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510(k) Data Aggregation

    K Number
    K250309
    Device Name
    BTL-199
    Date Cleared
    2025-08-07

    (185 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    QPL

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

    The BTL-199 is intended to stimulate peripheral nerves for relief of chronic intractable pain, post-traumatic pain, post-surgical pain and/or for relief of chronic painful diabetic peripheral neuropathy in the lower extremities. The BTL-199 is for use on patients 18 and older.

    Device Description

    The BTL-199 is an electromagnetic stimulator that delivers brief, focused electromagnetic pulses to non-invasively stimulate peripheral nerves, providing pain relief.

    The device consists of a main unit and specialized applicators, designed to deliver precise and effective therapy. The main unit is equipped with an intuitive color touch screen that provides step-by-step guidance for the operator throughout the therapy process. The device features a preset treatment protocol for ease of use, while also allowing operators to customize parameters to meet specific therapeutic needs. Adjustable parameters include frequency (up to 150 Hz), therapy time (up to 30 minutes), and intensity (0-100%). The interface displays detailed information about the therapy settings and session progress (i.e., treatment duration). The device uses a temperature sensor to monitor the temperature of the coil to ensure that the maximum permissible temperature of the applicator's contact areas (i.e., 43°C) are not exceeded. It also has an intensity predictor function that limits the maximum adjustable intensity of the device based on the therapy parameters set, so as not to overheat and damage the device.

    The device is equipped with three sets of applicators: AP-C-1, AP-C-2, and AP-C-4/5. Each applicator is intended for a different body area depending on the size and shape of the treated body part.

    • Applicator AP-C-1 is intended for treatment of larger body areas, such as back, waist, thighs, etc.
    • Applicator AP-C-2 is intended for treatment of smaller body areas, such as hands, arms, legs, etc.
    • Applicators AP-C-4/5 (AP-C-4 and AP-C-5 - for each side of the body respectively) is primarily intended for treatment of waist and lower back.
    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary for the BTL-199 device does not include any clinical study data or describe acceptance criteria related to device performance in a clinical setting.

    The submission is based on the device being "substantially equivalent" to predicate devices, which generally means that it has the same intended use and similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness. For devices like the BTL-199, classified as Class II, substantial equivalence can often be demonstrated through non-clinical testing (bench testing, electrical safety, biocompatibility, etc.) and a comparison of technological characteristics with predicate devices that have already been cleared.

    The "Clinical Testing" section explicitly states "Not applicable," which confirms that a clinical study proving device performance against specific acceptance criteria (like accuracy, sensitivity, or improvement in patient outcomes) was not required or submitted for this 510(k) clearance.

    Therefore, I cannot fulfill the request to describe acceptance criteria and a study proving the device meets them based on the provided text, as such information is not present. The document focuses on demonstrating substantial equivalence for regulatory clearance, not on presenting performance data from a clinical trial.

    If this were a device requiring clinical performance data (e.g., an AI-powered diagnostic device), the 510(k) summary would typically include a section detailing the clinical study, its methodology, and the results compared against pre-defined acceptance criteria. This is not the case for the BTL-199.

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    K Number
    K250286
    Date Cleared
    2025-07-03

    (153 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    QPL

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

    Rapid2 Magnetic Stimulators (Magstim Rapid2, Magstim Super Rapid2, Magstim Super Rapid2 Plus1) are intended to stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older.

    Device Description

    The Magstim Rapid2, Magstim Super Rapid2, Magstim Super Rapid2 Plus1 (herein collectively referred to as "Rapid2 Magnetic Stimulators") are computerized, electromechanical medical devices that provide brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older. The subject device is intended to be used in hospitals and clinics such as pain management clinics.

    Rapid2 Magnetic Stimulators are integrated systems consisting of a combination of hardware, software, and accessories. Rapid2 Magnetic Stimulators are offered in multiple configurations:

    • Rapid2
    • Super Rapid2
    • Super Rapid2 Plus1

    All three configurations have identical intended use/indications for use, common specifications, equivalent performance characteristics and equivalent composition to each other. Specifically, Rapid2 and Super Rapid2 have received prior clearance under K051864 for Peripheral Nerve Stimulation (Product Code: GWF, Regulation 21 CFR 882.1870). All Rapid2 Magnetic Stimulators are made up of components that have received prior clearance under K051864 (e.g., the 3190-00, 3192-00 and 3193-00 coils) and components which have received prior clearance under K051864 but have received modifications due to aspects like obsolescence (Mainframe, Power Supply etc.).

