K223266 · Thoracent, Inc. · ESW · Jan 16, 2024 · General, Plastic Surgery
Device Facts
Record ID
K223266
Device Name
Hilzo Esophageal Stents
Applicant
Thoracent, Inc.
Product Code
ESW · General, Plastic Surgery
Decision Date
Jan 16, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.3610
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The HILZO Esophageal Stents are indicated for use in esophageal strictures caused by intrinsic malignant tumors.
Device Story
HILZO Esophageal Stents are self-expanding tubular prostheses designed to maintain patency of esophageal strictures caused by malignant tumors. Available in partially and fully covered configurations, the stents are constructed from Nitinol wire. They are supplied pre-loaded on two types of delivery systems: Over the Wire (OTW, 14Fr/16Fr) and Through the Scope (TTS, 10.5Fr), allowing for deployment via endoscope working channels. The device features a flaring head design, with or without a removal lasso. Used by clinicians in a clinical setting, the stent is deployed to prevent migration caused by peristalsis or tumor in-growth. By providing mechanical support to the esophageal lumen, the device restores patency, potentially improving patient ability to swallow and reducing symptoms associated with malignant strictures.
Clinical Evidence
Bench testing only. No clinical data provided. Testing included biocompatibility (ISO 10993-1), shelf-life/sterilization validation, expansion/compression force, dimensional analysis, corrosion, kink resistance, tensile strength (delivery system and cover), deployment force/positioning, suture loop strength, radiopacity, and MR safety.
Technological Characteristics
Nitinol wire self-expanding stent; partially or fully covered with Silicone/PTFE. Available in 18-20 mm diameters and 60-150 mm lengths. Delivery systems: OTW (14Fr/16Fr) and TTS (10.5Fr). MR Conditional. Sterilized via Ethylene Oxide (EtO).
Indications for Use
Indicated for patients with esophageal strictures caused by intrinsic and/or extrinsic malignant tumors.
Regulatory Classification
Identification
An esophageal prosthesis is a rigid, flexible, or expandable tubular device made of a plastic, metal, or polymeric material that is intended to be implanted to restore the structure and/or function of the esophagus. The metal esophageal prosthesis may be uncovered or covered with a polymeric material. This device may also include a device delivery system.
Special Controls
The special control for this device is FDA's “Guidance for the Content of Premarket Notification Submissions for Esophageal and Tracheal Prostheses.”
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January 16, 2024
Thoracent, Inc. % Bosmat Friedman Regulatory Consultant ProMedoss, Inc. 3521 Hatwynn Rd. Charlotte, North Carolina 28269
Re: K223266
Trade/Device Name: Hilzo Esophageal Stents Regulation Number: 21 CFR 878.3610 Regulation Name: Esophageal Prosthesis Regulatory Class: Class II Product Code: ESW Dated: April 26, 2023 Received: April 26, 2023
Dear Bosmat Friedman:
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 (the 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 available 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.
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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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download). Your device is also subject to, among other requirements, the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
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For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-
devices/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,
# Sivakami Venkatachalam -S
for
Shanil P. Haugen, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital, and Urology 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) K223266
Device Name Hilzo Esophageal Stents
Indications for Use (Describe)
The HILZO Esophageal Stents are indicated for use in esophageal strictures caused by intrinsic malignant tumors.
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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K223266 Page 1 of 4
# 510(K) SUMMARY [as required by section 807.92(c)] HILZO Esophageal Stent 510(k) Number K223266
### 5.1 SUBMITTER
#### Applicant's Name:
Thoracent, Inc. Brian Lynch, CEO 11 Stewart Ave. Unit 1, Suite 200 Huntington, NY, USA 917-4396742 brian@thoracent.com
#### Contact Person:
Bosmat Friedman Regulatory Affairs Consultant 3521 Hatwynn Rd. Charlotte, NC 28269 Phone: 980-308-1636 bosmat.f(@promedoss.com
#### Date Revised:
December 14, 2023
#### 5.2 DEVICE
Trade Name: HILZO Esophageal Stents
| Classification Code: | Device: | Prosthesis, Esophageal |
|----------------------|--------------------|---------------------------|
| | Product Code: | ESW |
| | Regulation No: | 878.3610 |
| | Class: | 2 |
| | Medical Specialty: | General & Plastic Surgery |
| | Review Panel: | Gastroenterology/Urology |
#### 5.3 PREDICATE DEVICE
Primary Predicate:
- Niti-S Esophageal Stent System, manufactured by Taewoong Medical Co., . Ltd., cleared under K080782; Product Code: ESW
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Reference devices for
- . Esophageal TTS Stent, manufactured by Taewoong Medical Co., Ltd., cleared under K123205; Product Code: ESW.
- Bonastent Esophageal, manufactured by EndoChoice, Inc. cleared under . K092144: Product Code: ESW
## 5.4 DEVICE DESCRIPTION
The HILZO Esophageal Stents are partially covered and fully covered, self-expanding tubular prosthesis designed to maintain patency of esophageal strictures. The HILZO Esophageal stents are available loaded on two styles of delivery devices, Over the Wire (OTW) and Through the Scope (TTS). The OTW delivery devices are 14Fr and the TTS is 10.5Fr to enable delivery through the working channel of an endoscope. The stents are made of Nitinol wire and are designed to prevent stent migration due to peristaltic motion and tumor in-growth. The stents are available in a variety models, diameters and lengths.
# 5.5 INDICATIONS FOR USE
The HILZO Esophageal Stents are indicated for use in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors.
