K173779 · Sm Eng Co., Ltd. · GAM · Mar 12, 2018 · General, Plastic Surgery
Device Facts
Record ID
K173779
Device Name
REXMONO, PDREX
Applicant
Sm Eng Co., Ltd.
Product Code
GAM · General, Plastic Surgery
Decision Date
Mar 12, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4493
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
REXMONO is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular or neural tissue. PDREX is indicated for use in all types of soft tissue approximation, including use in cardiovascular tissue where growth is expected to occur, PDO suture is not indicated in adult cardiovascular tissue, microsurgery, ophthalmic and neural tissue.
Device Story
REXMONO and PDREX are synthetic absorbable monofilament surgical sutures provided with or without stainless steel (SUS 304) needles. REXMONO is composed of poly(glycolide-co-caprolactone); PDREX is composed of polydioxanone. Devices are supplied sterile for single use. Sutures are used by surgeons for soft tissue approximation and ligation. The device provides mechanical support to tissue during the healing process until the suture is absorbed by the body. REXMONO retains 68-78% tensile strength after 1 week, with complete absorption in 90-110 days. PDREX retains 50-60% tensile strength after 6 weeks, with complete absorption in 180-210 days. Clinical benefit is the secure approximation of soft tissues during surgical procedures.
Clinical Evidence
Bench testing only. No clinical data. Testing included USP <861> (diameter), USP <871> (needle attachment), USP <881> (tensile strength), and USP monograph requirements for absorbable sutures. Biocompatibility testing performed per ISO 10993 series (cytotoxicity, irritation, sensitization, systemic toxicity, genotoxicity, implantation, blood interaction). Sterile barrier system validated per ISO 11607-1/2 and ASTM F88/F1929. Accelerated aging stability tested per ASTM F1980.
Technological Characteristics
Materials: REXMONO (poly(glycolide-co-caprolactone)), PDREX (polydioxanone), Needle (SUS 304 stainless steel). Monofilament structure. Absorbable. Sterile. Single-use. Dimensions: various USP sizes (oversized). Tensile strength and needle attachment meet USP standards. Biocompatibility per ISO 10993.
Indications for Use
Indicated for general soft tissue approximation/ligation. REXMONO: includes ophthalmic; excludes cardiovascular/neural. PDREX: includes cardiovascular where growth expected; excludes adult cardiovascular, microsurgery, ophthalmic, and neural.
Regulatory Classification
Identification
An absorbable poly(glycolide/l-lactide) surgical suture (PGL suture) is an absorbable sterile, flexible strand as prepared and synthesized from homopolymers of glycolide and copolymers made from 90 percent glycolide and 10 percent l-lactide, and is indicated for use in soft tissue approximation. A PGL suture meets United States Pharmacopeia (U.S.P.) requirements as described in the U.S.P. “Monograph for Absorbable Surgical Sutures;” it may be monofilament or multifilament (braided) in form; it may be uncoated or coated; and it may be undyed or dyed with an FDA-approved color additive. Also, the suture may be provided with or without a standard needle attached.
Special Controls
*Classification.* Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA.” See § 878.1(e) for the availability of this guidance document.
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March 12, 2018
SM ENG CO., LTD % Sanglok Lee Manager Wise COMPANY Inc. #1005, 11-19, Gamasan-ro 27a-gil Guro-gu, Seoul, Korea
Re: K173779
Trade/Device Name: REXMONO, PDREX Regulation Number: 21 CFR 878.4493 Regulation Name: Absorbable Poly(Glycolide/L-Lactide) Surgical Suture Regulatory Class: Class II Product Code: GAM, NEW Dated: November 11, 2017 Received: December 12, 2017
Dear Sanglok Lee:
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 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);
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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# David Krause -S
for
Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
### Indications for Use
510(k) Number (if known) K173779
Device Name REXMONO, PDREX
#### Indications for Use (Describe)
REXMONO is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular or neural tissue.
