EkoSonic Endovascular Device with Control Unit 4.0
Applicant
Btg International, Inc.
Product Code
QEY · Cardiovascular
Decision Date
Apr 5, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.5150
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The EkoSonic Endovascular Device with Control Unit 4.0 is indicated for the: - Ultrasound facilitated, controlled and selective infusion of physician-specified fluids, including thrombolytics, into the vasculature for the treatment of pulmonary embolism. - Infusion of solutions into the pulmonary arteries. - Controlled and selective infusion of physician-specified fluids, including thrombolytics, into the peripheral vasculature.
Device Story
Device consists of disposable infusion catheter with removable ultrasound core and Control Unit 4.0. Catheter features multiple side holes for fluid infusion and up to 30 ultrasound elements for energy delivery. Control Unit 4.0 generates/controls RF energy delivered to ultrasound core; monitors treatment zone temperature via thermal sensors. Used in clinical settings by physicians for ultrasound-facilitated thrombolytic therapy in pulmonary embolism and peripheral vasculature. Ultrasound energy facilitates delivery of thrombolytic agents into blood clots; temperature feedback system limits surface temperature to 43°C to ensure safety. System provides controlled, selective infusion, potentially improving clot dissolution and patient outcomes.
Clinical Evidence
No clinical data provided. Substantial equivalence supported by bench testing, including hardware verification (electrical safety, EMC/EMI, battery, reliability) and software verification (firmware, UI, RF control, system integration). All tests passed.
Technological Characteristics
System comprises disposable infusion catheter (5.4 Fr, 106/135 cm length) and Control Unit 4.0. Ultrasound core contains 6-30 elements; frequency 2.0-2.5 MHz. RF energy source converted to ultrasound. Temperature monitoring/feedback loop limits surface temperature to 43°C. Software-limited power output (~50W). Internal lithium-ion backup battery. Radiopaque markers on ultrasound elements. Sterile, single-use.
Indications for Use
Indicated for patients requiring ultrasound-facilitated, controlled, selective infusion of fluids (including thrombolytics) into the vasculature for pulmonary embolism treatment, infusion into pulmonary arteries, or infusion into peripheral vasculature.
Regulatory Classification
Identification
An embolectomy catheter is a balloon-tipped catheter that is used to remove thromboemboli, i.e., blood clots which have migrated in blood vessels from one site in the vascular tree to another.
Predicate Devices
EKOS EkoSonic Endovascular Device with CU 4.0 (K162771)
Submission Summary (Full Text)
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November 22, 2021
BTG International, Inc. Benjamin Hornsey Regulatory Affairs Manager 11911 N Creek Pkwy S Bothell, Washington 98011
Re: K183361
Trade/Device Name: EkoSonic Endovascular Device with Control Unit 4.0 Regulation Number: 21 CFR 870.5150 Regulation Name: Embolectomy catheter Regulatory Class: Class II Product Code: QEY, KRA
Dear Benjamin Hornsey:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated April 5, 2019. Specifically. FDA is updating this SE Letter as an administrative correction because FDA has created a new product code to better categorize your device technology.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Gregory O'Connell, OHT2: Office of Cardiovascular Devices, (301) 796-6075, Gregory.Oconnell(@FDA.HHS.gov.
Sincerely,
Gregory W - Digitally signed by Gregory W. O'connell -S O'connell -S Date: 2021.11.22
Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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April 5, 2019
BTG International, Inc. Benjamin Hornsey Regulatory Affairs Manager 11911 N Creek Pkwy S Bothell, Washington 98011
Re: K183361
Trade/Device Name: EkoSonic Endovascular Device with Control Unit 4.0 Regulation Number: 21 CFR 870.1210 Regulation Name: Continuous Flush Catheter Regulatory Class: Class II Product Code: KRA Dated: March 5, 2019 Received: March 6, 2019
Dear Mr. Hornsey:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 of medical device-related adverse events) (21 CFR 803) for
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For
Digitally signed by Haiira F. Hajira F. Ahmad -S Date: 2019.04.05 Ahmad -S 14:01:06 -04'00'
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) K183361
Device Name
EkoSonic Endovascular Device with Control Unit 4.0
Indications for Use (Describe)
The EkoSonic Endovascular Device with Control Unit 4.0 is indicated for the:
- · Ultrasound facilitated, controlled and selective infusion of physician-specified fluids, including thrombolytics, into the vasculature for the treatment of pulmonary embolism.
