The Q Catheter is indicated for use with compatible guide catheters in facilitating the insertion and guidance of microcatheters into a selected blood vessel in the peripheral, coronary and neuro vascular systems.
Device Story
Single-lumen, variable stiffness catheter; used for endovascular insertion and guidance of microcatheters under fluoroscopy. Features radiopaque markers for visualization; hydrophilic coating to reduce friction; stainless-steel control (push) wire; pin vise for advancement. Introduced via 8F guide catheter/6F guide sheath over guidewire/microcatheter. Used by physicians in clinical settings during diagnostic/therapeutic procedures. Output is physical guidance of microcatheters to target vessels; enables delivery of therapeutic devices or diagnostic agents. Benefits patient by facilitating access to complex arterial anatomy.
Clinical Evidence
Bench testing only. Testing included dimensional verification, corrosion resistance, tensile strength of the pin vise, and system compatibility/simulated use testing with worst-case dimensional stack-up. All tests passed.
Technological Characteristics
Single-lumen, variable stiffness catheter; stainless-steel control wire; hydrophilic coating; radiopaque markers. Sizes: 3F, 4F, 5F, 6F. Sterilization: Ethylene Oxide (EO). Shelf life: 3 years. No electronic components or software.
Indications for Use
Indicated for use with compatible guide catheters to facilitate insertion and guidance of microcatheters into selected blood vessels in peripheral, coronary, and neurovascular systems for patients with arterial disease or damage.
Regulatory Classification
Identification
A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.
Predicate Devices
MIVI Mi-EXT Extension Catheter (now branded as the MIVI Q Distal Access Catheter) (K163233)
Submission Summary (Full Text)
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
April 6, 2020
MIVI Neurovascular Janel Hurtado Regulatory Affairs Director 6545 City West Parkway Eden Prairie, Minnesota 55344
## Re: K192558
Device Name: MIVI O Distal Access Catheter Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: QJP, DQY Dated: March 12, 2020 Received: March 13, 2020
## Dear Janel Hurtado:
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
{1}------------------------------------------------
801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Xiaolin Zheng, Ph.D., M.S. Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known) K192558
Device Name MIVI Q Distal Access Catheter
#### Indications for Use (Describe)
The Q Catheter is indicated for use with compatible guide catheters in facilitating the insertion and guidance of microcatheters into a selected blood vessel in the peripheral, coronary and neuro vascular systems.
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------|----------------------------------------------------------------------------------|
| <div> <span> ☑ Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> ☐ Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
## 510(K) SUMMARY
#### Date Prepared: November 8, 2019
| Table 1. General Information | |
|-----------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------|
| 510(k) Submitter | Contact |
| MIVI Neuroscience, Inc.<br>6545 City West Parkway<br>Eden Prairie, MN 55344 | Randy LaBounty<br>Vice President Regulatory, Clinical and Quality<br>Email: rlabounty@mivineuro.com |
| Trade Name | MIVI Q Distal Access Catheter |
| Common Name | Distal access catheter |
| Classification<br>Information | Percutaneous catheter; 21 CFR 870.1250 (Class II)<br>ProCode: QJP, DQY; Panel: Cardiovascular |
| Predicate<br>Device | MIVI Neuroscience, Inc. MIVI Mi-EXT Extension Catheter (now<br>branded as the MIVI Q Distal Access Catheter) (K163233) |
#### Device Description
The MIVI Q Catheter is a single-lumen, variable stiffness catheter with radiopaque markers on the distal and proximal end of the catheter portion for angiographic visualization. The catheter shaft has a hydrophilic coating to reduce friction during use. The proximal portion of the catheter is a stainless-steel control (push) wire. The Q catheter may be introduced via an 8F guide catheter/6F guide sheath and over a guidewire/microcatheter into the arterial vasculature until the desired vessel is reached. The catheter contains a pin vise threaded on the control wire, which may be used to advance the catheter.
#### Intended Use / Indications for Use
The Q Catheter is indicated for use with compatible guide catheters in facilitating the insertion and guidance of microcatheters into a selected blood vessel in the peripheral, coronary and neuro vascular systems.
#### Substantial Equivalence Comparison
Table 2 compares the substantial equivalence of the subject and predicate devices.