PDREX is indicated for use in all types of soft tissue approximation, including use in cardiovascular tissue where growth is expected to occur, PDO suture is not indicated in adult cardiovascular tissue, microsurgery, ophthalmic and neural tissue.
Type of Use (Select one or both, as applicable)
X 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)
FOR FDA USE ONLY
Health (CDRH) (Signature)
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K173779 page 1 of 9
Image /page/4/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized "W" that resembles a heartbeat line. Below the symbol, the text "WISE COMPANY Inc." is displayed in a simple font. Underneath that, the text "와이즈컴퍼니(주)" is displayed in a smaller font.
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
# 510(k) Summary
### The assigned 510(k) Number: K173779
● Date of Preparation: March 05, 2018
### ● Sponsor Identification
Company name: SM ENG CO., LTD Address: 46, Nakdong-daero 1302beon-gil, Sasang-gu, Busan, Korea TEL: +82 51 3058016 FAX: +82 513058021 Email: leesg@sm-eng.net
Establishment Registration Number: 3008912461
### ● Submission Correspondent
Sanglok, Lee Wise COMPANY Inc. #1005, 11-19, Gamasan-ro 27-gil, Guro-gu, Seoul, Korea TEL: +82 70 8812 3619 / +82 2 831 3615 FAX: +82 50 4031 3619 Email: info@wisecompany.org
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K173779 page 2 of 9
Image /page/5/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized line graph above the company name. Below the company name, there is text in Korean that says "와이즈컴퍼니(주)".
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.orq
### Proposed Device Identification
#### 1. REXMONO
### Device Identification and Regulatory information
Proprietary Name: REXMONO
Common Name: Synthetic Absorbable PGA-PCL Monofilament Suture With or Without Needle
Device Class: Class II Regulation Number: 21 C.F.R. 878.4493 Product Code: GAM
#### Indications for Use
REXMONO is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular or neural tissue
#### 2. PDREX
#### Device Identification and Regulatory information
Proprietary Name: PDREX Common Name: Synthetic Absorbable Monofilament Polydioxanone Suture With or Without Needle Device Class: Class II Product Code: NEW
#### Indications for Use
PDREX is indicated for use in all types of soft tissue approximation, including use in cardiovascular tissue where growth is expected to occur, PDO suture is not indicated in adult cardiovascular tissue, microsurgery, ophthalmic and neural tissue.
### Predicate Device Identification
#### 1. REXMONO
-Predicate Device 510(k) Number: K142810 Device Name: WEGO-PGCL Absorbable Surgical Monofilament Suture Manufacturer: FOOSIN MEDICAL SUPPLIES INC.LTD
#### 2. PDREX
-Predicate Device 510(k) Number: K073614 Device Name: WG-Surgical Sutures with Needle Manufacturer: FOOSIN MEDICAL SUPPLIES INC.LTD
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K173779 page 3 of 9
Image /page/6/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized "W" shape above the company name. Below the company name is the same name in Korean.
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
### · Device Description
#### 1. REXMONO
Synthetic Absorbable PGA-PCL Monofilament Suture With or Without Needle (REXMONO) are produced and provided by SM ENG Co., Ltd. REXMONO is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular or neural tissue.
Suture of REXMONO manufactured by SAMYANG Biopharmaceuticals Corporation, which is called MONOFAST. SM Eng is receiving bulk MONOFAST from Samyang, and then go through cutting, adhesion of need and thread, winding and sterilization process according to SM Eng procedure, which becomes REXMONO suture.
REXMONO is a sterilized medical device composed with absorbable monofilament suture, poly (glycolide-co-caprolactone), with needle, stainless steel SUS 304.
REXMONO Suture is a synthetic absorbable, monofilament, suture composed of poly (qlycolide-co-caprolactone). The suture is available undyed (natural) or dyed (D&C Violet No.2). Approximately 68~78% of tensile strength remain after 1 week. Complete absorption in tissues takes around 90 to 110 days.