    All Rapid2 Magnetic Stimulators are composed from the following main components:

    • Stimulating Unit & Power Supply
    • User Interface
    • Stimulating Coil
    • System and Stimulating Coil Cart and Holding Arm

    Rapid2 Magnetic Stimulators include temperature monitoring via two independent temperature sensors to ensure surfaces of the coils do not reach unacceptable levels. The cut-off is set to act at 40°C at which point the system will automatically be disabled. Over-temperature conditions are also communicated on the User Interface (UI) via a temperature gauge and alarm system. Rapid2 Magnetic Stimulators also includes the 3910-00 air-cooled coil to further mitigate any temperature conditions. The 3910-00 air-cooled coil comes with all 3 configurations (Rapid2, Super Rapid2 and Super Rapid2 Plus1) as standard.

    AI/ML Overview

    The provided document is an FDA 510(k) Clearance Letter for the Rapid2 Magnetic Stimulators. It does NOT contain information about a study proving the device meets acceptance criteria related to its performance in pain relief. Instead, it focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing of technical characteristics, safety standards compliance, and physical properties.

    The document does not describe an AI/ML-driven device, nor does it present results from a clinical study with patients or human readers using AI. The acceptance criteria and performance metrics described are related to physical and electrical characteristics of the magnetic stimulator, not diagnostic accuracy or clinical effectiveness in a traditional sense of "performance" as one might expect for an AI diagnostic device.

    Therefore, many of the requested items (e.g., sample size for test/training sets, data provenance, number of experts for ground truth, MRMC study, standalone performance, ground truth type) cannot be answered based on the provided text, as they pertain to clinical or AI/ML performance evaluation, which is not the subject of this 510(k) summary.

    However, I can extract information related to the technical acceptance criteria and how they align with the device's measured performance as described in the summary:


    Acceptance Criteria and Device Performance (Based on Technical and Safety Equivalence)

    The acceptance criteria for the Rapid2 Magnetic Stimulators are primarily based on demonstrating substantial equivalence to the predicate device (MagVenture Pain Therapy) in terms of technical characteristics, safety, and effectiveness for the stated indications for use. The "performance" reported is adherence to these characteristics and safety standards.

