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510(k) Data Aggregation

    Why did this record match?
    Device Name :

    Passeo-35 Xeo Peripheral Dilatation Catheter; Passeo-18 Peripheral Dilatation Catheters; Passeo-14 Peripheral

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

    The Passeo-35 Xeo peripheral dilatation catheter is indicated to dilate stenosis in the iliac, femoral, popliteal and infrapopliteal arteries and for the treatment of obstructive lesions of native or synthetic arteriovenous dialysis fistulae. Passeo-35 Xeo is also recommended for post-dilatation of balloon expandable and self-expanding stents in the peripheral vasculature.

    The Passeo-18 peripheral dilatation catheter is indicated to dilate stenosis in the femoral, popliteal and infrapopliteal arteries and for the treatment of obstructive lesions of native or synthetic arteriovenous dialysis fistulae.

    Passeo-14 is indicated for balloon dilatation of the stenotic portion of a lower limb artery for the purpose of improving perfusion.

    The Oscar Peripheral Multifunctional Catheter system is indicated for percutaneous transluminal interventions in the peripheral vasculature to provide support during access into and to dilate stenoses in femoral, popliteal and infrapopliteal arteries. The product is also intended for injection of radiopaque contrast media for the purpose of angiography.

    The Pantera LEO is indicated for balloon dilatation of the stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion and for post dilatation of coronary stents.

    The Pantera Pro is indicated for balloon dilatation of the stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion. The Pantera Pro (balloon diameter 2.0 – 4.0 mm) is also indicated for post-delivery expansion of balloon expandable stents.

    Device Description

    BIOTRONIK's Passeo 35 Xeo Catheter is an over-the-wire (OTW) balloon dilatation catheter, indicated for dilatation of stenotic segments in peripheral vessels. The Passeo 35 Xeo Catheter is a dual lumen design with both lumens contained within one tube. The smaller lumen is the balloon inflation/deflation lumen. The larger lumen permits the use of guide wires with a maximum diameter of 0.035" to facilitate advancement of the Passeo 35 Xeo Catheter towards and through the lesion(s) to be dilated.

    The Passeo-18 peripheral dilatation catheter is intended for dilatation of stenotic segments in peripheral vessels and arteriovenous dialysis fistulae. The dilatation balloon is designed to inflate to a known diameter at a specific inflation pressure consistent with the compliance chart on the label. One radiopaque marker is located at each end of the balloon to facilitate fluoroscopic visualization and positioning of the balloon catheter towards and across the lesion. The dilatation catheter includes a soft tapered tip to facilitate advancement of the catheter. The dilatation catheter has two Luer-ports at the proximal end. One port (inflation port) serves for connecting an inflation device to inflate/deflate the balloon. The other port enables flushing of the guide wire lumen. The dilatation catheter has a hydrophobic silicone coating on the shaft outer surface and a hydrophobic patchwork coating on the balloon.

    The Passeo-14 peripheral dilatation catheter is intended for the dilatation of stenotic segments in lower limb arteries. The dilatation balloon is designed to inflate to a known diameter at a specific inflation pressure consistent with the compliance chart on the label. One radiopaque marker is located at each end of the balloon to facilitate fluoroscopic visualization and positioning of the balloon catheter towards and across the lesion. The dilatation catheter includes a soft tapered tip to facilitate advancement of the catheter. The dilatation catheter has two Luer-ports at the proximal end. One port (inflation port) serves for connecting an inflation device to inflate/deflate the balloon. The other port enables flushing of the guide wire lumen.

    The Oscar Peripheral Multifunctional Catheter system is an intravascular balloon catheter system, supplied with a retractable sheath (Oscar Support Catheter), a flexible catheter (Oscar Dilator) and a PTA balloon (Oscar PTA balloon), allowing a variable guide wire support and injection of fluids, and adjustable length inflatable balloon up to 180 mm. The over the wire (OTW) catheter has a retractable sheath allowing the balloon to be inflated at various lengths as determined by the physician. The balloon lengths are graduated with evenly spaced radiopaque markers. The Oscar Peripheral Multifunctional Catheter system is a 4F and 6F catheter system with a shaft working length of 60 cm or 120 cm, compatible with 0.014" (Oscar 4F) and 0.018" (Oscar 6F) guide wires. The device uses a semi-compliant balloon with a size dependent rated burst pressure and an indicated clinical use range of 6 atm to 16 atm. The balloon expands to a set nominal diameter (2.0, 2.5, 3.0, 4.0, 5.0, 6.0 and 7.0 mm). If required, separate PTA balloon catheters in same size range are also available separately.

