The CT Compatible / MR Unsafe HDR Kobold Ring and Tandem Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus is accepted by up-to-date clinical guidelines. The Kobold Ring and Tandem Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
Device Story
The Kobold Ring and Tandem Applicator Set is a medical device used to deliver high dose rate (HDR) radiation to the cervix and uterus. It consists of intrauterine rings, ring caps, and tandems that interlock via a ring bracket. The device features a click-fit connector interface compatible with GammaMed and VariSource afterloaders. It is used in a clinical setting by radiation oncologists or medical physicists to provide a radiation boost to the cervix and parametrical tissues in conjunction with external beam radiation therapy. The device is designed for continuous patient contact for up to 24 hours. It is CT compatible but MR unsafe. The healthcare provider uses the applicator to position the radiation source precisely within the anatomy, facilitating targeted treatment that benefits the patient by maximizing radiation delivery to the tumor while minimizing exposure to surrounding healthy tissues.
Clinical Evidence
Bench testing only. No clinical data provided. Substantial equivalence is supported by comparison of physical characteristics, biocompatibility documentation, and adherence to established manufacturing standards for brachytherapy devices.
Technological Characteristics
Materials: Titanium, Ultem, Stainless Steel, Silicone, High Temperature Vinyl. Design: Ring/Tandem applicator with click-fit connector. Geometry: Defined (30, 45, 60-degree rings; 20mm and 60mm tandems; 5.0mm and 7.0mm caps). Compatibility: CT compatible, MR unsafe. Sterilization: Steam (18 min at 273°F/134°C, 44psi).
Indications for Use
Indicated for patients requiring high dose rate (HDR) radiation treatment of the cervix and uterus. Contraindications follow standard clinical guidelines and practice.
Regulatory Classification
Identification
A remote controlled radionuclide applicator system is an electromechanical or pneumatic device intended to enable an operator to apply, by remote control, a radionuclide source into the body or to the surface of the body for radiation therapy. This generic type of device may include patient and equipment supports, component parts, treatment planning computer programs, and accessories.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 9, 2015
Kobold, LLC % Ms. Kathy Arpin Regulatory Specialist 23403 E. Mission Avenue, Suite 220E LIBERTY LAKE WA 99019
Re: K142330
Trade/Device Name: Kobold Ring and Tandem Applicator Set Regulation Number: 21 CFR 892.5700 Regulation Name: Remote Controlled Radionuclide Applicator System Regulatory Class: II Product Code: JAO Dated: March 27, 2015 Received: April 1, 2015
Dear Ms. Arpin:
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 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.
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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/Resourcesfor You/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/Safety/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/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Michael D'Hara
for
Robert Ochs, Ph.D. Acting Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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#### Indications for Use
510(k) Number (if known) K142330
Device Name Kobold Ring and Tandem Applicator Set
#### Indications for Use (Describe)
The CT Compatible / MR Unsafe HDR Kobold Ring and Tandem Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus is accepted by up-to-date clinical guidelines.
The Kobold Ring and Tandem Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
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)
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# 510(k) Summary
This summary of 510(k) safety and effectiveness information is furnished in accordance with requirements detailed in 21 CFR 807.92.
1. The assigned 510(k) number is K142330
Submitter's Identification:
Kobold, LLC 23403 E. Mission Ave., Suite 220E Liberty Lake, WA 99019
Correspondence:
Kathy Arpin Kobold, LLC 23403 E. Mission Ave., Suite 220E Liberty Lake, WA 99019 Tel: 509-703-5090 Email: kathy.arpin@koboldmedical.com
Date of submission: August 14, 2014
2. Device name
Kobold Ring Type Applicator Set Proprietary name: Kobold Ring and Tandem Applicator Set™
- Regulation Section: 892.5700 A.
- B. Classification: Class II
- ﻥ Product Code: JAQ
- Panel: Radiology D.
#### 3. Intended Use
The CT Compatible / MR Unsafe HDR Kobold Ring and Tandem Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus is accepted by up-to-date clinical guidelines.
The Kobold Ring and Tandem Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
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#### 4.