REXMONO Sutures are U.S.P. except for diameters in the following sizes:
MAXIMUM SUTURE OVERSIZE IN DIAMETER (mm) FROM U.S.P.
| U.S.P.<br>SUTURE SIZE<br>DESIGNATION | MAXIMUM<br>OVERSIZE<br>(mm) |
|--------------------------------------|-----------------------------|
| 6-0 | 0.050 |
| 5-0 | 0.050 |
| 4-0 | 0.050 |
| 3-0 | 0.090 |
| 2-0 | 0.060 |
| 0 | 0.100 |
| 1 | 0.071 |
| 2 | 0.011 |
#### 2. PDREX
Synthetic Absorbable Monofilament Polydioxanone Suture With or Without Needle (PDREX) are produced and provided by SM ENG Co., Ltd. PDREX is indicated for use in all types of soft tissue approximation, including use in cardiovascular tissue where growth is expected to occur, PDO suture is not indicated in adult cardiovascular tissue, microsurgery, ophthalmic and neural tissue.
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K173779 page 4 of 9
Image /page/7/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo consists of a stylized line that resembles a heartbeat or a mountain range. Below the line, the text "WISE COMPANY Inc." is written in a serif font. Underneath the English text, there is Korean text that says "와이즈컴퍼니(주)".
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
Suture of PDREX manufactured by SAMYANG Biopharmaceuticals Corporation, which is called MONOSORB. SM Eng is receiving bulk MONOSORB from Samyang, and then go through cutting, adhesion of need and thread, winding and sterilization process according to SM Eng procedure, which becomes PDREX suture.
PDREX is a sterilized medical device composed with polydioxanone surgical suture, with needle, stainless steel SUS 304.
PDREX Suture is a synthetic absorbable, monofilament, suture composed of a Poly (pdioxanone). The suture is available dyed (D&C Violet No.2). Approximately 50~60% of tensile strength remain after 6 week. Complete absorption in tissues takes around 180 to 210 days.
PDREX Sutures are U.S.P. except for diameters in the following sizes:
MAXIMUM SUTURE OVERSIZE IN DIAMETER (mm) FROM U.S.P.
| U.S.P.<br>SUTURE SIZE<br>DESIGNATION | MAXIMUM<br>OVERSIZE<br>(mm) |
|--------------------------------------|-----------------------------|
| 7-0 | 0.025 |
| 6-0 | 0.050 |
| 5-0 | 0.050 |
| 4-0 | 0.050 |
| 3-0 | 0.090 |
| 2-0 | 0.060 |
| 0 | 0.100 |
| 1 | 0.071 |
| 2 | 0.011 |
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K173779 page 5 of 9
Image /page/8/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized "W" that also resembles a heartbeat line. Below the "W" is the text "WISE COMPANY Inc." in a simple, sans-serif font. Below that is the text "와이즈컴퍼니(주)".
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
### ● Non-Clinical Test Conclusion (REXMONO & PDREX)
Bench tests were conducted to verify that the proposed device (REXMONO & PDREX) met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
USP <861> SUTURES - DIAMETER USP <871> SUTURES - NEEDLE ATTACHMENT USP <881> TENSILE STRENGTH USP MONOGRAPH OF ABSORBABLE SURGICAL SUTURE
#### Sterile barrier system testing
ISO 11607-1, Packaging For Terminally Sterilized Medical Devices - Part 1: Requirements For Materials, Sterile Barrier Systems And Packaging Systems ISO 11607-2, Packaging For Terminally Sterilized Medical Devices - Part 2: Validation Requirements For Forming, Sealing And Assembly Processes ASTM F 88, Standard Test Method for Seal Strength of Flexible Barrier Materials ASTM F 1929, Standard Test Method for Detecting Seal Leaks in Porous Medical Package by Dye Penetration
Accelerated aging stability testing
- ASTM F 1980, Standard Guide For Accelerated Aging Of Sterile Barrier Systems For Medical Devices. (Sterility)
Biocompatibility testing
- 1) Suture Needle
- ISO 10993-12: Sample Preparation
- ISO 10993-5: Test for Cytotoxicity
- ISO 10993-10: Test for Irritation and Sensitization
- 2) Suture
- ISO 10993-1: Selection of Tests
- ISO 10993-2: Animal Welfare
- ISO 10993-12: Sample Preparation
- ISO 10993-5: Test for Cytotoxicity
- ISO 10993-10: Test for Irritation and Sensitization
- ISO 10993-11: Test for Systemic Toxicity
- ISO 10993-3: Tests for Genotoxicity
- ISO 10993-6: Test for Local Effects after Implantation
- ISO 10993-4: Selection of Tests for Interaction with Blood
Real-time and accelerated aging stability testing was performed to support shelf life of REXMONO. Additionally, the residual strength and absorption rate studies were demonstrated and the sutures were evaluated in accordance with the requirements outlined in FDA's Class II Special Controls Guidance Document: Surgical Sutures
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K173779 page 6 of 9
Image /page/9/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized line that resembles a heartbeat or a mountain range above the company name. Below the English name, the company name is also written in Korean: 와이즈컴퍼니(주).