    Acceptance Criteria Category/CharacteristicSubject Device Performance (Rapid2 Magnetic Stimulators)Predicate Device Performance (MagVenture Pain Therapy)Evaluation / Proof of Meeting Criteria
    Indications for UseStimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older.Stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older.Identical. Meets criteria by having the same intended use.
    Anatomical SitesAny area, such as hand, arm, waist, buttock, thigh, calf, back and lower back etc.Any area, such as hand, arm, waist, buttock, thigh, calf, back and lower back etc.Identical.
    Treatment FacilitiesHospitals & ClinicsHospitals & ClinicsIdentical.
    Treatment Time13 minutes per session (800 seconds)13 minutes per session (800 seconds)Identical.
    Pulse FrequencyRapid2: 0.1 – 50 Hz (pps); Super Rapid2 and Super Rapid2 Plus1: 0.1 – 100 Hz (pps)MagPro R30 & MagPro R30 with MagOption: 0.1 – 30 Hz (pps); MagPro X100 & MagPro X100 with MagOption: 0.1 – 100 Hz (pps)Similar range. Subject device's range covers or extends slightly beyond predicate, but the recommended protocol (0.5Hz) is well within both.
    Pulse Amplitude0 – 100%0 – 100%Identical.
    On-cycle duty period2-800 Seconds (0.5 Hz and up to 400 pulses)2-800 Seconds (0.5 Hz and up to 400 pulses)Identical.
    Off-cycle rest periodN/AN/AIdentical.
    Maximum Repetition RateRapid2: 50Hz; Super Rapid2: 100Hz; Super Rapid2 Plus1: 100HzMagPro R30 & MagPro R30 with MagOption: 30 pulses per second; MagPro X100 & MagPro X100 with MagOption: 100 pulses per secondUpper limit identical compared to predicate. Substantial equivalence demonstrated despite differences in how maximum output is achieved (explained in "SE Note 1").
    Pulse WidthBiphasic (300-425 µs)Biphasic (280-320 µs)Similar range. Differences deemed not to raise new safety/effectiveness questions due to compensating factors (see "SE Note 2").
    Pulse ModeStandardStandardSame.
    Temperature ControlAutomatic disable at 40°C; includes air-cooled coil; UI communication of over-temperature.Automatic disable at 43°C.Comparable/Better. Subject device has a lower cutoff and additional cooling/reporting features.
    Peak Magnetic Field at Coil Surface1.0-1.5T1.15-2.6TSubstantially equivalent. Subject device is a subset of the predicate's range. Differences explained in "SE Note 2" as not raising new safety/effectiveness concerns.
    Peak Magnetic Field Gradient (dB/dt) at 20mm from Coil Center9-12kT/s9-24kT/sSubstantially equivalent. Subject device is a subset of the predicate's range. Differences explained in "SE Note 2" as not raising new safety/effectiveness concerns.
    WaveformBiphasic, Biphasic BurstBiphasic, Monophasic, Biphasic Burst, Halfsine (combinations vary by predicate configuration)Substantially equivalent. Subject device's waveform is within the range available in the predicate.
    Software/Firmware ControlYesYesIdentical. Verified per IEC 62304.
    Power Supply TypePower Supply via dedicated power supply modules each using a separate input mains line cord.Power Supply via Isolation Transformer.Similar.
    Power Consumption230/240V Systems – 3000VA peak per input; 115V Systems – 2300VA peak per inputMaximum 2700VASimilar.
    User InterfaceLCD Capacitive TouchscreenLED DisplaySimilar. A difference in display technology, but performs the same function.
    Housing Material ConstructionStimulator: PUR, Stainless/Galvanized Steel; Coils: PC, PURStimulator: Aluminum, Aluzinc; Coils: PVC, ABS, PA, POMSimilar. Different specific materials but serve the same function.
    Applied Parts (Coils)Various, including previously cleared (K051864, K080499, K130403) and new coils (4150-00, 4170-00, 4189-00, 4190-00, 4510-00).Various, all previously cleared.Substantially equivalent coil range. New coils are evaluated for safety and function to be equivalent (see "SE Note 2").
    Applied Part AreaButterfly Coils: 152mm – 191mm; Circular Coils: 124.5mmButterfly Coils: 150mm; Circular Coils: 110-126mm; Special Coils: 160x80 mmSubstantially equivalent. (see "SE Note 2").
    SterilizationNon-sterile when used.Non-sterile when used.Identical.
    Electrical SafetyComplies with IEC 60601-1 Ed. 3.2Complies with IEC 60601-1 Ed. 3.1Meets/Exceeds. Complies with a newer edition of the standard.
    Mechanical SafetyComplies with IEC 60601-1 Ed. 3.2Complies with IEC 60601-1 Ed. 3.1Meets/Exceeds. Complies with a newer edition of the standard.
    Thermal SafetyComplies with IEC 60601-1 Ed. 3.2Complies with IEC 60601-1 Ed. 3.1Meets/Exceeds. Complies with a newer edition of the standard.
    Radiation SafetyNo radiation generated.No radiation generated.Same.
    BiocompatibilityComplies with ISO 10993-1, -5, -10; materials tested for Skin Irritation, Cytotoxicity, Skin Sensitization.Complies with ISO 10993.Same/Exceeds. Detailed compliance with relevant parts of the standard.
    Standards ComplianceISO 13485 (company); IEC 60601-1-2, IEC 60601-1-6, IEC 60601-1-8, IEC 62366-1 (device).EN ISO 13485 (company).Same/Equivalent. Device-specific standards compliance indicated.
    AcousticsTested per 60601-1 type testing and in-house, demonstrating substantially equivalent acoustic output. Labeling requires earplugs (30dB noise reduction).(Not specified beyond "similar")Comparable. Demonstrated and mitigated with user instructions.
    E-Field Decay & Linearity of OutputPerformance data showed "very similar" E-Field decay, linearity, and electric/magnetic field spatial distributions.(Not explicitly detailed, but implied to be baseline for comparison)Comparable. Results demonstrate equivalent effects at 0-2cm from coil surface.

    Regarding the specific questions that cannot be answered from the provided text:

    1. Sample sizes used for the test set and the data provenance: Not applicable or provided. The "test set" here refers to non-clinical testing of device characteristics, not a clinical study on patients or data.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable or provided. Ground truth in this context would implicitly be engineering specifications, laboratory measurements, and standard compliance testing, not expert clinical assessment of patient data.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable or provided. No adjudication process detailed for establishing technical specifications.
    4. 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/ML device, nor is it a diagnostic device being evaluated for reader performance.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. Not an AI/ML algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): The "ground truth" for this device's performance evaluation is based on engineering specifications, direct physical measurements (e.g., of magnetic fields, temperatures, electrical properties), and compliance with international safety and performance standards (e.g., IEC 60601 series, ISO 10993).
    7. The sample size for the training set: Not applicable or provided. This device does not use a "training set" in the machine learning sense.
    8. How the ground truth for the training set was established: Not applicable or provided.

    In summary, the provided document details the 510(k) clearance process for a non-AI/ML magnetic stimulator for pain relief. The "acceptance criteria" and "performance" are framed around demonstrating substantial technical and safety equivalence to a legally marketed predicate device, rather than clinical efficacy data from patient studies or AI algorithm performance metrics.

