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510(k) Data Aggregation

    K Number
    K210339
    Date Cleared
    2021-08-02

    (178 days)

    Product Code
    Regulation Number
    870.1210
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    For Bullfrog devices capable of treating <6 mm diameter vessels: In selective areas of peripheral and coronary vessels, the Bullfrog Micro-Infusion Device is intended for the infusion of diagnostic and therapeutic agents into the vessel wall and perivascular area, or intraluminally.

    For Bullfrog devices capable only of treating ≥6 mm diameter vessels: In selective areas of peripheral vessels, the Bullfrog Micro-Infusion Device is intended for infusion of diagnostic and therapeutic agents into the vessel wall and perivascular area, or intraluminally.

    Device Description

    The Mercator MedSystems Bullfrog Micro-Infusion Device is a wire-guided, singleoperator, endovascular catheter that consists of a perpendicular microneedle, which is sheathed by and contained within a semi-rigid polymer actuator balloon. The device is designed to be advanced to target vasculature and hydraulically actuated to move the microneedle through the external elastic lamina to deliver substances to adventitial and perivascular tissues. A compliant stabilizing balloon inflates with the actuator to provide a force opposite the needle tip for proper seating of the needle is retracted within the sheathing structure by vacuuming the hydraulic actuator.

    AI/ML Overview
    {
      "acceptance_criteria_and_performance_table": {
        "title": "Device Performance against Pre-determined Specifications and Acceptance Criteria",
        "headers": ["Test Category", "Test Performed", "Acceptance Criteria", "Reported Device Performance"],
        "rows": [
          ["Biocompatibility", "Biocompatibility Assessment", "Determined in accordance with ISO 10993", "Met"],
          ["Sterilization", "Sterilization testing", "Per ISO 11137-1:2006 and ISO 11137-2:2013", "Met"],
          ["Packaging", "Distribution testing", "Per ASTM D4169", "Met"],
          ["Packaging", "Pouch bubble testing", "Per ASTM F2096", "Met"],
          ["Packaging", "Pouch seal strength testing", "Per ASTM F88/F88M", "Met"],
          ["Labeling", "Label adhesion", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "System fluid delivery rate", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Catheter stiffness", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Actuator inflation and deflation time", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Actuator diameter minimum/maximum", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Actuator integrity after tortuous anatomy", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Actuator burst strength", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Drug line integrity", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Drug line burst strength", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Inflation line leakage under vacuum", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "System leakage under pressure", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Pressure relief valve cracking pressure and leak rate", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Radio-opaque markers intact", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Microneedle sheathing", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Microneedle insertion force at failure", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Microneedle durability", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Microneedle active length", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Actuator retraction force to failure and in vacuum", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Catheter bend kink resistance", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Tensile strength", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Torsional strength", "Not specified in document", "Met"],
          ["Mechanical and Fluid Delivery Performance", "Repetitive function and fatigue", "Not specified in document", "Met"]
        ]
      },
      "study_information": {
        "description": "The Bullfrog Micro-Infusion Device underwent non-clinical performance testing to demonstrate substantial equivalence and safety. This testing included mechanical and fluid delivery performance, biocompatibility, sterilization, and in-vivo safety studies. The testing adopted methodologies from prior versions of the device ([K161402](https://510k.innolitics.com/search/K161402)) for biocompatibility due to no material changes, and functional testing as defined in ISO 10555-1 with Amendments 1 and 2, along with customized testing for performance for changed components.",
        "sample_size_test_set": "Not specified in the provided document. The document refers to 'non-clinical testing of components' and 'Testing performed on the device' without detailing specific sample sizes for each test.",
        "data_provenance": "Not explicitly stated for all tests, but given the nature of the device (medical device) and the regulatory submission, the data is likely from laboratory testing conducted by Mercator MedSystems, Inc. The document refers to 'in-vivo safety studies' but does not provide details on their nature or origin. It is a retrospective summary of testing data for a 510(k) submission.",
        "number_of_experts_ground_truth_test_set": "Not applicable. The reported 'ground truth' or acceptance criteria for non-clinical performance tests are based on established standards (e.g., ISO, ASTM) and internal engineering specifications, not expert consensus on medical images or patient outcomes.",
        "qualifications_experts_ground_truth_test_set": "Not applicable. Ground truth for these non-clinical tests is based on published standards and engineering specifications.",
        "adjudication_method_test_set": "Not applicable. Adjudication methods are typically for clinical studies with subjective interpretations. Non-clinical tests usually have objective pass/fail criteria.",
        "mrmc_comparative_effectiveness_study": "No. The document details non-clinical performance testing of a medical device (catheter), not AI software. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not relevant or reported.",
        "standalone_algorithm_performance_study": "No. This is a physical medical device, not an algorithm or AI product. References to 'performance data' and 'performance testing' relate to the device's physical and functional attributes.",
        "type_of_ground_truth_used": "Engineering specifications, established international standards (ISO 10993, ISO 10555-1, ISO 11137-1, ISO 11137-2), and American Society for Testing and Materials (ASTM) standards (ASTM D4169, ASTM F2096, ASTM F88/F88M).",
        "sample_size_training_set": "Not applicable. This is a physical device, not an AI model, so there is no 'training set' in the context of machine learning.",
        "how_ground_truth_training_set_established": "Not applicable. There is no training set for this type of device."
      }
    }
    
