K Number
K250958
Device Name
APRO 55 Swift Catheter and Alembic Aspiration Tubing
Manufacturer
Date Cleared
2025-04-28

(28 days)

Product Code
Regulation Number
870.1250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The APRO 55 Swift Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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 thrombolytic drug therapy or who failed thrombolytic drug therapy are candidates for treatment. The Alembic Aspiration Tubing is intended to connect the APRO 55 Swift Catheter to the aspiration pump.
Device Description
The APRO 55 Swift Catheter is a single-lumen, braid and coil reinforced catheter designed to remove thrombus from the vasculature using aspiration. It targets aspiration from a suction pump directly to the thrombus to remove thrombus from an occluded vessel. The catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature, guided over a neurovascular guidewire under fluoroscopic visualization to the site of the primary occlusion. The distal shaft has a hydrophilic coating to aid navigation, and a radiopaque marker is at the distal end for fluoroscopic visualization. It is used with an aspiration pump connected via the Alembic Aspiration Tubing, along with a legally marketed canister and accessories kit. The catheter is available in lengths of 125 cm and 137 cm and is supplied with an introducer sheath. The Alembic Aspiration Tubing connects the APRO 55 Swift Catheter to the aspiration pump and features a flow control valve with an ON/OFF switch. It is available in a single size.
More Information

K232971 APRO 55 Catheter and Alembic Aspiration Tubing

No.
There is no mention of AI, DNN, or ML, nor any components or functionalities that would typically involve an AI model, such as image processing for detection or diagnosis. The device description focuses on mechanical and physical attributes for thrombus removal.

Yes
The device is used for revascularization in stroke patients, which involves restoring blood flow to an area, fitting the definition of a therapeutic intervention.

No

This device is a therapeutic device intended for the revascularization of patients with acute ischemic stroke by removing thrombus using aspiration. It is not used for diagnosing medical conditions.

No

The device is not a software-only medical device. Both the Intended Use/Indications for Use and Device Description sections clearly describe physical hardware components, including a catheter, aspiration pump, and tubing, which are designed to physically remove thrombus from the vasculature. While some medical devices may incorporate software, this description details a tangible medical instrument, not a stand-alone software application.

No.

The device is an interventional medical device used for mechanical thrombectomy, designed to physically remove thrombus from blood vessels, not to provide information about a physiological state or disease through in vitro examination of specimens.

N/A

Intended Use / Indications for Use

The APRO 55 Swift Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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 thrombolytic drug therapy or who failed thrombolytic drug therapy are candidates for treatment.

The Alembic Aspiration Tubing is intended to connect the APRO 55 Swift Catheter to the aspiration pump.

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

NRY

Device Description

The APRO 55 Swift Catheter is a single-lumen, braid and coil reinforced catheter. The APRO 55 Swift Catheter is designed to remove thrombus from the vasculature using aspiration. The APRO 55 Swift Catheter targets aspiration from a suction pump directly to the thrombus to remove thrombus from an occluded vessel. The APRO 55 Swift Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire under fluoroscopic visualization to the site of the primary occlusion. The distal shaft has a hydrophilic coating to aid navigation through the vasculature. A radiopaque marker is located at the distal end of the catheter for visualization under fluoroscopy. For the aspiration source, the APRO 55 Swift Catheter is used in conjunction with an aspiration pump with pre-specified performance parameters that is connected using the Alembic Aspiration Tubing, along with a legally marketed canister and accessories kit. The APRO 55 Swift Catheter is available in lengths of 125 cm and 137 cm and is supplied with an introducer sheath.

The Alembic Aspiration Tubing connects the APRO 55 Swift Catheter to the aspiration pump. The flow control valve allows control of the aspiration flow using an ON/OFF switch. It is available in a single size.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

intracranial (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)

Substantial equivalence was established based on non-clinical performance data. Human clinical data were not deemed necessary.

