K120961 · Concentric Medical, Inc. · NRY · Aug 3, 2012 · Cardiovascular
Device Facts
Record ID
K120961
Device Name
TREVO RETRIEVER
Applicant
Concentric Medical, Inc.
Product Code
NRY · Cardiovascular
Decision Date
Aug 3, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.1250
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Trevo Retriever is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV-tPA) or who fail IV-tPA therapy are candidates for treatment.
Device Story
Trevo Retriever is a mechanical thrombectomy device designed to restore blood flow in neurovasculature by removing thrombi. Device consists of a flexible, tapered nitinol core wire with a shaped distal section and radiopaque platinum/tungsten coil for fluoroscopic visualization. Hydrophilic coating reduces friction. Operated by physicians in clinical settings under fluoroscopic guidance. Device is inserted into the neurovasculature to engage and remove occlusive thrombi. Proximal end is compatible with Abbott guide wire extensions for catheter exchange. By restoring blood flow, the device aims to improve clinical outcomes in ischemic stroke patients within 8 hours of symptom onset. Bench testing confirmed mechanical integrity, kink resistance, and radial force characteristics. Clinical performance was validated in the TREVO 2 trial, demonstrating non-inferiority to the predicate Merci Retriever in revascularization success and safety profile.
Clinical Evidence
TREVO 2 trial: randomized, multi-center, prospectively controlled study (N=160 analyzed). Compared Trevo Retriever (n=79) to Merci Retriever (n=81). Primary efficacy endpoint: revascularization success (TICI ≥2a) post-device. Trevo achieved 87.3% success vs. 58.0% for Merci (p<0.0001). Primary safety endpoint: procedure-related serious adverse events (PRSAEs) through 24 hours; Trevo 13.9% vs. Merci 23.5%. 90-day good outcome (mRS ≤2) was 38.2% for Trevo vs. 17.9% for Merci.
Indicated for patients 18-85 years old experiencing acute ischemic stroke with persistent large vessel occlusion (internal carotid, middle cerebral M1/M2, basilar, or vertebral arteries) who are ineligible for or failed IV t-PA therapy. Contraindications include severe hypertension, coagulopathy, pregnancy, intracranial tumor, or excessive arterial tortuosity.
Regulatory Classification
Identification
A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.
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K120961
#### 3 2012 AUG
#### 510(K) SUMMARY
| Trade Name: | Trevo Retriever |
|--------------------------------|-------------------------------------------------------------------|
| Common Name: | Catheter, Thrombus Retriever |
| Classification: | Catheter, Thrombus Retriever, 21CFR 870.1250 - Class II |
| Submitter: | Concentric Medical, Inc. |
| | 301 E. Evelyn Avenue |
| | Mountain View, CA 94041 |
| | Tel 650-938-2100 |
| | Fax 650-237-5230 |
| Facility Registration #2954917 | |
| Contact: | Kirsten Valley<br>Vice President, Technology & Regulatory Affairs |
| Date Prepared: | July 27, 2012 |
| 1 64 6 4 4 4 4 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 | Uly ( ( ) ( LV LL | |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|--|
| Predicate Device: | Merci® Retriever (K063774 | |
### Device Description
Like the predicate device, the Trevo Retriever consists of a flexible, tapered core wire with a shaped section at the distal end and is designed to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke. A radiopaque coil at the distal end allows fluoroscopic visualization. Retriever dimensions are indicated on the product label. The Retriever has a hydrophilic coating to reduce friction during use. A torque device and an insertion tool are provided with the Retriever. The proximal end of the device is compatible with the Abbott guide wire extension to facilitate removal or exchange of a catheter while maintaining the Retriever position in the vessel.
#### Indications for Use
The Indications for Use are as follows:
The Trevo Retriever is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment. This is comparable to the predicate device's Indications for Use and does not impact the intended therapeutic use of the device in patients experiencing ischemic stroke or raise different issues of safety and effectiveness. As a result, the safety and effectiveness of the device are not impacted when used as indicated.
