K143589 · Synovis Life Technologies, Inc. · MVR · Jan 16, 2015 · General, Plastic Surgery
Device Facts
Record ID
K143589
Device Name
GEM Flow COUPLER Device and System
Applicant
Synovis Life Technologies, Inc.
Product Code
MVR · General, Plastic Surgery
Decision Date
Jan 16, 2015
Decision
SESE
Submission Type
Special
Regulation
21 CFR 878.4300
Device Class
Class 2
Indications for Use
The Flow COUPLER Device is a single use, implantable device that is intended to be used in the end-to-end anastomosis of veins and arteries normally encountered in microsurgical and vascular reconstructive procedures. The Flow COUPLER Device includes a pair of permanently implanted rings which secure the anastomosis and a removable Doppler probe that is press-fit onto one of the rings. When the Flow COUPLER Device is used in conjunction with the Flow COUPLER Monitor, the Flow COUPLER System is intended to detect blood flow and confirm vessel patency intra-operatively and post-operatively at the anastomotic site. Post-operatively, blood flow can be detected on an as needed basis for up to 7 days. The Flow COUPLER Doppler probe is not intended to be a permanent implant and should be removed 3 to 14 days post-operatively. The Flow COUPLER Device and System is intended to be used in the anastomosis of veins and arteries normally encountered in microvascular and vascular reconstructive procedures and in the detection of blood flow and confirmation of vessel patency following end-to-end anastomosis of vessels.
Device Story
System comprises implantable coupler rings and external Doppler monitor; used in microsurgical/vascular reconstructive procedures. Coupler rings (high-density polyethylene, stainless steel pins) provide sutureless end-to-end vessel anastomosis; permanent implant. 20 MHz Doppler probe press-fits onto ring; connects to monitor via external lead. Monitor provides pulsed Doppler ultrasound; produces audible signal upon blood flow detection. Used intra-operatively and post-operatively (up to 7 days) to confirm vessel patency. Probe removed 3-14 days post-op via gentle traction. Clinicians use audible output to assess anastomotic site health; aids in early detection of vascular compromise; facilitates timely clinical intervention.
Clinical Evidence
Bench testing only. No clinical data presented. Testing validated functional specifications for the 4.0mm line extension, including shock/vibration, pin alignment, ring retention, probe signal, and separation forces.
Technological Characteristics
Implantable rings: high-density polyethylene with stainless steel pins. Doppler probe: 20 MHz pulsed ultrasound. System: sterile, single-use implantable coupler + external monitor. Connectivity: wired probe to monitor. Sterilization: not specified. Software: not specified. Standards: EN ISO 14971:2012 (risk management).
Indications for Use
Indicated for patients undergoing microsurgical and vascular reconstructive procedures requiring end-to-end anastomosis of veins and arteries. Used for intra-operative and post-operative (up to 7 days) detection of blood flow and confirmation of vessel patency at the anastomotic site.
Regulatory Classification
Identification
An implantable clip is a clip-like device intended to connect internal tissues to aid healing. It is not absorbable.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 16, 2015
Synovis Life Technologies Incorporated Ms. Jodi Jorgenson Manager, Regulatory Affairs 2575 University Avenue West, Suite 180 Saint Paul, Minnesota 55114
Re: K143589
Trade/Device Name: GEM™ Flow COUPLER™ Device and System Regulation Number: 21 CFR 878.4300 Regulation Name: Implantable clip Regulatory Class: Class II Product Code: MVR, DPW Dated: December 17, 2014 Received: December 18, 2014
Dear Ms. Jorgenson:
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
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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 contact the Division of Industry and Consumer Education 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. 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 Industry and Consumer Education 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.
