K152275 · Avinger, Inc. · MCW · Oct 14, 2015 · Cardiovascular
Device Facts
Record ID
K152275
Device Name
Pantheris System
Applicant
Avinger, Inc.
Product Code
MCW · Cardiovascular
Decision Date
Oct 14, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.4875
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0 mm to 7.0 mm, using OCT-assisted orientation as an adjunct to fluoroscopy. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
Device Story
The Pantheris System is a peripheral atherectomy device used by physicians in clinical settings to remove atherosclerotic plaque. It consists of a catheter with an integrated imaging assembly, rotating cutter, balloon apposition mechanism, and tiltable nosecone, connected to a Lightbox HS Imaging Console via a sled and umbilical. The system utilizes Optical Coherence Tomography (OCT) to provide real-time, high-resolution visualization of the vessel lumen, allowing the physician to orient the cutter precisely toward the plaque under fluoroscopic guidance. By enabling targeted plaque excision, the device aims to restore vessel patency and improve blood flow, potentially reducing the need for more invasive interventions. The console processes optical signals to display images, which the physician uses to guide the atherectomy procedure, directly impacting clinical decision-making regarding the extent and location of plaque removal.
Clinical Evidence
The VISION Study was a prospective, multi-center, non-randomized trial (n=162). Primary effectiveness (technical success: residual stenosis <50% post-procedure) was 96%, exceeding the 92.13% performance goal. Primary safety (freedom from major adverse events at 6 months) was 78.5%, meeting the performance goal of 35.3% (upper 95% CI 43.2%). Secondary endpoints included procedural success (residual stenosis ≤30% in 79.3% of lesions), ABI, and quality of life measures.
Technological Characteristics
The system includes a sterile, single-use catheter (130 cm length, 8F sheath compatible) with an integrated optical fiber for OCT, a rotating cutter, and a balloon apposition mechanism. The Lightbox HS Imaging Console acts as an optical transceiver with a PC-based processing system. Connectivity is via a proprietary umbilical cable. The system is designed for use with 0.014" guidewires.
Indications for Use
Indicated for patients with symptomatic atherosclerotic plaque (stenosis >70%) in peripheral vasculature vessels with reference diameters 3.0-7.0 mm and lengths ≤15 cm. Contraindicated for iliac, coronary, cerebral, renal, or carotid vasculature.
Regulatory Classification
Identification
An intraluminal artery stripper is a device used to perform an endarterectomy (removal of plaque deposits from arterisclerotic arteries.)
Predicate Devices
Medtronic, Inc. (formerly Fox Hollow Technologies) SilverHawk Peripheral Plaque Excision System (K061188)
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized depiction of a human figure, represented by three overlapping profiles, positioned to the right of the department's name. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the figure.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 14, 2015
Avinger, Inc. c/o Ms. Patty Hevev Vice President, Clinical and Regulatory Affairs 400 Chesapeake Drive Redwood City, CA 94063
Re: K152275
Trade/Device Name: Pantheris System Regulation Number: 21 CFR 870.4875 Regulation Name: Intraluminal Artery Stripper Regulatory Class: Class II Product Code: MCW, NQQ Dated: August 11, 2015 Received: August 12, 2015
Dear Ms. Hevey:
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
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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 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/ReportaProblem/default.htm for the CDRH's Office
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.
of Surveillance and Biometrics/Division of Postmarket Surveillance.
Sincerely yours,
Kenneth J. Cavanaugh -S
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K152275
Device Name Pantheris System
Indications for Use (Describe)
The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0 mm, using OCT-assisted orientation as an adjunct to fluoroscopy.
