Phenom™ Catheters are intended for the introduction of interventional devices or diagnostic agents into the neuro, peripheral, and coronary vasculatures.
Device Story
Phenom Catheters are variable stiffness, single-lumen catheters designed for accessing small, tortuous vasculature. The device is used by physicians to introduce interventional devices or diagnostic agents into neuro, peripheral, and coronary vasculatures. The catheter features a hydrophilic-coated outer surface to enhance navigation and an inner PTFE liner to facilitate the movement of introduction devices. Radiopaque markers at the distal tip allow for visualization and positioning under fluoroscopy. The device is tracked coaxially over a steerable guidewire. It is provided with a shaping mandrel and may include a split introducer sheath. The catheter is sterilized via ethylene oxide. By providing a stable pathway, the device enables the delivery of therapeutic or diagnostic tools, potentially benefiting patients undergoing neurointerventional or vascular procedures.
Clinical Evidence
No clinical data. Bench testing only. Testing included compatibility with guide catheters/wires/RHV, coating lubricity, hub functional/dimensional requirements (ISO 80369-7/20), torque strength, tensile strength (ISO 10555-1), air aspiration, liquid leak, and particulate testing (USP 788). Biocompatibility testing confirmed the device is non-cytotoxic, non-sensitizing, non-irritant, non-toxic, non-pyrogenic, and hemocompatible.
Technological Characteristics
Variable stiffness, single-lumen catheter. Materials: PTFE liner, Pebax shaft, stainless steel reinforcement. Hydrophilic coating on distal segment. Radiopaque tip markers. Dimensions vary by model (17, 21, 27, Plus). Sterilization: Ethylene Oxide. Connectivity: None (mechanical device).
Indications for Use
Indicated for the introduction of interventional devices or diagnostic agents into the neuro, peripheral, and coronary vasculatures. Prescription use only.
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.
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February 25, 2021
Micro Therapeutics, Inc. d/b/a ev3 Neurovascular Prerana Gurubasavaraj Regulatory Affairs Specialist 9775 Toledo Way Irvine, California 92618
Re: K210230
Trade/Device Name: Phenom Catheters Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: DQY, KRA, QJP Dated: January 27, 2021 Received: January 28, 2021
Dear Prerana Gurubasavaraj:
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.
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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 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 (OS) 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.
Naira Muradyan, Ph.D. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K210230
Device Name Phenom™ Catheters
Indications for Use (Describe)
Phenom™ Catheters are intended for the introduction of interventional devices or diagnostic agents into the neuro, peripheral, and coronary vasculatures.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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## K210230
## 510(k) Summary
| 510(k) Owner: | Micro Therapeutics, Inc. d/b/a ev3 Neurovascular<br>9775 Toledo Way<br>Irvine, CA 92618<br>Establishment Registration: 2029214 |
|----------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Prerana Gurubasavaraj<br>Specialist, Regulatory Affairs<br>Telephone: (949) 297-5804<br>Email: prerana.gurubasavaraj@medtronic.com |
| Date Summary<br>Prepared: | February 24, 2021 |
| Trade Name of<br>Device: | Phenom™ Catheters |
| Device Classification<br>Name: | Catheter, Percutaneous |
| Regulation Medical<br>Specialty: | Cardiovascular |
| 510(k) Review Panel: | Cardiovascular |
| Classification Product<br>Code: | DQY |
| Subsequent Product<br>Code: | KRA, QJP |
| Regulation Number: | 870.1250<br>870.1210 |
| Regulation<br>Description: | Percutaneous catheter<br>Continuous flush catheter |
| Device Classification: | Class II |
| Predicate Device: | Phenom™ 17 Catheter, Phenom™ 21 Catheter, Phenom™ 27<br>Catheter, Phenom™ Plus Catheter<br>510(k): K151638<br>Phenom™ 27 Catheter<br>510(k): K180959 |
| Reference Device: | React™ 68 Catheter<br>510(k): K180715<br>Navien™ Intracranial Support Catheter |
# Device Description:
The Phenom™ Catheters are variable stiffness, single lumen catheters designed to access small, tortuous vasculature. They are available in a variety of lengths, stiffness and inner and outer diameters. The outer surface of the catheter is coated to enhance navigation in the vessel. The Phenom™ 17, 21, and 27 Catheters have a hydrophilic coating that spans the distal 100cm. The Phenom™ Plus Catheters have a hydrophilic coating that spans the distal 90cm. The catheter also incorporates a liner to facilitate movement of introduction devices passing through its lumen. The distal tip has radiopaque marker(s) to aid visualization and positioning under fluoroscopy. The Phenom™ Catheter is packaged with a shaping mandrel and may be accompanied with a split introducer sheath.
