Kobold Fletcher-model Tandem and Ovoid Applicator Set, Kobold Henschke-model Tandem and Ovoid Applicator Set, Kobold Vaginal Cylinder Applicator Set, Kobold Miami Cylinder Applicator Set
Kobold Fletcher-model Tandem and Ovoid Applicator Set, Kobold Henschke-model Tandem and Ovoid Applicator Set, Kobold Vaginal Cylinder Applicator Set, Kobold Miami Cylinder Applicator Set
Applicant
Kobold, LLC
Product Code
JAQ · Radiology
Decision Date
Feb 13, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.5700
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The CT Compatible / MR Unsafe HDR Kobold® Fletcher-model Tandem and Ovoid Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus with a Fletcher type applicator is accepted by up-to-date clinical guidelines. The Kobold® Fletcher-model Tandem and Ovoid Applicator Set is intended for continuous use of up to 24 hours of contact with patient. The CT Compatible / MR Unsafe HDR Kobold® Henschke-model Tandem and Ovoid Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus with a Henschke type applicator is accepted by up-to-date clinical guidelines. The Kobold® Henschke-model Tandem and Ovoid Applicator Set is intended for continuous use of up to 24 hours of contact with patient. The CT Compatible / MR Unsafe HDR Kobold® Vaginal Cylinder Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the vagina is accepted by up-to-date clinical guidelines. The Kobold® Vaginal Cylinder Applicator Set is intended for continuous use of up to 24 hours of contact with patient. The CT Compatible / MR Unsafe HDR Kobold® Miami Cylinder Applicator Set is indicated for use in any patient case where high dose rate (HDR) radiation treatment of the cervix, vagina, and uterus with a Miami type applicator is acceptable by up-to-date clinical guidelines. The Kobold® Miami Cylinder Set is intended for continuous use of up to 24 hours of contact with patient.
Device Story
Applicator sets for high dose rate (HDR) brachytherapy; used for radiation boosts to cervix, uterus, and vagina. Input: HDR radiation source delivered via afterloader. Operation: intrauterine tandems and vaginal colpostats/cylinders guide radiation source to target tissue; adjustable geometry (tandem curvature, ovoid distance) allows anatomical customization. Used in clinical settings by radiation oncologists/physicists. Output: localized radiation delivery to tumor/target tissue. Benefit: enables precise, customized radiation therapy for gynecological malignancies; facilitates treatment in cases with limited vaginal vault space or restricted anatomy.
Clinical Evidence
Bench testing only. No clinical data provided. Substantial equivalence supported by design comparison, biocompatibility documentation, and performance testing consistent with predicate devices.
Technological Characteristics
Materials: Titanium, Ultem®, Stainless Steel, Silicone, High Temperature Vinyl. Design: Intrauterine tandems and vaginal colpostats/cylinders. Energy: HDR radiation (via external afterloader). Connectivity: Mechanical interface (click-fit) for Elekta/Varian afterloaders. Sterilization: Steam (4 min at 270°F/132°C). Environmental: CT compatible, MR unsafe.
Indications for Use
Indicated for patients requiring high dose rate (HDR) radiation treatment of the cervix, uterus, or vagina, as accepted by clinical guidelines. Intended for continuous use up to 24 hours. Contraindications: per standard clinical 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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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines connecting them.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 13, 2017
Kobold, LLC % Ms. Christina Bernstein Engineer BB Medical Surgical 1736 Stockton Street, Studio 9 SAN FRANCISCO CA 94133
Re: K160610
Trade/Device Name: Kobold® Fletcher-model Tandem and Ovoid Applicator Set. Kobold® Henschke-model Tandem and Ovoid Applicator Set, Kobold® Vaginal Cylinder Applicator Set, Kobold® Miami Cylinder Applicator Set Regulation Number: 21 CFR 892.5700
Regulation Name: Remote controlled radionuclide applicator system Regulatory Class: II Product Code: JAQ Dated: January 17, 2017 Received: January 18, 2017
Dear Ms. Bernstein:
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
{1}------------------------------------------------
forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic 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/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. O'Hara
For
Robert Ochs, Ph.D. 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 Form
The complete Indications for Use form (FDA 3881) for the devices is reproduced here.
