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510(k) Data Aggregation

    K Number
    DEN110009
    Date Cleared
    2013-12-18

    (1056 days)

    Product Code
    Regulation Number
    890.5760
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The RESTIFFICTM Restless Leg Relaxer Foot Wrap is a prescription device intended to reduce symptoms of moderate to severe primary Restless Leg Syndrome (RLS) in adults and used during periods of rest or relaxation, when symptoms of RLS occur.

    Device Description

    The RESTIFFIC™ Restless Leg Relaxer Foot Wrap device is a foot wrap designed to apply continuous, adjustable squeezing pressure on specific muscles in the feet. The device is to be applied before bedtime or while the person is seated or supine.

    A more complete description of the device includes the following:

    • An outer cloth wrap to support and hold the pressure pad in place. (The wrap has an . open end so the pad can be removed and replaced, if needed. Only the cloth comes in contact with the skin);
    • . VELCRO straps and plastic buckles to hold the cloth wrap in place and allow for adjusting the pressure; and
    • Pressure pads of high density foam to put pressure on the medial and bottom part of ● the foot. The RESTIFFIC™ achieves its targeted pressure with a T- shaped pad that presses into the medial and bottom part of the foot.
    AI/ML Overview

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    Acceptance Criteria and Device Performance

    The provided document describes the regulatory classification of the RESTIFFIC™ Restless Leg Relaxer Foot Wrap, rather than explicitly stating acceptance criteria in the typical performance metric sense (e.g., sensitivity, specificity, accuracy). However, we can infer the primary "acceptance criterion" as demonstrating a statistically significant reduction in symptoms of moderate to severe primary Restless Leg Syndrome (RLS) in adults, particularly as measured by the International Restless Legs Scale (IRLS) score, with an acceptable safety profile. The "device performance" then refers to the study's findings regarding this symptom reduction and safety.

    Acceptance Criteria (Inferred from regulatory context)Reported Device Performance (from Clinical Study)
    Reduction in symptoms of moderate to severe primary RLSStatistically significant decrease in symptoms from severe or moderate to mild RLS, overall. Mean 17.22 reduction in IRLS score.
    Acceptable safety profile11 non-serious device-related adverse events (AEs) in 10 subjects (transient numbness, pain, or burning), all resolved upon loosening the device. No serious AEs. No subjects stopped using due to AEs.
    Improvement as assessed by cliniciansCGI-I: All subjects improved; 90% "much improved" or "very much improved".
    Decrease in severity as assessed by cliniciansCGI-S: 97% experienced a decrease in severity; 83% decreased at least two levels.
    Moderate to marked improvement with no side effects (CGI-EI)CGI-EI: 86% showed moderate to marked improvement with no side effects.

    Study Details

    The provided text describes a single-arm, historically-controlled, open-label study.

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

      • Sample Size: n=30 adult subjects.
      • Data Provenance: Not explicitly stated, but implies a prospective clinical study conducted specifically for the device's evaluation. No country of origin is mentioned.
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:

      • "Ground Truth" Methodology: The primary outcome (IRLS score) was a patient-reported outcome measure. Secondary outcomes (CGI-I, CGI-S, CGI-EI) were investigator-assessed measures of the subject's illness.
      • Number & Qualifications of Experts: The text does not specify the number or qualifications of the "investigators" who assessed the CGI metrics. It simply refers to them as "investigators."
    3. Adjudication Method for the Test Set:

      • No adjudication method (e.g., 2+1, 3+1) is mentioned or implied for either the patient-reported outcomes or the investigator-assessed outcomes. The CGI scores appear to be direct assessments by the investigators.
    4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

      • No, an MRMC comparative effectiveness study was not done.
      • The study was a single-arm trial comparing the device's results to "historical drug studies using meta-analyses," rather than a direct comparison with human readers or human readers with/without AI assistance. Therefore, there is no effect size related to human reader improvement with AI.
    5. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:

      • This question is not applicable as the RESTIFFICTM device is a physical, non-powered medical wrap and not an algorithm or AI system. Its performance inherently involves human interaction (wearing the device).
    6. Type of Ground Truth Used:

      • Primary Ground Truth: Patient-reported outcome (IRLS score).
      • Secondary Ground Truth: Investigator assessment (CGI-I, CGI-S, CGI-EI), which represents a clinical judgment of the subject's status.
      • No pathology or direct objective outcomes data (beyond symptom self-reporting and clinical impression) are mentioned.
    7. Sample Size for the Training Set:

      • Not applicable. The RESTIFFICTM device is a physical, non-powered medical device, not an AI or machine learning model that requires a "training set." The study described is a clinical trial evaluating its efficacy in a patient population.
    8. How the Ground Truth for the Training Set Was Established:

      • Not applicable for the reasons stated in point 7.
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