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# Indication for Use Statement:
Phenom™ Catheters are intended for the introduction of interventional devices or diagnostic agents into the neuro, peripheral, and coronary vasculatures.
| | Legally Marketed Predicate Devices<br>(K151638 & K180959) | | | | Phenom™<br>Catheters |
|--------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------|-------------------------|---------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indication for Use<br>Statement | The Phenom™ Catheters are intended for the introduction of<br>interventional devices and infusion of diagnostic or therapeutic<br>agents into the neuro, peripheral, and coronary vasculatures. | | | | Phenom™<br>Catheters are<br>intended for the<br>introduction of<br>interventional<br>devices or<br>diagnostic<br>agents into the<br>neuro,<br>peripheral, and<br>coronary<br>vasculatures. |
| Dimensions | Phenom™ 17<br>(K151638) | Phenom™ 21<br>(K151638) | Phenom™ 27<br>(K180959) | Phenom™ Plus<br>(K151638) | |
| Proximal/Distal<br>Outer Diameter<br>(OD) | 2.2 F / 1.8 F | 2.6 F / 2.3 F | 3.1 F / 2.8 F | 4.7 F / 4.2 F | Same |
| Internal<br>Diameter (ID) | 0.017" | 0.021" | 0.027" | 0.0445" | Same |
| Min. Guiding<br>Catheter ID | ≥ 0.035" | ≥ 0.038" | ≥ 0.0445" | ≥ 0.070 | Same |
| Max. Guidewire<br>OD | ≤ 0.014" | ≤ 0.018" | ≤ 0.025" | ≤ 0.041 | Same |
| Effective Length<br>(cm) | 75 - 170 | 75 - 170 | 75 - 160 | 75 - 150 | Phenom 17:<br>150<br>Phenom 21:<br>150, 160<br>Phenom 27:<br>150, 160<br>Phenom Plus:<br>120 |
| Distal segment<br>length (cm) | 6 - 20 | 6 - 20 | 6 - 20 | 6 - 20 | Same |
| Inner Lumen | Inner lumen lined with lubricious PTFE to facilitate movement of<br>guidewires and other devices. | | | | Same |
| No. of lumens | Single lumen | | | | Same |
| Shaft | Progressively softer from proximal end to distal tip | | | | Same |
| Method of<br>delivery/tracking | Coaxial tracking over steerable guidewire | | | | Same |
| Shaft Materials | PTFE and Pebax | | | | Same |
| Shaft<br>reinforcement | Metallic (Stainless Steel) reinforced | | | | Same |
| Inner Liner | PTFE liner | | | | Same |
| Tip Markers | 1 or 2 | 1 or 2 | 1 | 1 | Same |
| Tip Shaping | Steam shapeable straight tip;<br>Pre-shaped 45°, 90° and J | | Steam shapeable tip | Steam shapeable tip | Same |
| Coating | Hydrophilic coating | | | | |
| Packaging | | | | | |
| Pouch Material | PET/Tyvek | | | | NYLON/Tyvek |
| Pouch Dimensions | 11" X 12" (Hoop configuration)<br>11" X 13.75" (Tray configuration) | | | | 13" X 10.94" |
| Carton | Cardboard, Solid Bleach Sulfate | | | | Same |
| Accessories | | | | | |
| Shaping Mandrel | | | Yes | | Same |
| Split Introducer<br>Sheath<br>(Phenom™ 17) | | | No | | Yes |
| Sterilization | | | | | |
| Method | Ethylene Oxide (EO) | | | | Same |
| Stability | | | | | |
| Shelf Life | | | 36 Months | | 12 Months |
# Device Comparison:
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## Performance Data – Bench:
The following non-clinical bench testing was performed to evaluate the performance of the Phenom™ Catheters. The passing results of the testing demonstrated that the changes do not raise new questions of safety and effectiveness, supporting the substantial equivalence to the predicate devices.
