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510(k) Data Aggregation
(87 days)
C-BOOT LTD.
The IPC-Boot is a prescriptive device that induces controlled compression of the calf, the foot or a combined compression of both. The IPC-Boot is intended to assist patients, suffering from lymphatic or venous disorders, by treating many conditions including: Prevention of deep vein thrombosis (DVT), Enhancement of blood circulation, Reduction of post-operative pain and swelling, Reduction of wound-healing time, Stasis dermatitis, Treatment and assist healing of cutaneous ulceration, Venous stasis ulcers, Leg ulcers, Chronic venous insufficiencies, Reduction of edema, Prevent pooling of fluids in limbs, Lymphedema
IPC-Boot is actually a very similar version of C-Boot's legally marketed device, cleared under 510(k) number K041659. Similarly to the legally marketed device, it is made of the same materials and has the same design, technology and performances. The only modification that was made to the predicate device is the addition of external electric pump that can activate the device electrically when the patient is immobile. This modification provides a solution for such patients. The patient may choose whether the device will be used mechanically (self powered), by walking (as the original device) or electrically as the modified new device: IPC-Boot, when patient is immobile. The IPC-Boot is a wearable pneumatic compression technology embodied in a therapeutic boot that has the potential to increase treatment efficacy and improve the quality of life for peripheral vascular and lymph disorders patients. The IPC-Boot contains boot legging with inflatable sleeves from the patient's foot up to the knee. The IPC-Boot uses an external electric pump. The pump is generated the air to inflate the sleeves through the control system for producing intermittent compression to the lower limb. C-Boot's solution integrates the technological advantages of dynamic compression pumps that enable preset sequential pressure control which is identical to the pressure level of the preamended device (predicate). This enables the patient to individualize treatment regimes, with the mobility benefit of static compression stockings that activate the calf muscle pump and strengthened the body's natural tendency to enhance lymphatic and venous return, The modified device covers both self-powered and electrical compression devices and creates one integrated device.
This 510(k) summary describes a device, the IPC-Boot, which is an electrical lymph and venous-insufficiency system. The submission focuses on demonstrating substantial equivalence to a predicate device (C-Boot, K041659) by highlighting that the new device is a very similar version with the primary modification being the addition of an external electric pump for electrical activation when the patient is immobile. The submission asserts that this modification does not affect the device's intended use or alter its fundamental scientific technology.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not provide a table with specific, quantifiable acceptance criteria (e.g., pressure output ranges, cycle times, safety thresholds) for the IPC-Boot, nor does it present detailed study results against such criteria.
Instead, the submission states:
Acceptance Criterion | Reported Device Performance |
---|---|
Safety and Effectiveness | "New device verification and validation tests showed that it is as safe and as effective as the predicate device." |
"The evaluation of C-Boot non-clinical tests demonstrates that the device is as safe, as effective, and performs as well as or better than the predicate device (thanks to the electrical operation addition)." | |
Compliance with Predicate Device Specifications | "The modified device was tested with accordance to C-Boot's legally marketed device specification and all acceptance criteria were met." |
Labeling Claims Support | "Tests results are supporting all labeling claims and substantial equivalency." |
2. Sample Size Used for the Test Set and Data Provenance
The provided text does not include any information regarding the sample size used for the test set, nor does it specify the data provenance (e.g., country of origin, retrospective/prospective nature). The tests mentioned are "non-clinical" and seem to be engineering verification and validation rather than clinical studies with human subjects.
3. Number of Experts Used to Establish Ground Truth and Qualifications
Given that the document refers to "non-clinical tests" and "legally marketed device specification," it is highly unlikely that "experts" (like radiologists) were used to establish ground truth in the way medical imaging or diagnostic devices would require. The tests appear to be related to engineering specifications and performance, which would likely be assessed by engineers or technicians. No specific information on experts or their qualifications is provided.
