The Pantheris System is intended to remove plaque (atherectomy) from partially occluded vessels in the peripheral vasculature with a reference diameter of 3.0mm to 7.0mm, using OCT-assisted orientation and imaging. The system is an adjunct to fluoroscopy by providing images of vessel lumen, wall structures and vessel morphologies. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
Device Story
Pantheris System is a peripheral atherectomy catheter system utilizing Optical Coherence Tomography (OCT) for real-time image-guided plaque removal. The system comprises a sterile, single-use catheter (7Fr or 8Fr), a Lightbox Sled, and a Lightbox HS Imaging Console. During procedures, the catheter is inserted into the peripheral vasculature; the Lightbox transmits light through an optical fiber in the catheter to the intraluminal environment. The system receives and interprets backscattered light signals to generate real-time images of vessel lumen, wall structures, and morphologies. These images serve as an adjunct to fluoroscopy, allowing physicians to orient the atherectomy device precisely. The system is operated by physicians in a clinical setting to remove plaque from partially occluded vessels, potentially improving blood flow and patient outcomes. The PC-based console processes the OCT signals to provide the visualization platform.
Clinical Evidence
No new clinical testing was performed for this submission. Substantial equivalence is supported by clinical data provided in the initial Pantheris System (K152275) submission and non-clinical bench testing, including design verification, validation, biocompatibility, electrical safety, and sterilization studies.
Technological Characteristics
System utilizes Optical Coherence Tomography (OCT) for imaging. Catheter dimensions: 7Fr/8Fr, 110 cm length, compatible with 0.014" guidewires. Components: Catheter, Lightbox Sled, Lightbox HS Imaging Console (PC-based). Connectivity: Optical fiber interface. Sterilization: Single-use, sterile. Software: PC-based processing system for OCT signal interpretation.
Indications for Use
Indicated for plaque removal (atherectomy) in partially occluded peripheral vasculature vessels with reference diameters of 3.0mm to 7.0mm. Contraindicated for use in 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.)
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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 circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines representing hair or clothing.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 18, 2016
Avinger, Inc. Ms. Patty Hevey Vice President, Clinical and Regulatory Affairs 400 Chesapeake Drive Redwood City, CA 94063
Re: K162326
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 17, 2016 Received: August 19, 2016
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 devicerelated 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 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
Sincerely.
Brian D. Pullin -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) K162326
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 3.0mm, using OCT-assisted orientation and imaging. The system is an adjunct to fluoroscopy by providing images of vessel lumen, wall structures and vessel morphologies.
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) | |
|------------------------------------------------------------------------------------------------|---------------------------------------------|
| <span style="text-decoration: overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
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#### 1.0 510(K) SUMMARY
## 510(k) Notification K162326
#### 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:
October 17th 2016
# 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
- Primary Predicate Device Avinger Pantheris System (K160827), hereafter referred to ● as the current Pantheris System
- Secondary Predicate Device Avinger Pantheris System (K152275), hereafter referred ● to as the initial Pantheris System
- Secondary Predicate Device - Avinger Ocelot System (K140185), hereafter referred to as the Ocelot System
# DEVICE DESCRIPTION
The current Pantheris System (K160827), listed as the primary predicate device, consists of the Pantheris Catheter, Lightbox Sled with integrated Umbilical (referred to as "Sled") the Lightbox HS Imaging Console (referred to as "Lightbox") and the accessories that are packaged with the Pantheris Catheter: flush fixture, tweezers, syringes and stopcocks, and a Sterile Drape accessory that is packaged separately. The subject Pantheris System submitted as part of this 510(k) submission does not introduce any changes to the device specifications, materials or manufacturing processes and is identical to the current Pantheris System.
The Pantheris System combines the use of Avinger's Optical Coherence Tomography (OCT) technology (identical to the OCT Technology used in the Ocelot System (K140185)) with peripheral vascular atherectomy capabilities.