    Pantera LEO is a PTCA rapid exchange system with a balloon at the distal end of the catheter. A Luer port at the proximal end enables the attachment of an inflation device for the inflation of the balloon. The catheter provides a lumen, which enables the use of a guide wire to position the catheter. Radiopaque balloon markers aid in the placement of the catheter's balloon segment under fluoroscopy.

    Pantera Pro is a PTCA rapid exchange system with a balloon at the distal end of the catheter. A Luer port at the proximal end enables the attachment of an inflation device for the inflation of the balloon. The catheter provides a lumen, which enables the use of a guide wire to position the catheter. Radiopaque balloon markers aid in the placement of the catheter's balloon segment under fluoroscopy.

    AI/ML Overview

    The provided FDA 510(k) clearance letter (K250706) is for BIOTRONIK's peripheral and coronary dilatation catheters. This document describes several devices: Passeo-35 Xeo, Passeo-18, Passeo-14, Oscar Peripheral Multifunctional Catheter System, Pantera LEO PTCA Catheter, and Pantera Pro PTCA Catheter.

    It's important to note that this 510(k) Summary does not describe an AI/ML powered device. Instead, it focuses on the physical and performance characteristics of medical devices (catheters). Therefore, many of the requested criteria, such as "number of experts used to establish ground truth," "adjudication method," "MRMC comparative effectiveness study," "standalone algorithm performance," and details about training data, are not applicable to this type of submission.

    The "performance testing" mentioned throughout the document refers to bench testing and engineering assessments to ensure the physical device meets its design specifications and performs safely and effectively. It does not involve AI model performance evaluation with clinical data.

    Here's an attempt to answer the applicable parts of your request based on the provided text, with clear indications where the information is not present or not relevant to an AI/ML device:


    Acceptance Criteria and Study to Prove Device Meets Criteria

    The acceptance criteria for these devices are implicitly derived from the design specifications and are demonstrated through performance (bench) testing. The study proving these devices meet the acceptance criteria is a series of performance (bench) tests.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document describes technological characteristics and states that "All necessary performance testing was conducted... to ensure that the devices conform to the design specification." The "Subject Devices" column in the tables explicitly states "Identical" for most characteristics, meaning they meet the same specifications as the predicate devices. The only explicit change mentioned is that "Components will be brought into compliance with ISO 80369-7:2021" for Luer connectors and manifolds. The full set of specific performance acceptance criteria values (e.g., specific burst pressure thresholds, flexibility requirements, etc.) are not explicitly detailed in this summary but are indirectly stated as being met for "consistent performance during its intended use."

    Here's a summary derived from the comparison tables, focusing on the acceptance of "identical" characteristics:

    Acceptance Criteria CategorySpecific Criteria (from Predicate Device)Reported Device Performance (Subject Device)
    Intended UserPhysicians competent in PTA proceduresIdentical
    Method of PlacementStandard percutaneous access to site over a guide wire, with fluoroscopic visualizationIdentical
    SterilizationEO gas, SAL 10⁻⁶Identical
    Shelf Life3 yearsIdentical
    Radiopaque MarkersPresence, material, number, length, and spacing as specified for each device typeIdentical
    Usable LengthSpecified lengths (e.g., 90, 130, 170 cm for Passeo-35 Xeo)Identical
    Introducer Sheath CompatibilitySpecified F sizes and balloon diameter/length compatibilityIdentical
    Crossing ProfileMaximum inches/mm as specifiedIdentical
    Guide Wire CompatibilitySpecified guide wire diameter (e.g., 0.035" for Passeo-35 Xeo)Identical
    Shaft Outer DiameterSpecified F sizeIdentical
    Balloon DiameterSpecified range of diameters (e.g., 3.0-12.0 mm for Passeo-35 Xeo)Identical
    Balloon LengthSpecified range of lengths (e.g., 20-250 mm for Passeo-35 Xeo)Identical
    Balloon WrappingSpecified folds (e.g., 3-5 folds for Passeo-35 Xeo)Identical
    Balloon Nominal PressureSpecified atmIdentical
    Balloon RBP (Rated Burst Pressure)Specified atm, often varying by balloon diameter/lengthIdentical
    Guiding Catheter Compatibility (PTCA catheters)Minimum F size/IDIdentical
    Distal Outer Shaft/Balloon Coating (PTCA catheters)Hydrophilic/Hydrophobic coating as specifiedIdentical
    Luer Connectors and ManifoldsPreviously Luer lock connectors (L2)Will be brought into compliance with ISO 80369-7:2021 (This is the only explicitly noted difference/update)

    Overall Performance Conclusion: "The collective results of the performed testing demonstrated that the materials chosen, the manufacturing processes, and design of the components meet the established specifications necessary for consistent performance during its intended use. In addition, the collective bench testing demonstrates that the proposed device does not introduce new issues of safety or effectiveness when compared to the predicate device."