- · Infusion of solutions into the pulmonary arteries.
- · Controlled and selective infusion of physician-specified fluids, including thrombolytics, into the peripheral vasculature.
Type of Use (Select one or both, as applicable)
| <span> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> |
|--------------------------------------------------------------------------------------------------------|
| <span> <span style="font-size: 16px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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#### l. Submitter
EKOS Corporation, Inc. 11911 North Creek Parkway S Bothell, WA 98011
Phone: 425-415-3143 Fax: 425-415-3105
Contact Person: Benjamin Hornsey Date Prepared: December 3, 2018
### II. Device
| Proprietary Name: | EkoSonic™ Endovascular Device with Control Unit 4.0 |
|-----------------------|-----------------------------------------------------|
| Common or Usual Name: | Continuous Flush Catheter |
| Classification Name: | Catheter, Continuous Flush (21 CFR §870.1210) |
| Product Code: | KRA |
Continuous Flush Catheters have been classified by the FDA Cardiovascular Panel as Class II.
#### lll. Predicate Devices
The EkoSonic Endovascular Device with CU 4.0 (CU 4.0) is substantially equivalent to another legally marketed device. This predicate device is the EKOS EkoSonic Endovascular Device with CU 4.0 (K162771).
No reference devices were used in this submission.
### IV. Device Description
The EkoSonic Endovascular Device with CU 4.0 consists of an EkoSonic Endovascular Device and the Control System 4.0 (Control Unit 4.0 and Connector Interface Cables). The EkoSonic Endovascular Device consists of a disposable infusion catheter with removable ultrasound core. The infusion catheter contains multiple side holes distributed over the length of the treatment zone. The ultrasound core contains up to 30 ultrasound elements, evenly spaced over the treatment zone. Thermal sensors in the treatment zone monitor catheter temperature. The Control System 4.0 generates and controls the delivery of radiofrequency energy to the ultrasound core while monitoring and controlling the temperature of the treatment zone.
It is the modifications to the Control System 4.0 that are the subject of this submission.
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## V. Intended Use/Indications for use
The EkoSonic Endovascular Device with Control Unit 4.0 is indicated for the:
- Ultrasound facilitated, controlled and selective infusion of physician-specified fluids, including thrombolytics, into the vasculature for the treatment of pulmonary embolism.
- Infusion of solutions into the pulmonary arteries.
- Controlled and selective infusion of physician-specified fluids, including thrombolytics, into the peripheral vasculature.
| | EkoSonic Endovascular Device with | EkoSonic Endovascular Device with |
|--------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | CU 4.0 | CU 4.0 |
| | (Subject Device) | (Predicate Device) |
| 510(k) Number | K183361 | K162771 |
| Product Code | KRA | KRA |
| Indications for<br>Use | The EkoSonic Endovascular Device with CU 4.0<br>is indicated for the:<br>• Ultrasound facilitated, controlled and<br>selective infusion of physician-specified<br>fluids, including thrombolytics, into the<br>vasculature for the treatment of pulmonary<br>embolism.<br>• Infusion of solutions into the pulmonary<br>arteries.<br>• Controlled and selective infusion of<br>physician-specified fluids, including<br>thrombolytics, into the peripheral<br>vasculature. | The EkoSonic Endovascular Device with CU 4.0<br>is indicated for the:<br>• Ultrasound facilitated, controlled and<br>selective infusion of physician-specified<br>fluids, including thrombolytics, into the<br>vasculature for the treatment of pulmonary<br>embolism.<br>• Infusion of solutions into the pulmonary<br>arteries.<br>• Controlled and selective infusion of<br>physician-specified fluids, including<br>thrombolytics, into the peripheral<br>vasculature. |
| Principle of<br>Operation | The EkoSonic Endovascular Device with CU 4.0<br>employs ultrasound to facilitate the delivery of<br>thrombolytic agents into vascular blood clots. | The EkoSonic Endovascular Device with CU 4.0<br>employs ultrasound to facilitate the delivery of<br>thrombolytic agents into vascular blood clots. |