for
Sincerely yours,
# David Krause -S
Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K143589
## Device Name
GEM™ Flow COUPLERTM Device and System
#### Indications for Use (Describe)
The Flow COUPLER Device is a single use, implantable device that is intended to be used in the end-to-end anastomosis of veins and arteries normally encountered in microsurgical and vascular reconstructive procedures. The Flow COUPLER Device includes a pair of permanently implanted rings which secure the anastomosis and a removable Doppler probe that is press-fit onto one of the rings. When the Flow COUPLER Device is used in conjunction with the Flow COUPLER Monitor, the Flow COUPLER System is intended to detect blood flow and confirm vessel patency intra-operatively and post-operatively at the anastomotic site. Post-operatively, blood flow can be detected on an as needed basis for up to 7 days. The Flow COUPLER Doppler probe is not intended to be a permanent implant and should be removed 3 to 14 days post-operatively.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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#### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
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#### 2.0 510(K) SUMMARY
| Submitted by: | Synovis Micro Companies Alliance, Inc.<br>A Subsidiary of Synovis Life Technologies, Inc.<br>439 Industrial Lane<br>Birmingham, AL 35211-4464 |
|----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | FDA Registration #1062741 |
| | Tel: 205-941-0111<br>Fax: 205-941-1522 |
| Contact Person: | Jodi Jorgenson<br>Synovis Micro Companies Alliance, Inc.,<br>A Subsidiary of Synovis Life Technologies, Inc.<br>2575 University Avenue West<br>St. Paul, MN 55114-1024 |
| | Tel: 651-796-7399<br>Fax: 651-642-9018 |
| Date Prepared: | December 17, 2014 |
| Device Trade Name: | GEM™ Flow COUPLER™ Device and System |
| Common Name: | Microvascular Anastomotic Coupler<br>Cardiovascular Blood Flowmeter |
| Classification Name: | Microvascular Anastomotic Coupler<br>Regulation Number: 21CFR § 878.4300<br>Regulation Name: Implantable Clip<br>Regulatory Class: II<br>Product Code: MVR, DPW |
| Predicate Device: | GEM Flow COUPLER Device and System: K142609 |
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| Device Description: | The Flow COUPLER System consists of a Flow COUPLER Device<br>and a Flow COUPLER Monitor. The Flow COUPLER Device is a<br>sterile, single-use implantable pair of rings molded out of high<br>density polyethylene with stainless steel pins on each ring. The<br>Flow COUPLER Device is designed to serve as a mechanical,<br>sutureless device for connecting veins or arteries. A probe-holder<br>feature is molded on one Flow COUPLER ring and serves as the<br>press-fit point of attachment for a pre-attached 20 MHz Doppler<br>probe. The Doppler probe connects to the Flow COUPLER<br>Monitor unit, via the external lead.<br><br>The Flow COUPLER Monitor and Doppler probe is a pulsed<br>Doppler ultrasound system designed for the detection of blood flow<br>in vessels. An audible ultrasonic signal is produced when the<br>Doppler probe detects blood flow.<br><br>The Flow COUPLER Device and System has been specifically<br>designed for use in end-to-end anastomosis of blood vessels and the<br>detection of blood flow at the anastomotic site. On an as needed<br>basis, blood flow can be detected for up to 7 days. The Flow<br>COUPLER rings are intended to be a permanent implant. The Flow<br>COUPLER probe is not intended to be a permanent implant; the<br>probe should be removed, by gentle traction on the external lead,<br>3 to 14 days post-operatively. |
|-------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Statement of<br>Intended use: | The Flow COUPLER Device and System is intended to be used in<br>the anastomosis of veins and arteries normally encountered in |
| Technological<br>Comparisons: | The Flow Coupler Device and System is acting as its own predicate<br>and is therefore substantially equivalent having the same<br>technological characteristics including:<br>Intended use Indications for use Device functionality Device method of operation Device finished specifications Doppler probe (wire material, wire diameter, and insulation material) Power supply requirements Device monitor Packaging Sterilization method Shelf life The modified Flow Coupler device has the following differences as compared to the predicate device: Device size range Device dimension |
| Technology/Device<br>Testing: | A risk assessment of the size range extension in the form of a Design FMEA and Health Hazard Analysis has been conducted in accordance with EN ISO 14971: 2012.<br><br>Bench testing on the 4.0mm Flow COUPLER line extension was performed to validate that the functional specifications were not affected by the line extension. Testing included: shock and vibration, pin alignment, ring retention, probe signal, ring separation, and probe to COUPLER separation force.<br><br>The risk assessment and bench testing of this device demonstrate that the device is substantially equivalent to the predicate device. |
| Summary: | The device is substantially equivalent to the predicate device with respect to biocompatibility, manufacturing process, product performance, indications, sterilization, shelf life, packaging, and safety and efficacy. |
microvascular and vascular reconstructive procedures and in the detection of blood flow and confirmation of vessel patency following end-to-end anastomosis of vessels.
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#### Standards Data Report for 510(k)s – FDA 3654 3.0
Form FDA 3654 FDA Standards Data Report Forms is provided in Attachment A.
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.