| DEPARTMENT OF HEALTH AND HUMAN SERVICES |
|-----------------------------------------|
| Food and Drug Administration |
| <b>Indications for Use</b> |
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known) K160610
Device Name
Kobold® Fletcher-model Tandem and Ovoid Applicator Set, Kobold® Henschke-model Tandem and Ovoid Applicator Set, Kobold® Vaginal Cylinder Applicator Set, Kobold® Miami Cylinder Applicator Set
#### Indications for Use (Describe)
The CT Compatible / MR Unsafe HDR Kobold® Fletcher-model Tandem and Ovoid Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus with a Fletcher type applicator is accepted by up-to-date clinical guidelines. The Kobold® Fletcher-model Tandem and Ovoid Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
The CT Compatible / MR Unsafe HDR Kobold® Henschke-model Tandem and Ovoid Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus with a Henschke type applicator is accepted by up-to-date clinical guidelines. The Kobold® Henschke-model Tandem and Ovoid Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
The CT Compatible / MR Unsafe HDR Kobold® Vagmal Cylinder Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the vagina is accepted by up-to-date clinical guidelines. The Kobold® Vaginal Cylinder Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
The CT Compatible / MR Unsafe HDR Kobold® Miami Cylinder Applicator Set is indicated for use in any patient case where high dose rate (HDR) radiation treatment of the cervix, vagina, and uterus with a Miami type applicator is acceptable by up-to-date clinical guidelines. The Kobold® Miami Cylinder 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)
#### 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.
FORM FDA 3881 (8/14)
Page 1 of 1
PSC Publishing Sarvices (301) 443-6740
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# 510(k) Summary
# Kobold® Fletcher-model Tandem and Ovoid Applicator Set, Kobold® Henschke-model Tandem and Ovoid Applicator Set, Kobold® Vaginal Cylinder Applicator Set, Kobold® Miami Cylinder Applicator Set
This summary of 510(k) safety and effectiveness information is furnished in accordance with requirements detailed in 21 CFR 807.92.
1. The assigned submission number is K-160610
Submitter's Identification:
Deanna Hughes Kobold, LLC PO Box 1994 Veradale, WA 99037
Correspondence:
Deanna Hughes Kobold, LLC PO Box 1994 Veradale, WA 99037 Tel: 818.321.0116 Email: Deanna.Hughes@koboldmedical.com
Date of submission: January 17, 2017
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## 2. Device names:
Fletcher Type Applicator Set Proprietary name: Kobold® Fletcher-model Tandem and Ovoid Applicator Set
Henschke Type Applicator Set Proprietary name: Kobold® Henschke-model Tandem and Ovoid Applicator Set
Vaginal Cylinder Set Proprietary name: Kobold® Vaginal Cylinder Applicator Set
Miami Cylinder Set Proprietary name: Kobold® Miami Cylinder Applicator Set
- Regulation Section 892.5700 A.
- B. Classification: Class II
- C. Product Code: JAO
- Panel: Radiology D.
## 3. Intended Use:
The CT Compatible / MR Unsafe HDR Kobold® Fletcher-model Tandem and Ovoid Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus with a Fletcher type applicator is accepted by up-todate clinical guidelines. The Kobold® Fletcher-model Tandem and Ovoid Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
The CT Compatible / MR Unsafe HDR Kobold® Henschke-model Tandem and Ovoid Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the cervix and uterus with a Henschke type applicator is accepted by up-todate clinical guidelines. The Kobold® Henschke-model Tandem and Ovoid Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
The CT Compatible / MR Unsafe HDR Kobold® Vaginal Cylinder Applicator Set is indicated for use in any case where high dose rate (HDR) radiation treatment of the vagina is accepted by up-to-date clinical guidelines. The Kobold® Vaginal Cylinder Applicator Set is intended for continuous use of up to 24 hours of contact with patient.