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    K Number
    K161402
    Date Cleared
    2016-08-18

    (90 days)

    Product Code
    Regulation Number
    870.1210
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    In selective areas of peripheral and coronary vessels, the Bullfrog Micro-Infusion Device is intended for the infusion of diagnostic and therapeutic agents into the vessel wall and perivascular area, or intraluminally.

    Device Description

    The Mercator MedSystems Bullfrog Micro-Infusion Device is a wire-guided, singleoperator, endovascular catheter that consists of a perpendicular microneedle, which is sheathed by and contained within a semi-rigid polymer actuator balloon. The device is designed to be advanced to target vasculature and hydraulically actuated to move the microneedle through the external elastic lamina to deliver substances to adventitial and perivascular tissues. A compliant stabilizing balloon inflates with the actuator to provide a force opposite the needle tip for proper seating of the needle is retracted within the sheathing structure by vacuuming the hydraulic actuator.

    AI/ML Overview

    This document is a 510(k) summary for the Mercator MedSystems Bullfrog Micro-Infusion Device.

    Based on the provided information, no new performance testing was conducted to support substantial equivalence for the current submission (K161402). The document explicitly states: "No new performance testing was conducted to support substantial equivalence, since the predicate and subject devices are identical in terms of technological characteristics."

    Therefore, the requested information about acceptance criteria and reported device performance from a new study proving the device meets those criteria for the K161402 submission cannot be extracted from this document because no such new study was performed.

    However, the document mentions that performance testing of the predicate device (K153501) was conducted. This predicate device is also the "Bullfrog Micro-Infusion Device" by Mercator MedSystems, implying the subject device is identical to its predicate in design and performance, except for an update in the Indications for Use.

    The document states that the predicate device's performance testing included:

    • Mechanical and fluid delivery performance
    • Biocompatibility
    • Sterilization validation
    • In-vivo safety and effectiveness studies

    It further notes: "All tests met the pre-determined specifications and acceptance criteria."

    Since no new study directly addressing acceptance criteria for K161402 is provided, I cannot populate the table or answer the specific questions (2-9) about a study from this application. The information provided pertains to the predicate device's testing, for which details like specific acceptance criteria, sample sizes, expert qualifications, and ground truth methodologies are not included in this 510(k) summary.

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    K Number
    K153501
    Date Cleared
    2016-04-15

    (130 days)

    Product Code
    Regulation Number
    870.1210
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    In selective areas of peripheral and coronary vessels, the Bullfrog Micro-Infusion Device is intended for the infusion of diagnostic and therapeutic agents that are indicated for delivery into the vessel wall or perivascular area. The Bullfrog Micro-Infusion Device is also intended for the infusion of diagnostic and therapeutic agents intraluminally.

