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510(k) Data Aggregation

    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX Percutaneous Electrode System is intended for ablation of soft tissue in percutaneous and intraoperative surgical procedures.

    The CellFX Percutaneous Electrode System (Percutaneous Electrode) is not intended for use in cardiac procedures.

    Device Description

    The CellFX® nsPFA™ Percutaneous Electrode System includes the CellFX Console, a family of CellFX nsPFA Percutaneous Electrodes (13G and 18G) and Accessories: Percutaneous Adapter, pneumatic footswitch, and system software. The CellFX® Console is a proprietary energy-based platform for nanosecond Pulsed Field Ablation™ (nsPFA™) technology. nsPFA is a cell-specific, nonthermal ablation technology that delivers nanosecond-duration pulses of high-amplitude electrical energy to tissue via bipolar electrodes. The pulses create nanopores in lipid membranes, which disrupt the ability of the cell and internal organelles to maintain cellular homeostasis - ultimately leading to regulated cell death (e.g., apoptosis). The electrode is provided sterile, for single use only.

    This 510(k) supports the addition of the CellFX nsPFA Percutaneous Electrode, 18G, to the CellFX nsPFA Percutaneous Electrode family, which has smaller dimensions compared to that of the currently cleared CellFX nsPFA Percutaneous Electrode, 13G (K233705).

    AI/ML Overview

    The provided document is a 510(k) summary for the CellFX® nsPFA™ Percutaneous Electrode System, specifically focusing on the addition of an 18G electrode. This type of submission aims to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving absolute safety and effectiveness through extensive clinical trials. Therefore, the information you're looking for regarding acceptance criteria, specific device performance metrics in comparison to those criteria, and detailed study methodologies in terms of sample sizes, expert ground truth establishment, and comparative effectiveness studies (MRMC) would typically be found in direct PMA (Premarket Approval) submissions or more comprehensive clinical study reports, not usually within a 510(k) summary.

    However, I can extract the information that is present in the document which relates to performance and design control testing that supports the claim of substantial equivalence.

    Here's the breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not provide a table with specific quantitative acceptance criteria or detailed device performance metrics in the format you requested (e.g., sensitivity, specificity, accuracy against a numerical threshold). Instead, it states that various tests "met their respective acceptance criteria" or "passed," indicating qualitative compliance with established standards.

    Type of TestingAcceptance Criteria (Stated)Reported Device Performance (Stated)
    Biocompatibility TestingMet respective acceptance criteria (per FDA Guidance, ISO 10993-1)All tests for Pyrogenicity, Systemic Toxicity, Sensitization, Irritation, Cytotoxicity, and Hemolysis successful.
    Electrical Safety and EMC TestingComplies with IEC 60601-1, IEC 60601-1-2, 60601-2-2, IEC 60601-1-6, IEC 62366, and IEC 62304All electrical safety and EMC tests passed.
    Bench TestingPerforms as intended per its specificationsPerformed as intended per its specifications.
    Software Verification and Validation TestingAs recommended by FDA Guidance ("Content of Premarket Submissions for Device Software Functions," June 14, 2023) and ("Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery," March 9, 2020)Enhanced documentation level of software testing included, supports safety and effectiveness. Cybersecurity controls implemented to mitigate risk of malware.
    Pre-Clinical Animal Safety and Performance StudiesSafety and performance for ablation of soft tissueData demonstrates and supports the CellFX nsPFA Percutaneous Electrode System is safe and effective for ablation of soft tissue.

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

    • Sample Size for Test Set: Not specified for any of the tests.
    • Data Provenance: The pre-clinical animal study is described as an "in vivo GLP animal safety study." This implies a prospective study conducted under Good Laboratory Practice (GLP) guidelines, but does not specify the country of origin. Other tests (biocompatibility, electrical safety, bench, software) are typically performed in a laboratory setting, and their "provenance" would be the testing facility.

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

    • For Biocompatibility, Electrical Safety, Bench, Software Testing: The concept of "experts establishing ground truth" as it applies to clinical data is not relevant for these types of engineering and laboratory tests. Compliance is based on meeting predefined technical standards and specifications.
    • For Pre-Clinical Animal Safety and Performance Studies: The document doesn't specify the number or qualifications of experts involved in assessing the outcomes of the animal study. Conclusions would typically be drawn by veterinary pathologists or other scientific experts, but this detail is not provided.