The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|-----------------------------------------|
| Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-size: 16px;">☑</span> |
| Over-The-Counter Use (21 CFR 801 Subpart C) | <span style="font-size: 16px;">☐</span> |
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#### 510(K) SUMMARY 1.0
# 510(k) Notification K152275
#### GENERAL INFORMATION
Applicant:
Avinger, Inc. 400 Chesapeake Drive Redwood City, CA 94063 U.S.A. Phone: 650-241-7900 Fax: 650-241-7901
Contact Person:
Patty Hevey Vice President, Clinical and Regulatory Affairs Avinger, Inc. Phone: 650-222- 3666 Fax: 650-241-7901
Date Prepared:
August 11th, 2015
#### DEVICE INFORMATION
Trade Name:
Pantheris System
Generic/Common Name:
Peripheral Atherectomy Catheter
Classification:
21 CFR§870.4875, Intraluminal Artery Stripper, Class II 21 CFR\$892.1560, Ultrasonic Pulsed Echo Imaging System, Class II
Product Codes:
MCW, NQQ
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#### PREDICATE DEVICES
- Medtronic, Inc. (formerly Fox Hollow Technologies) SilverHawk Peripheral . Plaque Excision System (K061188)
- . Avinger Ocelot System (K140185)
## DEVICE DESCRIPTION
The Pantheris System consists of the Pantheris Catheter (packaged with the Flush Fixture), Lightbox Sled (referred to as Sled), the Lightbox HS Imaging Console, the Lightbox Umbilical (referred to as Umbilical), Sterile Drape (accessory) and the Occlusion Sheath (optional accessory). The Pantheris System combines the use of Avinger's Optical Coherence Tomography (OCT) technology with peripheral vascular atherectomy capabilities.
The Pantheris Catheter has a working length of 130 cm and is a sterile, singleuse device that is compatible with 8F sheaths and 0.014" guidewires. The Pantheris Catheter consists of an imaging assembly, a rotating cutter, an apposition mechanism (balloon) and a flexible, tiltable nosecone. It also incorporates an Optical Fiber that allows for real-time OCT guided directional atherectomy during the procedure. The Pantheris Catheter and optional Occlusion Sheath accessory are provided sterile and are intended for single-use only.
The Pantheris Catheter is connected to the Lightbox HS Imaging Console via the Sled and the Umbilical. The Sled provides optical and rotational power to the Pantheris Catheter. The Umbilical is a 3-meter long optical and electrical extension cable that connects the Sled to the Lightbox HS Imaging Console.
The Lightbox HS Imaging Console is an optical transceiver, transmitting light to the intraluminal environment through the optical fiber on the Pantheris Catheter and receiving and interpreting the signal from the tissue using a PC-based processing system. The Lightbox provides a visualization platform that allows for real-time OCT-assisted directional atherectomy. The Lightbox HS Imaging Console consists of a cart with two monitors; a PC based processing system, an isolation transformer and an OCT system.
#### INDICATIONS FOR USE
The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0 mm to 7.0 mm, using OCT-assisted orientation as an adjunct to fluoroscopy. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
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#### SUBSTANTIAL EQUIVALENCE
The Pantheris System intended use, technological characteristics and principles of operation are similar to the Avinger Ocelot System (K140185) and the Medtronic SilverHawk Peripheral Plaque Excision System (K061188) with the exception of the following:
- Catheter working length ●
- Distal catheter outer diameter ●
- Minimum vessel diameter access ●
- Method of vessel apposition ●
- Method of distal catheter deflection
- Cutting component speed ●
- Length of excised cut
- . Catheter OCT element
Any differences between the Pantheris System and the predicate devices do not alter the intended use of the Pantheris System. The significance of the differences between the Pantheris System and the predicate devices was evaluated in the VISION clinical trial.
## NONCLINICAL TESTING IN SUPPORT OF SUBSTANTIAL EQUIVALENCE DETERMINATION
All necessary performance testing was conducted on the Pantheris System to support a determination of substantial equivalence to the predicate devices. The nonclinical testing conducted on the Pantheris System provided in the IDE G130159 submission and remaining applicable to the current Pantheris System includes:
- Pantheris design verification and validation studies ●
- Packaging and shelf-life ●
- Biocompatibility ●
- Sterilization ●
- Software verification and validation ●
- Electrical safety, electromagnetic compatibility, and laser safety testing ●
- Pantheris GLP Animal Safety and Performance Report ●
The collective results of the non-clinical testing demonstrate that the Pantheris System meets the established specifications necessary for consistent performance for its intended use.
