← Product Code [MNH](/submissions/OR/subpart-d%E2%80%94prosthetic-devices/MNH) · K133575

# SPINEVISION LUMIS CANNULATED PEDICLE SCREW FIXATION SYSTEM, SPINEVISION U.L.I.S. PEDICLE SCREW FIXATION SYSTEM (K133575)

_Spinevision S.A. · MNH · Jun 30, 2014 · Orthopedic · SESE_

**Canonical URL:** https://fda.innolitics.com/submissions/OR/subpart-d%E2%80%94prosthetic-devices/MNH/K133575

## Device Facts

- **Applicant:** Spinevision S.A.
- **Product Code:** [MNH](/submissions/OR/subpart-d%E2%80%94prosthetic-devices/MNH.md)
- **Decision Date:** Jun 30, 2014
- **Decision:** SESE
- **Submission Type:** Traditional
- **Regulation:** 21 CFR 888.3070
- **Device Class:** Class 2
- **Review Panel:** Orthopedic
- **Attributes:** Therapeutic

## Intended Use

The U.L.I.S.™ and LUMIS™ systems are pedicle screw systems indicated for skeletally mature patients who: • have severe spondylolisthesis (Grades 3 and 4) at the L5-S1 vertebra; • receive fusions using autogenous bone graft only; • have the device fixed or attached to the lumbar and sacral spine (L3 to sacrum); and • have the device removed after the development of a solid fusion. In addition, the U.L.I.S.™ and LUMIS™ systems are pedicle screw systems intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine (T10-S1): • Degenerative spondylolisthesis with objective evidence of neurologic impairment • Fracture • Curvatures (i.e. scoliosis, kyphosis, and/or lordosis) • Spinal tumor • Failed previous fusion (pseudoarthrosis)

## Device Story

System consists of cannulated (LUMIS) and non-cannulated (U.L.I.S.) pedicle screws and spinal rods; used for rigid spinal fixation and stabilization. Components assembled into constructs tailored to patient anatomy; implanted by surgeons in clinical settings. Provides immobilization of spinal segments to facilitate bone fusion; intended for removal after solid fusion achieved. Benefits include correction of spinal deformities and stabilization of unstable segments. Device is non-sterile; requires surgical implantation.

## Clinical Evidence

No clinical data presented. Substantial equivalence supported by bench testing including static compression, static torsion, and dynamic compression per ASTM F1717-13, and transverse subassembly testing per ASTM F1798-13.

## Technological Characteristics

Materials: Titanium Ti-6Al-4V ELI (ASTM F136) and Cobalt Chromium alloy (ASTM F1537). Components: Cannulated/non-cannulated polyaxial and monobloc pedicle screws, spinal rods. Function: Rigid spinal stabilization. Non-sterile, surgical implant.

## Regulatory Identification

(1) Rigid pedicle screw systems are comprised of multiple components, made from a variety of materials that allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Such a spinal implant assembly consists of a combination of screws, longitudinal members (e.g., plates, rods including dual diameter rods, plate/rod combinations), transverse or cross connectors, and interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors).(2) Semi-rigid systems are defined as systems that contain one or more of the following features (including but not limited to): Non-uniform longitudinal elements, or features that allow more motion or flexibility compared to rigid systems.

