K210839 · Soundbite Medical Solutions, Inc. · PDU · Apr 20, 2021 · Cardiovascular
Device Facts
Record ID
K210839
Device Name
SoundBite Crossing System - Peripheral (14P)
Applicant
Soundbite Medical Solutions, Inc.
Product Code
PDU · Cardiovascular
Decision Date
Apr 20, 2021
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.1250
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The SoundBite® Crossing System - Peripheral (14P) is indicated to facilitate the intraluminal placement of conventional guidewires or treatment devices beyond peripheral artery chronic total occlusions. The SoundBite® Crossing System - Peripheral (14P) is not intended for use in the carotid arteries.
Device Story
The SoundBite Crossing System - Peripheral (14P) is a recanalization tool used by physicians in clinical settings to cross peripheral artery chronic total occlusions (CTOs). The system consists of a reusable mobile console and a single-use sterile titanium alloy active wire (0.014" diameter). The console generates controlled mechanical pulses (shock waves) transmitted along the wire, causing the distal tip to accelerate axially in a reciprocating motion, functioning as a micro-jackhammer. This mechanical action facilitates the advancement of the wire through occlusions, allowing for the subsequent placement of conventional guidewires or treatment devices. The device benefits patients by enabling successful crossing of complex arterial blockages. Physicians operate the system via a footswitch, monitoring the procedure to guide the wire through the vasculature.
Clinical Evidence
Bench testing only. No clinical data. Verification and validation included visual/dimensional inspection, simulated use, coating integrity, tip pull, flexibility, fracture resistance, torque/tensile strength, corrosion resistance, distal temperature, lubricity, and particulate testing. Console testing included output stability, life-cycle, and electrical/software verification per ANSI AAMI ES60601-1 and IEC 60601-1-2. Biocompatibility testing performed per GLP. Summative usability evaluation confirmed safe use without serious errors.
Technological Characteristics
System comprises a mobile AC-powered console and a 300 cm titanium alloy active wire (0.014" diameter). Wire features PTFE coating (excluding distal tip) and a radiopaque marker. Principle of operation is mechanical pulse-driven axial reciprocation. Sterilization via Ethylene Oxide. Software verified per IEC 62304. Electrical safety per ANSI AAMI ES60601-1 and electromagnetic compatibility per IEC 60601-1-2.
Indications for Use
Indicated for patients with peripheral artery chronic total occlusions to facilitate intraluminal placement of guidewires or treatment devices. Not for use in carotid arteries.
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.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square and the words "U.S. Food & Drug Administration".
April 20, 2021
Soundbite Medical Solutions, Inc. Dominique Abecassis Director, Compliance 2300 Boulevard Alfred-Nobel Montreal, Quebec H4S 2A4 Canada
Re: K210839
Trade/Device Name: SoundBite Crossing System - Peripheral (14P) Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous catheter Regulatory Class: Class II Product Code: PDU Dated: March 18, 2021 Received: March 22, 2021
#### Dear Dominique Abecassis:
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 mediation-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,
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
Enclosure
{2}------------------------------------------------
## Indications for Use
510(k) Number (if known) K210839
Device Name SoundBite® Crossing System - Peripheral (14P)
Indications for Use (Describe)
SoundBite® Crossing System - Peripheral (14P) is indicated to facilitate the intraluminal placement of conventional guidewires or treatment devices beyond peripheral artery chronic total occlusions.
SoundBite® Crossing System - Peripheral (14P) is not intended for use in the carotid arteries.
Type of Use (Select one or both, as applicable)
| <div> <span style="font-size:100%;">☒</span> Prescription Use (Part 21 CFR 801 Subpart D) </div> |
|--------------------------------------------------------------------------------------------------------------|
| <div> <span>☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </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}------------------------------------------------
#### K210839
Page 1 of 4
## 510(K) Summary
As required by 21 CFR 807.92
| Date Prepared: | 15 March 2021 |
|--------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitted by: | Soundbite Medical Solutions, Inc. |
| | 2300 Boulevard Alfred-Nobel,<br>Montreal, Quebec, Canada<br>H4S 2A4 |
| Contact: | Dominique Abecassis<br>Director, Compliance<br>Tel: (514) 956-2525 x 3352<br>Fax: (514) 956-2529<br>E-mail: dominique.abecassis@soundbitemedical.com |
| Trade/Device Name: | SoundBite® Crossing System – Peripheral (14P) |
| Common Name: | System for Crossing Total Occlusions |
| Regulation: | 21 CFR 870.1250, Percutaneous Catheter |
| Device Class: | Class II |
| Product Code: | PDU (Catheter for Crossing Total Occlusions) |
| Predicate Device: | SoundBite® Crossing System – Peripheral by Soundbite Medical<br>Solutions Inc. (K192211) |
### Device Description:
The SoundBite® Crossing System - Peripheral (14P) is a recanalization tool, designed to help physician's placement of conventional guidewires or treatment devices in the intraluminal space beyond chronic total occlusions in the peripheral vasculature. The SoundBite® Crossing System - Peripheral (14P) consists of the reusable mobile SoundBite® Console, a single-use sterile SoundBite® Active Wire 14P, and their respective accessories.
The SoundBite® Console generates controlled mechanical pulses (i.e., shock waves) which are transmitted to the SoundBite® Active Wire 14P and cause the distal tip of the wire to accelerate axially in a reciprocating motion, acting like a micro-jackhammer.
The SoundBite® Active Wire 14P is similar in construction to the 0.018" CTO crossing wire provided with the predicate device, with a friction reducing PTFE coating (except for the distal tip), a radiopaque marker near the tip, and enhanced flexibility at the distal end. It has an outer
{4}------------------------------------------------
diameter of 0.36 mm (0.014") and it is 300 cm long, with a working length of 145 cm. At the proximal end of the SoundBite® Active Wire 14P, a section reducer allows the wire to be connected to the SoundBite® Console. The single-use SoundBite® Active Wire 14P is supplied sterile with a shelf life of 24 months.