    4. Adjudication Method for the Test Set:

    • For Biocompatibility, Electrical Safety, Bench, Software Testing: Adjudication methods like 2+1 or 3+1 are typically used for clinical image interpretation or diagnostic performance studies. For these tests, the outcome is determined by adherence to a standard or a pass/fail criterion, not by expert consensus on ambiguous findings.
    • For Pre-Clinical Animal Safety and Performance Studies: The document does not describe any specific adjudication method for the animal study results.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:

    • No, an MRMC comparative effectiveness study was not done. This type of study is typically performed for diagnostic or AI-assisted diagnostic devices to assess how human reader performance changes with or without AI assistance. The CellFX system is an electrosurgical device for tissue ablation, not a diagnostic imaging device, so an MRMC study is not relevant to its regulatory pathway as described here.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done:

    • The device is a physical electrosurgical system with associated software. The concept of "standalone performance" (algorithm only) as applicable to AI diagnostics (e.g., an algorithm interpreting images without human input) does not directly apply here. The software verification and validation testing assesses the software's performance within the integrated device system.

    7. The Type of Ground Truth Used:

    • Biocompatibility: Adherence to established biological safety standards (e.g., ISO 10993-1).
    • Electrical Safety and EMC: Compliance with international electrical and electromagnetic compatibility standards (e.g., IEC 60601 series).
    • Bench Testing: Performance against predefined engineering specifications and functional requirements.
    • Software Verification and Validation Testing: Compliance with software development lifecycle processes and functional requirements as per FDA guidance.
    • Pre-Clinical Animal Safety and Performance Studies: Biological effects observed in animal tissue (e.g., lesion formation, cellular changes, lack of adverse events) in a GLP study. This is considered an in vivo biological ground truth in an animal model.

    8. The Sample Size for the Training Set:

    • This document describes a device submission for an electrosurgical ablation system, not a machine learning or AI algorithm in the context of diagnostic image analysis where distinct training and test sets of patient data are typical.
    • Therefore, the concept of a "training set" in the context of machine learning model development is not directly applicable or discussed in this 510(k) summary for this type of medical device. The software component refers to system control and safety functions, not an AI diagnostic algorithm.

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

    • As explained in point 8, a "training set" for an AI algorithm is not referenced in this document.
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    K Number
    K233705
    Date Cleared
    2024-03-08

    (109 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX® Percutaneous Electrode System is intended for ablation of soft tissue in percutaneous and intraoperative surgical procedures. It is not intended for use in cardiac procedures.

    Device Description

    The CellFX® Percutaneous Electrode System includes the CellFX Console, CellFX Percutaneous Electrode and Accessories: Percutaneous Adapter, pneumatic footswitch, and system software. The CellFX® Console is a proprietary energy-based platform for nanosecond Pulsed Field Ablation™ (nsPFA™) technology. nsPFA is a cell-specific, nonthermal ablation technology that delivers nanosecond-duration pulses of highamplitude electrical energy to tissue via bipolar electrodes. The pulses create nanopores in lipid membranes, which disrupt the ability of the cell and internal organelles to maintain cellular homeostasis - ultimately leading to regulated cell death (e.g., apoptosis). The electrode is provided sterile, for single use only.

    AI/ML Overview

    The provided text is an FDA 510(k) summary for the CellFX® Percutaneous Electrode System. It describes the device, its intended use, and the data presented to demonstrate its substantial equivalence to predicate devices. However, the document does not describe an AI/ML medical device.

    Therefore, many of the requested points, such as "number of experts used to establish ground truth", "adjudication method", "MRMC comparative effectiveness study", "standalone algorithm performance", "sample size for training set", and "how ground truth for training set was established", are not applicable to this device's submission and are consequently not present in the provided text.

    The device discussed is an electrosurgical cutting and coagulation device that uses nanosecond Pulsed Field Ablation (nsPFA) technology. Its performance is demonstrated through various traditional medical device validation methods, including biocompatibility testing, electrical safety and EMC testing, bench testing, software verification and validation, pre-clinical animal studies, and a human safety study.

    Here's an attempt to answer the applicable points based on the provided text, while explicitly stating when information is not present or not relevant due to the device type:

    1. A table of acceptance criteria and the reported device performance

    The document does not present a formal table of "acceptance criteria" against specific "reported device performance" values in a quantitative manner for most tests. Instead, it states that tests "met their respective acceptance criteria" or "passed". For the human safety study, a quantitative result is provided.