### Technological Characteristics
There are technological differences between Trevo and the predicate device. The effect of these differences on safety and effectiveness has been addressed in a clinical study which supports that the clinical performance of the two devices is substantially equivalent. Table 1 provides a comparison between the Trevo device and the predicate Merci device.
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| Attribute | Predicate Merci Retriever Device (K063774) | Subject Trevo Retriever |
|-----------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------|
| Device Description | The Retriever consists of a flexible, tapered core wire with a shaped section at the distal end. A platinum coil allows fluoroscopic visualization. The Retriever has a hydrophilic coating to reduce friction. The Retriever has a shaft marker to indicate proximity of Retriever tip relative to Microcatheter tip. A torque device and insertion tool are provided with the Retriever. | Same as the predicate device |
| Distal End (shaped section) Configuration | Image: Distal End Configuration of Merci Retriever Device | Image: Distal End Configuration of Trevo Retriever Device |
| Anatomical Sites | Neurovasculature | Same as cleared device |
| Target Population | Patients with symptoms of an ischemic stroke | Same as cleared device |
| Single/Multiple Use | Single Use | Same as cleared device |
| Materials | | |
| Core Wire Material | Nitinol (nickel titanium alloy) | Same as cleared device |
| Distal Shaped Section Material | Nitinol | Same as cleared device |
| Coil Material Distal to Distal Shaped Section | Platinum/Tungsten | Same as cleared device |
| Coil Material Proximal to Shaped Section | 304 Stainless Steel | Same as cleared device |
| Solder | Gold/Tin | Same as cleared device |
| Nominal Design Attributes | | |
| Proximal Core Wire Diameter | 0.0137" | 0.0180" |
| Shaped Section Diameter (nominal) | Variable along length ranging from 3mm-1.5mm | 4 mm |
| Shaped Section Length (nominal) | 7 mm | 20 mm |
| Distal Tip Length (nominal) | 7 mm | 4 mm |
| Accessory Devices<br>Provided (not in direct<br>contact with patient) | Insertion tool and torque device provided<br>in product package | Same as cleared device |
| Packaging | | |
| Materials and<br>Configuration | Polyethylene Hoop, polycarbonate<br>mounting card, Tyvek/Film Pouch, MDPE<br>Tubing Clips, Chipboard carton<br>Image: packaging | Same as cleared device |
| Sterilization Method | 100% EtO | Same as cleared device |
| How Supplied | Sterile/Single Use | Same as cleared device |
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#### Testing Summary
#### Bench Testing
The results of verification and validation conducted on the Trevo Retriever demonstrate that it performs as designed, is suitable for its intended use and is substantially equivalent to the predicate device. Specifically, the following tests were performed on the proposed device:
- Simulated Use Testing: the device's ability to be used in a neurovascular model per . procedural instructions outlined in the Instructions for Use was successfully evaluated.
- Tensile Testing: the device's mechanical integrity under tensile loads was successfully . evaluated.
- Radial Force Testing: the resulting radial force when the device is constrained radially 0 was successfully evaluated.
- . Tip Deflection Force Testing: the force to deflect the distal tip of the device was successfully evaluated.
- 0 Torque/Tensile Durability: the ability of the device to withstand torque and tensile load cycles without fracture was successfully evaluated.
- Kink Resistance: the ability of the device shaft to resist kinking was successfully . evaluated.
- Device safety (vessel response) was successfully evaluated in an animal model .
#### Clinical Testing
To demonstrate substantial equivalence, a randomized, multi-center, prospectively controlled IDE clinical trial (TREVO 2) was conducted comparing the efficacy of the subject Trevo Retriever to the predicate Merci Retriever for removing occlusive thrombi in patients experiencing an ischemic stroke.