The Pantheris Catheter comes in both a 7Fr and 8Fr size. Both sizes have a working length of 110 cm and are sterile, single-use devices that are compatible with 7Fr and 8Fr sheaths (respectively) and 0.014" guidewires. The Pantheris Catheter incorporates an Optical Fiber that allows for real-time OCT guided directional atherectomy during the procedure.
The Pantheris Catheter is connected to the Lightbox via the Sled. The Lightbox 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 PCbased processing system. The Lightbox provides a visualization platform for the real-time OCT-assisted directional atherectomy. The Lightbox consists of a cart with two monitors; a PC based processing system, an isolation transformer and an OCT system.
### PROPOSED 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 3.0mm to 7.0mm, using OCT-assisted orientation and imaging. The system is an adjunct to fluoroscopy by providing images of vessel lumen, wall structures and vessel morphologies. The Pantheris System is NOT intended for use in the iliac, coronary, cerebral, renal or carotid vasculature.
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#### SUBSTANTIAL EQUIVALENCE
The subject Pantheris System and the primary predicate device, the current Pantheris System (cleared under K160827) are identical. They have the same device specifications, materials, manufacturing processes, device packaging, principles of operation for vessel visualization and OCT technological characteristics. Post the clearance of K160827 on March 1, 2016, the current Pantheris System's Lightbox software was updated to version 4.0.1. The proposed Indications for Use for the subject Pantheris System is very similar to the current Pantheris System (K160827) Indications for Use.
The subject Pantheris System and the secondary predicate device, the initial Pantheris System (cleared under K152275) are very similar. They have almost identical device specifications, materials, manufacturing processes, device packaging, principles of operation for vessel visualization and OCT technological characteristics.
The subject Pantheris System and the secondary predicate device, the Ocelot System (K140185) have very similar intended use, principles of operation for vessel visualization and OCT technological characteristics.
Any differences between the subject Pantheris System and the predicate devices do not alter the intended use or impact the safety and effectiveness of the Pantheris System.
### NONCLINICAL TESTING IN SUPPORT OF SUBSTANTIAL EQUIVALENCE DETERMINATION
The subject Pantheris System is identical to the primary predicate device, the Pantheris System cleared under K160827. The changes proposed in this submission do not alter the Pantheris System specifications, design, functionality or manufacturing process. The changes only pertain to updates to the labeling to accurately reflect the Pantheris System's current imaging functionality.
The non-clinical, bench testing conducted on the Pantheris System and provided in the prior K160827 and K152275 submissions, are applicable to the subject Pantheris System, including the following:
- Design verification and bench validation studies ●
- Packaging and shelf-life ●
- Software verification and validation
- o Electrical safety, electromagnetic compatibility, and laser safety testing
- o Biocompatibility
- In-vivo animal validation study
- Sterilization o
The collective results of the non-clinical testing demonstrate that the subject Pantheris System meets the established specifications necessary for consistent performance for its intended use.
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Use of the same OCT technology between the subject and the predicate devices, along with successful OCT image comparisons between the subject Pantheris System, the Ocelot System (K140185) and images from the submitted compendium, confirm a determination of substantial equivalence between the subject device and the predicate devices regarding the updates to the subject Pantheris System labeling.
### CLINICAL TESTING IN SUPPORT OF SUBSTANTIAL EQUIVALENCE DETERMINATION
Clinical testing of the Pantheris System was included for the secondary predicate, the initial Pantheris System original 510(k) submission (K152275). Due to the equivalence between the Systems no new clinical testing is included in this 510(k) submission.
# CONCLUSION
The subject Pantheris System discussed in this submission is equivalent to the primary predicate device (current Pantheris System, K160827) in terms of specifications, design, functionality and manufacturing process. No new issues of safety or effectiveness are raised in this submission. The use of identical OCT technology in the predicate devices (the current Pantheris System (K160827), the intial Pantheris System (K152275) and the Ocelot System (K140185) and the successful OCT image comparisons, confirm that the Pantheris System is substantially equivalent to the predicate devices listed above.
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.