    Test CategoryAcceptance Criteria (Stated or Implied)Reported Device Performance
    Biocompatibility TestingAll tests meet respective acceptance criteria as per ISO 10993-1."All biocompatibility tests met their respective acceptance criteria."
    Electrical Safety and Electromagnetic Compatibility (EMC) TestingCompliance with IEC 60601-1, IEC 60601-1-2, 60601-2-2, 60601-1-6, IEC 62366, IEC 62304."All electrical safety and EMC tests passed."
    Bench TestingDevice performs as intended per its specifications."The CellFX Percutaneous Electrode System performs as intended per its specifications."
    Software Verification and Validation TestingSoftware functions safely and effectively (enhanced documentation level). Cybersecurity controls mitigate risk."Software verification and validation testing were conducted and enhanced documentation was provided... supports the safety and effectiveness of the device." "Cybersecurity controls have been implemented to mitigate the risk..."
    Pre-Clinical Animal Safety and Performance StudiesDemonstrate safety and performance for soft tissue ablation."The data provided... demonstrates and supports that the CellFX Percutaneous Electrode System is safe and effective for ablation of soft tissue..."
    Human Safety StudyDemonstrate safety and effectiveness (though no specific quantitative criteria are listed)."Subjects showed an average of 95% reduction in ablation zones by 30 days. No serious adverse events were observed."

    2. Sample sized used for the test set and the data provenance

    • Test Set Sample Size:
      • Human Safety Study: Ten (10) subjects.
      • Pre-Clinical Animal Studies: "Two in vivo animal studies were conducted," but specific sample sizes for animals are not provided.
    • Data Provenance:
      • The document implies the human safety study was conducted prospectively.
      • The geographical origin of the data (country) is not explicitly stated. Given the FDA submission, it's likely US-based or data accepted by the FDA.

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

    • Not Applicable. This is not an AI/ML device requiring human expert annotation for ground truth. The "ground truth" for this device's performance is objective measurement (e.g., ablation zone reduction as measured by ultrasound in the human study, or physical/electrical parameters in bench testing, or pathological examination in animal studies).

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

    • Not Applicable. This concept is specifically relevant to human labeling or ground truth establishment in AI/ML performance studies. It is not relevant to the validation tests described for this device.

    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

    • No. An MRMC study was not done because this is not an AI/ML diagnostic or assistive device. The study performed was a human safety study of the device's direct clinical effect.

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

    • Not Applicable. This is not an AI/ML algorithm. The device's performance is evaluated via its physical and biological effects.

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

    • Human Safety Study: Outcomes data primarily, specifically "average of 95% reduction in ablation zones" (likely measured clinically, possibly via imaging like ultrasound, and "No serious adverse events were observed."
    • Pre-Clinical Animal Studies: Likely involved pathological examination of ablated tissues for safety and effectiveness endpoints.
    • Bench Testing: Engineering specifications and performance measurements.
    • Biocompatibility/Electrical Safety: Standardized test methods specified by international standards (e.g., ISO, IEC).

    8. The sample size for the training set

    • Not Applicable. This is not an AI/ML device, so there is no "training set."

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

    • Not Applicable. As there is no training set for an AI/ML algorithm, this question is not relevant.
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    K Number
    K213674
    Device Name
    CellFX System
    Date Cleared
    2022-09-22

    (304 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX® System is indicated for dermatological procedures requiring ablation and resurfacing of the skin.

    Specific Indication: The CellFX System with the CellFX Treatment Tip 2.5mm is indicated for the treatment of sebaceous hyperplasia (SH) in patients with Fitzpatrick skin types I-III.

    Device Description

    The Pulse Biosciences® CellFX® System is a proprietary platform technology. The CellFX System consists of the CellFX Console, CellFX Handpiece, CellFX Treatment Tips, and CellFX Software. The CellFX System delivers nanosecond duration electrical pulses that disrupt the function of cells leading to cell death, while sparing non-cellular tissue. The CellFX System delivers a series of timed, nanosecond electrical pulses (referred to as a "Cycle") to ablate and resurface tissue areas in dermatologic conditions.

    The CellFX Console delivers short electric pulses at amplitudes up to 15 kV and pulse widths up to 700 ns. The electrical energy pulses are applied directly to targeted tissue using sterile Treatment Tips with stainless steel microneedles. The treatment parameters are selected by the user through a user interface on the Touchscreen Display of the CellFX Console.

    AI/ML Overview

    The provided text describes the CellFX System, an electrosurgical device for dermatological procedures. It outlines its specifications, compares it to a predicate device, and presents performance data from a clinical study to support its safety and effectiveness for treating sebaceous hyperplasia (SH).

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state "acceptance criteria" in a tabulated format. Instead, it presents co-primary safety and effectiveness endpoints from a clinical study, implying these are the measures against which the device's performance was judged. The study aimed to demonstrate non-inferiority of the CellFX System to Electrodessication.