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    K Number
    K241785
    Manufacturer
    Date Cleared
    2025-03-27

    (280 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    QPL

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

    With handheld applicators:

    PMS mode:

    Fotona StarFormer is intended for muscle conditioning, used for stimulating muscles including abdomen muscles in order to improve or facilitate muscle performance.

    Fotona StarFormer is intended to be used under medical supervision for adjunctive therapy. Fotona StarFormer is intended for stimulating neuromuscular tissue for bulk muscle excitation in arms, legs, buttocks and thighs for rehabilitative purposes - Prevention of disuse atrophy and increasing local blood circulation.

    TENS mode:

    Fotona StarFormer is intended to stimulate peripheral nerves for relief of chronic intractable, post traumatic and post-surgical pain for patients 18 years or older.

    Fotona StarFormer is to be used for the temporary relief of pain associated with sore or aching muscles in the shoulder, waist, back, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.

    With Chair Back applicator:

    TENS mode:

    Fotona StarFormer is intended to stimulate peripheral nerves in the back for relief of chronic intractable, post traumatic and post-surgical pain for patients 18 years or older. Fotona StarFormer is to be used for the temporary relief of pain associated with sore or aching muscles in the back due to strain from exercise or normal household work activities.

    Device Description

    StarFormer is a non-invasive therapeutic device. The device comprises of a magnetic stimulation coil located in the handheld applicators and in the back of a chair. During the treatment, an alternating electric current is sent into the stimulation coil. The coil builds up a rapidly changing magnetic waves which propagate into the underlying tissue where they induce a secondary electric current. This current stimulates neurons and activates muscle contractions. The device consists of a system controller board which also drives the touchscreen and the GUI, a high voltage current power supply, handheld applicators and a chair.

    AI/ML Overview

    The provided document is a 510(k) summary for the Fotona StarFormer (M008-3T) device, a transcutaneous electrical nerve stimulator. However, it does not contain the specific details about acceptance criteria or a comparative effectiveness study that demonstrates how the device meets acceptance criteria.

    The document indicates that:

    • Nonclinical testing was performed, including electrical safety, mechanical strength, thermal safety, electromagnetic compatibility, software verification and validation, and cybersecurity testing. It explicitly states, "All pre-determined acceptance criteria were met" for these tests.
    • No premarket clinical investigations were conducted. The rationale provided is that "performance of StarFormer is based on the well-established magnetic stimulation technology and does not carry significant residual risk for patients."

    Therefore, I cannot provide details on:

    1. A table of acceptance criteria and reported device performance (since these are not specified beyond a general statement of compliance).
    2. Sample size used for a test set or data provenance (as no clinical test set is described).
    3. Number of experts or their qualifications for ground truth establishment.
    4. Adjudication method for the test set.
    5. Multi-reader multi-case (MRMC) comparative effectiveness study, nor the effect size on human readers.
    6. Stand-alone performance (algorithm only) as this is a device and not an AI algorithm being evaluated in a clinical "standalone" sense.
    7. Type of ground truth used (as no clinical study is detailed).
    8. Sample size for the training set (as no AI/ML model training is described in the context of clinical performance evaluation).
    9. How ground truth for the training set was established.

    The document focuses on demonstrating substantial equivalence to predicate devices primarily through comparison of technological characteristics and compliance with nonclinical performance standards, rather than clinical efficacy studies with specific acceptance criteria that might be seen for novel AI/ML devices.

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    K Number
    K233364
    Device Name
    Axon Therapy
    Date Cleared
    2024-01-10

    (100 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    QPL

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

    The Axon Therapy is intended to stimulate peripheral nerves for relief of chronic intractable pain, post-surgical pain and/or for relief of chronic painful diabetic peripheral neuropathy in the lower extremities. The Axon Therapy is for use on patients 18 and older.

    Device Description

    The Axon Therapy is a magnetic stimulator system that provides brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves and provide chronic nerve pain relief. The subject device is intended to be used in clinics such as pain management clinics and physical therapy clinics. The device consists of Magnetic Stimulation Coil, Liquid Cool Unit, and a Cart. The Axon Therapy includes a thermal shutdown feature which is activated once the inside temperature of the stimulation coil either: (A) reaches 45°C or (B) exceeds 41°C for a total of nine minutes during a 20-minute session.

    AI/ML Overview

    The provided document is a 510(k) summary for the Axon Therapy device, which is a magnetic stimulator system intended for pain relief. The submission seeks to establish substantial equivalence to a previously cleared device (K210021, also Axon Therapy by NeuraLace). This document does not contain information about acceptance criteria and a study proving the device meets those criteria in the typical format of an AI/ML medical device submission.