Bench Testing: Performance bench testing was not conducted as sterility and shelf-life testing was sufficient for verification and validation of the change in packaging configuration.

Sterility and Shelf-Life: The APRO 55 Swift Catheter is sterilized using an ethylene oxide sterilization cycle that was verified to a sterility assurance level of 1 x 10⁻⁶ in accordance with ISO 11135. Aging studies established that the packaging remains functional for the labeled expiration date. Both t=0 and aging studies for packaging integrity and seal strength were performed and met the acceptance criteria.

Biocompatibility: The design and manufacturing of the subject device utilize the same materials, processing methods, and sterilization as the predicate device (K232971) and the reference device (K243287), for which Alembic has already conducted biocompatibility testing in compliance with ISO 10993-1. Therefore, no additional biocompatibility testing is required.

Animal Study: An animal study was deemed not necessary to support the substantial equivalence of the subject 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.

K232971 APRO 55 Catheter and Alembic Aspiration Tubing

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.

K243287 APRO 70 Swift Catheter and Alembic Aspiration Tubing

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

§ 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).

FDA 510(k) Clearance Letter - APRO 55 Swift Catheter and Alembic Aspiration Tubing

Page 1

U.S. Food & Drug Administration
10903 New Hampshire Avenue Doc ID # 04017.07.05
Silver Spring, MD 20993
www.fda.gov

April 28, 2025

Alembic, LLC
Lisa Yen
Vice President of Regulatory and Quality
627 National Avenue
Mountain View, California 94043

Re: K250958
Trade/Device Name: APRO 55 Swift Catheter and Alembic Aspiration Tubing
Regulation Number: 21 CFR 870.1250
Regulation Name: Percutaneous Catheter
Regulatory Class: Class II
Product Code: NRY
Dated: March 28, 2025
Received: March 31, 2025

Dear Lisa Yen:

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 (the 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 available 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.

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K250958 - Lisa Yen Page 2

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-device-reporting-mdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/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-devices/device-advice-comprehensive-regulatory-

Page 3

K250958 - Lisa Yen Page 3

assistance/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

Page 4

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120
Expiration Date: 07/31/2026
See PRA Statement below.

510(k) Number (if known): K250958

Device Name: APRO 55 Swift Catheter and Alembic Aspiration Tubing

Indications for Use (Describe):

The APRO 55 Swift Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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 thrombolytic drug therapy or who failed thrombolytic drug therapy are candidates for treatment.

The Alembic Aspiration Tubing is intended to connect the APRO 55 Swift Catheter to the aspiration 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)

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 (8/23) Page 1 of 1 PSC Publishing Services (301) 443-6740 EF

Page 5

510(k) Summary K250958

Date Prepared: April 24, 2025

Applicant NameAlembic, LLC
Applicant Address627 National Avenue, Mountain View, CA 94043 United States
Applicant Contact Telephone650-388-5087
Applicant ContactLisa Yen
Applicant Contact Emaillyen@alembicllc.com
Device Trade NameAPRO 55 Swift Catheter and Alembic Aspiration Tubing
Common NameCatheter, Thrombus Retriever
Classification NamePercutaneous Catheter
Regulation Number21 CFR 870.1250
Product CodeNRY
Predicate DeviceK232971 APRO 55 Catheter and Alembic Aspiration Tubing
Reference DeviceK243287 APRO 70 Swift Catheter and Alembic Aspiration Tubing

Device Description

The APRO 55 Swift Catheter is a single-lumen, braid and coil reinforced catheter. The APRO 55 Swift Catheter is designed to remove thrombus from the vasculature using aspiration. The APRO 55 Swift Catheter targets aspiration from a suction pump directly to the thrombus to remove thrombus from an occluded vessel. The APRO 55 Swift Catheter is introduced through a guide catheter or long femoral sheath and into the intracranial vasculature and guided over a neurovascular guidewire under fluoroscopic visualization to the site of the primary occlusion. The distal shaft has a hydrophilic coating to aid navigation through the vasculature. A radiopaque marker is located at the distal end of the catheter for visualization under fluoroscopy. For the aspiration source, the APRO 55 Swift Catheter is used in conjunction with an aspiration pump with pre-specified performance parameters that is connected using the Alembic Aspiration Tubing, along with a legally marketed canister and accessories kit. The APRO 55 Swift Catheter is available in lengths of 125 cm and 137 cm and is supplied with an introducer sheath.