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A total of 178 patients were randomized, 88 to treatment with the Trevo device and 90 to the Merci device. On review by the Core Lab, 81 subjects randomized to Trevo and 82 subjects randomized to Merci met all angiographic entry criteria. An attempt to treat with the device was made in 79 Trevo and 81 Merci subjects. The population for analysis of the primary effectiveness and safety endpoints includes these 160 subjects were treated with the device to which they were randomized. There were no subjects with missing endpoint data. Statistical Analysis
Analysis of the primary efficacy endpoint (successful revascularization of the target occlusion, using the TICI score as the metric) was performed using a one-sided test per Blackwelder's formulation of the primary efficacy non-inferiority hypothesis at the 0.025 level of significance. The primary safety endpoint of the study was the incidence of procedure-related serious adverse events (PRSAEs) through 24 hours post procedure. These events were adjudicated by an independent clinical events committee per protocol. There was no statistical hypothesis related to the primary safety endpoint.
### Study Procedures
Diagnostic angiographic data was obtained at baseline (prior to patient randomization), again at the conclusion of revascularization attempts with the assigned study device, and post procedure. 24-hour post-procedure follow-up included CT or MR imaging and NIHSS examination. Follow-up at day 7-10 (or discharge if earlier) and at day 90 (+/-14 days) included NIHSS exam and modified Rankin Scale (mRS).
### Inclusion Criteria
- Patient presenting with clinical signs and symptoms consistent with a diagnosis of Acute . Ischemic Stroke, and:
- o a. Patient has failed IV t-PA therapy
- Or
- b. Patient is contraindicated for IV t-PA administration o
- Age 18-85 (has had 18th birthday, but not yet had 86th birthday) ●
- . NIHSS 8 8 < NIHSS < 29
- Anticipated life expectancy of at least 6 months .
- . No significant pre-stroke disability (mRS < 1)
- . Written informed consent to participate given by patient or legal representative
- . Angiographic confirmation of a persistent large vessel occlusion in the internal carotid, middle cerebral (M1 and/or M2 segments), basilar and/or vertebral arteries
- . Treatable within 8 hours of symptom onset, defined as the first pass being made with the assigned study device
### Exclusion Criteria
- . Baseline glucose < 50 mg/dL (2.78 mmol) or > 400 mg / dL (22.20 mmol)
- . Known hemorrhagic diathesis, coagulation factor deficiency, or oral anticoagulant therapy with INR > 3.0
- Treated with Heparin within 48 hours with a PTT greater than 2 times the lab normal .
- Baseline platelet count < 30,000
- History of severe allergy (more than rash) to contrast medium or nitinol .
- Severe, sustained hypertension (SBP>185 mm Hg or DBP>110 mm Hg) .
KIZOq
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NOTE: If the blood pressure can be successfully reduced and maintained at the acceptable level using medication, the patient can be enrolled
- . Pregnancy
- Patient participating in another investigational drug or device study .
- CT showing hypodensity or MR showing hyperintensity involving greater than 1/3 of the ● MCA territory. For non-MCA strokes, CT showing hypodensity or MR showing hyperintensity involving > 100cc of tissue.
- . Baseline CT/MR evidence of significant mass effect with midline shift
- . Baseline CT evidence of hemorrhage
- . Baseline CT/MR evidence of intracranial tumor (except small meningioma)
- . Angiographic evidence of vasculitis or arterial dissection
- . Stenosis in a proximal vessel that requires treatment or that prevents access to the thrombus with the assigned study device
- � Angiographic evidence of excessive arterial tortuosity that would preclude the assigned study device from reaching the thrombus
- . Bilateral stroke
| Reason for Exclusion | Number of<br>Subjects |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|
| Angiographic evidence of vasculitis or arterial dissection | 0 |
| Angiographic evidence of excessive arterial tortuosity that would<br>preclude the assigned study device from reaching the thrombus | 1 |
| Vessel too small | 1 |
| No angiographic evidence of a persistent large vessel occlusion in the<br>internal carotid, middle cerebral (M1 and/or M2 segments), basilar<br>and/or vertebral arteries | 26* |
| CT showing hypodensity or MR showing hyperintensity involving<br>greater than 1/3 of the MCA territory (discovery concurrent with<br>angiography) | 1 |
| Stenosis in a proximal vessel that requires treatment or that prevents<br>access to the thrombus with the assigned study device | 3* |
### Table 2: Summary of Reasons for Frelusion during Angiographic Screening
*1 subject had 2 exclusion criteria
#### Primary Efficacy Endpoint
Primary Efficacy was assessed by the independent Core Lab. Revascularization as measured by TICI was determined for each subject following the use of the assigned study device. Use of any IA lytic or treatment of a proximal carotid stenosis was automatically counted as a revascularization failure regardless of the subjects's revascularization status after use of the device (Table 3a). In an additional analysis, subjects were counted as revascularization failures if any adjunctive therapy was used at the site of an occlusion regardless of revascularization status after the use of the assigned study device (Table 3b). Subjects with a baseline TICI 2a by Core Lab and subjects in whom the device was never attempted were excluded from both analyses. The test for non-inferiority is highly significant and establishes that the Trevo Retriever is non-inferior and substantially equivalent to the Merci Retriever.