    Instead, it focuses on demonstrating substantial equivalence by highlighting that the subject device has identical design, dimensions, materials, intended use, and technological characteristics to the predicate device. The primary change is an expansion of the Indications for Use to include "chronic painful diabetic peripheral neuropathy in the lower extremities."

    Therefore, the information regarding acceptance criteria, test set details, expert ground truth establishment, MRMC studies, and standalone performance for an AI/ML device is not present in this document. The document describes a clinical study done to support the expanded indication, which is different from a performance study for an AI/ML algorithm.

    Here's a breakdown of what can be extracted and what is missing/not applicable based on the provided text, assuming the request is looking for AI/ML device study details:

    Information Present or Inferable:

    • 1. A table of acceptance criteria and the reported device performance:
      • Acceptance Criteria (Inferable for Clinical Study): The primary efficacy objective for the clinical study was to compare the proportion of "responders" (>=50% reduction from baseline in neuropathic pain intensity as measured by an in-clinic visual analog score (VAS) for the primary area of pain at Day 30, with no increase over baseline pain medications within four weeks of the Day 30 visit) between the Axon Therapy plus CMM group and the Sham plus CMM group. While not a formal "acceptance criteria" table for AI/ML, this is the clinical endpoint criteria.
      • Reported Device Performance:
        • Axon Therapy group: -57.6% reduction in VAS pain scores.
        • Sham group: -12.5% reduction in VAS pain scores.
        • p-value:
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    Why did this record match?
    Product Code :

    QPL

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

    To stimulate peripheral nerves for relief of chronic intractable, post traumatic and post-surgical pain for patients 18 years or older

    Device Description

    The MagVenture Pain Therapy is a magnetic stimulator system that provides brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves and provide relief of chronic intractable, post-traumatic and post-surgical pain. The subject device is intended to be used in hospitals and clinics such as pain management clinics. The device consists of Magnetic Stimulator, Stimulation Coils, Liquid Cool Unit (optional), and a Trolley. All coils of the MagVenture Pain Therapy have a built-in thermo sensor to measure the temperature of the coil surfaces to prevent high temperature on the skin of the patient or operator. The temperature allowed by the system is maximum 43°C or between 44°C for less than 10 minutes. The system will automatically disable if this maximum temperature is reached.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification for the MagVenture Pain Therapy device. This type of submission relies on demonstrating substantial equivalence to a legally marketed predicate device, rather than requiring new clinical trials to prove safety and effectiveness. Therefore, the information regarding specific acceptance criteria and a study proving those criteria are not directly presented in the format requested for a device with novel claims.

    However, based on the document, we can infer acceptance criteria from the comparison to the predicate device and the discussion of technological characteristics. The study proving the device meets these inferred criteria is essentially a comparison study against the predicate device and an assessment of why any differences do not raise new questions of safety or effectiveness.

    Here's an attempt to answer your questions based on the provided text, recognizing the limitations of a 510(k) submission:

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

    The "acceptance criteria" for a 510(k) are typically that the new device is "substantially equivalent" to a predicate device, meaning it has the same intended use and either has the same technological characteristics or, if it has different technological characteristics, those do not raise different questions of safety and effectiveness. The performance is reported by comparing it to the predicate.