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

    The document specifies "performance testing" or "bench testing," which refers to laboratory-based evaluations of the physical device. It does not mention a test set with patient data or any sample size related to clinical data. The provenance is not applicable as this concerns physical device characteristics, not data.

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

    This information is not applicable as the evaluation is not based on expert-labeled ground truth for an AI/ML algorithm but on physical measurements and engineering tests of the device.

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

    This information is not applicable as the evaluation is not based on expert consensus or adjudication of clinical cases for an AI/ML algorithm.

    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

    This information is not applicable as the device is a physical medical instrument (catheter), not an AI/ML diagnostic or assistive tool.

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

    This information is not applicable as the device is a physical medical instrument (catheter), not an AI/ML algorithm.

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

    The "ground truth" for these devices is the established engineering specifications, material properties, and performance benchmarks that the predicate devices have successfully met. These are verified through various physical and mechanical bench tests (e.g., burst pressure, flexibility, lubricity, dimensional accuracy, etc.). The document indicates these tests confirm the new devices' conformity to these specifications.

    8. The sample size for the training set

    This information is not applicable as the device is a physical medical instrument (catheter) and does not involve AI/ML training.

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

    This information is not applicable as the device is a physical medical instrument (catheter) and does not involve AI/ML training or a training set with ground truth.

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    K Number
    K151744
    Manufacturer
    Date Cleared
    2015-10-08

    (101 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Passeo-18 Peripheral Dilation Catheter

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

    The Passeo-18 peripheral dilatation catheter is indicated to dilate stenoral, popliteal and infrapopliteal arteries and for the treatment of obstructive lesions of native or synthetic arteriovenous dialysis fistulae.

    Device Description

    The Passeo-18 peripheral dilatation catheter is intended for dilatation of stenotic segments in peripheral vessels and arteriovenous dialysis fistulae. The dilatation balloon is designed to inflate to a known diameter at a specific inflation pressure consistent with the compliance chart on the label. One radiopaque marker is located at each end of the balloon to facilitate fluoroscopic visualization and positioning of the balloon catheter towards and across the lesion.

    The dilatation catheter includes a soft tapered tip to facilitate advancement of the catheter has two Luer-ports at the proximal end. One port (inflation port) serves for connecting an inflation device to inflate/deflate the balloon. The other port enables flushing of the dilatation catheter has a hydrophobic silicone coating on the shaft outer surface and a hydrophobic patchwork coating on the balloon.

    The dilatation catheter is compatible wire and introducer sheath sizes according to the recommendations on the label.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the BIOTRONIK Passeo-18 Peripheral Dilatation Catheter, specifically detailing the justification for clearance of additional device size configurations and minor design changes. The document focuses on non-clinical performance testing to demonstrate substantial equivalence to a previously cleared predicate device. It explicitly states that no clinical data was submitted or relied upon for this substantial equivalence determination. Therefore, questions related to human reader performance, multi-reader multi-case studies, or ground truth established by experts/pathology/outcomes data are not applicable to this submission.

    Here's an analysis of the acceptance criteria and the study as described:

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

    Test NameTest Conditions / Specifications (Acceptance Criteria implicitly defined)Reported Device Performance
    Dimensional Verification
    Visual and Dimensional InspectionThe balloon catheter was visually inspected for defects, printing, coating homogeneity, x-ray marker positioning and adherence to dimensional specs.Inspectional acceptance criteria were met.
    Crossing Profile (system profile)The diameter of the device is measured by passing the device through a ring-hole gauge to verify French size compatibility.Acceptance criteria for crossing profile were met. Crossing profile is within specs of predicate.
    Simulated Use Testing
    Simulated UseTesting is conducted to demonstrate that the balloon catheter can be safely and reliably prepared, delivered, and retracted using the recommended techniques and instructions for use, without damage to the device.Acceptance criteria were met. Test shows device performs similar to predicate in a simulated use environment.
    Trackability and PushabilityTest recorded frictional force (N) when tracked over a guide wire in arterial model.Acceptance criteria were met. Test shows device performs similar to predicate in a simulated use environment.
    Pullback and reintroduction testWith the balloon in an appropriate sheath, the friction to introduce and pullback the device after inflation to RBP is evaluated.Pullback and reintroduction was comparable or better than comparator product. Device performs similar to predicate.
    Balloon Inflation / Deflation TimeInflation and deflation time are measured with the device placed in an anatomical model. Inflation and deflation times were measured for characterization.Inflation time was characterized and deflation time was determined to be according to specifications within the instructions for use.
    Compatibility with Contrast mediaDevices were stored for in contrast medium (ionic and non-ionic) for a specified time, dilated to RBP and then visually inspected.No visible damage or deformation. Device performs similar to predicate.
    Mechanical Testing
    Balloon Compliance RadialRadial compliance is calculated as the balloon diameter at NP and at RBP.Radial compliance meets acceptance criteria. Device performs similar to predicate.
    Balloon Compliance AxialAxial compliance (balloon length at RBP and NP) of the device is measured to verify that it meets product specification.The difference between balloon length at RBP and NP is within specification.
    Balloon burst strengthThis test determines the balloon Rated Burst Pressure (RBP). The balloon is inflated until burst and pressure at burst is recorded. The burst failure mode is recorded.Balloons met acceptance criteria for lower 99.9% quantile at 95% confidence interval for all sizes.
    Balloon FatigueThe balloons were subjected to repeat inflation/deflation cycles to determine survivability of the balloon. Any loss of pressure, whether due to failure of the balloon, shaft or proximal or distal seals, was reported as a test failure. All failure modes were recorded.Results demonstrate that 90% of the balloons will survive the test with at least 95% confidence.
    Tensile Strength CatheterFollowing simulated use, a tensile strain is applied along the relevant catheter region until the first sign of fracture. The force (Fmax) at first sign of damage is recorded.Tensile strength performance (Fmax) for distal and proximal balloon sections met performance specifications.
    Resistance to KinkTest was performed to determine the minimum bending radius of the catheter shaft at proximal and distal locations.Measured mean catheter kink radius was well within the acceptance criteria.
    Torsional rigidityTest was performed to assess the ability to inflate and deflate the balloon following application of a torsional load.Device meets acceptance criteria. Device performs similar to predicate.
    RotatabilityTest was performed to evaluate torque response. The proximal end of the device is rotated until the first rotational movement at the distal end is observed.Device meets acceptance criteria. Device performs similar to predicate.
    Post-Dilatation TestIn a simulated arterial model, balloon is positioned within a deployed stent and subjected to multiple inflation/deflation cycles.All samples withstood all inflation/deflation cycles within the stent without bursting. Device performs similar to predicate.
    Biocompatibility
    CytotoxicityL929 cells are incubated with test article extracts and evaluated for percentage of cell growth inhibition and compared to a control sample (control: cells exposed to extraction medium).Growth analyses of cells cultured with test article extract showed no cytotoxic effects of the test article.
    Gas Chromatography – Mass Spectrometry (GC/MS)The old materials are compared to the new materials. The test articles are extracted in different solvents (polar and non-polar, e.g. purified water, isopropyl alcohol and hexane) and the extracts are analyzed by GC-MS fingerprint analysis.There are no significant differences between old and new materials.
    Fourier Transform Infrared Spectroscopy (FT-IR) analysisFourier Transform Infrared Spectroscopy (FT-IR) was utilized to compare the chemical composition of the new materials and old materials. The resulting FT-IR spectra were compared.Materials had greater than 99% correlation according to FT-IR analysis. The new materials are similar to the predicate.
    Sterilization Validation
    Correction factor and bioburdenTest conducted to determine typical device bioburden prior to sterilization.Determine bioburden correction factor. Device meets specifications for CFU/device.
    Test for inhibitors and activators, Pyrogen testTest conducted to determine device endotoxin levels after manufacturing.Bacterial endotoxin test results met acceptance criteria.
    Validation of the Sterilization SuccessTest was performed according to determine if sterilization parameters are sufficient for a SAL of 1x10-6.Testing confirmed SAL of 10-6. The device performs similar to predicate.
    Residual gas analysis: EO and ECHTest conducted to determine EO and ECH residuals on the device following two sterilization cycles.Device meets acceptance criteria. The device performs similar to predicate.

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

    The document does not specify exact sample sizes (N-numbers) for each individual test. It mentions "all sizes" for balloon burst strength and refers to "samples" in other tests. The data provenance is non-clinical bench testing and simulated use environment testing, not clinical data from patients. The location of testing is not explicitly stated, but it would typically be conducted by the manufacturer (BIOTRONIK) or a contracted lab.

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

    Not applicable. This was a non-clinical device performance study. Ground truth was established through engineering specifications, material science analysis, and physical measurements, not by human experts interpreting clinical data.