    Device Description

    The Mercator MedSystems Bullfrog Micro-Infusion Device is a wire-guided, singleoperator, endovascular catheter that consists of a perpendicular microneedle, which is sheathed by and contained within a semi-rigid polymer actuator balloon. The device is designed to be advanced to target vasculature and hydraulically actuated to move the microneedle through the external elastic lamina to deliver substances to adventitial and perivascular tissues. A compliant stabilizing balloon inflates with the actuator to provide a force opposite the needle tip for proper seating of the needle is retracted within the sheathing structure by vacuuming the hydraulic actuator.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the Bullfrog Micro-Infusion Device, based only on the input you provided.

    Note: The provided document is a 510(k) summary for a medical device. These summaries typically highlight that performance tests were done and met criteria, but they do not usually contain the detailed acceptance criteria or the full study results that would be found in a complete test report or clinical study report. Therefore, much of the requested information (especially specific numerical acceptance criteria, detailed study parameters, and specific quantitative results) is not present in this document.

    While the document states that performance testing, biocompatibility, sterilization validation, and in-vivo safety and effectiveness studies were conducted and all tests met pre-determined specifications and acceptance criteria, it does not provide the specific acceptance criteria or the detailed results of these studies. It also explicitly states "N/A" for "Indications for Use" under a section heading, which is likely a formatting error as it also lists indications for use earlier in the document.


    1. Table of Acceptance Criteria and Reported Device Performance

    Performance MetricAcceptance Criteria (Not provided in detail)Reported Device Performance (Summary)
    Mechanical PerformancePre-determined specifications and acceptance criteria (details not provided)All tests met the pre-determined specifications and acceptance criteria. (General statement)
    Fluid Delivery PerformancePre-determined specifications and acceptance criteria (details not provided)All tests met the pre-determined specifications and acceptance criteria. (General statement)
    BiocompatibilityIn accordance with ISO 10993, Biological Evaluation of Medical Devices. (Specific criteria not provided)The biocompatibility assessment was conducted in accordance with ISO 10993. (General statement implying compliance)
    Sterilization ValidationPre-determined specifications and acceptance criteria (details not provided)All tests met the pre-determined specifications and acceptance criteria. (General statement)
    In-Vivo SafetyPre-determined specifications and acceptance criteria (details not provided)All tests met the pre-determined specifications and acceptance criteria. (General statement). Labeling contains instructions, cautions, and warnings for safe and effective use.
    In-Vivo EffectivenessPre-determined specifications and acceptance criteria (details not provided)All tests met the pre-determined specifications and acceptance criteria. (General statement)
    Risk Profile ComparisonSame risk profile as the predicate device (qualitative)Risk analysis has shown that the Bullfrog Micro-Infusion Device has the same risk profile as the predicate.

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not explicitly state the sample sizes used for any specific test sets (e.g., for mechanical, fluid delivery, or in-vivo studies). It also does not specify the country of origin of the data or whether the studies were retrospective or prospective. It only mentions "in-vivo safety and effectiveness studies" without details.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    This information is not provided in the document. The document describes a medical device, and the "ground truth" concept as usually applied to AI algorithms (e.g., expert consensus on images) is not applicable or detailed here. For device performance, the "ground truth" would typically be defined by the physical or biological reality measured during testing against defined specifications.

    4. Adjudication Method for the Test Set

    This information is not provided in the document.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

    No MRMC comparative effectiveness study is mentioned for the Bullfrog Micro-Infusion Device. This type of study is typically associated with diagnostic imaging or AI algorithms, not directly with a physical interventional medical device as described here.

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done

    The Bullfrog Micro-Infusion Device is a physical interventional medical device, not an algorithm. Therefore, "standalone algorithm performance" is not applicable in this context.

    7. The Type of Ground Truth Used

    For a physical device, the "ground truth" is established through engineering specifications, physical measurements, chemical analyses (biocompatibility), and biological outcomes (in-vivo studies, safety/effectiveness). The document generally states that tests met "pre-determined specifications and acceptance criteria," which implies that these specifications serve as the "ground truth" against which performance was measured. No specific mention of expert consensus, pathology, or outcomes data as a distinct ground truth source (like in imaging studies) is given for the device's technical performance.

    8. The Sample Size for the Training Set

    This information is not applicable. The Bullfrog Micro-Infusion Device is a physical medical device, not an AI algorithm that requires a training set.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable, as it is a physical device and not an AI algorithm.

