Hypnos (369054-200)

K250851 · Cadwell Industries, Inc. · OLZ · Dec 14, 2025 · Neurology

Device Facts

Record IDK250851
Device NameHypnos (369054-200)
ApplicantCadwell Industries, Inc.
Product CodeOLZ · Neurology
Decision DateDec 14, 2025
DecisionSESE
Submission TypeTraditional
Regulation21 CFR 882.1400
Device ClassClass 2
AttributesSoftware as a Medical Device, Pediatric

Intended Use

Cadwell Hypnos is a software application used for Polysomnography (PSG) and other clinical sleep studies. It is intended for use by research and clinical sleep professionals. It measures, records, displays, organizes, analyzes, summarizes, and retrieves physiological signals during sleep and wake used to assist in the assessment of sleep and the diagnosis of various sleep disorders including sleep related breathing disorders. The software can be used for analysis (computer-assisted as well as manual scoring of events), display, retrieval, summarization, reporting and networking of data received from devices used to monitor sleep related parameters. Hypnos is indicated for use in all sleep disorders patient populations from neonate to adult, including infants, pediatrics and geriatric populations. Computer-assisted analysis features of the application are only intended for use on adults. Hypnos is only indicated for use by trained medical professionals for the purpose of assessing sleep disorders. Intended environments include hospitals, institutions, sleep centers, sleep clinics, and other sleep disorders testing environments. Hypnos is NOT intended to be used to perform automatic diagnosis.

Device Story

Hypnos is a software application for polysomnography (PSG) and sleep studies; it acquires, records, displays, analyzes, and reports physiological signals (e.g., EEG, ECG, EMG, EOG, respiratory effort, airflow, oximetry). Used in hospitals, sleep centers, and clinics by trained medical professionals. The software facilitates manual scoring and provides computer-assisted event detection (e.g., apneas, hypopneas, limb movements, sleep staging) based on AASM standards. Clinicians review, verify, and modify all computer-generated annotations. The device does not perform automatic diagnosis; it serves as an aid for clinicians to assess sleep quality and diagnose sleep-related breathing disorders. Benefits include streamlined data organization, standardized event marking, and efficient report generation, supporting clinical decision-making for patient treatment.

Clinical Evidence

Performance testing compared Hypnos computer-assisted scoring against EnsoSleep (reference) using 42,972 epochs from 36,088 scored events. Results showed >80% agreement across all clinical event types. Key metrics: Apnea (96.7% overall), Obstructive Apnea (96.0%), Central Apnea (98.1%), Hypopnea (89.3%), Desaturation (97.3%), Heart Rate (99.8%), and Limb Movements (87.4%). No complications or contraindications were identified.

Technological Characteristics

Software-only device for PSG data management. Features include FFT analysis, signal processing, and event detection algorithms. Operates on standard PC hardware via keyboard/mouse input. Complies with IEC 62304 (software lifecycle), ISO 14971 (risk management), and IEC 62366-1 (usability). Supports AASM scoring standards. Connectivity includes networking for data retrieval and reporting.

Indications for Use

Indicated for all sleep disorders patient populations from neonate to adult (infants, pediatrics, geriatric) for manual review. Computer-assisted analysis features indicated for adult patients only. Intended for use by trained medical professionals in clinical/research environments to assist in sleep disorder assessment.

Regulatory Classification

Identification

An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.