## CLINICAL TESTING IN SUPPORT OF SUBSTANTIAL EQUIVALENCE DETERMINATION
The VISION Study is a prospective, multi-center, non-randomized study to evaluate the safety and effectiveness of the Pantheris System. The primary effectiveness endpoint of this study was technical success, defined as the percent of target lesions
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that have a residual diameter stenosis < 50% post the Pantheris device alone as assessed by an independent Angiographic Core Laboratory.
The primary safety endpoint is defined as freedom from a composite of major adverse events (MAEs) through 6-Month follow-up as adjudicated by an independent Clinical Events Committee (CEC). Secondary effectiveness endpoints include, procedural success, defined as the percent of target lesions that have residual diameter stenosis ≤ 30% post-Pantheris and/or any other adjunctive therapy, determined by independent Angiographic Core Laboratory, Ankle-Brachial Index (ABI), Rutherford Classification and quality of life measures using both SF-12 and VascuOoL questionnaires at 30 days and 6 months.
Secondary safety endpoints include freedom from MAE through 30 days, freedom from procedural related emboli and freedom from target vessel revascularization (TVR) through 30 days and 6 months.
The data in this report will present all subjects enrolled in the VISION Study (n=162 subjects; 134 subjects in the Intention-To-Treat (ITT) Cohort and 28 subjects in the Roll-In Cohort) through 30 days with the primary focus on the 130 Per Protocol Cohort subjects who underwent atherectomy with the Pantheris Catheter.
A total of 162 subjects were enrolled in the VISION Study. The treated population consisted of subjects presenting with documented symptomatic atherosclerotic plaque (stenosis >70% by visual estimation) who met all eligibility criteria. The primary disease had to be located in reference vessel diameters of >3.0 mm and ≤7.0 and not exceed <15 cm in length. Subjects were followed through 30-days and six months post-procedure.
Primary safety and effectiveness endpoints were based on an independent Clinical Events Committee (CEC) and independent angiographic Core lab reviews, respectively. The Pantheris System successfully excised plaque below the prespecified target stenosis of ≤ 50% in 96% (158/164) of lesions treated; meeting the primary effectiveness performance goal of 92.13% with a lower 95% confidence bound of 87%, indicating the primary effectiveness endpoint was met. A total of twenty (20) safety events were identified by the Clinical Events Committee (CEC) resulting in an overall safety event rate of 21.5% (20/93) in the per protocol population (78.5% event free); meeting the safety performance goal of 35.3% with a 95% 1-sided upper confidence bound of 43.2%, indicating the primary safety endpoint was also met.
The secondary efficacy endpoint defined as the percent of target lesions that have a residual diameter stenosis of <30% residual stenosis post Pantheris and any other adjunctive therapy was achieved in 79.3% of lesions.
The secondary safety endpoints defined as freedom from MAEs through 30 days, including procedural emboli and clinically driven target vessel revascularization
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(TVR) as adjudicated by an independent CEC, further confirmed that the device has provided clinical improvement in subjects' clinical status over time.
The study endpoints achieved the effectiveness performance goals while demonstrating a safety profile indicating the Pantheris Catheter can be used to safely excise plaque from lower extremity arteries with precision. The study results also demonstrate low acute device related adverse events.
#### CONCLUSION
The results of the non-clinical and clinical testing demonstrate that the Pantheris System is as safe and effective as the predicate devices. The clinical testing demonstrates that the technological characteristics employed by the Pantheris System do not raise any new issues of safety or effectiveness. Therefore, the Pantheris System is substantially equivalent to the identified predicate devices.
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.