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    K Number
    K131401
    Date Cleared
    2013-07-02

    (48 days)

    Product Code
    Regulation Number
    874.4680
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Blowfish™ Transbronchial Micro-Infusion Catheter is intended to deliver therapeutic and diagnostic agents that are indicated or labeled for airway, tracheal or bronchial delivery into selected and sub-selected regions of the airway tree.

    Device Description

    The Blowfish™ Transbronchial Micro-Infusion Catheter is a bronchoscope guided, single-operator, catheter that consists of a microscopic, tapered stainless steel infusion port, a semi-rigid/semi-elastic polymer balloon, a composite metal and polymer catheter shaft, a pressure relief valve and a proximal hub with standard luer attachment fittings. The device is designed to be advanced through a bronchoscope to a target location in the tracheobronchial three and inflated to move the micro-infusion port into the airway wall to deliver therapeutics to the bronchial tissue including the bronchial adventitia.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the Blowfish Transbronchial Micro-Infusion Catheter:

    Important Note: The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to a predicate device. It is not a detailed clinical study report or a direct description of acceptance criteria for a new AI/software device. Therefore, many of the requested categories for AI/software device evaluation (like sample size for test sets, ground truth establishment, MRMC studies, standalone performance, etc.) are not applicable or explicitly stated for this type of medical device submission.

    The "acceptance criteria" discussed in this document refer to the device meeting its mechanical performance requirements and biocompatibility standards for demonstrating substantial equivalence to a predicate device. It's a different type of evaluation than what's typically performed for a diagnostic AI algorithm.


    Acceptance Criteria and Device Performance for Blowfish Transbronchial Micro-Infusion Catheter

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySource of Criteria / Standard MetReported Device Performance
    Mechanical & Fluid Delivery Performance"Product specification""All tests met the pre-determined acceptance criteria." (Specific details of the criteria and corresponding performance values are not provided in this summary.)
    Packaging & Labeling Testing(Implied regulatory requirements)"All tests met the pre-determined acceptance criteria." (Specific details not provided.)
    Shelf-Life Testing(Implied regulatory requirements)"All tests met the pre-determined acceptance criteria." (Specific details not provided.)
    BiocompatibilityISO 10993-1: Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Toxicity"was previously conducted with a legally marketed device (K062752)" and for the Blowfish, "materials included... were tested and demonstrated to be biocompatible and safe." (Specific test outcomes not detailed, but conformance to standard is asserted.)
    In-vivo Safety (Porcine Model)(Implied safety endpoints)"Test results indicated that the catheter's materials, mode of action and procedure... are safe and do not raise different questions of safety and effectiveness compared to the predicate device." (No specific quantitative performance metrics provided; general statement of safety.)
    SterilitySAL 10-6Sterile (SAL 10-6)
    Single Use(Design specification)Yes
    Target Diameter (Balloon)(Design specification)6.0 mm to 16.0 mm
    Max Inflation Pressure (Balloon)(Design specification)2 atm controlled by pressure relief valve
    Bronchoscope Channel ID(Compatibility specification)2.8 mm
    Length(Design specification)Up to 145 cm

    2. Sample size used for the test set and the data provenance:

    • Test Set Sample Size: Not specified in the summary. The performance data section refers generally to "bench, in vitro and in vivo animal studies" without providing specific subject counts for each test.
    • Data Provenance:
      • Bench (laboratory, in vitro) studies.
      • In vivo animal studies using a porcine model.
      • No mention of human clinical data or geographical origin of data for these specific tests. The biocompatibility data references a previous 510(k) (K062752) for another device.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not Applicable. This device is a catheter, not a diagnostic algorithm. Therefore, there is no "ground truth" established by experts in the context of diagnostic interpretation. The evaluation is focused on engineering performance, material safety, and in-vivo physiological effects in an animal model.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    • Not Applicable. As above, no diagnostic "ground truth" requiring adjudication.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • Not Applicable. This is a hardware device, not an AI or diagnostic software.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

    • Not Applicable. This is a hardware device, not an AI or diagnostic software.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • Not Applicable / Reinterpreted: The "ground truth" for this device's evaluation is primarily established by:
      • Engineering specifications: For mechanical and fluid delivery performance (e.g., meeting specific pressure, diameter, length requirements).
      • Regulatory standards: For biocompatibility (ISO 10993-1).
      • Physiological safety: Observed outcomes in the porcine animal model to ensure the device's interaction with tissue is safe and does not raise new safety concerns compared to the predicate.