    Here's a table summarizing these endpoints and the reported performance:

    Acceptance Criterion (Implied)MeasureCellFX System PerformanceElectrodessication Performance
    Safety Endpoint 1: Non-inferiority regarding hyperpigmentation and scarring at 60 days post-treatment.Percentage of lesions showing hyperpigmentation or scarring.19.2%12.1%
    Safety Endpoint 2: Non-inferiority regarding skin textural changes (crusting, other textural changes) at 30 days post-treatment.Percentage of lesions showing skin textural changes.6.8%10.3%
    Effectiveness Endpoint: Non-inferiority regarding aesthetic improvement at 60 days post-last treatment.Percentage of lesions rated "improved" or "much improved" using the 5-point GAIS (scores of 4 or 5).76.9%75.5%

    Interpretation of "Acceptance":
    The document states: "Evaluation of primary safety and effectiveness endpoints showed CellFX to be noninferior to Electrodessication." This is the key statement indicating the device met its implied acceptance criteria. While the CellFX System had a slightly higher rate of hyperpigmentation/scarring (19.2% vs 12.1%), the study appears to have concluded non-inferiority based on statistical analysis not fully detailed in this excerpt. The other safety endpoint and the effectiveness endpoint showed comparable or numerically better performance for CellFX.

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

    • Sample Size for Test Set:
      • Total subjects: 59
      • Total SH lesions treated with CellFX System: 121
      • Total SH lesions treated with Electrodessication: 107
    • Data Provenance:
      • The study was described as a "prospective, multi-center, randomized, comparison clinical study."
      • The document does not specify the country of origin of the data.
      • Given it's a prospective clinical study, the data is prospective.

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

    • The ground truth for the safety and effectiveness endpoints was established by a "blinded Investigator."
    • The document refers to a single "blinded Investigator" (singular) assessing the endpoints for safety and a "blinded site investigator" (singular) for effectiveness. This phrasing suggests a single expert (per site, if multi-center) or a single central expert. However, in multi-center trials, typically multiple investigators at different sites are involved in assessments. Without further detail, it's hard to definitively state the number of distinct human experts involved across all sites who collectively established the ground truth.
    • Qualifications of Experts: The document identifies them as "Investigator" or "site investigator." It does not provide specific qualifications (e.g., years of experience, specific medical specialization like dermatology).

    4. Adjudication Method for the Test Set

    • The document implies that the assessments were made by a "blinded Investigator" for safety endpoints and a "blinded site investigator" for the effectiveness endpoint. It does not describe any adjudication method (e.g., 2+1, 3+1, consensus panel) if there were multiple assessors or concerns about disagreement. It appears that the assessment of the single "blinded Investigator" served as the ground truth.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No, a "multi-reader multi-case (MRMC) comparative effectiveness study" involving human readers assisted by AI vs. without AI assistance was not done.
    • This study was a direct comparison between the CellFX System (device) and Electrodessication (active comparator), both applied by clinicians, and assessed by human investigators. It does not involve AI assistance for human readers.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    • No, a standalone (algorithm only) performance study was not done.
    • The CellFX System is a physical electrosurgical device, not an AI algorithm. Its performance is intrinsically linked to its application by a human operator.

    7. The Type of Ground Truth Used

    • The ground truth was based on expert assessment (by the "blinded Investigator" or "blinded site investigator") of clinical outcomes (pigmentation, scarring, textural changes, aesthetic improvement) at specified follow-up times (30 and 60 days). This could be categorized as clinical assessment/outcomes data derived from expert observation. It is not pathology or another objective measure described as such.

    8. The Sample Size for the Training Set

    • The document describes a clinical study to support the safety and effectiveness of the device. This clinical study represents the "test set" or the primary data used for evaluating the device's performance against the specified endpoints.
    • The CellFX System is a hardware device delivering a specific energy type, not an AI/ML algorithm that requires a distinct "training set." Therefore, the concept of a separate "training set" for the device itself is not applicable in this context. The manufacturing and design process for such a device would involve various engineering and preclinical tests, but not a "training set" in the sense of machine learning.

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

    • As explained above, there is no "training set" in the context of an AI/ML algorithm for which ground truth would need to be established. The "ground truth" (clinical outcomes) established by the blinded investigators in the described clinical trial serves as the basis for the evaluation of the device's performance, not for training it.
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    K Number
    K222075
    Device Name
    CellFX System
    Date Cleared
    2022-09-02

    (50 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX® System is intended for dermatological procedures requiring ablation and resurfacing of the skin.

    Device Description

    The Pulse Biosciences® CellFX® System is a proprietary platform technology. The CellFX System consists of the CellFX Console, CellFX Handpiece, CellFX Treatment Tips, and CellFX Software. The CellFX System delivers nanosecond duration electrical pulses that disrupt the function of cells leading to cell death, while sparing non-cellular tissue. The CellFX System delivers a series of timed, nanosecond electrical pulses (referred to as a "Cycle") to ablate and resurface tissue areas in dermatologic conditions.

