The MEMO 3D™ device is intended for correction of mitral insufficiencies or steno-insufficiences. The use of the MEMO 3D™ device is indicated for correction of congenital or acquired mitral insufficiencies with dilatation and deformation of the mitral annulus. Type I insufficiencies, with no manifest lesions in the subvalvular apparatus, can be treated with the device on its own. For type II insufficiencies, characterized by valve prolapse sustained by elongation/breakage of the chordae tendineae and papillary muscles, and type III insufficiencies, characterized by partially immobilized leaflets due to the fusion/hypertrophy of the chordae tendineae, the device implantation must be accompanied by corrective valvuloplasty.
Device Story
MEMO 3D™ Semirigid Annuloplasty Ring; surgical implant for mitral valve repair. Device consists of metallic inner core embedded in medical-grade silicone, encased in tubular knitted fabric coated with Carbofilm™ (turbostratic carbon). Supplied pre-mounted on disposable holder to maintain shape and assist in measured plications of mitral annulus during implantation. Available in 24mm-38mm sizes. Used by cardiac surgeons in OR to restore mitral valve function; device provides structural support to annulus. Benefits include correction of mitral insufficiency/steno-insufficiency; stabilization of annulus geometry. Implantation may require concurrent valvuloplasty for Type II or Type III insufficiencies.
Clinical Evidence
Bench testing only. No clinical data presented. Non-clinical testing included ultimate tensile strength, suture pull-out, rigidity determination, computational stress analysis, fatigue and durability testing, corrosion resistance, biocompatibility, sterilization validation, pyrogenicity, and shelf-life.
Indicated for patients with congenital or acquired mitral insufficiency or steno-insufficiency involving mitral annulus dilatation and deformation. Contraindicated in patients with severe organic lesions with chordae tendineae retraction, congenital malformations with limited valvular tissue, extensive valve leaflet calcification, or evolving bacterial endocarditis.
Regulatory Classification
Identification
An annuloplasty ring is a rigid or flexible ring implanted around the mitral or tricuspid heart valve for reconstructive treatment of valvular insufficiency.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Guidance for Annuloplasty Rings 510(k) Submissions.”
Predicate Devices
Baxter Healthcare Corporation Carpentier-Edwards Physio Annuloplasty Ring (K926138)
Carbomedics AnnuloFlex™ Annuloplasty System (K023185)
Submission Summary (Full Text)
{0}------------------------------------------------
K07/327
| 510(k) Summarv of Safety and Effectiveness | |
|--------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | |
| Submitter | Sorin Biomedica Cardio S.r.l.<br>I-13040 Saluggia (VC) Italy<br>Via Crescentino<br>+39.0161.4871 [voice] |
| Contact | Heather Crawford, RAC<br>Regulatory Affairs Project Manager<br>CarboMedics, Inc.<br>1300 East Anderson Lane<br>Austin, Texas 78752<br>512.435.3266 [voice] |
| | 512.435.3350 [facsimile]<br>heather.crawford@sorin.com [email] |
| Date | May 10, 2007 |
| Device | Trade Name: MEMO 3D™ Semirigid Annuloplasty Ring 21 CFR 870.3800: Annuloplasty Ring Product Code: KRH - Class II - Special Controls Medical Specialty: Cardiovascular |
| Predicate<br>Devices | K926138: Baxter Healthcare Corporation Carpentier-Edwards Physio Annuloplasty Ring K970375 and K021051: Carbomedics AnnuloFlo™ System K023185: Carbomedics AnnuloFlex™ Annuloplasty System |
AUG 1 0 2007
Continued on next page
v - Page 1 of 3
MEMO 3D and Carbofilm are trademarks of Sorin Biomedica Cardio.
Carpentier-Edwards and Carpentier-Edwards Physio are registered trademarks of Edwards Lifesciences.