Predicate Devices

Reference Devices

Related Devices

Submission Summary (Full Text)

{0} FDA U.S. FOOD & DRUG ADMINISTRATION December 14, 2025 Cadwell Industries, Inc James Blevins Product Manager, Sleep Diagnostics 909 N Kellogg St Kennewick, Washington 99336 Re: K250851 Trade/Device Name: Hypnos (369054-200) Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: Class II Product Code: OLZ, OLV Dated: November 14, 2025 Received: November 14, 2025 Dear James Blevins: 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. 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. {1} K250851 - James Blevins Page 2 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 (QS) 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 (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-reporting-combination-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. All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system. 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-devices/medical-device-safety/medical-device-reporting-mdr-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/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 {2} K250851 - James Blevins Page 3 the DICE website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/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, Patrick Antkowiak -S for Jay Gupta 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 {3} DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Indications for Use Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below. Submission Number (if known) K250851 Device Name Hypnos (369054-200) Indications for Use (Describe) Cadwell Hypnos is a software application used for Polysomnography (PSG) and other clinical sleep studies. It is intended for use by research and clinical sleep professionals. It measures, records, displays, organizes, analyzes, summarizes, and retrieves physiological signals during sleep and wake used to assist in the assessment of sleep and the diagnosis of various sleep disorders including sleep related breathing disorders. The software can be used for analysis (computer-assisted as well as manual scoring of events), display, retrieval, summarization, reporting and networking of data received from devices used to monitor sleep related parameters. Hypnos is indicated for use in all sleep disorders patient populations from neonate to adult, including infants, pediatrics and geriatric populations. Computer-assisted analysis features of the application are only intended for use on adults. Hypnos is only indicated for use by trained medical professionals for the purpose of assessing sleep disorders. Intended environments include hospitals, institutions, sleep centers, sleep clinics, and other sleep disorders testing environments. Hypnos is NOT intended to be used to perform automatic diagnosis. Type of Use (Select one or both, as applicable) ☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C) ## 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.” {4} # CADWELL Hypnos 510(k) Summary ## Submitter Information Submitter Name: Cadwell Industries, Inc. 909 N. Kellogg Street Kennewick, Washington 99336 Submitter Phone: 509-735-6481 Contact Person: James Blevins Product Manager, Sleep Diagnostics Date Summary Prepared: February 28, 2025 ## Subject Device Trade Name: Hypnos Common Name: Standard Polysomnograph with Electroencephalograph Classification Name: 21 CFR 882.1400, Electroencephalograph Class II Product Code: OLZ, OLV ## Predicate Device 510(k) Number: K142988 Trade Name: Sleepware G3 Submitter Name: Respironics Classification Name: 21 CFR 882.1400, Electroencephalograph Product Code: OLZ, MNR, OLV ## Reference Predicate Device 510(k) Number: K210034 Trade Name: EnsoSleep Submitter Name: EnsoData, Inc. Classification Name: 21 CFR 882.1400, Electroencephalograph Product Code: OLZ ## Device Description Hypnos software is used to acquire, record, transmit, analyze, store, manage, report, and display physiological and environmental data collected by PSG and/or HSAT hardware. Hypnos software allows users to analyze signals both manually and using detectors to facilitate interpretation of a sleep study by a qualified user. {5} CADWELL® Hypnos 510(k) Summary # Indications for Use Cadwell Hypnos is a software application used for Polysomnography (PSG) and other clinical sleep studies. It is intended for use by research and clinical sleep professionals. It measures, records, displays, organizes, analyzes, summarizes, and retrieves physiological signals during sleep and wake used to assist in the assessment of sleep and the diagnosis