    The CellFX Console is capable of delivering short electric pulses at amplitudes up to 15 kV and pulse widths up to 700 ns. The electrical energy pulses are applied directly to targeted tissue using sterile Treatment Tips with stainless steel microneedles. The treatment parameters are selected by the user through a user interface on the Touchscreen Display of the CellFX Console.

    AI/ML Overview

    The provided document is a 510(k) summary for the CellFX System, which is an electrosurgical device for dermatological procedures. It outlines the substantial equivalence determination to a previously cleared predicate device (K211444). The document does not describe an AI/ML-driven device or an acceptance criteria table with reported device performance, sample sizes for test/training sets, expert adjudication methods, MRMC studies, or specific ground truth establishment for AI models.

    Therefore, I cannot fulfill the request as the provided text lacks the necessary information about an AI/ML device and its performance evaluation. The document focuses on the CellFX System's electrical safety, biocompatibility, bench testing, software validation, and an animal study to demonstrate its safety and performance for ablation and resurfacing.

    The term "acceptance criteria" is used in a general sense for biocompatibility tests and performance of the device in the animal study, but not in the context of an AI/ML model's diagnostic or predictive performance against a ground truth.

    Here's what I can extract given the limitations of the provided text, related to the general performance data presented:

    General Performance Data from the Document (Not AI/ML Specific):

    1. A table of acceptance criteria and the reported device performance:

      • Biocompatibility Testing:
        • Acceptance Criteria: All biocompatibility tests (Pyrogenicity, Systemic Toxicity, Sensitization, Irritation, Cytotoxicity, Hemolysis) met their respective acceptance criteria per FDA Guidance.
        • Reported Performance: "All biocompatibility tests met their respective acceptance criteria."
      • Electrical Safety and Electromagnetic Compatibility (EMC):
        • Acceptance Criteria: Compliance with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-2, IEC 60601-1-6, IEC 62366, and IEC 62304.
        • Reported Performance: "All electrical safety and EMC tests passed."
      • Bench Testing:
        • Acceptance Criteria: Device performs as intended and meets product specifications.
        • Reported Performance: "The performance testing for the CellFX System (Console, Handpiece and Tip) verified that the CellFX System performed as intended and met product specifications."
      • Software Verification and Validation Testing:
        • Acceptance Criteria: Supports safety and effectiveness; cybersecurity controls mitigate risk.
        • Reported Performance: "Completed software testing supports the safety and effectiveness of the device." "Cybersecurity controls have been implemented..."
      • Animal Study (Safety and Performance):
        • Acceptance Criteria (Safety): No acute procedural-related adverse events or complications. Full and acceptable healing of treated sites, no effect on draining lymph nodes or non-target organs.
        • Reported Performance (Safety): "All CellFX treatments were successfully completed with no acute procedural-related adverse events or procedural complications..." "Pathology results support the safety of the CellFX System as there was full and acceptable healing of treated sites, no effect on draining lymph nodes or nontarget organs."
        • Acceptance Criteria (Performance): All test articles meet the acceptance criteria; treatment zones successfully achieve degeneration and necrosis of active treatment sites while epidermis remains intact in majority of sites.
        • Reported Performance (Performance): "All test articles met the acceptance criteria for device performance. The treatment zones met the acceptance criteria and successfully achieved degeneration and necrosis of active treatment sites while the epidermis remained intact in the majority of the treatment sites. The device performed as intended."
    2. Sample size used for the test set and the data provenance:

      • Animal Study: 10 Yucatan mini-pigs.
      • Provenance: Animal study (swine skin). The document does not specify a country of origin, nor whether it's retrospective or prospective, but animal studies for regulatory submission are typically prospective.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable/Not mentioned for any of the tests described. The "ground truth" for the animal study appears to be a pathological assessment of tissue changes and healing, implicitly performed by qualified veterinary pathologists, though details are not provided.
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable/Not mentioned.
    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:

      • No MRMC study was mentioned. This device is not an AI-assisted diagnostic tool.
    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable. This is not an AI/ML device. The "performance" assessment focuses on the physical and biological effects of the electrosurgical device.
    7. The type of ground truth used:

      • For the animal study: Pathological assessment of tissue degeneration, necrosis, healing, and lack of adverse effects on lymph nodes/organs.
    8. The sample size for the training set:

      • Not applicable. This is not an AI/ML device.
    9. How the ground truth for the training set was established:

      • Not applicable. This is not an AI/ML device.
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    K Number
    K221671
    Device Name
    CellFX® System
    Date Cleared
    2022-08-01

    (53 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX® System is intended for dermatological procedures requiring ablation and resurfacing of the skin.