The CT Compatible / MR Unsafe HDR Kobold® Miami Cylinder Applicator Set is indicated for use in any patient case where high dose rate (HDR) radiation treatment of the cervix, vagina, and uterus with a Miami type applicator is acceptable by up-to-date clinical guidelines. The Kobold® Miami Cylinder 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® Fletcher-model Tandem and Ovoid Applicator Set design is based on the conventional modified Fletcher GYN applicator. Kobold manufactures versions compatible with HDR afterloaders. This applicator is mainly utilized for HDR radiation boosts to the cervix and parametrial tissues in conjunction with external beam radiation therapy. This GYN set consists of precision manufactured intrauterine tandems and a pair of interlocking vaginal colpostats with Fletcher type unshielded barrel or cylinder ovoids (all components are designed to allow for customization of the treated geometry). The distance between the two lateral ovoids is adjustable with a lock knob. Four differing tandem geometries are provided in the set: one straight, one with slight curvature, one with medium curvature, and one with maximal curvature. These allow for maximal accommodation of the uterine shape and flexure.
The CT Compatible / MR Unsafe HDR Kobold® Henschke-model Tandem and Ovoid Applicator Set design is based on the conventional modified Henschke GYN applicator. Kobold manufactures versions compatible with HDR afterloaders. This applicator is mainly utilized for HDR radiation boosts to the cervix and parametrial tissues in conjunction with external beam radiation therapy. This GYN set consists of precision manufactured intrauterine tandems and a pair of interlocking vaginal colpostats with Henschke type unshielded ovoids (all components are designed to allow for customization of the treated geometry). The distance between the ovoids is adjustable with a lock knob. Four differing tandem geometries are provided in the set: one straight, one with slight curvature, one with medium curvature, and one with maximal curvature. These allow for maximal accommodation of the uterine shape and flexure.
The CT Compatible / MR Unsafe HDR Kobold® Vaginal Cylinder Applicator Set design is based on conventional cylindrical HDR delivery systems with a connector interface compatible with major manufacturers' afterloaders. This applicator is particularly useful in providing an HDR radiation as definitive treatment, adjuvant treatment, or as a treatment boost to the vaginal walls with or without external beam radiation therapy. The set consists of precision manufactured vaginal cylinders of varied diameters for optimal radiation treatment delivery and anatomical customization.
The CT Compatible / MR Unsafe HDR Kobold® Miami Cylinder Applicator Set design is based on conventional modified Miami applicators with a connector interface compatible with major manufacturers' afterloaders. This applicator set is particularly useful when the vaginal vault space is limited or narrow due to tumor, restricted anatomy, or fibrosis. It can also be useful to treat tumors that extend from the uterus or cervix down onto the vaginal wall. The set consists of a precision manufactured intrauterine tandems and a full set of variable diameter Miami cylinders (all components are designed to allow for customization of the treated geometry). The distance that the tandem is inserted can be customized for each case. Various tandems are provided: straight. slight curvature. medium curvature, and maximal curvature. These allow for maximal accommodation of the uterine flexure.
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### న.
Substantial Equivalence Information:
Information presented supports substantial equivalence of CT Compatible / MR Unsafe HDR Kobold® Fletcher-model Tandem and Ovoid 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 general sterilization procedures.
Information presented supports substantial equivalence of CT Compatible / MR Unsafe HDR Kobold® Henschke-model Tandem and Ovoid 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 general sterilization procedures.
Information presented supports substantial equivalence of CT Compatible / MR Unsafe HDR Kobold® Vaginal Cylinder 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 general sterilization procedures
Information presented supports substantial equivalence of CT Compatible / MR Unsafe HDR Kobold® Miami Cylinder 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 general sterilization procedures.
Please see predicate device brochures in Appendix C and previously cleared K123912 and K123941.