The Alembic Aspiration Tubing connects the APRO 55 Swift Catheter to the aspiration pump. The flow control valve allows control of the aspiration flow using an ON/OFF switch. It is available in a single size.

Indications for Use

The APRO 55 Swift Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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 thrombolytic drug therapy or who failed thrombolytic drug therapy are candidates for treatment.

Page 1 of 6

Page 6

The Alembic Aspiration Tubing is intended to connect the APRO 55 Swift Catheter to the aspiration pump.

Technological Characteristics Comparison

The subject device has the same intended use and is identical to the predicate device, APRO 55 Catheter and Alembic Aspiration Tubing (K232971), in terms of technology, principle of operation, materials, sterilization method, and performance. The only difference lies in the packaging configuration. A comparison of the subject, predicate, and reference devices is provided in Table 1 below. There are no changes to the Alembic Aspiration Tubing compared to what was included in the K232971 submission.

Table 1. Comparison with the Predicate and Reference Devices

CategorySubject Device APRO 55 Swift Catheter and Alembic Aspiration TubingPredicate Device APRO 55 Catheter and Alembic Aspiration TubingReference device APRO 70 Swift Catheter and Alembic Aspiration Tubing
510(k) NumberK250958K232971K243287
Regulatory Class, Product CodeSameClass II, 21 CFR 870.1250, NRYClass II, 21 CFR 870.1250, NRY

Page 2 of 6

Page 7

Table 1. Comparison with the Predicate and Reference Devices

CategorySubject Device APRO 55 Swift Catheter and Alembic Aspiration TubingPredicate Device APRO 55 Catheter and Alembic Aspiration TubingReference device APRO 70 Swift Catheter and Alembic Aspiration Tubing
510(k) NumberK250958K232971K243287
Indications for UseThe APRO 55 Swift Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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 thrombolytic drug therapy or who failed thrombolytic drug therapy are candidates for treatment. The Alembic Aspiration Tubing is intended to connect the APRO 55 Swift Catheter to the aspiration pump.The APRO 55 Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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. The Alembic Aspiration Tubing is intended to connect the APRO 55 Catheter to the aspiration pump.The APRO 70 Swift Catheter with an aspiration pump and the Alembic Aspiration Tubing is intended 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 thrombolytic drug therapy or who failed thrombolytic drug therapy are candidates for treatment. The Alembic Aspiration Tubing is intended to connect the APRO 70 Swift Catheter to the aspiration pump.
Materials
HubSameNylonNylon
AdhesiveSameCyanoacrylateCyanoacrylate
Strain ReliefSameSantoprene (thermoplastic elastomer)Santoprene (thermoplastic elastomer)
LinerSamePolytetrafluoroethylene/Tecoflex compositePolytetrafluoroethylene/Tecoflex composite
Shaft Coil or BraidSame304V stainless steel braid 304V stainless steel coil304V stainless steel braid 304V stainless steel coil

