The Primi™ Support Catheter is intended to be used in conjunction with guidewires in order to access discreet regions of the peripheral vasculature. It may be used to facilitate placement and exchange of guidewires and other interventional devices. The support catheter also may be used to selectively infuse/deliver physician specified diagnostic and/or therapeutic agents, such as sterile saline, contrast agents, vaso-dilators, anti-blastics, lytics, and anti-thrombotics, with or without a guidewire in position.
Device Story
Single-lumen support catheter; used in peripheral vasculature; facilitates guidewire placement/exchange; enables selective infusion of diagnostic/therapeutic agents via luer hub. Features tapered tip for crossing; radiopaque marker for positioning; integral spine wire for support. Available in various diameters (0.014", 0.018", 0.035") and lengths (90-170 cm). Distal portion includes advanced hydrophilic coating for lubricity. Operated by physicians in clinical settings. Benefits include improved access to discreet vascular regions and reduced friction during insertion.
Clinical Evidence
Bench testing only. Testing included biocompatibility (ISO 10993), dimensional analysis, wire movement/compatibility, torque, kink resistance, hub leakage, peripheral model passage, coating durability/particulate analysis, radiopacity, injection pressure, flow rate, and tensile strength. All tests met specifications.
Technological Characteristics
Single-lumen catheter; Pebax hub/outer/distal shaft; HDPE inner shaft; stainless steel tapered core wire; platinum/iridium marker band. Advanced hydrophilic coating on distal portion. 5 Fr and 6 Fr sheath compatibility. Max injection pressure 300 psi. Sterilized for single use.
Indications for Use
Indicated for patients requiring access to peripheral vasculature for guidewire placement/exchange or selective infusion of diagnostic/therapeutic agents.
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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#### 510 (k) SUMMARY ·
#### Applicant
ThermopeutiX, Inc. 9951B Businesspark Avenue San Diego, California 92131 Phone: (858) 549-1760 Fax: (858) 549-1717
#### Manufacturer
ThermopeutiX, Inc. 9951B Businesspark Avenue San Diego, California 92131 Phone: (858) 549-1760 Fax: (858) 549-1717
2 6 2013
Contact Person
Jason Ford, Quality Assurance
Common Names: Support Catheter
Classification Name: Devices of this type are classified as Class II under 21 CFR Part CFR Part 870.1250, Percutaneous Catheter (Product Code DQY).
Proprietary Name: Primi™ Support Catheter
Predicate Devices
The ThermopeutiX Primi™ Support Catheter with the advanced hydrophilic coating is substantially equivalent in indications, design, construction and features to the ThermopeutiX Primi™ Support Catheter cleared under 510(k) K130850 with the exception of the hydrophilic coating.
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#### Indications for Use
There is no change in the indications for use for the Primi™ Support Catheter with the advanced hydrophilic coating. The existing Primi™ Support Catheter indications statement remains unchanged. The indications for use are as follows:
The Primi™ Support Catheter is intended to be used in conjunction with guidewires in order to access discreet regions of the peripheral vasculature. It may be used to facilitate placement and exchange of guidewires and other interventional devices. The support catheter also may be used to selectively infuse/deliver physician specified diagnostic and/or therapeutic agents, such as sterile saline, contrast agents, vaso-dilators, anti-blastics, lytics, and anti-thrombotics, with or without a guidewire in position.
#### Device Description
The ThermopeutiX Support Catheter that is the submission is a single lumen catheter with a radiopaque marker that aids in positioning the catheter and a tapered tip to facilitate entry. The catheter utilizes an integral spine wire. The catheter is available in several diameters and lengths which are 0.014", 0.018", or 0.035" guidewire compatible. The working lengths are 90 cm thru 170 cm. Reference Table 1 for model number availability. The distal portion of the catheter shaft has a hydrophilic coating to facilitate insertion. The device has a luer hub connector to allow infusion of diagnostic and/or therapeutic agents. The device is supplied sterile and is intended for single use only. Reference Table 2 below for physical and performance characteristics.