- A. Predicate device name: Kobold® Fletcher Type Applicator Set, Kobold® Henschke Type Applicator Set, Kobold® Vaginal Cylinder Applicator Set, Kobold Sure-Guide Miami Cylinder Set
- B. Predicate device K number: 123912, 123941
- C. Comparison with predicate:
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| SUBSTANTIAL<br>EQUIVALENCE<br>TABLE | KOBOLD LLC | KOBOLD LLC |
|----------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| K-Number | K-160610 | K-123912 |
| Device Description | Applicator Set, Fletcher model | Applicator Set, Fletcher Type |
| Indications for Use | The CT Compatible / MR Unsafe<br>HDR Kobold® Fletcher-model<br>Tandem and Ovoid Applicator Set is<br>indicated for use in any case where<br>high dose rate (HDR) radiation<br>treatment of the cervix and uterus<br>with a Fletcher type applicator is<br>accepted by up-to-date clinical<br>guidelines. The Kobold® Fletcher-<br>model Tandem and Ovoid<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<br>where high dose rate (HDR)<br>radiation treatment of the cervix<br>and uterus is accepted by up-to-<br>date clinical guidelines. |
| Afterloader Compatibility* | Elekta: microSelectron®, Flexitron®<br>Varian: GammaMed®, VariSource®<br>with click-fit connector. | GammaMed®, VariSource® with<br>click-fit connector. |
| Design Geometry | Flexible | 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 4 min at 270°F (132°C), 44psi<br>(3 bar) Dry 15 min. | Steam 18 min at 273°F (134°C),<br>44psi (3 bar) Dry 15 min; no<br>Sterrad® compatibility<br>documented |
| Biocompatibility | Documented | Documented |
| Anatomical Sites | Uterus, Cervix | Uterus, Cervix |
| Environmental<br>Compatibility | CT Compatible / MR Unsafe | CT/MRI Compatible |
{8}------------------------------------------------
| SUBSTANTIAL<br>EQUIVALENCE<br>TABLE | KOBOLD LLC | KOBOLD LLC |
|----------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| K-Number | K-160610 | K-123912 |
| Device Description | Applicator Set, Henschke model | Applicator Set, Henschke Type |
| Indications for Use | The CT Compatible / MR Unsafe<br>HDR Kobold® Henschke-model<br>Tandem and Ovoid Applicator Set is<br>indicated for use in any case where<br>high dose rate (HDR) radiation<br>treatment of the cervix and uterus<br>with a Henschke type applicator is<br>accepted by up-to-date clinical<br>guidelines. The Kobold® Henschke-<br>model Tandem and Ovoid<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<br>where high dose rate (HDR)<br>radiation treatment of the cervix<br>and uterus is accepted by up-to-<br>date clinical guidelines. |
| Afterloader Compatibility | Elekta: microSelectron®, Flexitron®<br>Varian: GammaMed®, VariSource®<br>with click-fit connector. | GammaMed®, VariSource® with<br>click-fit connector. |
| Design Geometry | Flexible | 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 4 min at 270°F (132°C), 44psi<br>(3 bar) Dry 15 min. | Steam 18 min at 273°F (134°C),<br>44psi (3 bar) Dry 15 min; no<br>Sterrad® compatibility<br>documented |
| Biocompatibility | Documented | Documented |
| Anatomical Sites | Uterus, Cervix | Uterus, Cervix |
| Environmental<br>Compatibility | CT Compatible / MR Unsafe | CT/MRI Compatible |
{9}------------------------------------------------
| SUBSTANTIAL<br>EQUIVALENCE<br>TABLE | KOBOLD LLC | KOBOLD LLC |
|----------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| K-Number | K160610 | K-123941 |
| Device Description | Vaginal Cylinder Applicator Set | Cylinder Set, Vaginal |
| Indications for Use | The CT Compatible / MR Unsafe<br>HDR Kobold® Vaginal Cylinder<br>Applicator Set is indicated for use in<br>any case where high dose rate (HDR)<br>radiation treatment of the vagina is<br>accepted by up-to-date clinical<br>guidelines. The Kobold® Vaginal<br>Cylinder Applicator Set is intended<br>for continuous use of up to 24 hours<br>of contact with patient. | The CT/MRI Compatible Sure-<br>Guide Vaginal Cylinder Set is<br>indicated for use in any patient<br>case where High Dose Rate<br>(HDR) radiation treatment of the<br>vagina is acceptable for up-to-<br>date clinical and practice<br>guidelines. |
| Afterloader Compatibility | Elekta: microSelectron®, Flexitron®<br>Varian: GammaMed®, VariSource®<br>with click-fit connector. | GammaMed®, VariSource® with<br>click-fit connector. |
| 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 4 min at 270°F (132°C), 44psi<br>(3 bar) Dry 15 min. | Steam 18 min at 273°F (134°C),<br>44psi (3 bar) Dry 15 min; no<br>Sterrad® compatibility<br>documented |