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| Lab), With Study Device Attempted, Any IA lytic Considered as Treatment Failure | | | | |
|---------------------------------------------------------------------------------|--------------------------------------|--------------------------------------|-------------------------|----------------------|
| Primary Effectiveness<br>Endpoint | Trevo (N=79)<br>% (n/N)<br>[95% CI]a | Merci (N=81)<br>% (n/N)<br>[95% CI]a | Difference<br>[95% CI]b | p-value |
| Post-Device Revascularization<br>Success (TICI ≥2a) | 87.3% (69/79)<br>[78.0%, 93.8%] | 58.0% (47/81)<br>[46.5%, 68.9%] | 29.3%<br>[15.0%, 42.4%] | <0.0001c<br><0.0001d |
Table 3a: Primary Effectiveness Endpoint for Subjects with Baseline TICI 0 or 1 (by Core Lab), with Study Device Attempted. Any IA Jytic Considered as Treatment Failur
a: Exact Clopper Pearson confidence intervals on individual proportions; b: Exact confidence intervals on differences in proportions computed with StatXact Version 8; c: Non-inferiority hypothesis using Blackwelder's method with noninferiority margin of 10%; d: One-sided Fisher's exact test of superiority
### Table 3b: Primary Effectiveness Endpoint for Subjects with Baseline TICI 0 or 1 (by Core Lab), with Study Device Attempted, Any Adjunctive Treatment Considered as Treatment Failure
| Primary Effectiveness<br>Endpoint | Trevo (N=79)<br>% (n/N)<br>[95% CI]a | Merci (N=81)<br>% (n/N)<br>[95% CI]a | Difference<br>[95% CI]b | p-value |
|-----------------------------------------------------|--------------------------------------|--------------------------------------|-------------------------|----------|
| Post-Device Revascularization<br>Success (TICI ≥2a) | 79.7% (63/79) | 49.4% (40/81) | 30.4% | <0.0001c |
| | [69.2%, 88.0%] | [38.1%, 60.7%] | [15.0%,44.1%] | <0.0001d |
a: Exact Clopper Pearson confidence intervals on individual proportions; b: Exact confidence intervals on differences in proportions computed with StatXact Version 8; c: Non-inferiority hypothesis using Blackwelder's method with noninferiority margin of 10%; d: One-sided Fisher's exact test of superiority
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### Primary Safety Endpoint and Good Outcomes
The incidence of procedure-related serious adverse events through 24 hours post-procedure was reported for the Trevo and Merci arms (Table 4). The rate for this composite endpoint was numerically lower in the Trevo arm supporting the safety of the Trevo Retriever. Subjects with a baseline TICI 2a by Corelab and subjects in whom the device was never attempted were excluded from this analysis.