#### Device Description
The CT Compatible / MR Unsafe HDR Kobold Ring and Tandem Applicator Set™ design is based on the modified conventional Ring/Tandem applicator with a click fit connector interface. This applicator is particularly useful in providing an HDR radiation boost to the cervix and parametrical tissues in conjunction with external beam radiation therapy. The applicator consists of precision manufactured intrauterine rings, ring caps, and tandems, interlocking via a ring bracket. All components are designed for a defined geometry. The rings are provided in three different angles (30 degrees, 45 degrees, and 60 degrees) with three different tandem lengths (20 mm, and 60 mm from the ring axis) provided for each ring angle. Two ring caps are provided (5.0 mm and 7.0 mm).
## న్.
## Substantial Equivalence Information
Information presented supports substantial equivalence of the CT Compatible / MR Unsafe HDR Kobold Ring and Tandem Applicator Set™ to the predicate device. The proposed device has similar indications for use, similar nature of body contact, is similar in shape and design, has the same fundamental technology and uses the same sterilization procedures. Please see predicate device brochures in Appendix C.
- Predicate device name: Kobold Fletcher Type Applicator Set; Kobold Henschke A. Type Applicator Set
- Predicate device K number: 123912 B.
- ட் Comparison with predicate:
| SUBSTANTIAL<br>EQUIVALENCE<br>TABLE | KOBOLD, LLC | KOBOLD, LLC |
|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| K-Number | K-142330 | K-123912 |
| Device Description | Applicator Set, Ring Type | Applicator Set, Henschke Type;<br>Applicator Set, Fletcher Type |
| Indications for Use | The CT Compatible / MR Unsafe<br>HDR Kobold Ring and Tandem<br>Applicator Set is indicated for use<br>in any case where high dose rate<br>(HDR) radiation treatment of the<br>cervix and uterus is accepted by<br>up-to-date clinical guidelines.<br>The Kobold Ring and Tandem<br>Applicator Set is intended for<br>continuous use of up to 24 hours of<br>contact with patient. | The CT/MRI Compatible HDR<br>Henschke Type Applicator and<br>Fletcher Type Applicator are<br>indicated for use in any case where<br>high dose rate (HDR) radiation<br>treatment of the cervix and uterus<br>is accepted by up-to-date clinical<br>guidelines. |
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| Afterloader Compatibility | GammaMed®, VariSource® with<br>click-fit connector | GammaMed®, VariSource® with<br>click-fit connector |
|----------------------------------------------------|-----------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------|
| Design Geometry | Defined | Flexible |
| Materials | Titanium, Ultem®, Stainless Steel,<br>Silicone, High Temperature Vinyl | Titanium, Ultem®, Stainless Steel,<br>Silicone, High Temperature Vinyl |
| Packing | Tray | Tray |
| Sterility | Provided Non-Sterile | Provided Non-Sterile |
| Sterilization Methods,<br>Sterilization Conditions | Steam 18 min at 273°F (134°C),<br>44psi (3 bar) Dry 15 min; no<br>Sterrad® compatibility documented | Steam 18 min at 273°F (134°C),<br>44psi (3 bar) Dry 15 min; no<br>Sterrad® compatibility documented |
| Biocompatibility | Documented | Documented |
| Anatomical Sites | Uterus, Cervix | Uterus, Cervix |
| Environmental<br>Compatibility | CT Compatible/MR Unsafe | CT/MRI Compatible |
## 6.
Test Principle, Performance Characteristics
The FDA has not established special controls or performance standards for this device.
# 7.
Bench Testing
Extensive testing in accordance with known standards is documented by the manufacturer for predicate device K123912. The standard is a specification for the materials used in surgical implant applications and predicate brachytherapy devices and for manufacturer's acceptance procedures for predicate device as provided in Appendix A.
## 8.
#### Conclusions
The Kobold Ring Type Applicator Set is similar in intended use and technological characteristics to predicate device reviewed. The device is similar with respect to indications for use and physical characteristics to predicate device in terms of section 510(k) substantial equivalency.
Contraindications: As per clinical guidelines and standard clinical practice.
Warnings and Precautions: The precautions and warnings are provided in the device labeling for the Kobold Ring and Tandem Applicator Set™.
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## 9.
Summary
| Description | Comparison with Predicate Device |
|-----------------------------|----------------------------------|
| Biocompatibility | Safe as Predicate Device |
| Performance Characteristics | Substantially equivalent |
| Intended Use | Substantially equivalent |
| Performance Tests | Not Required |
Based on the information submitted in this 510(k) application, the Kobold Ring and Tandem Applicator Set™ has been demonstrated to be substantially equivalent to the predicate device.
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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.
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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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.
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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.