    8. The sample size for the training set:

    • Not Applicable. This device uses traditional engineering and biological testing, not machine learning, so there is no "training set."

    9. How the ground truth for the training set was established:

    • Not Applicable. (See #8)
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    K Number
    K062752
    Date Cleared
    2006-12-07

    (84 days)

    Product Code
    Regulation Number
    870.1210
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    In selective areas of peripheral and coronary vessels, the MicroSyringe II Infusion Catheter is intended for the infusion of diagnostic and therapeutic agents that are indicated for delivery into the vessel wall or perivascular area. The MicroSyringe II Infusion Catheter is also intended for the infusion of diagnostic and therapeutic agents intraluminally.

    Device Description

    The Mercator MicroSyringe II is a wire-guided endovascular catheter that consists of a perpendicular microneedle delivery port, which is sheathed by and consists of a semi rigid nolymor halless sollyery port, which is sheathed within a semi-rigid polymer balloon actuator with an integrated compliant low-pressure forcing balloon opposite the microneedle. The device is advanced over a 0.014" guidewire, using a single operator method. The device is advanced over a 0.014 guidewire, use the needle delivery port into the troutinent vossel and nythanically actualed to ctructures structures.

    AI/ML Overview

    The provided text is a 510(k) summary for the Mercator MicroSyringe II Infusion Catheter and does not contain the detailed information requested regarding acceptance criteria and a specific study proving device performance against those criteria in the context of an AI/ML model.

    This document describes a medical device clearance for an infusion catheter, not an AI/ML powered device. Therefore, many of the requested categories related to AI/ML performance, ground truth, expert review, training sets, and comparative effectiveness studies are not applicable or detailed in this submission.

    However, I can extract the relevant information that is present:


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategoryReported Device Performance
    Mechanical PerformanceMet all required specifications for the tests.
    Fluid Delivery PerformanceMet all required specifications for the tests.
    BiocompatibilityMet all required specifications for the tests. Materials used are suitable for this use and have been used in several previously cleared products.
    Sterilization ValidationMet all required specifications for the tests.
    In-vivo SafetyMet all required specifications for the tests.
    Overall Safety and Effectiveness (vs. Predicates)"The results of these tests demonstrated that the device is as safe and effective as the legally marketed predicate devices." This implies that the performance across the above categories was equivalent or superior to the predicate devices (Mercator MicroSyringe Infusion Catheter K040139, Dispatch Coronary Infusion Catheter K932616, Selective Infusion II Catheter K914751, Isolate Infusion Catheter System K913517). The specific quantitative metrics for "acceptance criteria" are not explicitly detailed beyond "met all required specifications."

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document does not specify the sample sizes (e.g., number of units tested, number of in-vivo subjects) for the mechanical, fluid delivery, biocompatibility, sterilization, or in-vivo safety testing. It also does not state the provenance of the data (e.g., country of origin, retrospective or prospective).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    Not applicable. This is a medical device for infusion, not an AI/ML diagnostic or predictive device requiring expert-established ground truth in the context of image interpretation or similar. The "performance" assessment is based on engineering and biological testing.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This is not an AI/ML device requiring human adjudication of performance outcomes in that context. Device performance was likely assessed against engineering specifications and possibly animal studies in a direct, objective manner.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This is not an AI-assisted device, and no MRMC study information is provided.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is a physical medical device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The "ground truth" for the performance of this physical device would typically be defined by:

    • Engineering specifications and standards for mechanical and fluid delivery performance.
    • Relevant ISO standards and guidelines for biocompatibility and sterilization validation.
    • Pre-clinical (in-vivo animal) study results for safety.

    The document states that "All components, subassemblies and/or full devices met the required specifications for the tests," implying these specifications served as the ground truth or target.

    8. The sample size for the training set

    Not applicable. This is a physical medical device, not an AI/ML model.

    9. How the ground truth for the training set was established

    Not applicable. This is a physical medical device, not an AI/ML model.

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