    Device Description

    The Pulse Biosciences® CellFX® System is a proprietary platform technology. The CellFX System consists of the CellFX Console, CellFX Handpiece, CellFX Treatment Tips, and CellFX Software. The CellFX System delivers nanosecond duration electrical pulses that disrupt the function of cells leading to cell death, while sparing non-cellular tissue. The CellFX System delivers a series of timed, nanosecond electrical pulses (referred to as a "Cycle") to ablate and resurface tissue areas in dermatologic conditions.

    The CellFX Console is capable of delivering short electric pulses at amplitudes up to 15 kV and pulse widths up to 700 ns. The electrical energy pulses are applied directly to targeted tissue using sterile Treatment Tips with stainless steel microneedles. The treatment parameters are selected by the user through a user interface on the Touchscreen Display of the CellFX Console.

    AI/ML Overview

    The provided text describes the CellFX® System and its substantial equivalence to a predicate device, focusing on safety and performance, particularly concerning higher energy settings. However, it does not contain specific acceptance criteria with numerical targets, nor does it present a human reader study (MRMC) or a standalone algorithm performance study. The device is a physical electrosurgical system, not an AI/ML-driven diagnostic tool, which explains the absence of some of the requested information.

    Here's a breakdown of the available information based on your request:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of numerical acceptance criteria for performance metrics. Instead, it refers to general statements of acceptance met during various tests.

    Acceptance Criteria (Stated Generally)Reported Device Performance
    Device performs as intendedAll test articles met the acceptance criteria for device performance. The performance testing for the CellFX System (Console, Handpiece and Tip) verified that the CellFX System performed as intended and met product specifications.
    Safety (e.g., no acute adverse events, acceptable healing, no effect on draining lymph nodes or non-target organs)All CellFX treatments were successfully completed with no acute procedural adverse events. Pathology results support the safety of the CellFX System as there was acceptable healing of treated sites, no effect on draining lymph nodes or nontarget organs. The animal study data confirmed that the device performs as intended and does not raise safety concerns.
    Performance (e.g., treatment zones achieving degeneration and necrosis of active treatment sites while epidermis remained intact)The treatment zones met the acceptance criteria and successfully achieved degeneration and necrosis of active treatment sites while the epidermis remained intact in the majority of the treatment sites. The device performed as intended.
    BiocompatibilityBiocompatibility testing was not required as there were no changes to the device compared to the predicate that would impact biocompatibility. (Implies predicate device previously met biocompatibility criteria)
    Electrical safety and electromagnetic compatibility (EMC)The CellFX System complies with IEC 60601-1, IEC 60601-1-2, 60601-2-2, IEC 60601-1-6, IEC 62366, and IEC 62304. All electrical safety and EMC tests passed.
    Software Verification and ValidationSoftware verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance. Completed software testing supports the safety and effectiveness of the device. Cybersecurity controls implemented to mitigate risk. Considered a "moderate" level of concern.

    2. Sample Size and Data Provenance

    The only clinical-like study mentioned is an animal study.

    • Sample Size (Test Set): 15 Yucatan mini-pigs.
    • Data Provenance: Prospective animal study (Yucatan mini-pigs). The country of origin is not specified but is implicitly under US regulatory purview given the FDA submission.

    3. Number of Experts and Qualifications for Ground Truth (Test Set)

    Not applicable as this was an animal study evaluating device performance and safety, not a diagnostic accuracy study requiring human expert interpretation of images or clinical data for ground truth. Ground truth would have been established through pathological examination and observation of healing in the animal models.

    4. Adjudication Method for the Test Set

    Not applicable. The animal study evaluated physiological and pathological responses to the device treatment, not a diagnostic outcome requiring adjudication of expert opinions. The assessment of pathological outcomes would typically involve veterinary pathologists.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, an MRMC comparative effectiveness study was not done. The device is an electrosurgical system for ablation and resurfacing, not a diagnostic imaging or AI-assisted diagnostic tool. Therefore, a study comparing human readers with and without AI assistance is not relevant to this device.

    6. Standalone Performance Study (Algorithm Only)

    No, a standalone (algorithm only) performance study was not done. This device is a physical electrosurgical system, not a software algorithm or AI model designed for standalone diagnostic or analytical performance. Its "performance" refers to its physical operation and biological effects.

    7. Type of Ground Truth Used

    For the animal study:

    • Pathology: Evaluation of treatment zones (degeneration and necrosis), epidermal integrity, and effects on draining lymph nodes and non-target organs.
    • Outcomes Data: Observation of acute procedural adverse events and healing.

    8. Sample Size for the Training Set

    Not applicable. This is a physical medical device, not an AI/ML model that requires a training set in the conventional sense. The "training" for such a device would relate to engineering design, testing, and validation, not data-driven model training.

    9. How Ground Truth for the Training Set Was Established

    Not applicable. As explained in point 8, there is no "training set" in the context of an AI/ML model for this type of device. The device's performance characteristics are established through engineering design, bench testing, and in vivo studies, where "ground truth" for these measurements is based on physical and biological principles.

