrates 38 Aspiration Catheter to a compatible vacuum pump and control flow between them. The aspiration tubing consists of tubing attached to a suction connector on one end and a male Luer lock on the other with an intermediate on/off fluid flow control device and is supplied sterile and for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Fluoroscopy

Anatomical Site

Intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries)

Indicated Patient Age Range

Not Found

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-Clinical Performance Data:

  • Biocompatibility Testing: Performed in accordance with ISO 10993-1: 2018.
    • Socrates 38 Aspiration Catheter:
      • Cytotoxicity (MEM Elution): Cell culture was observed for cytotoxic reactivity. Conclusion: Non-cytotoxic.
      • Sensitization: Study animals with subject device were observed for dermal sensitization. Conclusion: No sensitization reaction.
  • Functional Testing: Performed in accordance with ISO 10555-1:2013, ISO 80369-7:2016, ISO 80369-20:2015, AAMI TIR 42: 2021, and FDA Guidance Documents: "Intravascular Catheters, Wires, and Delivery Systems with Lubricious Coatings - Labeling Considerations (October 2019)", and "Non-Clinical Engineering Tests and Recommended Labeling for Intravascular Stents and Associated Delivery Systems (April 2010)."
    • Socrates 38 Aspiration Catheter:
      • Visual & Dimensional: Pass
      • Dynamic Flow: Pass
      • Liquid Leak / Static Burst: Pass
      • Torque - Turns to Failure: Pass
      • Simulated Clot Retrieval and Compatibility Testing (System): Pass
      • Tensile/Elongation: Pass
      • Flexural Fatigue: Pass
      • Particulate: Pass
      • Coating Integrity: Pass
      • Suction Flow Rate (System): Pass
      • Tip Stiffness: Pass
      • Delivery and Retrieval: Pass
      • Air Ingress/Negative Collapse: Pass
      • Kink Radius: Pass
      • Hub Luer Design Verification: Pass
      • Corrosion Resistance: Pass
      • Compatibility with Agents: Pass
      • Usability and Radiopacity Validation: Physicians evaluated subject and predicate catheters for various performance characteristics, including radiopacity, in a human cadaver. Pass.
    • Socrates Aspiration Tubing:
      • Visual & Dimensional: Pass
      • Vacuum Drop: Pass
      • Leakage: Pass
      • Negative Collapse (Degree of Collapse): Pass
      • Joint Tensile: Pass
      • Simulated Clot Retrieval and Compatibility Testing (System): Pass
      • Suction Flow Rate (System): Pass
    • Additional Testing: Shelf-life, packaging integrity, and sterilization including ethylene oxide (EO), ethylene chlorohydrin (ECH) residuals, and bacterial endotoxin levels.
  • Animal Study: Comparative animal study conducted under Good Laboratory Practices (GLP) in a porcine model against a control (the Penumbra System with the ACE 68 Reperfusion Catheter).
    • Assessments: Aspiration of experimental soft and firm clots and application of maximum vacuum with the device in a wedged position against the vessel wall.
    • Time points: Subacute (3 day) and chronic (30 day).
    • Key results: Clot aspiration and wedge assessment results were comparable between the test and control systems. Angiographic and histological evaluations concluded the systems were comparable at all time points.

Clinical Performance Data: No clinical study was conducted as non-clinical performance data was determined to be sufficient.

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.

K113163

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

Not Found

§ 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).

0

September 20, 2023

Image /page/0/Picture/1 description: The image shows the logos of the Department of Health & Human Services and the U.S. Food & Drug Administration. The Department of Health & Human Services logo is on the left and features a stylized human figure. The FDA logo is on the right and features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

Scientia Vascular, Inc. Thomas Lippert Regulatory Affairs Associate 3487 West 2100 South Suite 100 West Valley City, Utah 84119

Re: K223913

Trade/Device Name: Socrates Aspiration System Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: August 22, 2023 Received: August 23, 2023

Dear Thomas Lippert:

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,

Naira Muradyan -S

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

2

Indications for Use

510(k) Number (if known) K223913

Device Name Socrates™ Aspiration System

Indications for Use (Describe)

As part of the Socrates Aspiration System, the Socrates 38 Aspiration Catheter with a compatible suction pump is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral -M1 and M2 segments, basilar, and vertebral arteries) 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.

As part of the Socrates Aspiration System, the Socrates Aspiration Tubing is indicated to connect the Socrates 38 Aspiration Catheter to a compatible suction pump.