| Biocompatibility | Documented | Documented |
| Anatomical Sites | vagina | vagina |
| Environmental<br>Compatibility | CT Compatible / MR Unsafe | CT/MRI Compatible |
{10}------------------------------------------------
| SUBSTANTIAL<br>EQUIVALENCE<br>TABLE | KOBOLD LLC | KOBOLD LLC |
|----------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| K-Number | K160610 | K-123941 |
| Device Description | Miami Cylinder Applicator Set | Cylinder Set, Miami |
| Indications for Use | The CT Compatible / MR Unsafe<br>HDR Kobold® Miami Cylinder<br>Applicator Set is indicated for use in<br>any patient case where high dose rate<br>(HDR) radiation treatment of the<br>cervix, vagina, and uterus with a<br>Miami type applicator is acceptable<br>by up-to-date clinical guidelines. The<br>Kobold® Miami Cylinder Applicator<br>Set is intended for continuous use of<br>up to 24 hours of contact with patient. | The CT/MRI Compatible Miami<br>HDR Set is indicated for use in<br>any patient case where High Dose<br>Rate (HDR) radiation treatment<br>of the cervix, vagina and uterus is<br>acceptable for up-to-date clinical<br>and practice guidelines. |
| Afterloader Compatibility | Elekta: microSelectron®, Flexitron®<br>Varian: GammaMed®, VariSource®<br>with click-fit connector. | GammaMed®, VariSource® with<br>click-fit connector. |
| 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 4 min at 270°F (132°C), 44psi<br>(3 bar) Dry 15 min. | Steam 18 min at 273°F (134°C),<br>44psi (3 bar) Dry 15 min; no<br>Sterrad® compatibility<br>documented |
| Biocompatibility | Documented | Documented |
| Anatomical Sites | cervix, vagina, and uterus | cervix, vagina, and uterus |
| Environmental<br>Compatibility | CT Compatible / MR Unsafe | CT/MRI Compatible |
{11}------------------------------------------------
# 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 in K-123912 and K-123941. Standards specification for the materials used in surgical implant applications and predicate brachytherapy devices is in Appendix A. Finished device acceptance testing visual method sheets and performance tests are in Appendix A.
## 8.
### Conclusions
The Kobold® Fletcher-model Tandem and Ovoid Applicator Set is similar in intended use and technological characteristics to the predicate device reviewed. The device is substantially equivalent with respect to indications for use and physical characteristics to the predicate device.
The Kobold® Henschke-model Tandem and Ovoid Applicator Set is similar in intended use and technological characteristics to the predicate device reviewed. The device is substantially equivalent with respect to indications for use and physical characteristics to the predicate device.
The Kobold® Vaginal Cylinder Applicator Set is similar in intended use and technological characteristics to the predicate device reviewed. The device is substantially equivalent with respect to indications for use and physical characteristics to the predicate device.
The Kobold® Miami Cylinder Applicator Set is similar in intended use and technological characteristics to the predicate device reviewed. The device is substantially equivalent with respect to indications for use and physical characteristics to the predicate device.
Contraindications: As per clinical guidelines and published and accepted standard clinical practice.
Warnings and Precautions: The precautions and warnings are provided in the device labeling for the Kobold® Fletcher-model Tandem and Ovoid Applicator Set, the Kobold® Henschke-model Tandem and Ovoid Applicator Set, the Kobold® Vaginal Cylinder Applicator Set, and the Kobold® Miami Cylinder Applicator Set.
{12}------------------------------------------------
### 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® Fletchermodel Tandem and Ovoid Applicator Set has been demonstrated to be substantially equivalent to the predicate device. The Kobold® Henschke-model Tandem and Ovoid Applicator Set has been demonstrated to be substantially equivalent to the predicate device. The Kobold® Vaginal Cylinder Applicator Set has been demonstrated to be substantially equivalent to the predicate device. The Kobold® Miami Cylinder Applicator Set has been demonstrated to be substantially equivalent to the predicate device.
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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.