of various sleep disorders including sleep related breathing disorders. The software can be used for analysis (computer-assisted as well as manual scoring of events), display, retrieval, summarization, reporting and networking of data received from devices used to monitor sleep related parameters. Hypnos is indicated for use in all sleep disorders patient populations from neonate to adult, including infants, pediatrics and geriatric populations. Computer-assisted analysis features of the application are only intended for use on adults. Hypnos is only indicated for use by trained medical professionals for the purpose of assessing sleep disorders. Intended environments include hospitals, institutions, sleep centers, sleep clinics, and other sleep disorders testing environments. Hypnos is NOT intended to be used to perform automatic diagnosis. {6} # CADWELL Hypnos 510(k) Summary # Summary of Technological Characteristics and Comparison to the predicate device Hypnos has equivalent technological characteristics to the predicate device. The following table provides a side-by-side comparison of the Indications for Use and technological characteristics of the subject and predicate devices. | Characteristics | Subject Device Hypnos | Primary Predicate Device Sleepware G3 (K142988) | Reference Predicate EnsoSleep (K210034) | Discussion of Major Differences | | --- | --- | --- | --- | --- | | Device Class | Class II | Class II | Class II | No differences | | Class Name | Electroencephalograph | Electroencephalograph | Electroencephalograph | No differences | | Product Code | OLZ (Primary) = Automatic Event Detection Software for Polysomnograph with Electroencephalograph OLV = Standard polysomnograph with electroencephalograph | OLZ (Primary) = Automatic Event Detection Software for Polysomnograph with Electroencephalograph MNR = Ventilatory Effort Recorder OLV = Standard polysomnograph with electroencephalograph | OLZ (Primary) = Automatic Event Detection Software for Polysomnograph with Electroencephalograph | No differences. MNR does not apply to the subject device since it is software only. | | Environment of Use | Sleep center (independent or hospital) | Sleep center (independent or hospital) | Sleep center (independent or hospital) | No differences | | Intended User | Medical Professional | Medical Professional | Medical Professional | No differences | | Target Patient Population | Neonate to adult, including infants, pediatrics and geriatric populations for manual review functions. Adult only for automatic event detection. | Infant or adult patients. | Pediatric and adult patients | No differences | | Type of Use | Prescription use only | Prescription use only | Prescription use only | No differences | {7} # CADWELL Hypnos 510(k) Summary | Characteristics | Subject Device Hypnos | Primary Predicate Device Sleepware G3 (K142988) | Reference Predicate EnsoSleep (K210034) | Discussion of Major Differences | | --- | --- | --- | --- | --- | | Indications for Use | Cadwell Hypnos is a software application used for Polysomnography (PSG) and other clinical sleep studies. It is intended for use by research and clinical sleep professionals. It measures, records, displays, organizes, analyzes, summarizes, and retrieves physiological signals during sleep and wake used to assist in the assessment of sleep and the diagnosis of various sleep disorders including sleep related breathing disorders. The software can be used for analysis (computer-assisted as well as manual scoring of events), display, retrieval, summarization, reporting and networking of data received from devices used to monitor sleep related parameters. Hypnos is indicated for use in all sleep disorders patient populations from neonate to adult, including infants, pediatrics and geriatric populations. Computer-assisted analysis features of the application are only intended for use | Sleepware G3 is a software application used for analysis (automatic and manual scoring), display, retrieval, summarization, report generation and networking of data received from monitoring devices used to categorize sleep related events that help aid in the diagnosis of sleep related disorders. It is indicated for use with infant or adult patients in a clinical environment by or on the order of a physician. The optional Somnolyzer Inside scoring package has the same intended use as Sleepware G3, but is indicated for use with adult patients only. | EnsoSleep is intended for use in the diagnostic evaluation by a physician to assess sleep quality and as an aid for physicians in the diagnosis of sleep