Type of Use (Select one or both, as applicable)

☑ Prescription Use (Part 21 CFR 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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3

Scientia Vascular, Inc Traditional 510(k) Socrates™ Aspiration System

Image /page/3/Picture/2 description: The image contains a logo with a stylized blue design at the top, followed by the word "SCIENTIA" in a stylized font. Below the word, there is the text "510(k) SUMMARY K223913" and then "(Per 21 CFR 807.92)". The text appears to be related to a regulatory submission or summary document.

SCIENTIA VASCULAR, INC Socrates™ Aspiration System

SUBMITTER

Submitter Name and Address Scientia Vascular, Inc. 3487 West 2100 South Suite 100 West Valley City, UT 84119

Contact Person Thomas Lippert Regulatory Affairs Associate Phone: 1 (888) 385-9016 Email: regulatory(@scientiavascular.com

Date Prepared September 20, 2023

DEVICE

Trade Name:Socrates Aspiration System
Common Name:Catheter, Thrombus Retriever
Classification Name:Percutaneous Catheter
Regulation:21 CFR 870.1250
Product Code:NRY
Review Panel:Neurology
Device Class:II

PREDICATE DEVICE

Predicate Device
Trade Name:Penumbra System® MAX
Predicate 510(k) Number:K113163
Device Models:Reperfusion Catheters 3MAX and 4MAX

4

DEVICE DESCRIPTION

The Scientia Vascular Socrates Aspiration System is composed of two components: the Socrates 38 Aspiration Catheter, designed to aid in accessing vasculature, and the Socrates Aspiration Tubing, designed to connect the aspiration catheter to a compatible suction pump and control flow between them. When used with a compatible vacuum pump, these components facilitate the aspiration and removal of thrombus from the neurovasculature. Both components are supplied sterile for single use only.

The Socrates 38 Aspiration Catheter is a single lumen, variable stiffness catheter designed to be advanced over a steerable guidewire. The catheter shaft design includes nitinol, polymers of varying durometer, and an internal lubricious liner. To reduce friction during manipulation, a hydrophilic coating is applied to the distal exterior section of the catheter shaft. A single radiopaque tip marker provides visualization under fluoroscopy. The proximal end of the catheter includes a clear hub with Luer lock and a stainless-steel strain relief. The catheter is supplied sterile, for single use only and is packaged with a rotating hemostasis valve (RHV).

The Socrates Aspiration Tubing is designed to connect the Socrates 38 Aspiration Catheter to a compatible vacuum pump and control flow between them. The aspiration tubing consists of tubing attached to a suction connector on one end and a male Luer lock on the other with an intermediate on/off fluid flow control device and is supplied sterile and for single use only.

INTENDED USE

The Socrates Aspiration System with a compatible suction pump is intended for use in the revascularization of patients with acute ischemic stroke.

INDICATIONS FOR USE

As part of the Socrates Aspiration System, the Socrates 38 Aspiration Catheter with a compatible suction pump is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) 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.

As part of the Socrates Aspiration System, the Socrates Aspiration Tubing is indicated to connect the Socrates 38 Aspiration Catheter to a compatible suction pump.

5

COMPARISON OF TECHNOLOGICAL CHARACTERISTICS

The technological characteristics of the Socrates Aspiration System are compared to those of the predicate device, the Penumbra System® MAX (K113163) in Table 1, below.