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

    Not applicable. Adjudication methods are relevant for studies involving human interpretation or clinical outcomes. This study focuses on physical and mechanical properties of the 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

    Not applicable. No clinical studies, and specifically no MRMC studies, were performed or submitted. The submission explicitly states: "The determination of substantial equivalency on this subject device does not rely upon the clinical data. There is no clinical data submitted in this application."

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

    Not applicable. This is not an AI/algorithm-based device. It is a physical medical device (catheter).

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

    The ground truth for this submission is based on engineering specifications, material standards, and benchmark performance metrics of the predicate device. For example, for "Balloon burst strength," the ground truth is the specified Rated Burst Pressure (RBP) and accepted failure modes. For "Biocompatibility," the ground truth involves established biological safety standards and comparison to the predicate's material composition.

    8. The sample size for the training set

    Not applicable. There is no "training set" as this is not an AI/machine learning model.

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

    Not applicable. There is no "training set" for this physical device.

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    K Number
    K072765
    Device Name
    PASSEO 18
    Manufacturer
    Date Cleared
    2007-12-12

    (75 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    PASSEO 18

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

    Passeo-18 is indicated to dilate stenosis in the femoral, popliteal and infrapopliteal arteries and for the treatment of obstructive lesions of native or synthetic arteriovenous dialysis fistulae

    Device Description

    The Passeo-18 peripheral transluminal angioplasty (PTA) balloon catheter is indicated for dilatation of stenotic segments in peripheral vessels. Two radiopaque markers are located at either end of the ballon to facilitate fluoroscopic visualization and positioning of the balloon catheter towards and across the lesion. The dilatation balloon is designed to inflate to a known diameter at a specific inflation pressure consistent with the compliance chart on the label. The balloon catheter includes a tapend of tip to facilitate advancement of the catheter.

    The balloon catheter shaft has two Luer ports at the proximal end. One port (inflation port) serves for connecting an inflation device to inflate/deflate the balloon. The other port enables insertion of the guide wire. The balloon catheter has a two lumen co-axial design. The outer lumen is the balloon inflation/deflation lumen. The inner lumen permits the use of guide wires with diameters up to a maximum of 0.018" to facilitate advancement of the balloon catheter towards and through the lesion(s) to be dilated. The balloon catheter is compatible with introducers sizes according to the recommendations on the label. The balloon cather has a silicone coating to improve the trackability and pushability characteristics.

    AI/ML Overview
    {
      "1. A table of acceptance criteria and the reported device performance": {
        "Acceptance Criteria": "The Passeo-18 PTA Catheter is substantially equivalent to the predicate devices (BIOTRONIK's Pheron peripheral PTA catheter, [K033217](https://510k.innolitics.com/search/K033217) and [K052757](https://510k.innolitics.com/search/K052757)) based on indications for use and general specifications.",
        "Reported Device Performance": "The FDA determined that the Passeo-18 PTA catheter is substantially equivalent to its predicate devices for the indicated uses, indicating it meets the acceptance criteria for safety and effectiveness."
      },
      "2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)": "Not applicable. This is a 510(k) premarket notification for a medical device (PTA catheter), not an AI/ML diagnostic device study involving a test set of data. The submission relies on demonstrating substantial equivalence to a predicate device, not on clinical performance data derived from a specific test set.",
      "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 document pertains to a medical device (PTA catheter) and not an AI/ML diagnostic device requiring expert interpretation for ground truth.",
      "4. Adjudication method (e.g. 2+1, 3+1, none) for the test set": "Not applicable. This document pertains to a medical device (PTA catheter) and not an AI/ML diagnostic device requiring adjudication of expert interpretations.",
      "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 document pertains to a medical device (PTA catheter) and not an AI/ML diagnostic device, so no MRMC study was conducted or is relevant.",
      "6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done": "Not applicable. This document pertains to a physical medical device (PTA catheter) and not an algorithm or AI. Performance is evaluated through bench testing and comparison to predicate devices, not through standalone algorithm performance.",
      "7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)": "Not applicable. For a 510(k) of this nature, 'ground truth' largely refers to established engineering standards, biocompatibility testing results, and performance characteristics (e.g., inflation diameter at pressure, flexibility, trackability) demonstrated to be equivalent to the predicate device. These are not typically established by expert consensus of patient data, pathology, or outcomes in the same way an AI/ML diagnostic device's ground truth would be.",
      "8. The sample size for the training set": "Not applicable. This is a 510(k) for a medical device (PTA catheter), not an AI/ML diagnostic device. Therefore, there is no training set in the context of an algorithm.",
      "9. How the ground truth for the training set was established": "Not applicable. This is a 510(k) for a medical device (PTA catheter), not an AI/ML diagnostic device. Therefore, there is no training set and no ground truth establishment for a training set."
    }
    
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