{1}------------------------------------------------
## 510(k) Summary of Safety and Effectiveness, Continued
| <b>Indications<br/>for Use</b> | The MEMO 3D™ device is intended for correction of mitral insufficiencies<br>or steno-insufficiences. <p>The use of the MEMO 3D™ device is indicated for correction of congenital or acquired mitral insufficiencies with dilatation and deformation of the mitral annulus. Type I insufficiencies, with no manifest lesions in the subvalvular apparatus, can be treated with the device on its own. For type II insufficiencies, characterized by valve prolapse sustained by elongation/breakage of the chordae tendineae and papillary muscles, and type III insufficiencies, characterized by partially immobilized leaflets due to the fusion/hypertrophy of the chordae tendineae, the device implantation must be accompanied by corrective valvuloplasty.</p> |
|--------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <b>Contra-<br/>indications</b> | The annuloplasty rings should not be used in the case of: <ul><li>Severe organic lesions with retraction of chordae tendinae</li><li>Congenital malformations with limited valvular tissue</li><li>Extensive calcification of valve leaflets</li><li>Evolving bacterial endocarditis</li></ul> |
| <b>Device<br/>Description</b> | The MEMO 3D™ Semirigid Annuloplasty Ring is supplied as a sterile, non- pyrogenic, non-ferromagnetic ring pre-mounted on a disposable holder. The annuloplasty ring is manufactured by embedding a metallic inner core with medical grade silicone. The resulting silicone sheath, around the metallic core, is then encased within a tubular knitted fabric coated with Carbofilm™, which is a thin layer of turbostratic carbon. The fabric is then sewn along its length with Carbofilm™ coated polyester thread. <p>The annuloplasty ring is attached to the disposable holder to maintain the shape of the ring during implantation and allow for measured plications of the mitral annulus. Suture guides are present on the holder to aid the surgeon during ring placement.</p> <p>The MEMO 3D™ annuloplasty ring is available in sizes 24mm through 38mm in two millimeter increments. A complete set of accessory instrumentation is to be available separately to properly size the annulus and implant the annuloplasty ring.</p> |
| | <i>Continued on next page</i> |
| | K071327 |
v - Page 2 of 3
MEMO 3D and Carbofilm are trademarks of Sorin Biomedica Cardio. Carpentier-Edwards and Carpentier-Edwards Physio are registered trademarks of Edwards Lifesciences.
{2}------------------------------------------------
## 510(k) Summary of Safety and Effectiveness, Continued
The MEMO 3D™ Semirigid Annuloplasty Ring is considered to be Technological Characteristics substantially equivalent in technological characteristics and intended use to the predicate devices. Equivalency is supported by multiple characteristics, including:
- Intended use 。一
- Anatomical site for implantation -
- Product labeling -
- Physical characteristics -
- Target population -
- Performance testing -
- Safety characteristics -
Non-Clinical Testing demonstrated that the MEMO 3D™ Semirigid Annuloplasty Ring is Testing substantially equivalent to the predicate devices for repair of the mitral valve. Non-clinical testing included: ultimate tensile strength, suture pull-out, rigidity determination, computational stress analysis, fatigue and durability testing, corrosion resistance, biocompatibility, sterilization validation, pyrogenicity, and shelf-life.
- Conclusion The MEMO 3D™ Semirigid Annuloplasty Ring has been demonstrated as safe and effective for its intended use. With respect to intended use and technological characteristics, the MEMO 3DTM Semirigid Annuloplasty Ring is substantially equivalent to the legally marketed predicate devices.
071327
v - Page 3 of 3
MEMO 3D and Carbofilm are trademarks of Sorin Biomedica Cardio. Carpentier-Edwards and Carpentier-Edwards Physio are registered trademarks of Edwards Lifesciences.
{3}------------------------------------------------
Public Health Service
Image /page/3/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features the department's name arranged in a circular fashion around a symbol. The symbol is a stylized depiction of an eagle or bird-like figure, with three curved lines representing its wings or body.
AUG 1 0 2007
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Sorin Biomedica Cardio S.R.L. C/O Heather Crawford, RAC Project Manager, Regulatory Affairs Carbomedics, Inc. 1300 East Anderson Lane Austin, TX 78752-1793
Re: K071327
Trade/Device Name: MEMO 3D™ Semirigid Annuloplasty Ring Regulation Number: 21 CFR 870.3800 Regulation Name: Annuloplasty Ring Regulatory Class: Class II Product Code: KRH Dated: May 10, 2007 Received: May 11, 2007
Dear Ms Crawford:
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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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
{4}------------------------------------------------
## Page 2 - Ms. Crawford
comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance. please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Blyminmar for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{5}------------------------------------------------
## Indications for Use
510(k) Number (if known):
07/327
Device Name: MEMO 3D™ Semirigid Annuloplasty Ring
Indications for Use:
MEMO 3D™ device is intended for correction of mitral insufficiencies or stenoinsufficiencies.
The use of the MEMO 3D™ device is indicated for correction of congenital or acquired mitral insufficiencies with dilatation and deformation of the mitral annulus. Type I insufficiencies, with no manifest lesions in the subvalvular apparatus, can be treated with the device on its own. For type II insufficiencies, characterized by valve prolapse sustained by elongation/breakage of the chordae tendineae and papillary muscles, and type III insufficiencies, characterized by partially immobilized leaflets due to the fusion/hypertrophy of the chordae tendineae. the device implantation must be accompanied by corrective valvuloplasty.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use_ (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
B. Hemmerm
Division Sign-Off Division of Cardlovascular Devices 510(k) Number
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Learn the FDA Browser
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.