disorders and respiratory related sleep disorders in pediatric and adult patients as follows: • Pediatric patients 13 years and older with polysomnography (PSG) tests obtained in a Hospital or Sleep Clinic • Adult patients with PSGs obtained in a Hospital or Sleep Clinic • Adult patients with Home Sleep Tests EnsoSleep is a software-only medical device to be used under the supervision of a clinician to analyze physiological signals and automatically score sleep study results, including the staging of sleep, detection of arousals, leg movements, and sleep disordered breathing events including obstructive apneas (OSA), central sleep apneas (CSA), and hypopneas. | No difference to the primary predicate. Hypnos was specifically designed to enable clinical users to record, review and manually annotate PSG studies on neonate, infant, pediatric and adult patient populations. The software includes controls that are defaulted to industry standards for all age populations and are adjustable based on the discretion of the clinician. The computer-assisted marking feature in Hypnos is only indicated for use in Adult patients. | {8} # CADWELL Hypnos 510(k) Summary | Characteristics | Subject Device Hypnos | Primary Predicate Device Sleepware G3 (K142988) | Reference Predicate EnsoSleep (K210034) | Discussion of Major Differences | | --- | --- | --- | --- | --- | | | on adults. Hypnos is only indicated for use by trained medical professionals for the purpose of assessing sleep disorders. Intended environments include hospitals, institutions, sleep centers, sleep clinics, and other sleep disorders testing environments. Hypnos is NOT intended to be used to perform automatic diagnosis. | | All automatically scored events and physiological signals which are retrieved, analyzed, displayed, and summarized are subject to verification by a qualified clinician. Central sleep apneas (CSA) should be manually reviewed and modified as appropriate by a clinician. All events can be manually marked or edited within records during review. Photoplethysmography (PPG) total sleep time is not intended for use when electroencephalograph (EEG) data is recorded. PPG total sleep time is not intended to be used as the sole or primary basis for diagnosing any sleep related breathing disorder, prescribing treatment, or determining whether additional diagnostic assessment is warranted. | | | User input | Mouse/keyboard | Mouse/keyboard | Mouse/keyboard | No differences | | Acquire, display, store, and archive PSG data | Yes | Yes | Yes | No differences | | Data Collection | By separate acquisition hardware | By separate acquisition hardware | By separate acquisition hardware | No differences | | FFT Analysis | Yes | Yes | Yes | No differences | {9} # CADWELL Hypnos 510(k) Summary | Characteristics | Subject Device Hypnos | Primary Predicate Device Sleepware G3 (K142988) | Reference Predicate EnsoSleep (K210034) | Discussion of Major Differences | | --- | --- | --- | --- | --- | | Software Detectors | | | | | | Respiratory event marking | Yes | Yes | Yes | No differences | | Sleep staging/ scoring | Yes | Yes | Yes | No differences | | Arousal event marking | Yes | Yes | Yes | No differences | | Limb Movements event marking | Yes | Yes | Yes | No differences | | Snore event marking | Yes | Yes | Yes | No differences | | Oxygen Desaturation event marking | Yes | Yes | Yes | No differences | | Heart Rate data trend & summary (including Heart Rate Variability) | Yes | Yes | Yes | No differences | | CO2 data trend & summary | Yes | Yes | Yes | No differences | | Associate related events | Yes | Yes | Yes | No differences | | Derived respiratory traces | Yes | Yes | Yes | No differences | | Synchronized patient video | Yes | Yes | Yes | No differences | | Oximetry data display and reporting | Yes | Yes | Yes | No differences | | Audio/ Visual Alerts On Calibrated Channels | Yes | Yes | Yes | No differences | | Signals recorded (output) | Respiratory Effort (abdomen and chest) Airflow Pressure Snore Body Position Pulse Rate Oximeter ECG EEG EMG EOG DC | Respiratory Effort (abdomen and chest) Airflow Pressure Snore Body Position Pulse Rate Oximeter ECG EEG EMG EOG DC | Respiratory Effort (abdomen and chest) Airflow Pressure Snore Body Position Pulse Rate Oximeter ECG EEG EMG EOG DC | No differences | {10} | Characteristics | Subject Device Hypnos | Primary Predicate Device Sleepware G3 (K142988) | Reference Predicate EnsoSleep (K210034) | Discussion of Major Differences | | --- | --- | --- | --- | --- | | | Leg Movement Other signals for sleep studies | Leg Movement Other signals