Page 3 of 6

Page 8

Table 1. Comparison with the Predicate and Reference Devices

CategorySubject Device APRO 55 Swift Catheter and Alembic Aspiration TubingPredicate Device APRO 55 Catheter and Alembic Aspiration TubingReference device APRO 70 Swift Catheter and Alembic Aspiration Tubing
510(k) NumberK250958K232971K243287
ExtrusionsSameThermoplastic polyurethanes, thermoplastic elastomerThermoplastic polyurethanes, thermoplastic elastomer
Marker BandSamePlatinum/ iridiumPlatinum/ iridium
CoatingSameHydrophilic coatingHydrophilic coating
Dimensions
Outer DiameterSame as predicate0.066 inch0.083 inch
Inner DiameterSame as predicate0.055 inch0.070 inch
Effective LengthSame as predicate125, 137 cm125, 132, 135 cm
Coated LengthSame as predicate90, 102 cm90, 97, 100 cm
Tip ShapeSameStraightStraight
Accessories
Introducer SheathSameYesYes
Packaging Materials
PouchSameNylon/polyethylene/TyvekNylon/polyethylene/Tyvek
Hoop CoilSame as referenceNot includedPolyethylene
Packaging TubeNot includedPolyethyleneNot included
Packaging CardSamePolyethylenePolyethylene
Shelf CartonSameSolid bleached sulfate paperboardSolid bleached sulfate paperboard
Other
SterilizationSameEthylene oxideEthylene oxide
Shelf LifeSame as reference6 months1 year
Method of SupplySameSterile and single useSterile and single use

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Page 9

Table 1. Comparison with the Predicate and Reference Devices

CategorySubject Device APRO 55 Swift Catheter and Alembic Aspiration TubingPredicate Device APRO 55 Catheter and Alembic Aspiration TubingReference device APRO 70 Swift Catheter and Alembic Aspiration Tubing
510(k) NumberK250958K232971K243287
Packaging ConfigurationSame as referenceThe catheter is placed in a polyethylene dispenser tube. The dispenser tube and the introducer sheath are positioned on a polyethylene packaging card, which is then inserted into a Tyvek pouch. The pouch, along with the instructions for use (IFU) is packaged in a bleached sulfate carton box.The catheter is placed in a coiled polyethylene dispenser tube. The introducer sheath, positioned on a polyethylene packaging card, is attached to the dispenser tube, which is then inserted into a Tyvek pouch. The pouch, along with the IFU is packaged in a bleached sulfate carton box.

Alembic Aspiration Tubing

| Aspiration Tubing | Same | 110 inch length Tubing ID = 0.110 inch | 110 inch length Tubing ID = 0.110 inch |

Non-Clinical Testing Summary

The following data were provided to evaluate the performance and support the substantial equivalence of the APRO 55 Swift Catheter.

Bench Testing

Performance bench testing was not conducted as sterility and shelf-life testing was sufficient for verification and validation of the change in packaging configuration.

Sterility and Shelf-Life

The APRO 55 Swift Catheter is sterilized using an ethylene oxide sterilization cycle that was verified to a sterility assurance level of 1 x 10⁻⁶ in accordance with ISO 11135. Aging studies established that the packaging remains functional for the labeled expiration date. Both t=0 and aging studies for packaging integrity and seal strength were performed and met the acceptance criteria.

Biocompatibility

The subject APRO 55 Swift Catheter is classified as an externally communicating device with circulating blood contact for a limited duration (≤24 hours) in accordance with ISO 10993-1 and the FDA guidance document, Use of International Standard ISO 10993-1, "Biological

Page 5 of 6

Page 10

evaluation of medical devices—Part 1: Evaluation and testing within a risk management process."

The design and manufacturing of the subject device utilize the same materials, processing methods, and sterilization as the predicate device (K232971) and the reference device (K243287), for which Alembic has already conducted biocompatibility testing in compliance with ISO 10993-1. Therefore, no additional biocompatibility testing is required.

Animal Study

An animal study was deemed not necessary to support the substantial equivalence of the subject device.

Clinical Testing Summary

Substantial equivalence was established based on non-clinical performance data. Human clinical data were not deemed necessary.

Conclusion

Based on the comparison of the technological characteristics and the non-clinical testing described in this 510(k) Summary, the subject device is found to be substantially equivalent to the predicate device. The differences in technological characteristics do not raise new questions of safety and effectiveness.

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