| Feature | Subject Device<br>MIVI Q Distal Access Catheter | Currently Marketed<br>Predicate Device<br>MIVI Q Distal Access<br>Catheter | | |
|-----------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|
| 510(k) Holder &<br>Manufacturer | MIVI Neuroscience, Inc. | | | |
| Table 2. Comparison with Currently Marketed Predicate | | | | |
| Feature | Subject Device<br>MIVI Q Distal Access Catheter | Currently Marketed<br>Predicate Device<br>MIVI Q Distal Access Catheter | | |
| 510(k)# | K192558 | K163233 | | |
| Classification<br>Information | Percutaneous catheter<br>21 CFR 870.1250 (Class II)<br>ProCode: QJP, DQY | | | |
| Indications / Intended Use | Indicated for use with compatible guide catheters in facilitating the<br>insertion and guidance of microcatheters into a selected blood vessel<br>in the peripheral, coronary and neuro vascular systems. | | | |
| Principle of Operation | Used to endovascularly insert and guide microcatheters under<br>fluoroscopy during diagnostic and/or therapeutic procedures for<br>patients with arterial disease or damage. | | | |
| Design Information | | | | |
| Configuration | Distal | Single-lumen, variable stiffness, braided (5F & 6F) / coiled (3F & 4F) | | |
| | Proximal | Control (push) wire through a guide catheter luer fitting | | |
| | Tip | Straight | | |
| | Radiopaque<br>Markers | Two (2) - Distal and Proximal | | |
| | Catheter<br>Coating | Hydrophilic | | |
| | Catheter Sizes | 3F, 4F, 5F, 6F | | |
| Total Length<br>(cm) | 3F | 148 | 163 | |
| | 4F | 135 | 150 | |
| | 5F | 130 | 145 | |
| | 6F | 130 | 145 | |
| Extensible Length | | Range | Fixed | |
| Extensible<br>Length (cm)<br>with:<br>90cm Guide | 3F | 40-42 | 42 | |
| | 4F | 27-29 | 29 | |
| | 5F | 22-24 | 24 | |
| | 6F | 22-24 | 24 | |
| Table 2. Comparison with Currently Marketed Predicate | | | | |
| Feature | | | Subject Device<br>MIVI Q Distal Access Catheter | Currently Marketed<br>Predicate Device<br>MIVI Q Distal Access<br>Catheter |
| | 95cm Guide | 3F | 35-37 | 42 |
| | | 4F | 22-24 | 29 |
| | | 5F | 17-19 | 24 |
| | | 6F | 17-19 | 24 |
| Control Wire Length | | | 104 cm | 119 cm |
| | Pin Vise Shape | | Looped shape<br>(Pin vise not removable) | Straight shape<br>(Pin vise can be removed) |
| | Guidewire<br>Compatibility<br>(cm) | 3F | 0.018" | |
| | | 4F | 0.035" | |
| | | 5F | | |
| | | 6F | | |
| Catheter Biomaterials | | | Patient contacting materials are identical between the subject and<br>currently marketed predicate. | |
| Accessories / Packaging / Sterilization / Shelf Life / Labeling | | | | |
| | Provided Accessories | | | None |
| Required Accessories<br>(not provided) | | | 8F guide catheter / 6F guide sheath<br>with rotating hemostasis valve with Y adapter and stopcock. | 8F guide catheter / 6F<br>guide sheath<br>Y adapter with rotating<br>hemostasis valve (lengths<br>between 6-8 cm) |
| Package Configuration | | | Catheter inserted in a plastic tube, mounted on an insert card, and<br>sealed in a pouch. Sealed pouch packaged in carton along with<br>Instructions for Use. | |
| Sterile & Non-<br>pyrogenic? | | | Yes | |
| Sterilization Method | | | Ethylene Oxide (EO) | |
| Shelf Life | | | 3 years | |
| Labeling | | | Proposed IFU | Current IFU |
{4}------------------------------------------------
Page | 2
{5}------------------------------------------------
{6}------------------------------------------------
### Non-Clinical Performance Testing
#### Bench Testing
| Table 3. Design Verification Testing | | |
|--------------------------------------|-------------------------------------------------------------------|---------|
| Test | Test Method | Results |
| Dimensional Verification | Ensure device meets dimensional requirements. | Pass |
| Corrosion Resistance | Any exposed metallic components must not show signs of corrosion. | Pass |
| Tensile Strength – Pin Vise | Ensure adequate device tensile strength. | Pass |
| System Compatibility / Simulated Use | Simulated use testing with “worst case” dimensional stack up. | Pass |
Based on the test results, the Q catheter with the described wire modification is considered verified to perform to its design specifications.
#### Biocompatibility
The MIVI Q Distal Access Catheter patient contacting materials are the same materials used in the currently marketed predicate MIVI Q Catheter K163233 with an identical biocontact. There is no change to colorants between the subject and predicate devices.
#### Sterilization
The MIVI Q Distal Access Catheter packaging configuration and packaged device density are the same for the predicate K163233 and subject device. No additional testing or validation is required for the subject device to be adopted into the existing sterilization cycles.
#### Shelf Life and Expiration Dating
The modified Q catheter will be labeled with an expiration date of 3 years from the date of sterilization, which is the same as the predicate K163233. The change to the length and distal feature of the control (push) wire does not introduce any new materials and does not impact the shelf life of the product.
#### Substantial Equivalence Summary and Conclusion
The modified MIVI Q Distal Access Catheter has identical indications, principle of operation, and a similar design to the currently marketed MIVI Q catheter predicate device. Based on the predicate comparison, risk assessment, and device testing results, the modified MIVI Q catheter has been shown to be appropriate for its intended use and is therefore considered substantially equivalent to the predicate device. The modified Q catheter raises no new questions of safety or effectiveness compared to the predicate device and is therefore substantially equivalent.
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.