Table 1. Comparison between Subject & Predicate Device Technological Characteristics
Note: Differences are bolded
CharacteristicSubject Device
Socrates Aspiration System
(K223913)Predicate Device
Penumbra System® MAX
(K113163)
Reperfusion Catheter 3MAX
unless otherwise notedComparison
Analysis
Indications for
UseAs part of the Socrates
Aspiration System, the
Socrates 38 Aspiration
Catheter with a compatible suction pump is indicated for
use in the revascularization of
patients with acute ischemic
stroke secondary to intracranial
large vessel occlusive disease
( within the internal carotid,
middle cerebral - M1 and M2
segments, basilar, and
vertebral arteries) 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.
As part of the Socrates
Aspiration System, the Socrates
Aspiration Tubing is indicated
to connect the Socrates 38
Aspiration Catheter to a
compatible suction pump .The Penumbra System is intended
for use in the revascularization of
patients with acute ischemic
stroke secondary to intracranial
large vessel occlusive disease (in
the internal carotid, middle
cerebral - M1 and M2 segments,
basilar, and vertebral arteries)
within 8 hours of symptom onset.The differences
reflect that the
subject device
does not include a
suction pump and
the more current
wording regarding
IV t-PA therapy.
Intended UseRevascularization of patients
with acute ischemic stroke.Revascularization of patients with
acute ischemic stroke.Same
Catheter
MaterialsHub
PolycarbonateHub
PolycarbonateThe differences
have been
evaluated via non-
clinical testing.
Strain Relief
Stainless SteelStrain Relief
Stainless Steel
Catheter Shaft
PEBAX, Polyurethane, Nitinol,
and PTFECatheter Shaft
Polyether Block Amide (PEBAX),
Urethane, Nylon, Stainless
Steel/Nitinol, and PTFE
Radiopaque Marker
TantalumRadiopaque Marker
Platinum/Iridium
Catheter
DimensionsOuter Diameter
Proximal: 0.053"
Distal: 0.053"
Inner Diameter
Proximal: 0.038"
Distal: 0.038"Proximal: 0.064"
Distal: 0.041"
Effective Lengths (3MAX)
153 cm
Hydrophilic Coating length
Effective Lengths
115 cm and 156 cm
Hydrophilic Coating length
90 cm95 cm
Effective Lengths (4MAX)
139 cm
Hydrophilic Coating length
Unknown
CoatingHydrophilicHydrophilicSame
Tip ShapeStraightStraightSame
Radiopaque
Markers1 Distally Located Radiopaque
Marker1 Distally Located Radiopaque
MarkerSame
Condition
SuppliedSterile, Single UseSterile, Single UseSame
Sterilization
MethodEthylene Oxide (EO)EOSame
Packaged
AccessoriesRotating Hemostasis Valve
(RHV)RHV and Shaping MandrelSimilar
Aspiration
Tubing Set
FeaturesLength: 100 in (254 cm)
Inner Diameter (ID): 0.110 in
Vacuum control: ClampLength: 112 in.
ID: 0.110 in
Vacuum control: Flow SwitchThe differences
have been
evaluated via non-
clinical testing.
Aspiration Pump
FeaturesPressure: -20 inHg to -29inHgPressure: -20 inHg to -29inHgSame

6

7

The subject device, Socrates Aspiration System, has technological characteristic differences as shown in Table 1 above when compared to the predicate device. These differences do not raise new questions of safety and effectiveness for the subject device. Evaluation of the risks for the subject device in the form of failure modes and effect analysis (FMEA) was conducted along with testing of the subject device to demonstrate the substantial equivalence to the predicate.

NON-CLINICAL PERFORMANCE DATA

The following non-clinical performance data were provided in support of the substantial equivalence determination:

  • Biocompatibility ●
  • Functional Testing ●
  • . Animal Study

Biocompatibility Testing

The biocompatibility evaluation of the subject device, Socrates Aspiration System, was performed in accordance with ISO 10993-1: 2018, and is summarized in Table 2 below.

Table 2. Summary of Subject Device Biocompatibility Testing Performed
TestTest SummaryConclusion of Testing
Socrates 38 Aspiration Catheter
Cytotoxicity
(MEM Elution)Cell culture was observed for
cytotoxic reactivity.Non-cytotoxic
SensitizationThe study animals with subject
device were observed for dermal
sensitization.No sensitization reaction.

8

9

Functional Testing

Following a risk assessment per ISO 14971:2012 Medical Devices - Application of Risk Management to Medical Devices, the functional testing summarized in Table 3 was performed in accordance with the following standards:

  • ISO 10555-1:2013 (corrected 2014) Intravascular catheters Sterile and single-. use catheters - Part 1: General requirements,
  • . ISO 80369-7:2016 Small bore connectors for liquids and gases in healthcare applications - Connectors for intravascular or hypodermic applications,
  • ISO 80369-20:2015 Small bore connectors for liquids and gases in healthcare ● applications - Common test methods,
  • AAMI TIR 42: 2021 Evaluation of Particulates Associated with Vascular Medical ● Devices.