    Acceptance Criteria (Inferred from Substantial Equivalence to Predicate)Reported Device Performance (MagVenture Pain Therapy)
    Intended Use: Stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older.Same as predicate device, Axon Therapy (K210021).
    Anatomical Sites: Similar range of application areas.Same as predicate device.
    Treatment Facilities: Hospitals & Clinics.Same as predicate device.
    Treatment Time: 13 min per session (800 seconds).Same as predicate device.
    Pulse Amplitude: 0-100%.Same as predicate device.
    On-cycle duty period: 2-800 seconds (0.5 Hz and up to 400 pulses)Same as predicate device.
    Off-cycle reset period: N/A.Same as predicate device.
    Pulse Mode: Standard.Same as predicate device.
    Maximum coil temperature: 43°C (system automatically disables if reached).Same as predicate device (predicate 41°C, but both disable at max).
    Software/Firmware/Microprocessor control: Yes.Same as predicate device.
    Power Source: Similar electrical specifications.Similar (subject: 120V~, 50/60 Hz; predicate: 110V to 220V ac, 50/60 Hz). Deemed "Same".
    User Interface: LED display.Same as predicate device.
    Sterilization: Non-sterile when used.Same as predicate device.
    Electrical Safety: Complies with IEC60601-1 v3.1.Complies with IEC60601-1 v3.1 (from predicate). Deemed "Same".
    Mechanical Safety: Complies with IEC60601-1 v3.1.Complies with IEC60601-1 v3.1 (from predicate). Deemed "Same".
    Chemical Safety: Complies with IEC60601-1 v3.1.Complies with IEC60601-1 v3.1 (from predicate). Deemed "Same".
    Thermal Safety: Complies with IEC60601-1 v3.1.Complies with IEC60601-1 v3.1 (from predicate). Deemed "Same".
    Radiation Safety: No radiation generated.Complies (from predicate, implies no radiation). Deemed "Same".
    Biocompatibility: Complies with ISO 10993.Complies with ISO 10993 (from predicate). Deemed "Same".
    Standards: Company complies with EN ISO 13485.Complies (from predicate). Deemed "Same".
    Pulse frequency: Acceptable range without new safety/effectiveness questions.0.1-30 Hz (pps) for R30, 0.1-100 Hz (pps) for X100. Predicate: 0-2 Hz (pps). Deemed "Substantially equivalent" because 0.5 Hz is shared and higher rates are physiologically within range.
    Maximum repetition rate: Acceptable rate without new safety/effectiveness questions.30 pps for R30, 100 pps for X100. Predicate: 2 pps. Deemed "Substantially equivalent" for reasons similar to pulse frequency.
    Pulse Width: Biphasic (similar µsec).Biphasic (280-320 µsec). Predicate: Biphasic (290 µsec). Deemed "Substantially equivalent".
    Maximum output power: Acceptable power without new safety/effectiveness questions.100% at 15 pps for subject. Predicate: 100% at 2 pps. Deemed "Substantially equivalent" because both achieve 100% at 2 pps.
    Waveform: Biphasic functionality.Biphasic (and Monophasic for X100). Predicate: Biphasic. Deemed "Substantially equivalent" because all can do biphasic.
    Peak Magnetic Field at coil surface (T): No new issues.1.15-2.6 T*. Predicate: Not publicly available. Deemed "Substantially equivalent".
    Peak Magnetic Field Gradient dB/dt in coil center at 20mm distance from coil surface: No new issues.9-24 kT/s*. Predicate: Not publicly available. Deemed "Substantially equivalent".
    Housing Material Construction: No new safety issues.Stimulator: Aluminum, Aluzinc; Coils: PVC, ABS, PA, POM. Predicate: Stimulator: Al sheet EN AW 5754; Coil: ABS. Deemed "Substantially equivalent".
    Applied Parts: Magnetic coils, no new safety issues.Various coils (MMC-140-II, MCF-140, RT-120-II, MMC-90, MCF-125, Cool-B65, Cool-125). Predicate: Magnetic coil 60BF-NL. Deemed "Substantially equivalent".
    Applied Parts area: Acceptable coil dimensions.Butterfly coils: 150 mm; Circular coils:110-126 mm; Special coils: 160x80 mm. Predicate: 160 mm. Deemed "Substantially equivalent".

    The "study" demonstrating these criteria are met is the comparison presented in the 510(k) submission, specifically the "Comparison of Technological Characteristics" table and the "Substantial Equivalence Notes" which explain why differences do not raise new safety or effectiveness questions.

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

    The document does not describe a clinical "test set" in the traditional sense of a clinical trial. Instead, the "testing" references non-clinical testing performed on the predicate device (K094019) and the argument that the current device is "identical in all features (e.g., design, dimensions, materials, biocompatibility), except for the indications for use." Therefore, "no new bench testing is needed."

    This implies that the "data provenance" for the foundational performance characteristics comes from the testing previously conducted for the predicate devices (MagPro Family device K094019 and Axon Therapy K210021), not a new test set for this submission.

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

    Not applicable. This is a 510(k) submission based on substantial equivalence, not a de novo clinical study with a new "test set" requiring expert ground truth establishment. The ground truth for safety and effectiveness is established by the prior clearance of the predicate device.

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

    Not applicable. As above, there is no new clinical "test set" with 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 device is a Transcutaneous Electrical Nerve Stimulator for Pain Relief, not an AI-assisted diagnostic or imaging device. Therefore, MRMC studies and AI assistance are not relevant to this submission.

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

    Not applicable. This is a physical medical device (magnetic stimulator), not an algorithm or AI system. Its performance is intrinsic to the device's physical operation, not an algorithm's output.