| PU14 -20-90 | PU14-40-90 | PU14 -60-90 | PU14 -80-90 | PU14 -100-90 | PU14 -120-90 |
|----------------|----------------|----------------|----------------|-----------------|-----------------|
| PU14 -20-90HF | PU14 -40-90HF | PU14 -60-90HF | PU14 -80-90HF | PU14 -100-90HF | PU14 -120-90HF |
| PU18-20-90 | PU18-40-90 | PU18-60-90 | PU18-80-90 | PU18-100-90 | PU18-120-90 |
| PU35-20-90 | PU35-40-90 | PU35-60-90 | PU35-80-90 | PU35-100-90 | PU35-120-90 |
| PU14 -20-130 | PU14 -40-130 | PU14 -60-130 | PU14 -80-130 | PU14 -100-130 | PU14 -120-130 |
| PU14 -20-130HF | PU14-40-130HF | PU14 -60-130HF | PU14 -80-130HF | PU14 -100-130HF | PU14 -120-130HF |
| PU18-20-130 | PU18-40-130 | PU18-60-130 | PU18-80-130 | PU18-100-130 | PU18-120-130 |
| PU35-20-130 | PU35-40-130 | PU35-60-130 | PU35-80-130 | PU35-100-130 | PU35-120-130 |
| PU14 -20-150 | PU14 -40-150 | PU14 -60-150 | PU14 -80-150 | PU14 -100-150 | PU14 -120-150 |
| PU14 -20-150HF | PU14 -40-150HF | PU14 -60-150HF | PU14 -80-150HF | PU14 -100-150HF | PU14 -120-150HF |
| PU18-20-150 | PU18-40-150 | PU18-60-150 | PU18-80-150 | PU18-100-150 | PU18-120-150 |
| PU35-20-150 | PU35-40-150 | PU35-60-150 | PU35-80-150 | PU35-100-150 | PU35-120-150 |
| PU14 -20-170 | PU14 -40-170 | PU14 -60-170 | PU14 -80-170 | PU14 -100-170 | PU14 -120-170 |
| PU14 -20-170HF | PU14 -40-170HF | PU14 -60-170HF | PU14 -80-170HF | PU14 -100-170HF | PU14 -120-170HF |
| PU18-20-170 | PU18-40-170 | PU18-60-170 | PU18-80-170 | PU18-100-170 | PU18-120-170 |
| PU35-20-170 | PU35-40-170 | PU35-60-170 | PU35-80-170 | PU35-100-170 | PU35-120-170 |
#### Table 1- Model Numbers for the Primi™ Support Catheter with the advanced hydrophilic coating
* The HF suffix indicates the high flow version
PUxx-yy-zzz, xx=guide wire size (0.014", 0.018", or 0.035")
yy=distal shaft length (20mm, 40mm, 60mm, 100mm, or 120mm) zzz=Overall catheter length (150cm or 170cm)
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| Element/Feature | ThermopeutiX Primi Support Catheters |
|----------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Working Length (s) | 90 cm - 170 cm; polymer shaft with integral spine wire |
| Distal Shaft Length (mm) | 20, 40, 60, 80, 100, 120 |
| Outside Diameter (s) | Distal:0.045" - 0.064"<br>Proximal: 0.060" - 0.080" |
| Lumen | One |
| Guide wire Compatibility | 0.014" - 0.035" |
| Distal End Configuration | Tapered tip for ease of crossing |
| Fluid connection | Luer hub connector |
| Flow rate @ 150 psi | 0.014" wire models > 0.80 cc/sec, Saline<br>0.035" wire models > 0.50 cc/sec, Saline<br>0.014" wire models > 0.30 cc/sec, Contrast<br>0.035 wire models > 0.15 cc/sec, Contrast |
| Maximum Injection Pressure | 300 psi |
| Hydrophilic Coating | Yes; distal portion, for lubricity |
| Radiopaque Markers | One |
| Sheath Compatibility | 5 Fr and 6 Fr |
| Catheter Materials | Hub-Pebax<br>Outer Shaft-Pebax<br>Inner Shaft-HDPE<br>Distal Shaft-Pebax w/radiopaque filler<br>Core Wire-Stainless Steel tapered wire<br>Coating-Hydrophilic proprietary coating |
## Table 2-Physical and Performance Characteristics
#### Technological Characteristics Comparison
The Primi™ Support Catheter with the advanced hydrophilic coating is identical in design and construction to the currently marketed Primi™ Support Catheter with the exception of the hydrophilic coating. The advanced hydrophilic coating provides comparable lubricity with a reduction in particulates. The coating is applied to the same portion of the candidate device as the predicate device. The coating thickness is considered equivalent between the candidate and predicate device.