| Test | Test Method Summary | Results |
|---------------------------------------|--------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------|
| Performance | | |
| Compatibility – Guide Catheter | The Phenom™ Catheters were<br>evaluated for compatibility with<br>guide catheters in a simulated<br>tortuous path model. | The Phenom™ Catheters are<br>compatible for use with a guide<br>catheter. |
| Compatibility – Guide Wire | The Phenom™ Catheters were<br>evaluated for compatibility with<br>guide wires in a simulated<br>tortuous path model. | The Phenom™ Catheters are<br>compatible for use with a guide<br>wire. |
| Compatibility – RHV | The Phenom™ Catheters were<br>evaluated for compatibility with<br>a standard RHV. | The Phenom™ Catheters are<br>compatible with the standard<br>used RHV. |
| Coating Lubricity (Friction<br>Force) | The Phenom™ Catheters were<br>evaluated for coating lubricity<br>under simulated clinical<br>conditions. | The Phenom™ Catheters exhibit<br>acceptable friction force under<br>simulated clinical conditions. |
| Hub Functional & Dimensional | The Phenom™ Catheters were<br>evaluated per ISO 80369-<br>7:2016 and ISO 80369-20:<br>2015. | The Phenom™ Catheters met<br>the acceptance criteria for hub<br>functional & dimensional<br>requirements. |
| Torque Strength | The Phenom™ Catheters were<br>evaluated for torsional strength<br>integrity during use in a<br>simulated path model. | The Phenom™ Catheters exhibit<br>acceptable torsional strength<br>integrity. |
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| Test | Test Method Summary | Results |
|-------------------|-----------------------------------------------------------------------|----------------------------------------------------------------------------------------------------|
| Tensile | The Phenom™ Catheters were evaluated per ISO 10555-1:2013, Annex B. | The Phenom™ Catheters met the acceptance criteria for tensile strength. |
| Air Aspiration | The Phenom™ Catheters were evaluated per ISO 10555-1:2013 | The Phenom™ Catheters met the acceptance criteria for air aspiration. |
| Liquid Leak | The Phenom™ Catheters were evaluated per ISO 10555-1:2013 | The Phenom™ Catheters met the acceptance criteria for liquid leak. |
| Particulate | The Phenom™ Catheters were evaluated per USP <788>. | The Phenom™ Catheters met the acceptance criteria for particulate. |
| Design Validation | The Phenom™ Catheters were evaluated per ANSI/AAMI HE75:2009/(R) 2018 | The Phenom™ Catheters met the user needs and intended use(s) for which it was designed and tested. |
## Biocompatibility:
Biocompatibility was conducted for the Phenom™ Catheters. The Phenom™ Catheters are categorized as a limited exposure (< 24 hours), external communicating devices contacting circulating blood. The following biocompatibility endpoint testing was conducted for the Phenom™ Catheters:
| Test | Test Method Summary | Results |
|---------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|----------------|
| Cytotoxicity – MEM Elution | Cell culture treated with test sample exhibited slight reactivity (Grade 1). | Non-cytotoxic |
| Sensitization – Guinea Pig Maximization | Animals treated with test sample exhibited no dermal reactions (Grade 0). | Non-sensitizer |
| Irritation – Intracutaneous Study in Rabbits | Animals treated with test sample exhibited no dermal reactions (Score 0.0). | Non-irritant |
| Acute Systemic Toxicity –<br>Systemic Toxicity Study in Mice | Animals treated with test sample exhibited no mortality or evidence of systemic toxicity. | Non-toxic |
| Material Mediated Pyrogenicity –<br>USP Rabbit Pyrogen Study | Individual animals treated with test sample exhibited no temperature rise above 0.5°C. | Non-pyrogenic |
| Hemocompatibility – Platelet<br>and Leukocyte Counts | Blood treated with the test sample exhibited platelet and leukocyte counts within the average normalized values and control values. | Non-activator |
| Hemocompatibility – Partial<br>Thromboplastin Time | Blood treated with the test article exhibited clotting time within the control values. | Non-activator |
| Hemocompatibility – Hemolysis<br>Direct Contact and Extract Methods | Blood treated with the test sample directly and indirectly exhibited no hemolysis and was within the control values. | Non-hemolytic |
| Hemocompatibility –<br>Complement Activation | Normal human serum treated with the test sample exhibited complement activation within the control values. | Non-activator |
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### Performance Data - Animal:
No animal testing was conducted. The differences in technological characteristics do not raise new questions of safety and effectiveness as demonstrated through non-clinical bench testing using wellestablished acceptable scientific methods.
### Performance Data - Clinical:
No clinical testing was conducted. The differences in technological characteristics do not raise new questions of safety and effectiveness as demonstrated through non-clinical bench testing using wellestablished acceptable scientific methods.
### Conclusion:
There is no change to the Intended Use for the Phenom™ Catheters in comparison to the legally marketed predicate device. In addition, the differences in technological characteristics do not raise new questions of safety and effectiveness as demonstrated through non-clinical bench testing using well-established acceptable scientific methods. The information provided in this submission supports a determination of substantial equivalence for the Phenom™ Catheters.
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.