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    K Number
    K211444
    Device Name
    CellFX System
    Date Cleared
    2021-08-25

    (107 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX® System is intended for dermatological procedures requiring ablation and resurfacing of the skin.

    Device Description

    The Pulse Biosciences® CellFX® System is a proprietary platform technology. The CellFX System consists of the CellFX Console, CellFX Handpiece, CellFX Treatment Tips, and CellFX Software. The CellFX System delivers nanosecond duration electrical energy pulses that disrupt the function of cells leading to regulated cell death, while sparing non-cellular tissue. The CellFX System delivers a series of timed, nanosecond electrical pulses (referred to as a "Cycle") to ablate and resurface tissue areas in dermatologic conditions.

    The CellFX Console is capable of delivering short electric pulses at amplitudes up to 15 kV and pulse widths up to 700 ns. The electrical energy pulses are applied directly to targeted tissue using sterile Treatment Tips with stainless steel microneedles. The treatment parameters are selected by the user through a user interface on the Touchscreen Display of the CellFX Console.

    AI/ML Overview

    The provided document is a 510(k) summary for the CellFX System. It describes the device, its intended use, and its comparison to a predicate device. However, it does not contain the level of detail requested in the prompt regarding acceptance criteria, specific study results, sample sizes, ground truth establishment, or multi-reader multi-case studies.

    The document focuses on demonstrating substantial equivalence to a predicate device (K203299 - CellFX® System) by confirming that the technological characteristics, mechanism of action, and indications for use are the same, and that performance testing validates these similarities.

    Here's a breakdown of what can be extracted and what information is missing:


    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that a study was conducted and that "All test articles met the acceptance criteria for device performance. The treatment ablation areas met the acceptance criteria and successfully achieved degeneration and necrosis of active treatment sites while the epidermis remained intact in the majority of the treatment sites. The device performed as intended."

    However, the specific, quantitative acceptance criteria are not detailed in the document. Therefore, a table cannot be fully constructed as requested.

    Acceptance CriteriaReported Device Performance
    Not specified in document (e.g., specific percentage of ablation, specific lesion size reduction, specific histological outcomes)"All test articles met the acceptance criteria for device performance. The treatment ablation areas met the acceptance criteria and successfully achieved degeneration and necrosis of active treatment sites while the epidermis remained intact in the majority of the treatment sites. The device performed as intended."
    No adverse events"All CellFX treatments were successfully completed with no adverse events."
    Acceptable histological findings, no evidence of thermal damage at treatment sites"Pathology results support the safety of the CellFX System with acceptable histological findings and no evidence of thermal damage at CellFX treatment sites."

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

    • Sample Size (Test Set): Two Yucatan pigs.
    • Data Provenance: Animal study (swine skin model), conducted to characterize treatment ablation areas. The country of origin is not specified but is implied to be part of the studies supporting a U.S. FDA submission. The study is prospective in nature as it involved applying the device and then observing the results.

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

    The document does not specify the number or qualifications of experts used to establish the ground truth for the animal study. It mentions "Pathology results," which implies evaluation by pathologists, but no details are given.


    4. Adjudication method for the test set

    The document does not describe any adjudication method.


    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

    • No, a multi-reader, multi-case (MRMC) comparative effectiveness study involving human readers and AI assistance was not conducted or reported in this document.
    • This device is an electrosurgical cutting and coagulation device, not an AI-powered diagnostic or interpretive device that typically involves human readers.

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

    This question is not applicable to the CellFX System as described. It is a physical medical device (an electrosurgical system) and does not primarily involve an "algorithm only" performance separate from its direct application. The software component mentioned is for control and safety, not for standalone diagnostic or interpretive tasks. The "performance" assessment focuses on the device's physical effects on tissue.


    7. The type of ground truth used

    The ground truth for the animal study appears to be histological findings from pathology, as the document states, "Pathology results support the safety of the CellFX System with acceptable histological findings and no evidence of thermal damage at CellFX treatment sites."


    8. The sample size for the training set

    The document does not mention a "training set" in the context of an algorithm or AI. The performance data is based on an animal study and bench testing, not an AI model that requires a training set.


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

    Not applicable, as no training set for an AI/algorithm is mentioned.

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    K Number
    K203299
    Device Name
    CellFX System
    Date Cleared
    2021-02-02

    (85 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Pulse Biosciences, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CellFX® System is intended for dermatological procedures requiring ablation and resurfacing of the skin.