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| | | | | | | | Table 3-Predicate Device Characteristics Comparison |
|--|--|--|--|--|--|--|-----------------------------------------------------|
| | | | | | | | |
| Table 3-Predicate Device Characteristics Comparison | | |
|-----------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Element/Feature | ThermopeutiX Primi Support Catheter (This 510k) | ThermopeutiX Primi Support Catheter 510(k) K130850 |
| Working Length (s) | 90 cm – 170 cm; polymer shaft with integral spine wire | 90 cm – 170 cm; polymer shaft with integral spine wire |
| Outside Diameter (s) | Distal:0.045" – 0.064"<br>Proximal: 0.060" – 0.080" | Distal:0.045" – 0.064"<br>Proximal: 0.060" – 0.080" |
| Lumen | One | One |
| Guide wire Compatibility | 0.014"-0.035" | 0.014"-0.035" |
| Guide wire Use | Over the Wire | Over the Wire |
| Distal End Configuration | Tapered tip for ease of crossing | Tapered tip for ease of crossing |
| Fluid connection | Luer hub connector | Luer hub connector |
| Flow rate @ 150 psi w/Saline | 0.014" wire models > 0.80 cc/sec<br>0.035" wire models > 0.50 cc/sec | 0.014" wire models > 0.80 cc/sec<br>0.035" wire models > 0.50 cc/sec |
| Flow rate @ 150 psi w/Contrast | 0.014" wire models > 0.30 cc/sec<br>0.035" wire models > 0.15 cc/sec | 0.014" wire models > 0.30 cc/sec<br>0.035" wire models > 0.15 cc/sec |
| Maximum Injection Pressure | Do not exceed 300 psi | Do not exceed 300 psi |
| Coating | Yes; advanced hydrophilic, distal portion | Yes; hydrophilic, distal portion |
| Coating Length | 65 cm, 115 cm or 140 cm<br>(lengths are the same as the predicate across all models) | 65 cm, 115 cm or 140 cm |
| Coating Thickness | Same as predicate | Proprietary |
| Radiopaque Markers | One | One |
| Sheath Compatibility | 5 Fr and 6 Fr | 5 Fr and 6 Fr |
| Materials Used | Hub-Pebax<br>Outer Shaft-Pebax<br>Inner Shaft-HDPE<br>Distal Shaft-Pebax w/radiopaque filler<br>Core Wire-Stainless Steel tapered wire<br>Coating-Advanced hydrophilic proprietary coating<br>Marker Band Platinum/Iridium | Hub-Pebax<br>Outer Shaft-Pebax<br>Inner Shaft-HDPE<br>Distal Shaft-Pebax w/radiopaque filler<br>Core Wire-Stainless Steel tapered wire<br>Coating-Hydrophilic proprietary coating<br>Marker Band Platinum/Iridium |
# Non-Clinical Tests
The non-clinical tests performed on sample devices are listed below. All testing passed internal protocol requirements and met product specifications. All of the requirements in the standards utilized were met.
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-Biocompatibility Testing (ISO10993-1)
-Cytotoxicity (ISO 10993-5)
-Sensitization (Guinea Pig Maximization ISO 10993-10)
-Irritation (ISO 10993-10)
-Systemic Toxicity (ISO 10993-11)
-Complement Activation (C3a and SC5b-9 ISO10993-4)
-Pyrogen (ISO 10993-11)
-Hemocompatibility (Hemolysis, Thromboresistance, Partial Thromboplastin Time (ISO
10993-4 and ASTM F2382)
-Device Functional Testing
-Dimensional
-Wire Movement/Compatibility
-Catheter Torque
-Catheter Kink
-Hub Leakage
-Peripheral Model Passage
-Coating Particulate
-Coating Durability/Integrity
-Radiopacity
-Maximum Injection Pressure
-Flow Rate Testing (wire in/wire out)
-Tensile Test (distal tip, distal tip to wire, distal shaft to proximal shaft, hub to shaft)
-Pouch Seal Integrity
-All performance testing was repeated on samples with a minimum of 10 month aging.
#### Conclusion
Based on the non-clinical testing results, the Primi™ Support Catheters with the advanced hydrophilic coating are substantially equivalent to the legally marketed device identified in this submission.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol resembling an eagle or bird in flight, composed of three curved lines.
September 26, 2013
Public Health Service
Food and Drug Administration 0903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
Thermopeutix, Inc. Mr. Jason Ford Quality Engineer 9951B Businesspark Avenue San Diego, CA 92131
Re: K132701
Trade/Device Name: Primi™ Support Catheter Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous catheter Regulatory Class: II Product Code: DOY Dated: July 30, 2013 Received: August 29, 2013
Dear Mr. Ford:
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.
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.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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/ReportalProblem/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/ResourcesforYou/Industry/default.htm.
Sincerely yours.
# Bram D. Zuckerman -S
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
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ThermopeutiX, Inc. Special 510(k) Premarket Notification July 30, 2013
### INDICATIONS FOR USE STATEMENT
510(k) Number (If Known):
Device Name: Primi™ Support Catheter
Indications For Use:
The Primi™ Support Catheter is intended to be used in conjunction with guidewires in order to access discreet regions of the peripheral vasculature. It may be used to facilitate placement and exchange of guidewires and other interventional devices. The support catheter also may be used to selectively infuse/deliver physician specified diagnostic and/or therapeutic agents, such as sterile saline, contrast agents, vaso-dilators, anti-blastics, lytics, and anti-thrombotics, with or without a guidewire in position.
Prescription Use: (Part 21 CFR 801 Subpart D) AND/OR
Over-the-counter Use: (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
# Bram D. Zuckerman -S 2013.09.26 20:13:14 -04
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
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.