| | Trevo<br>N= 79 pts | Merci<br>N= 81 pts | Difference<br>[95% CI]a | p-<br>Value |
|-------------------------------------------------------------------------------|--------------------------------|---------------------------------|--------------------------|-------------|
| Primary Safety Endpoint | | | | |
| Composite Events<br>[95% Conf. Interval]c | 13.9% (11/79)<br>[7.2%, 23.6%] | 23.5% (19/81)<br>[14.8%, 34.2%] | -9.5%<br>[-22.1%, 2.8%] | 0.1567b |
| Vessel Perforation | 0.0% (0/79) | 9.9% (8/81) | -9.9%<br>[-18.5%, -3.9%] | |
| Intramural Arterial Dissection | 0.0% (0/79) | 1.2% (1/81) | -1.2%<br>[-6.7%, 3.5%] | |
| Symptomatic ICH | 5.1% (4/79) | 9.9% (8/81) | -4.8%<br>[-14.1%, 3.8%] | |
| Embolization to Previously<br>Uninvolved Territory | 7.6% (6/79) | 4.9% (4/81) | 2.7%<br>[-5.6%, 11.4%] | |
| Access Site Complication<br>Requiring Surgical Repair or<br>Blood Transfusion | 1.3% (1/79) | 0.0% (0/81) | 1.3%<br>[-3.3%, 6.9%] | |
| Mortality within 24 hrs | 1.3% (1/79) | 0.0% (0/81) | 1.3%<br>[-3.3%, 6.9%] | |
| in vivo Device Failure | 0.0% (0/79) | 0.0% (0/81) | 0.0%<br>[-4.6%, 4.6%] | |
| Other PR-SAE | 0.0% (0/79) | 0.0% (0/81) | 0.0%<br>[-4.6%, 4.6%] | |
| Secondary Endpoint | | | | |
| Good Outcome at 90 days (mRS ≤<br>2) | 38.2% (29/76) | 17.9% (14/78) | 20.2%<br>[6.4%, 34.1%] | |
#### Table 4: Summary of Primary Safety Endpoint and 90-day Good Outcomes
a. Exact computations with StatXact Version 8; b. Fisher's exact test; c. Exact Clopper Pearson confidence intervals on individual proportions
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| Concentric Medical Classification<br>Term | Trevo Patients<br>N=86 pts | Merci Patients<br>N=89 pts |
|----------------------------------------------------|-----------------------------------|-----------------------------------|
| Units | % (Number of pts) [Number of AEs] | % (Number of pts) [Number of AEs] |
| Total Adverse Events (AE) | 96.5% (83) [388] | 96.6% (86) [493] |
| Mortality at 90 days | 33.7% (29/86) [29] | 23.8% (21/88) [21] |
| Neurologic | 73.3% (63) [136] | 83.1% (74) [178] |
| Cerebral Edema | 15.1% (13) [14] | 18.0% (16) [16] |
| Headache | 10.5% (9) [10] | 9.0% (8) [8] |
| Dysphagia (Difficulty Swallowing) | 16.3% (14) [14] | 27.0% (24) [24] |
| IVH | 5.8% (5) [5] | 6.7% (6) [6] |
| SAH | 12.8% (11) [11] | 23.6% (21) [21] |
| ICH - HI -1 | 14.0% (12) [12] | 21.3% (19) [19] |
| ICH – HI -2 | 8.1% (7) [7] | 6.7% (6) [6] |
| ICH - PH1 | 14.0% (12) [12] | 21.3% (19) [19] |
| ICH – PH2 | 8.1% (7) [7] | 5.6% (5) [5] |
| Neurologic Decline | 11.6% (10) [10] | 24.7% (22) [22] |
| Late ICH | 4.7% (4) [4] | 6.7% (6) [6] |
| Depression | 4.7% (4) [4] | 5.6% (5) [5] |
| Progression of index Stroke | 9.3% (8) [8] | 6.7% (6) [6] |
| Cardiac | 37.2% (32) [39] | 30.3% (27) [43] |
| Arrhythmia - Tachycardia | 7.0% (6) [6] | 3.4% (3) [3] |
| Atrial Fibrillation | 10.5% (9) [9] | 7.9% (7) [7] |
| Hypotension - Sustained - Tx | 7.0% (6) [6] | 5.6% (5) [6] |
| Dermatologic | 9.3% (8) [11] | 7.9% (7) [7] |
| Gastrointestinal | 17.4% (15) [16] | 16.9% (15) [19] |
| Constipation | 2.3% (2) [2] | 5.6% (5) [5] |
| Nausea and Vomiting (Non-Neuro) | 9.3% (8) [8] | 3.4% (3) [3] |
| Hematologic | 18.6% (16) [16] | 27.0% (24) [28] |
| Anemia | 16.3% (14) [14] | 19.1% (17) [17] |
| Metabolic | 26.7% (23) [34] | 33.7% (30) [45] |
| Hyperglycemia | 9.3% (8) [8] | 10.1% (9) [9] |
| Electrolyte Imbalance | 18.6% (16) [23] | 27.0% (24) [32] |
| Musculoskeletal | 14.0% (12) [13] | 13.5% (12) [19] |
| Joint/Extremity Pain | 7.0% (6) [6] | 11.2% (10) [13] |