# Intended Use / Indications for Use:
The SoundBite® Crossing System - Peripheral (14P) is indicated to facilitate the intraluminal placement of conventional guidewires or treatment devices beyond peripheral artery chronic total occlusions.
The SoundBite® Crossing System - Peripheral (14P) is not intended for use in the carotid arteries.
## Substantial Equivalence Comparison:
The SoundBite® Crossing System - Peripheral (14P) is substantially equivalent to the predicate device, the SoundBite® Crossing System - Peripheral (K192211), in intended use and indications for use, fundamental technologies, principles of operation, and labeling. Non-clinical bench testing data, and performance data from animal studies have been submitted to demonstrate that the differences in device characteristics do not raise questions related to safety or performance. A side-by-side comparison of key device characteristics is presented in the following table:
| Device<br>Characteristic | Predicate Device 510(k) K192211<br>SoundBite® Crossing System – Peripheral | SoundBite® Crossing System –<br>Peripheral (14P) |
|-------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| System<br>Components | ■ AC-powered, mobile SoundBite®<br>Console generator and footswitch.<br>■ Single-use SoundBite® Active Wire 18 | ■ AC-powered, mobile SoundBite®<br>Console generator and footswitch.<br>■ Single-use SoundBite® Active Wire 14P |
| Mechanism of<br>Action | Mechanical pulses sent along the length of<br>the Titanium alloy SoundBite® Active Wire<br>cause the distal tip to accelerate axially in a<br>reciprocating (back-and-forth) motion,<br>acting like a micro-jackhammer. | Mechanical pulses sent along the length of<br>the Titanium alloy SoundBite® Active Wire<br>cause the distal tip to accelerate axially in a<br>reciprocating (back-and-forth) motion, acting<br>like a micro-jackhammer. |
| Console Setting:<br>Pulse Repetition<br>Rate (PRR) | 10 Hz | 20 Hz |
| Wire Connection | Titanium alloy section reducer for<br>connection to the SoundBite® Console | Titanium alloy section reducer for<br>connection to the SoundBite® Console |
| Maximum<br>Active Wire<br>Diameter<br>over Usable<br>Length | 0.46 mm (0.018") | 0.36 mm (0.014") |
| Working<br>Length | 150 cm | 145 cm |
| Radiopaque Marker | 10 mm radiopaque coil starting at 1.5 mm<br>from the distal tip | 10 mm radiopaque coil starting at 0.75 mm<br>from the distal tip |
{5}------------------------------------------------
| Device<br>Characteristic | Predicate Device 510(k) K192211<br>SoundBite® Crossing System – Peripheral | SoundBite® Crossing System –<br>Peripheral (14P) |
|--------------------------|----------------------------------------------------------------------------|-------------------------------------------------------------------------|
| Wire Shaft Diameter | 0.46 mm (0.018") | 0.36 mm (0.014") |
| Wire Tip Diameter | 0.29 mm (0.0115") | 0.27 mm (0.0105") |
| Wire Material | Titanium alloy | Titanium alloy |
| Wire Coating | PTFE coating on main body of the wire only;<br>no coating on distal end | PTFE coating on main body of the wire only;<br>no coating on distal end |
| Wire Sold Sterile | Yes | Yes |
| Sterilization Method | Ethylene Oxide | Ethylene Oxide |
| Shelf Life | 24 months | 24 months |
## Summary of Non-Clinical Testing:
Design verification and validation testing was conducted following systematic risk assessment in accordance with the FDA-recognized consensus standard ISO 14971 and FDA guidance.
Substantial equivalence of the device, both at the system and component levels (i.e., sterility assurance to the point of care, packaging integrity and shelf-life, biocompatibility, electrical/mechanical safety, and electromagnetic compatibility) has been verified and/or validated in accordance with current FDA-recognized consensus standards and regulatory requirements. The medical device software system has been designed, and verified in compliance with the FDA-recognized consensus standard IEC 62304.
SoundBite® Crossing System - Peripheral (14P) was assessed in the following areas:
- . Visual and dimensional inspection
- 트 Simulated use
- Coating integrity l
- Tip pull l
- l Flexibility resistance
- Fracture resistance l
- l Torque strength
- Tensile strength 트
- Corrosion resistance I
- l Torqueability
- Distal temperature i
- Tip flexibility .
- Catheter qualification l
- Lubricity assessment 트
- Particulate testing I
{6}------------------------------------------------
- 트 Shelf-life testing
SoundBite® Console was assessed in the following areas:
- 트 Console Output Stability
- Life-Cycle Testing 트
- Console and Shipping Container Labels Verification
- 트 Electronics and Software Verification
- 트 ANSI AAMI ES60601-1:2005/(R) 2012 and A1:2012
- IEC 60601-1-2 Edition 4.0 2014-02
Biocompatibility: A full panel of biocompatibility tests was successfully performed in accordance with product classification, under GLP, demonstrating that all utilized materials and methods of construction/processing passed biocompatibility requirements.
Usability: Representative users were included in a summative evaluation. The study confirms that the SoundBite® Crossing System - Peripheral (14P) can be used without serious use errors or problems, for the intended uses under the expected use conditions.
The results from bench testing indicate that the performance characteristics of the SoundBite® Crossing System - Peripheral (14P) are substantially equivalent to the predicate device and do not raise new questions of safety or performance.
### Conclusion:
The data submitted with this Special 510(k) premarket notification demonstrate that the SoundBite® Crossing System - Peripheral (14P) is substantially equivalent to the predicate device.
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.