for sleep studies | Leg Movement Other signals for sleep studies Actigraphy PPG Esophogeal Manometry | | | Report generation including counts indexes, max/min/average/duration, range based data summaries. Numeric & graphical representations | Yes, customizable templates | Yes, customizable templates | Yes, customizable templates | No differences | | Standard of Scoring | The American Academy of Sleep Medicine (AASM) Manual for the Scoring of Sleep and Associated Events | The American Academy of Sleep Medicine (AASM) Manual for the Scoring of Sleep and Associated Events | The American Academy of Sleep Medicine (AASM) Manual for the Scoring of Sleep and Associated Events | No differences | {11} CADWELL Hypnos 510(k) Summary # Summary of Non-clinical Testing FDA-recognized standards were applied throughout the design process of Hypnos. All verification, validation, and usability testing has been performed per the design requirements. Passing results support the intended use of Hypnos and ensures adequate safety, effectiveness and reliability. Software testing was conducted in accordance with IEC 62304:2015-06. Risk Management activities were conducted per ISO 14971:2019. Usability testing is in accordance with IEC 62366-1:2020-06 Information to be provided to the User is in accordance with ISO 20417:2021-04 Corrected version 2021-12 The features of Hypnos have been compared with the predicate in order to demonstrate substantial equivalence. Specifically, both software applications have equivalent primary functions, including the following: opening and selecting existing sleep studies; displaying and navigating sleep study data/signals; manually scoring/annotating sleep study data by adding events/markers; facilitating the use of AASM standards; creating trend/summary overviews and interpretation reports; interfacing to analysis tools, and saving/storing scored recordings. Both applications visualize signals and events in equivalent ways, allow equivalent edits of scored events, and provide equivalent basic scoring and physician information via overviews and indexes. # Summary of Clinical Testing ## Methodology Our data included analysis of 42,972 recorded epochs, of which 36,088 were scored. These studies were chosen at random from existing sleep studies of acceptable signal quality from accredited labs where analysis had been performed by EnsoSleep (K210034) and had not been edited by human scorers. Studies were chosen at random from sleep labs independent of Cadwell. The studies were copied with annotations from the EnsoSleep analysis extracted. Annotations were then stripped from the studies and Hypnos analyzers were run using default settings based on recommendations from the AASM and then events were compared between the two analysis sets. ## Results The results of the performance testing indicate that the computer-assisted scoring in the Hypnos subject device performs equivalently to the reference predicate device, with general event annotation above 80% across all valid clinical event types. There were no complications or contraindications found during the study. Individual performance metrics for each detector can be found in the tables below along with the Confidence Interval at 95% (95% CI): | Respiratory Events | Median | Overall | Over Detection | 95% CI | | --- | --- | --- | --- | --- | | Apnea | 98.1% | 96.7% | 3.0% | ±1.06 [95.64%, 97.76%] | | Obstructive Apnea | 98.1% | 96.0% | 4.3% | ±1.52 [94.78%, 97.52%] | | Central Apnea | 99.4% | 98.1% | 0.6% | ±1.16 [96.94%, 99.26%] | | Hypopnea | 89.1% | 89.3% | 10.1% | ±1.82 [94.48%, 97.52%] | | Respiratory Events | 88.6% | 88.6% | 10.8% | ±1.76 [86.84%, 90.36%] | {12} + CADWELL Hypnos 510(k) Summary | Desaturation | Median | Overall | Over Detection | 95% CI | | --- | --- | --- | --- | --- | | Desaturation | 97.9% | 97.3% | 2.7% | ±0.61 [96.69%,97.91%] | | Heart Rate | Median | Overall | Over Detection | 95% CI | | --- | --- | --- | --- | --- | | Heart Rate | 100.0% | 99.8% | 0.1% | ±0.15 [99.65%,99.95%] | | Limb Movements | Median | Overall | Over Detection | 95% CI | | --- | --- | --- | --- | --- | | LM | 88.4% | 87.4% | 4.2% | ±2.83 [84.57%,90.23%] | | PLM | 93.4% | 91.3% | 1.8% | ±2.61 [88.69%,93.91%] | | PLMS Series | 99.1% | 98.9% | 0.5% | ±0.33 [98.57%,99.23%] | # Conclusion The Intended Use Comparison, the Technical Comparison, and Performance Testing Data results indicate that Hypnos presents no new questions of safety and effectiveness and is substantially equivalent to the legally marketed predicate devices.
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