## 5.6 SUBSTANTIAL EQUIVALENCE
The subject and predicate devices are both single- use, partially covered and fully covered esophageal stents indicated for use in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors. The stent weave pattern, delivery devices as well as the available stent sizes are equivalent in design and performance.
| Feature | HILZO Esophageal Stent | Niti-S Esophageal (OTW) K080782 | Comparison to Predicate |
|----------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Reg. Number | 878.3610 | 878.3610 | Same |
| Product Code | ESW | ESW | Same |
| Indication for Use | The HILZO Esophageal Stents are indicated for use in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors | Niti-S Esophageal Stent is intended for use in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors. | Same |
| Principle of Operation | TTS and OTW models available | OTW | Same as both devices |
| Biocompatibility | Biocompatible per ISO 10993 | Biocompatible per ISO 10993 | Same |
| Single use | Yes | Yes | Same |
| Feature | HILZO Esophageal Stent | Niti-S Esophageal<br>(OTW)<br>K080782 | Comparison to Predicate |
| Sterility | Eto | Eto | Same |
| Stent material | Nitinol | Nitinol | Same |
| Covering<br>material | Silicone/PTFE | Silicone | Similar; biocompatibility testing<br>supports the safety and effectiveness<br>profile of the HILZO Esophageal Stent;<br>literature survey and material tensile<br>strength testing support the use of PTFE<br>cover material |
| Stent diameter<br>(mm) | 18-20 mm | 16 - 20 mm | Same; compression and expansion<br>testing support the stent diameter<br>difference |
| Stent total length<br>(mm) | 60-150 mm | 60-120 mm | Similar; compression and expansion<br>testing support the increased stent<br>length; FDA has cleared other<br>esophageal stents with a length of 150<br>such as K172813 and K211706 |
| Stent head | Silicone covered and uncovered<br>flaring stent head design<br>with/without removal string<br>(lasso) | Silicon covered and uncovered<br>flaring stent head design<br>with/without removal string<br>(lasso) | Similar flaring stent head design |
| Delivery<br>Diameter | OTW - 14 Fr, 16 Fr<br>TTS = 10.5 Fr | OTW - 16 Fr and 20 Fr | Similar; deployment testing and tensile<br>strength testing demonstrate delivery<br>device performance |
| MR Status | MR Conditional | MR Conditional | Same |
| Expansion force | Fully Covered:<br>18X60 - Avg. 0.442 kgf<br>18X150 - Avg. 0.443 kgf<br>20X60 - Avg. 0.520 kgf<br>20X150 - Avg. 0.460 kgf<br>Partial Covered:<br>18X60 - Avg. 0.445 kgf<br>18X150 - Avg. 0.446 kgf<br>20X60 - Avg. 0.528 kgf<br>20X150 - Avg.0.537 kgf | Fully Covered:<br>18X60 - Avg. 0.439 kgf<br>18X150 - Avg. 0.443 kgf<br>20X60 - Avg. 0.521 kgf<br>20X150 - Avg. 0.543 kgf<br>Partial Covered:<br>18X60 - Avg. 0.440 kgf<br>18X150 - Avg. 0.448 kgf<br>20X60 - Avg. 0.530 kgf<br>20X150 - Avg.0.542 kgf | Similar; all results fell within the ±5%<br>difference acceptance criteria. The<br>results support our SE claim |
| Compression<br>force | Fully Covered:<br>18X60 - Avg. 3.073 kgf<br>18X150-Avg. 3.189 kgf<br>20X60 - Avg. 3.75 kgf<br>20X150 - Avg. 3.844 kgf<br>Partial Covered:<br>18X60 - Avg. 3.097 kgf<br>18X150 - Avg. 3.176 kgf<br>20X60 - Avg. 3.876 kgf<br>20X150 - Avg.3.925 kgf | Fully Covered:<br>18X60 - Avg. 3.093 kgf<br>18X150-Avg. 3.168 kgf<br>20X60 - Avg. 3.786 kgf<br>20X150 - Avg. 3.889 kgf<br>Partial Covered:<br>18X60 - Avg. 3.141 kgf<br>18X150 - Avg. 3.220 kgf<br>20X60 - Avg. 3.875 kgf<br>20X150 - Avg.3.914 kgf | Similar; all results fell within the ±5%<br>difference acceptance criteria. The<br>results support our SE claim |
The following table provides a comparison with the predicate:
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Any differences in technological characteristics do not raise different questions of safety or effectiveness.
#### 5.7 PERFORMANCE DATA
The following performance data is provided in support of the substantial equivalence determination.
# Biocompatibility:
The stent and delivery system underwent extensive biocompatibility data in accordance with guidance document: Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". Per the obtained results, the HILZO Esophageal Stent System was found to be biocompatible.
# Non-Clinical Performance Testing:
The HILZO Esophageal Stents have undergone and successfully passed the following:
- Shelf-life and sterilization validation -
- Expansion force testing -
- Compression force testing -
- Dimensional testing -
- -Corrosion testing
- -Kink resistance testing
- -Tensile strength testing (delivery system)
- Tensile strength test (cover material) -
- Deployment force and deployment positioning testing -
- -Suture Loop Tensile Strength Testing
- Radiopacity testing -
- MR safety -
# 5.8 CONCLUSION
The HILZO Esophageal Stents have the same indications for use and technological characteristics as its predicates. Niti-S and Esophageal. The company has provided sufficient comparative testing between the HILZO Esophageal Stents and the predicates, as well as additional pre-clinical bench data to demonstrate our substantial equivalency claim. Consequently, it is clear that the HILZO Esophageal Stents are as safe and effective as their primary predicates without raising any new safety and/or effectiveness concerns.
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.