## Special Controls

*Classification.* (1) Class II (special controls), when intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis). These pedicle screw spinal systems must comply with the following special controls:(i) Compliance with material standards;
(ii) Compliance with mechanical testing standards;
(iii) Compliance with biocompatibility standards; and
(iv) Labeling that contains these two statements in addition to other appropriate labeling information:
 “Warning: The safety and effectiveness of pedicle screw spinal systems have been established only for spinal conditions with significant mechanical instability or deformity requiring fusion with instrumentation. These conditions are significant mechanical instability or deformity of the thoracic, lumbar, and sacral spine secondary to severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra, degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis). The safety and effectiveness of these devices for any other conditions are unknown.”
“Precaution: The implantation of pedicle screw spinal systems should be performed only by experienced spinal surgeons with specific training in the use of this pedicle screw spinal system because this is a technically demanding procedure presenting a risk of serious injury to the patient.”
(2) Class II (special controls), when a rigid pedicle screw system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion in the treatment of degenerative disc disease and spondylolisthesis other than either severe spondylolisthesis (grades 3 and 4) at L5-S1 or degenerative spondylolisthesis with objective evidence of neurologic impairment. These pedicle screw systems must comply with the following special controls:
(i) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use.
(ii) Non-clinical performance testing must demonstrate the mechanical function and durability of the implant.
(iii) Device components must be demonstrated to be biocompatible.
(iv) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments.
(v) Labeling must include the following:
(A) A clear description of the technological features of the device including identification of device materials and the principles of device operation;
(B) Intended use and indications for use, including levels of fixation;
(C) Identification of magnetic resonance (MR) compatibility status;
(D) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user; and
(E) Detailed instructions of each surgical step, including device removal.
(3) Class II (special controls), when a semi-rigid system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion for any indication. In addition to complying with the special controls in paragraphs (b)(2)(i) through (v) of this section, these pedicle screw systems must comply with the following special controls:
(i) Demonstration that clinical performance characteristics of the device support the intended use of the product, including assessment of fusion compared to a clinically acceptable fusion rate.
(ii) Semi-rigid systems marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with the special controls in paragraphs (b)(2)(i) through (v) and paragraph (b)(3)(i) of this section.

## Predicate Devices

- LUMIS™ Pedicle Screw Fixation System ([K112607](/device/K112607.md)/[K130302](/device/K130302.md))
- U.L.I.S.™ Pedicle Screw Fixation System ([K112607](/device/K112607.md)/[K130302](/device/K130302.md))
- UNI-THREAD Spinal System ([K013301](/device/K013301.md))
- Scient'x Polyaxial LP ([K062912](/device/K062912.md))
- Xia Spinal System ([K050461](/device/K050461.md)/[K052761](/device/K052761.md)/[K060361](/device/K060361.md)/[K060748](/device/K060748.md)/[K071373](/device/K071373.md)/[K113666](/device/K113666.md))
- VIPER® System, VIPER®2 system ([K061520](/device/K061520.md)/[K111571](/device/K111571.md)/[K090648](/device/K090648.md)/[K102701](/device/K102701.md))
- EXPEDIUM® Spine System ([K041119](/device/K041119.md)/[K062174](/device/K062174.md)/[K090230](/device/K090230.md)/[K090799](/device/K090799.md))
- DePuy Spine - Moss Miami-titanium ([K955348](/device/K955348.md))
- Alphatec Zodiac ([K071890](/device/K071890.md))

## Submission Summary (Full Text)

> This content was OCRed from public FDA records by [Innolitics](https://innolitics.com). If you use, quote, summarize, crawl, or train on this content, cite Innolitics at https://innolitics.com.
>
> Innolitics is a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices, including [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/).