| Concentric Medical Classification<br>Term | Trevo Patients<br>N=86 pts | Merci Patients<br>N=89 pts |
| Procedural | 12.8% (11) [11] | 18.0% (16) [17] |
| Access Site Complication | 5.8% (5) [5] | 1.1% (1) [1] |
| Embolization to Previously<br>Uninvolved Territory | 5.8% (5) [5] | 4.5% (4) [4] |
| Vessel Perforation | 1.2% (1) [1] | 10.1% (9) [9] |
| Pulmonary | 38.4% (33) [53] | 50.6% (45) [71] |
| Pneumonia | 10.5% (9) [11] | 23.6% (21) [23] |
| Pulmonary Edema | 4.7% (4) [4] | 5.6% (5) [5] |
| Respiratory Distress | 9.3% (8) [9] | 3.4% (3) [3] |
| Respiratory Failure - Acute | 5.8% (5) [5] | 21.3% (19) [19] |
| Vascular | 12.8% (11) [13] | 15.7% (14) [14] |
| Deep Vein Thrombosis (DVT) | 11.6% (10) [12] | 14.6% (13) [13] |
| Constitutional | 15.1% (13) [15] | 16.9% (15) [18] |
| Fever | 4.7% (4) [4] | 6.7% (6) [6] |
| Positive Cultures | 4.7% (4) [4] | 7.9% (7) [7] |
| Urogenital | 27.9% (24) [30] | 29.2% (26) [32] |
| Urinary Tract Infection | 16.3% (14) [15] | 21.3% (19) [20] |
| Hematuria | 7.0% (6) [6] | 1.1% (1) [2] |
| Urinary Retention | 3.5% (3) [3] | 5.6% (5) [5] |
Adverse Events and Mortality in Subjects in whom the Assigned Study Device was Used Table 5: Summary of Adverse Events
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#### Conclusion
The data collected on both the primary efficacy endpoint and the primary safety in the TREVO 2 clinical trial demonstrate that the Trevo Retriever is substantially equivalent to the predicate Merci Retriever.
## Summary of Substantial Equivalence
The Trevo Retriever is comparable to the predicate device with regard to device design, materials, intended use, and patient population. The conclusions drawn from the verification and validation testing, animal studies and clinical trial conducted using the Trevo Retriever demonstrate that it performs as designed, is suitable for its intended use and is substantially equivalent to the legally marketed predicate device.
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/9/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle with three stripes forming its wing and body. The eagle is enclosed in a circle of text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES · USA".
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
> AUG 3 2012
Concentric Medical, Inc. c/o Ms. Kirsten Valley Vice President, Technology & Regulatory Affairs 301 East Evelyn Avenue Mountain View, CA 94041
Re: K120961
Trade/Device Name: Trevo Retriever Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: July 30, 2012 Received: July 31, 2012
Dear Ms. Valley:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
{10}------------------------------------------------
Page 2 - Ms. Kirsten Valley
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely vours.
-Malvina B. Evdelman, M.D. Director Division of Ophthalmic, Neurological, and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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### Indications for Use
510(k) Number (if known):
Device Name: Trevo Retriever
Indications for Use:
The Trevo Retriever is intended to restore blood flow in the neurovasculature by removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV-tPA) or who fail IV-tPA therapy are candidates for treatment.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Page 1 of 1
JOE HVTTER
(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
KI20961
510(k) Number.
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1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.