4. Adjudication Method for the Test Set
The concept of an "adjudication method" (like 2+1 or 3+1) is typically relevant to clinical studies involving human interpretation or assessment, especially in cases of disagreement among experts. Since the tests described are non-clinical and focus on device specifications, an adjudication method in this sense is not applicable and not mentioned in the document.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study was done or mentioned. The submission is focused on demonstrating substantial equivalence through non-clinical testing of the modified device against the predicate's specifications, not on comparing human reader performance with and without AI assistance.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
The IPC-Boot is a physical medical device (pneumatic compression boot), not an algorithm or an AI-driven system. Therefore, the concept of a "standalone" algorithmic performance study does not apply to this device. The evaluation would be on the device's mechanical and electrical performance as a standalone unit.
7. Type of Ground Truth Used
The "ground truth" for the non-clinical tests appears to be the legally marketed device's (predicate device's) specifications and performance characteristics. The modified device was evaluated against these established benchmarks. The text indicates: "The modified device was tested with accordance to C-Boot's legally marketed device specification and all acceptance criteria were met." This implies that the 'ground truth' was a set of engineering and performance standards derived from the predicate device.
8. Sample Size for the Training Set
Since the IPC-Boot is a physical medical device and not an AI/machine learning system, a "training set" in the context of algorithm development is not applicable and not mentioned. The device itself is manufactured, not "trained."
9. How the Ground Truth for the Training Set Was Established
As there is no training set for this type of device, the method of establishing its ground truth is not applicable. The reference points for performance were the predicate device's specifications.
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(132 days)
C-BOOT LTD.
The C-Boot™ is a prescriptive device that induces controlled compression of the calf, the foot or a combined compression of both.
The C-Boot™ is intended to assist patients, suffering from lymphatic or venous disorders, by treating many conditions including:
- Prevention of deep vein thrombosis (DVT)
- Enhancement of blood circulation
- Reduction of post-operative pain and swelling
- Reduction of wound-healing time
- Stasis dermatitis
- Treatment and assist healing of cutaneous ulceration
- Venous stasis ulcers
- Leg ulcers
- Chronic venous insufficiencies
- Reduction of edema
- Prevent pooling of fluids in limbs
- Lymphedema
C-Boot Ltd. introduces a wearable pneumatic compression technology embodied in a therapeutic boot that has the potential to increase treatment efficacy and improve the quality of life for peripheral vascular and lymph distorders patients.
C-Boot's solution integrates the technological advantages of dynamic compression pumps, that enable preset sequential pressure control to individualize treatment regimes, with the mobility benefit of static compression stockings, that activate the calf muscle pump and strengthened the body's natural tendency to enhance lymphatic and venous return.
The device relates to a self-powered compression devices and methods for promoting circulation and therapeutic compression: It is comprising a pump, a plurality of sleeves or limb massager, which utilizes sequential, cyclical pressure, energy or vector forces, to aid circulation in a body part such as the limbs. The inflatable sleeves are filled with air by the pump and transmit massaging movement to the vessel walls whenever the patient wearing the device - walks or transmits body's weight from one leg to another. The pressure generated is a function of the user's body weight and gravitational force. The device provides methods to harness energy generated during movement and weight transfer and uses the energy for compressing to create a massaging effect on the circulation and the muscular-skeletal system.
The C-Boot™ - Lymph and Venous-Insufficiency System's 510(k) summary (K041659) does not contain sufficient information to fill out the requested table and details regarding acceptance criteria and a specific study proving device performance against those criteria.
The document indicates that the C-Boot™ is found substantially equivalent to predicate devices, namely the "WizAir™ Ambulant Pneumatic Compression System" (K002287) and the "Lympha Press®" (K810338). The rationale for substantial equivalence is based on similar technological characteristics and the claim that C-Boot™ functions within the same boundaries of performance as the predicate devices, without raising new safety or effectiveness issues.
However, the submission does not detail specific acceptance criteria for the C-Boot™ itself, nor does it present a study with quantitative results of the C-Boot™'s performance against such criteria. The document states:
- "A series of functional, performance and safety testing, including comparative analysis to Mego-Afek® and WizAir™ - demonstrates that C-Boot™ is substantially equivalent to Mego-Afek® and WizAir™, without raising new safety and/or effectiveness issues." (Page 3, Section 12. Performance Data)
This statement indicates that testing was performed, but it does not provide the results of these tests, any acceptance criteria used, or the methodology (sample size, ground truth, etc.) of these tests. Without this information, the requested table and details cannot be completed.
Therefore, I cannot provide the requested information based on the provided text.
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