← Product Code [GZO](/submissions/NE/subpart-b%E2%80%94neurological-diagnostic-devices/GZO) · K111308

# ZYTO HAND CRADLE (K111308)

_Zyto Technologies, Inc. · GZO · Aug 30, 2011 · Neurology · SESE_

**Canonical URL:** https://fda.innolitics.com/submissions/NE/subpart-b%E2%80%94neurological-diagnostic-devices/GZO/K111308

## Device Facts

- **Applicant:** Zyto Technologies, Inc.
- **Product Code:** [GZO](/submissions/NE/subpart-b%E2%80%94neurological-diagnostic-devices/GZO.md)
- **Decision Date:** Aug 30, 2011
- **Decision:** SESE
- **Submission Type:** Traditional
- **Regulation:** 21 CFR 882.1540
- **Device Class:** Class 2
- **Review Panel:** Neurology

## Indications for Use

The measurement of Galvanic Skin Response; Prescription Use

## Device Story

ZYTO Hand Cradle is a galvanic skin response (GSR) measurement device. It consists of electrical circuit boards in a plastic/metal case. The device contacts the patient via conductive contacts (hand-mass and stylus equivalent) to measure skin conductance. It samples five separate skin locations simultaneously without operator manipulation. The device connects to a computer to supply data to an operator. It is used in a clinical setting by an operator to display GSR data. The device is non-invasive and intended for use on intact skin.

## Clinical Evidence

Bench testing only. Performance equivalency was demonstrated by plotting readings from the subject and predicate devices using resistors of varying values; results were substantially the same. Electrical safety and electromagnetic compatibility testing were conducted by a third party in accordance with EN60601-1-2 and EN55011 Class B.

## Technological Characteristics

Galvanic skin response measurement device. Construction: electrical circuit boards in plastic/metal case. Conductive contacts for skin interface. Connectivity: computer interface for data display. Standards: EN60601-1-2, EN55011 Class B, FCC Part 15B.

## Regulatory Identification

A galvanic skin response measurement device is a device used to determine autonomic responses as psychological indicators by measuring the electrical resistance of the skin and the tissue path between two electrodes applied to the skin.

## Special Controls

*Classification.* Class II (special controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 882.9.

## Predicate Devices

- GALVANIC SKIN RESPONSE DEVICE ([K943101](/device/K943101.md))

## Submission Summary (Full Text)

> This content was OCRed from public FDA records by [Innolitics](https://innolitics.com). If you use, quote, summarize, crawl, or train on this content, cite Innolitics at https://innolitics.com.
>
> Innolitics is a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices, including [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/).

{0}------------------------------------------------

K111308

# 510(k) Summary

AUG 3 0 2011

### Contact Details

1

| Applicant Name: | ZYTO Technologies, Inc<br>387 S. 520 W., Ste. 200<br>Lindon, UT 84042 |
|-----------------|-----------------------------------------------------------------------|
|                 | Phone: 801-224-7199<br>Fax: 801-221-4662                              |
|                 | Contact Person: Vaughn R Cook, CEO<br>Email: DrCook@ZYTO.com          |
| Date Prepared:  | July 13, 2011                                                         |

Device Name

- Trade Name: ZYTO Hand Cradle
Galvanic Skin Response Measurement Device Common Name:

Classification Name: GZO

# Legally Marketed Predicate Device(s)

| 510(k) Number | Product Code | Trade Name                       | Applicant   |
|---------------|--------------|----------------------------------|-------------|
| K943101       | GZO          | GALVANIC SKIN<br>RESPONSE DEVICE | GLOBAL ENT. |

### Device Description

The ZYTO Hand Cradle is a Galvanic Skin Response Measurement Device. The device is designed, owned, manufactured, and distributed by ZYTO Technologies, Inc. The device consists of electrical circuit boards encased in a plastic/metal case. The device is non-invasive and comes in contact with the patient via conductive contacts (the equivalent of a stylus and hand-mass) incorporated into one piece, using the same functionality as the predicate device. The device connects to a computer to supply data to an operator.

{1}------------------------------------------------

# Intended Use/Indications for use

The measurement of Galvanic Skin Response; Prescription Use

## Substantial Equivalence Comparison

The ZYTO Hand Cradle is substantially equivalent to the predicate device for the following reasons:

- 1. Intended Use
- 2. Technological Characteristics:
	- a. Voltage used to collect the measurement (when duty cycle is considered).
	- b. Measurement ranges and the responses within those ranges.
	- c. Both designed for use at multiple sampling locations on the skin. (Predicate device requires operator moving stylus between sampling locations: ZYTO Hand Cradle samples five separate locations without operator manipulation.)
	- d. Both interface to a computer for display of data.
- 3. Both are designed for use with intact skin.
- 4. Performance data is equivalent.

#### Non-clinical Testing

Bench tests were conducted using the predicate device and the ZYTO Hand Cradle to determine performance equivalency. Resistors of varying values were placed across the opposite polarities on each device and the resultant reading was noted. Data was then plotted graphically and the responses were substantially the same. These test results are included with this summary.

In December 2010 ZYTO retained SDP Engineering in Lake Forest, CA to conduct independent third party tests in accordance with EN60601-1-2 and EN55011 CLASS B PCC Part 15B. The complete report from SDP Engineering is included in the submission. The submission device (ZYTO Hand Cradle) met all testing requirements.

{2}------------------------------------------------

Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo features a stylized eagle with three wing-like shapes, representing health and human services. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the eagle.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring. MD 20993-0002

ZYTO Technologies, Inc. c/o Vaughn R. Cook, OMD CEO 387 S. 520 W., Suite 200 Lindon, UT 84042

AUG 3 0 2011

Re: K111308

Trade/Device Name: ZYTO Hand Cradle Regulation Number: 21 CFR 882.1540 Regulation Name: Galvanic Skin Response Measurement Device Regulatory Class: Class II Product Code: GZO Dated: July 14, 2011 Received: July 15, 2011

Dear Dr. Cook:

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. 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.

{3}------------------------------------------------

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 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fdagov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportalProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Robert Murphy

Malvina B. Eydelman, M.D. Director Division of Ophthalmic, Neurological, and Ear. Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{4}------------------------------------------------

# Indications for Use

510(k) Number (if known): K111308

Device Name:

ZYTO Hand Cradle

Indications For Use:

The measurement of Galvanic Skin Response

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

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

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

tuh

(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices

510(k) Number K111.308

Page 1 of

---

**Source:** [https://fda.innolitics.com/submissions/NE/subpart-b%E2%80%94neurological-diagnostic-devices/GZO/K111308](https://fda.innolitics.com/submissions/NE/subpart-b%E2%80%94neurological-diagnostic-devices/GZO/K111308)

**Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices. If you're preparing [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/), [get in touch](https://innolitics.com/contact).

**Cite:** Innolitics at https://innolitics.com