{0}------------------------------------------------

# JUN 3 0 2014

| Date                                           | June 27, 2014                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |
|------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter                                      | SpineVision, S.A.<br>Antony parc II<br>10 place du Général de Gaulle<br>CS70001<br>Antony Cedex 92184, France<br>Tel: +33 1 53 33 25 25<br>Fax : + 33 1 53 33 25 39                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| SpineVision Contact                            | Helene PLAS, QA&RA Manager<br>Tel: +33 1 53 33 25 25<br>Fax : + 33 1 53 33 25 39<br>corp.quality@spinevision.com                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |
| US Regulatory Contact                          | Mr. J.D. WEBB<br>Tel: +1 512-388-0199<br>Fax: +1 512-692-3699<br>ortho.medix@sbcglobal.net                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
| Trade Name                                     | SpineVision LUMIS™ Cannulated Pedicle Screw Fixation System<br>SpineVision U.L.I.S.™ Pedicle Screw Fixation System                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Common Name<br>Classification Name             | Pedicle Screw Spinal System                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
| Product code                                   | MNI, MNH, KWQ, KWP                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| CFR section                                    | 888.3070, 888.3050                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Legally marketed<br>predicate devices          | LUMIS™ Pedicle Screw Fixation System (K112607/K130302)<br>U.L.I.S.™ Pedicle Screw Fixation System (K112607/K130302)<br>UNI-THREAD Spinal System(K013301)<br>Scient'x Polyaxial LP (K062912)<br>Xia Spinal System (K050461/K052761/K060361/K060748/K071373/K113666)<br>VIPER® System, VIPER®2 system (K061520/K111571/K090648/K102701)<br>EXPEDIUM® Spine System (K041119/K062174/K090230/K090799)<br>DePuy Spine - Moss Miami-titanium (K955348)<br>Alphatec Zodiac (K071890)                                                                                                                                                                                                                                                                                               |
| Description                                    | The SpineVision® Universal Lumbar Intuitive System (U.L.I.S.™ System), and Lumbar Universal Minimally Invasive System (LUMIS™ System) are composed of cannulated (LUMIS™) and non-cannulated (U.L.I.S.™) pedicle screws and fixation rods Their components can be rigidly assembled in a variety of constructs, each corresponding to the needs and anatomy of a specific patient and are supplied non-sterile.<br>The purpose of this submission is to include design modification and new diameters and lengths of the LUMIS™ Cannulated Polyaxial Pedicle Screws and U.L.I.S.™ Polyaxial Pedicle Screws, creation of LUMIS™ Cannulated Monobloc Pedicle Screws and U.L.I.S.™ Monobloc Pedicle Screws, addition of CoCr Spinal Rods, and new lengths of UNI-Thread® rods. |
| Material                                       | Titanium Ti-6Al-4V ELI per ASTM F136 (ISO 5832-3)<br>Cobalt Chromium (CoCr) alloy per ASTM F1537                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |
|                                                | When used for anterior screw fixation or as a posterior, non-pedicle system of the non-cervical spine, the U.L.I.S.™ and LUMIS™ systems are indicated for:<br>• Degenerative disc disease (discogenic back pain with degeneration of the disc confirmed by history and radiographic studies)<br>• Spondylolisthesis<br>• Fracture<br>• Spinal stenosis<br>• Curvatures (i.e. scoliosis, kyphosis, and/or lordosis)<br>• Tumors<br>• Failed previous fusion (pseudoarthrosis)                                                                                                                                                                                                                                                                                                |
| Intended use                                   | The U.L.I.S.™ and LUMIS™ systems are pedicle screw systems indicated for skeletally mature patients who:<br>• have severe spondylolisthesis (Grades 3 and 4) at the L5-S1 vertebra;<br>• receive fusions using autogenous bone graft only;<br>• have the device fixed or attached to the lumbar and sacral spine (L3 to sacrum); and<br>• have the device removed after the development of a solid fusion.<br>In addition, the U.L.I.S.™ and LUMIS™ systems are pedicle screw systems intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to                                                                                                                                                                |
|                                                | fusion in the treatment of the following acute and chronic<br>instabilities or deformities of the thoracic, lumbar, and sacral spine<br>(T10-S1):                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |
|                                                | • Degenerative spondylolisthesis with objective evidence of<br>neurologic impairment                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
|                                                | • Fracture                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
|                                                | • Curvatures (i.e. scoliosis, kyphosis, and/or lordosis)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |
|                                                | • Spinal tumor                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |
|                                                | • Failed previous fusion (pseudoarthrosis)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
| Summary of<br>Technological<br>Characteristics | The SpineVision Universal Lumbar Intuitive System<br>(U.L.I.S.TMSystem), and Lumbar Universal Minimally Invasive<br>System (LUMISTM System) instrumentations are manufactured in<br>Titanium Ti-6Al-4V ELI complying with ASTM F136 and CoCr<br>complying with ASTM F1537. The LUMISTM Pedicle screw system is<br>cannulated. The devices provide correction and rigid stabilization<br>of the spine during development of solid bone fusion following<br>corrective spine surgery for a number of indications (listed above).                                                                                                                                                                                                                                              |
|                                                | The SpineVision® Universal Lumbar Intuitive System (U.L.I.S.TM<br>System), and Lumbar Universal Minimally Invasive System<br>(LUMISTM System) conform to special control established for<br>Pedicle Screw Spinal System and to "Spinal System 510(k)s -<br>Guidance for Industry and FDA Staff Document" issued on May 3,<br>2004.                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Performance data                               | Mechanical testing was conducted per ASTM F1717-13 "Standard<br>Test Methods for Spinal Implant Constructs in Vertebrectomy<br>Model" and ASTM F1798-13 "Standard Test Method for Evaluating<br>the Static and Fatigue Properties of Interconnection Mechanisms<br>and Subassemblies Used in Spinal Arthrodesis Implants. Testing<br>according to ASTM F1717-13 includes Static Compression, Static<br>Torsion and Dynamic Compression. ASTM F1798-13 testing was<br>Transverse Test Apparatus for Subassembly. Results demonstrate<br>comparable mechanical properties to the predicate devices.<br>No clinical data has been presented.                                                                                                                                   |
| Substantial equivalence                        | SpineVision Universal Lumbar Intuitive System (U.L.I.S.TM<br>System), and Lumbar Universal Minimally Invasive System<br>(LUMISTM System) are substantially equivalent to their predicate<br>devices in terms of intended use, material, design, mechanical<br>properties and function.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
| Conclusion                                     | Engineering analysis and design validation/verification were used<br>to support substantial equivalence. SpineVision Universal Lumbar<br>Intuitive System (U.L.I.S.™ System), and Lumbar Universal<br>Minimally Invasive System (LUMIS™ System) are equivalent to                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |
|                                                | the predicate devices.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |

# 510(k) SUMMARY

{1}------------------------------------------------

.

{2}------------------------------------------------

. ・

:

:

.

: :

:

.

{3}------------------------------------------------

.

:

:

.

.

and the comments of the comments of

. . . . . .

{4}------------------------------------------------

Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle with three stripes forming its body and wings. The eagle is facing right. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the eagle.

### DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

June 30, 2014

Spine Vision, S.A., % Mr. J.D. Webb The OrthoMedix Group, Incorporated 1001 Oakwood Boulevard Round Rock. Texas 78681

Re: KI33575

Trade/Device Name: SpineVision U.L.I.S.TM Pedicle Screw Fixation System and LUMIS™ Cannulated Pedicle Screw Fixation System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class II Product Code: MNH, MNH, KWP, KWQ Dated: June 10, 2014 Received: June 13, 2014

Dear Mr. Webb:

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. 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 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

{5}------------------------------------------------

Page 2 - Mr. J.D. Webb

forth in the quality systems (QS) regulation (21 CFR Part 820): and if applicable, the clectronic product radiation control provisions (Sections 531-542 of the Act): 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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

http://www.fda.gov/MedicalDevices/Safetv/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely vours,

# Ronald P. Jean -S for

Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{6}------------------------------------------------

### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

# Indications for Use

#### 510(k) Number (if known) K133575

#### Device Name

SpineVision U.L.I.S.TM Pedicle Screw Fixation System and LUMIS™ Cannulated Pedicie Screw Fixation System

Indications for Use (Describe)

When used for anterior screw fixation or as a posterior, non-pedicle system of the U.L.I.S.™ and LUMISTM systems are indicated for:

· degenerative disc disease (discogenic back pain with degeneration of the disc confirmed by history and radiographic studies)

- · spondylolisthesis
- · fracture
- · spinal stenosis
- · curvatures (i.e. scoliosis, kyphosis, and/or lordosis)
- tumors
- · failed previous fusion (pseudoarthrosis)

The U.L.I.S.™ and LUMIS™ systems are pedicle screw systems indicated for skeletally mature patients who:

- · have severe spondylolisthesis (Grades 3 and 4) at the L5-S1 vertebra;
- · receive fusions using autogenous bone graft only;
- · have the device fixed or attached to the lumbar and sacral spine (L3 to sacrum); and
- · have the device removed after the development of a solid fusion.

In addition, the U.L.I.S.™ and LUMIS™ systems are pedicle screw systems intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine (T10-S1):

- · degenerative spondylolisthesis with objective evidence of neurologic impairment
- · fracture
- · curvatures (i.e. scoliosis, kyphosis, and/or lordosis)
- · spinal tumor
- · failed previous fusion (pseudoarthrosis)

Type of Use (Select one or both, as applicable)

2 Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

### PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

# FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

{7}------------------------------------------------

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."

---

**Source:** [https://fda.innolitics.com/submissions/OR/subpart-d%E2%80%94prosthetic-devices/MNH/K133575](https://fda.innolitics.com/submissions/OR/subpart-d%E2%80%94prosthetic-devices/MNH/K133575)

**Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices. If you're preparing [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/), [get in touch](https://innolitics.com/contact).

**Cite:** Innolitics at https://innolitics.com