| Software Version | 01.02.02 | 01.00.05 |
| Battery Version | 8742-003 | 6841-002 |
| Infusion Hole<br>Pattern | Multiple side-holes | Multiple side-holes |
| Catheter Working<br>Length | 106 cm or 135 cm | 106 cm or 135 cm |
| Treatment Zone<br>Length | 6 cm - 50 cm | 6 cm - 50 cm |
| | EkoSonic Endovascular Device with<br>CU 4.0<br>(Subject Device) | EkoSonic Endovascular Device with<br>CU 4.0<br>(Predicate Device) |
| Compatible<br>Guide Wire | 0.035" | 0.035" |
| Outer Diameter | 5.4 Fr | 5.4 Fr |
| Placement Mode | Percutaneous/endovascular | Percutaneous/endovascular |
| Packaged Sterile | Yes - EkoSonic Device | Yes - EkoSonic Device |
| Single-Use<br>Disposable | Yes - EkoSonic Device | Yes - EkoSonic Device |
| Materials<br>Biocompatible | Yes - EkoSonic Device | Yes - EkoSonic Device |
| Radiopaque<br>Markers | Yes on IDDC<br>MSD ultrasound elements are radiopaque | Yes on IDDC<br>MSD ultrasound elements are radiopaque |
| Mechanism of<br>Action | Ultrasound | Ultrasound |
| Energy Source | R/F electrical from CU 4.0 converted to<br>ultrasound | R/F electrical from CU 4.0 converted to<br>ultrasound |
| Ultrasound<br>Transducer(s) in<br>Catheter | 6 to 30 | 6 to 30 |
| Acoustic<br>Characteristics | Frequency = 2.0 - 2.5 MHz | Frequency = 2.0 - 2.5 MHz |
| Battery Backup | Internal, lithium-ion backup battery | Internal, lithium-ion backup battery |
| Maximum<br>Output Power<br>Limit | Power is available for ~100W Pulses. The<br>power output is limited by software to ~50W. | Power is available for ~100W Pulses. The<br>power output is limited by software to ~50W. |
| Maximum<br>EkoSonic Device<br>Temperature | Temperature monitoring, feedback and control<br>system limits the surface temperature of the<br>IDDC to 43°C during operation. | Temperature monitoring, feedback and control<br>system limits the surface temperature of the<br>IDDC to 43°C during operation. |
## VI. Comparison of Technological Characteristics with the Predicate Device
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The device modifications described in the submission do not affect the intended use,
indications for use or the technological characteristics for the EkoSonic Endovascular System.
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## VII. Performance Data
Testing has confirmed that the EkoSonic Endovascular Device with CU 4.0 functions as intended and is substantially equivalent to the predicate device.
| Hardware Testing Performed | |
|--------------------------------------|------|
| Secondary Cell Battery Tests | Pass |
| Reliability Prediction | Pass |
| Battery Hardware Design Verification | Pass |
| Electrical Safety | Pass |
| Hardware Inspection | Pass |
| EMC/EMI | Pass |
| RF Board Hardware Tests | Pass |
| System Integration | Pass |
| CIC Hardware Tests | Pass |
| Shipping Package Tests | Pass |
| Design Verification Hardware Tests | Pass |
| UI Board Hardware Tests | Pass |
| Environmental Tests | Pass |
| Power Management Module Tests | Pass |
| Short Circuit Response | Pass |
| Patched Fastener Design Verification | Pass |
| EkoSonic Device Reliability | Pass |
| Software Testing Performed | |
|----------------------------|------|
| Periodic Self-Test | Pass |
| User Interface | Pass |
| Firmware Upgrade | Pass |
| Event Logging | Pass |
| System Connect Validation | Pass |
| Single Channel RF | Pass |
| Graphing | Pass |
| Device Compatibility | Pass |
| Dual Channel RF | Pass |
| Therapy Support | Pass |
| System Startup | Pass |
| Processor Communication | Pass |
| Constant Parameter | Pass |
| Source Code Inspection | Pass |
| AC and Battery Power | Pass |
Performance standards have not been promulgated for Continuous Flush Catheters.
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## VIII. Conclusions
The EkoSonic Endovascular Device with CU 4.0 is substantially equivalent to the predicate device. The modifications to the Control System 4.0 do not affect the intended use or the technological characteristics for the system and do not raise new questions of safety or effectiveness.
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.