    Device Description

    The Pulse Biosciences® CellFX® System is a proprietary platform technology. The CellFX System consists of the CellFX Console, CellFX Handpiece, CellFX Treatment Tips, and CellFX Software. The CellFX System delivers nanosecond duration electrical pulses that disrupt the function of cells leading to cell death, while sparing non-cellular tissue. The CellFX System delivers a series of timed, nanosecond electrical pulses (referred to as a "Cycle") to ablate and resurface tissue areas in dermatologic conditions.

    The CellFX Console is capable of delivering short electric pulses at amplitudes up to 15 kV and pulse widths up to 700 ns. The electrical energy pulses are applied directly to targeted tissue using sterile Treatment Tips with stainless steel microneedles. The treatment parameters are selected by the user through a user interface on the Touchscreen Display of the CellFX Console.

    AI/ML Overview

    The provided text describes the CellFX® System, an electrosurgical cutting and coagulation device, and its acceptance criteria for FDA clearance. The information focuses on safety and performance, drawing comparisons to a predicate device, Fractora by Invasix Ltd.

    Here's a breakdown of the requested information based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    For Biocompatibility Testing:

    Acceptance CriteriaReported Device Performance
    All tests met respective acceptance criteria as per FDA Guidance (June 16, 2016): Use of International Standard ISO 10993-1.All biocompatibility tests met their respective acceptance criteria.

    For Electrical Safety and Electromagnetic Compatibility (EMC):

    Acceptance CriteriaReported Device Performance
    Compliance with IEC 60601-1, IEC 60601-1-2, 60601-2-2, IEC 60601-1-6, IEC 62366, and IEC 62304.All electrical safety and EMC tests passed.

    For Software Verification and Validation Testing:

    Acceptance CriteriaReported Device Performance
    Software testing supports the safety and effectiveness of the device. Cybersecurity controls mitigate malware risk as per FDA Draft Guidance.Completed software testing supports the safety and effectiveness of the device. Cybersecurity controls have been implemented.

    For Animal Study (Safety):

    Acceptance CriteriaReported Device Performance
    No procedure-related complications; CellFX treatments considered safe based on intra-procedural treatments, gross evaluation, histopathological analysis, clinical pathology, and in-life physical examinations.All animals survived to their termination date with no procedure-related complications. CellFX treatments are considered to be safe.

    For Animal Study (Performance):

    Acceptance CriteriaReported Device Performance
    All test articles meet the acceptance criteria for device performance. Treatment zones meet acceptance criteria. Successful degeneration and necrosis of active treatment sites while the epidermis remained intact.All test articles met the acceptance criteria for device performance. The treatment zones met the acceptance criteria. The CellFX treatment sites successfully achieved degeneration and necrosis of active treatment sites while the epidermis remained intact. The device is expected to perform as intended.

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

    The primary testing described for effectiveness and safety is an Animal Study.

    • Sample Size: 15 Yucatan pigs.
    • Data Provenance: The study was conducted as a GLP (Good Laboratory Practice) animal safety study. While the geographical origin isn't specified, GLP studies are typically conducted in controlled laboratory environments. It is a prospective study since animals underwent treatments specifically for the study.

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

    The document does not explicitly state the number or qualifications of experts for establishing ground truth within the animal study. However, the evaluation included:

    • Gross evaluation
    • Histopathological analysis
    • Clinical pathology
    • In-life physical examinations

    These types of evaluations would typically be performed by qualified veterinary pathologists, clinicians, and support staff, but specific numbers and qualifications are not provided in this summary.

    4. Adjudication Method for the Test Set

    The document does not specify an adjudication method like 2+1 or 3+1. The evaluations for the animal study (gross, histopathological, clinical pathology, physical exams) suggest a comprehensive assessment, likely involving consensus among the relevant scientific and medical professionals involved in the study, but a formal adjudication process is not detailed.

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

    No, an MRMC comparative effectiveness study involving human readers or interpretation of results is not mentioned or described in this document. The study described is an animal study validating device safety and performance.

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

    This device is not an AI algorithm. It's a physical electrosurgical system. Therefore, the concept of "standalone (algorithm only)" is not applicable here. The performance described is that of the physical device in an animal model.

    7. The Type of Ground Truth Used

    For the animal study, the ground truth was established through a combination of:

    • Histopathology: Microscopic examination of tissue samples.
    • Clinical Pathology: Analysis of blood or other body fluids.
    • Gross Evaluation: Macroscopic observation of tissues and organs.
    • In-life Physical Examinations: Direct clinical assessment of the animals.
    • Survival Data: Absence of procedure-related complications.

    This constitutes a comprehensive set of biological and pathological observations.

    8. The Sample Size for the Training Set

    The document does not describe a training set. This is a premarket notification for a physical medical device, not an AI/ML algorithm that typically undergoes a training phase with a dataset.

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

    As there is no training set described for this device, information on how its ground truth was established is not applicable.

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