As well as the FDA Guidance Documents:

  • Intravascular Catheters, Wires, and Delivery Systems with Lubricious Coatings -● Labeling Considerations (October 2019),
  • Non-Clinical Engineering Tests and Recommended Labeling for Intravascular Stents and ● Associated Delivery Systems (April 2010).

| Table 3. Summary of Subject Device Functional Testing

Socrates 38 Aspiration Catheter
TestTest Method SummaryResults
Visual & DimensionalTest per ISO-10555-1:2014.
Dimensional inspection per
engineering drawings.Pass
Dynamic FlowReference ISO-10555-1:2014.
Dynamic flow rate was
characterized.Pass
Liquid Leak / Static BurstTest Per ISO-10555-1:2014.Pass
Torque - Turns to FailureTorque - turns to failure were
evaluated in an anatomical model
with comparison to the predicate.Pass
Simulated Clot Retrieval
and Compatibility
Testing (System)An anatomical model designed to
simulate the tortuous
neurovasculature was used for
performance (including simulated
thrombectomy) testing with the
aspiration system (tubing and
RHV) attached to a vacuum pump.Pass
Tensile/ElongationReference ISO-10555-1:2014.
Peak tensile force and
elongation measured by
displacement at break.Pass

10

Socrates – Aspiration System
Flexural FatigueThe catheter was flexed for multiple cycles and inspected for damage.Pass
ParticulateParticulates of various size ranges were counted after simulated use in a tortuous path model with comparison to the predicate.Pass
Coating IntegrityFrictional force of the coated catheter portion was determined after simulated use in a tortuous path model. Coating integrity was visually inspected pre- and post-simulated use.Pass
Suction Flow Rate (System)Measured the suction flow rate at maximum pressure while the catheter is connected to the aspiration tubing.Pass
Tip StiffnessMeasured the cantilever bending stiffness of the catheter tip.Pass
Delivery and RetrievalMeasured the forces required to deliver and retrieve the catheter in a tortuous pathway with ancillary devices.Pass
Air Ingress/Negative CollapseTest per ISO-10555-1:2014 for air ingress through the catheter hub. Negative collapse testing checks for catheter lumen integrity while being subjected to a worst-case vacuum pressure.Pass
Kink RadiusThe catheter is wrapped around mandrels of descending sizes to determine minimum kink radius.Pass
Hub Luer Design VerificationTest per ISO-80369-7.Pass
Corrosion ResistanceTest Per ISO-10555-1:2014.Pass

11

Compatibility with AgentsThe catheters were inspected and functionally tested post exposure to agents (contrast media and saline) used during test procedures.Pass
Usability and Radiopacity ValidationPhysicians evaluated subject and predicate catheters for various performance characteristics, including radiopacity, in a human cadaver.Pass
Socrates Aspiration Tubing
Visual & DimensionalVisual and dimensional inspection per engineering drawing.Pass
Vacuum DropThe aspiration tubing was evaluated for ability to hold a vacuum over a specified time period.Pass
LeakageThe ability of the clamp to prevent leakage after a specified number of cycles was evaluated.Pass
Negative Collapse (Degree of Collapse)Test per ISO 10079-4.Pass
Joint TensilePeak tensile force measured at break.Pass
Simulated Clot Retrieval and Compatibility Testing (System)An anatomical model designed to simulate the tortuous neurovasculature was used for performance (including simulated thrombectomy) testing with the aspiration system (tubing and RHV) attached to a vacuum pump.Pass
Suction Flow Rate (System)Measured the suction flow rate at maximum pressure while the catheter is connected to the aspiration tubing.Pass

Additionally, the subject device and packaging were evaluated for the proposed shelf-life, packaging integrity and sterilization including ethylene oxide (EO), ethylene chlorohydrin (ECH) residuals, and bacterial endotoxin levels.

Animal Study

12

The safety and effectiveness of the Socrates Aspiration System was evaluated in a comparative animal study conducted under Good Laboratory Practices (GLP) in a porcine model against a control (the Penumbra System with the ACE 68 Reperfusion Catheter). Assessments included aspiration of experimental soft and firm clots and application of maximum vacuum with the device in a wedged position against the vessel wall. Both the subject and control systems were evaluated at subacute (3 day) and chronic (30 day) time points. Clot aspiration and wedge assessment results were comparable between the test and control systems. Angiographic and histological evaluations concluded the systems were comparable at all time points.

CLINICAL PERFORMANCE DATA

The non-clinical performance data presented were determined to be sufficient to support the substantial equivalence of the Socrates Aspiration System. Therefore, no clinical study was conducted.

CONCLUSION

The subject device, Socrates Aspiration System, has the same intended use and similar indications for use as the predicate device. The differences in technological characteristics do not raise new questions of safety or effectiveness and have been evaluated through testing and the resulting data demonstrate that the subject device, Socrates Aspiration System, is substantially equivalent to the predicate.