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

    The ground truth for the safety and effectiveness of the device's underlying technology and performance characteristics is established through:

    • Prior FDA clearances: The substantial equivalence relies on the fact that the predicate devices (MagPro Family and Axon Therapy) were previously cleared by the FDA based on their demonstrated safety and effectiveness.
    • Compliance with recognized standards: The document explicitly states compliance with standards like IEC60601-1 v3.1 (electrical, mechanical, chemical, thermal safety) and ISO 10993 (biocompatibility). These standards represent established "ground truths" for various aspects of device safety.
    • Physiological understanding: The justification for wider pulse frequencies and repetition rates refers to the "range of physiological action potentials (from 0.05 to 500 Hz) of the human nervous system," indicating an appeal to established physiological knowledge as a "ground truth" for safety.

    8. The sample size for the training set

    Not applicable. This is not a machine learning or AI device that requires a "training set."

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

    Not applicable.

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    K Number
    K210021
    Device Name
    Axon Therapy
    Date Cleared
    2021-06-11

    (158 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    QPL

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

    The Axon Therapy is intended to stimulate peripheral nerves for relief of chronic intractable, post-traumatic and postsurgical pain for patients 18 and older.

    Device Description

    The Axon Therapy is a magnetic stimulator system that provides brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves and provide chronic nerve pain relief. The subject device is intended to be used in clinics such as pain management clinics and physical therapy clinics. The device consists of Magnetic Stimulation Coil, Liquid Cool Unit, and a Cart. The Axon Therapy includes a thermal shutdown feature which is activated once the inside temperature of the stimulation coil either: (A) reaches 45°C or (B) exceeds 41°C for a total of nine minutes during a 20-minute session.

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for Axon Therapy by NeuraLace Medical, Inc. This document focuses on demonstrating substantial equivalence to a predicate device, as opposed to proving novel acceptance criteria in the traditional sense of a clinical trial for a new drug or high-risk device. Therefore, the "acceptance criteria" here largely refer to meeting the requirements for substantial equivalence to a legally marketed predicate device, primarily through non-clinical and clinical testing designed to show that the new device is as safe and effective as the predicate.

    Given this context, I will interpret "acceptance criteria" as the performance and safety benchmarks established by the predicate device and the relevant FDA standards, which the Axon Therapy must meet or surpass. The "study that proves the device meets the acceptance criteria" refers to the set of tests and clinical data provided to demonstrate this substantial equivalence.

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


    Acceptance Criteria and Reported Device Performance

    The "acceptance criteria" are implicitly defined by the characteristics of the predicate device (Shenzhen Roundwhale Technology Co., Ltd. R-C1 TENS and EMS Stimulator; K181688) and other reference devices, along with relevant industry standards (IEC, etc.). The reported device performance demonstrates how the Axon Therapy aligns with or improves upon these.

    Table of (Implicit) Acceptance Criteria and Reported Device Performance:

    Feature/Criterion (Implicit)Predicate Device/Standard Baseline (Implied Acceptance)Reported Axon Therapy PerformanceStatement of Equivalence/Met Criteria
    Indications for UseSymptomatic relief of chronic intractable pain, post-traumatic pain, and post-surgical pain (for patients 18+)Stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 and older.Identical to the predicate device.
    Magnetic Stimulation Type (vs. Electrical)Electrical nerve stimulation (TENS/EMS)Magnetic stimulator system providing brief and focused magnetic pulses.This is a difference from the predicate but demonstrated to be substantially equivalent through testing. The document states: "Performance and clinical data demonstrate that there is no impact on safety and effectiveness when compared to the predicate device." "Axon Therapy does not result in burn marks, skin irritation, or analgesic tolerance, highlighting the safety benefit."
    Safety - Electrical SafetyIEC 60601-1 (general), IEC 60601-1-11 (home use)Tested compliance to IEC 60601-1:2005+AMD1:2012 CSV.Substantially equivalent; no new questions of safety.
    Safety - EMCIEC 60601-1-2Tested compliance to IEC 60601-1-2 Edition 4.0 2014-02.Substantially equivalent; no new questions of safety.
    Safety - SoftwareIEC 62304Software development and testing in compliance to IEC 62304:2006.Identical to predicate device; no new questions of safety.
    Safety - UsabilityIEC 62366Tested compliance to IEC 60601-1-6 Edition 3.1 2013-10 and IEC 62366:2007+AMD1:2014 CSV.Substantially equivalent.
    Safety - BiocompatibilityImplicitly met by predicate device materials and general standards.Housing materials: Stimulator: AL sheet EN AW 5754 H111, Coil: ABS. Biocompatibility testing performed.Substantially equivalent; no new questions of safety.
    Safety - Adverse EventsAdverse events associated with predicate TENS devices (e.g., burn marks, skin irritation, analgesic tolerance)Two non-serious adverse events related to device use: hypersensitivity (n=3) and muscle soreness (n=5). Does not result in burn marks, skin irritation, or analgesic tolerance.AE profile is similar or better than predicate device. Demonstrates safety benefit.
    Performance - Pain Relief EffectivenessEffectiveness in relieving chronic pain (as per predicate's intended use).Statistically significant decrease in pain scores (NRS/MVAS) after sessions. All subjects had a decreased MVAS score after 12 weeks.Demonstrated clinical effectiveness; performance testing for substantial equivalence.
    Performance - Clinical Use Case (Clinic/Home)Predicate likely for home/clinic use (given TENS/EMS).Intended for use in clinics (e.g., pain management, physical therapy clinics).Consistent with expected use environment for such devices.
    Performance - Stimulation Protocol AccuracyImplicitly accurate for predicate.Validated.Performance testing for substantial equivalence.
    Performance - Thermal ManagementImplicitly managed by predicate or standard requirements.Thermal shutdown feature activated at 45°C or >41°C for 9 mins during 20-min session. Temperature on surface at maximum output validated.Addresses user safety and device longevity.
    Technical - WaveformBiphasic square (predicate); Biphasic wave (reference device K160280)Biphasic wave.Identical to reference device; no new safety/effectiveness questions compared to predicate.
    Technical - Pulse FrequencyUnknown (predicate); 1-55 Hz (reference K973929); 0-22 Hz (reference K160280)0-2 Hz.Similar to reference devices; no new safety/effectiveness questions.
    Technical - Pulse AmplitudeUnknown (predicate); 0-100% (reference K973929, K160280)0 to 100% (max 80% recommended).Identical to reference devices; no new safety/effectiveness questions.
    Technical - Pulse WidthUnknown (predicate); Biphasic (280 µsec) (reference K160280)Biphasic (290 µsec).Identical to reference device; no new safety/effectiveness questions.
    Technical - Maximum Repetition RateUnknown (predicate); 20 pps (reference K160280)2 pulses per second (pps).Similar to reference device; no new safety/effectiveness questions.
    Technical - Applied Part Area25 cm2 (predicate).16 cm2.Substantially equivalent; no new safety/effectiveness questions.

    Study Details:

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

      • Clinical Studies:
        • Total subjects: n=105.
        • Subgroup 1: 25 subjects.
        • Subgroup 2: 80 subjects (105 - 25).
      • Data Provenance: The document does not explicitly state the country of origin or whether the data was retrospective or prospective. It states "NeuraLace conducted multiple clinical studies," implying prospective studies conducted by the company.
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

      • This information is not explicitly provided. For a pain relief device, "ground truth" is typically subjective patient-reported pain scores (NRS/MVAS) rather than readings established by experts.
    3. Adjudication Method for the Test Set:

      • Not applicable/Not mentioned, as the primary outcome (pain scores) is patient-reported.
    4. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

      • No, an MRMC study was not done. The clinical studies focused on the effectiveness and safety of the device itself (with or without a human in the loop, but the device is user-applied in a clinical setting). It was not a comparative study of human readers assisted by AI vs. unassisted human readers.
    5. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • This question is generally relevant for AI/software-based diagnostic devices. For a physical medical device like Axon Therapy, a "standalone algorithm" is not applicable in the same way. The device functions to stimulate nerves, and its performance is measured by its physical output (magnetic pulses) and clinical outcomes (pain relief), not by an algorithm making a diagnosis or interpretation. The software validation mentioned (IEC 62304) ensures the software controlling the device operates correctly, which is part of the integrated device performance.
    6. The Type of Ground Truth Used:

      • Clinical Efficacy: Patient-reported outcome measures (PROMs) using the Numeric Rating Scale (NRS) or Mechanical Visual Analog Scale (MVAS) for pain. This is a subjective patient outcome as ground truth for pain relief.
      • Safety: Occurrence of adverse events, evaluated by clinicians and reported.
      • Technical Performance: Quantitative measurements from performance testing (e.g., magnetic field characteristics, stimulation protocol accuracy, temperature). Compliance with electrical safety, EMC, and usability standards are also part of the "ground truth" for device safety and functionality.
    7. The Sample Size for the Training Set:

      • This document describes a premarket notification for a physical medical device, not an AI/ML algorithm that requires a "training set" in the context of machine learning. The term "training set" is not applicable here. The clinical studies described (n=105 total subjects) are the testing/validation set for the device's clinical performance and safety.
    8. How the Ground Truth for the Training Set was Established:

      • See point 7; "training set" in the AI/ML sense is not relevant. The device's "training" refers to its design, engineering, and manufacturing process, optimized through non-clinical and preclinical testing to ensure it meets its intended function prior to clinical evaluation.
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