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
1
### ● Substantially Equivalent Conclusion
The following table compares the REXMONO and PDREX to the predicate devices with respect to intended use, technological characteristics and principles of operation, etc.
| REXMONO | | PDREX | | | |
|--------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Property | Proposed<br>device:<br>REXMONO | Predicate<br>device:<br>WEGO-PGCL<br>Absorbable<br>Surgical<br>Monofilament<br>Suture | Property | Proposed<br>device:<br>PDREX | Predicate<br>device:<br>WG-Surgical<br>Sutures with<br>Needle |
| 510(k)<br>Number | K173779 | K142810 | 510(k)<br>Number | K173779 | K073614 |
| Product<br>Code | GAM | Same | Product<br>Code | NEW | Same |
| Indications<br>for use<br>statements | REXMONO is<br>indicated for<br>use in general<br>soft tissue<br>approximation<br>and/or<br>ligation,<br>including use<br>in ophthalmic<br>procedures,<br>but not for use<br>in<br>cardiovascula<br>r or neural<br>tissue | Same. The<br>WEGO-PGCL<br>Absorbable<br>Surgical<br>Monofilament<br>Suture is<br>indicated for<br>use in general<br>soft tissue<br>approximation<br>and/or, but not<br>for use in<br>cardiovascula<br>r or<br>neurological<br>procedure | indications<br>for use<br>statements | PDREX is<br>indicated for<br>use in general<br>soft tissue<br>approximation<br>and/or<br>ligation,<br>including use<br>in ophthalmic<br>procedures,<br>but not for use<br>in<br>cardiovascula<br>r or neural<br>tissue | Absorbable<br>Polydioxanon<br>e Suture with<br>Needle is<br>indicated for<br>use in all<br>types of soft<br>tissue<br>approximation<br>, including<br>use in<br>cardiovascula<br>r tissue where<br>growth is<br>expected to<br>occur, PDO<br>suture is not<br>indicated in<br>adult<br>cardiovascula<br>r tissue, |
| | | | | | microsurgery,<br>ophthalmic<br>and neural<br>tissue. |
| Class | II | Same | Class | II | Same |
| Sterile | Yes | Same | Sterile | Yes | Same |
| Single Use | Yes | Same | Single Use | Yes | Same |
| Configuratio<br>n | PGA-PCL<br>Suture and<br>Needle | Same | Configuratio<br>n | Polydioxanon<br>e Suture and<br>Needle | Same |
| Suture | | | | | |
| Material | Poly(glycolide<br>-co-<br>caprolactone))<br>copolymer | Same | Material | Poly (p-<br>dioxanone) | Same |
| Coating<br>material | None | Same | Coating<br>material | None | None |
| Color | Undyed<br>(natural) and<br>dyed (D&C<br>Violet No.2) | Same | Color | Dyed (D&C<br>Violet No.2). | Violet or<br>Undyed |
| Absorbable/<br>Nonabsorba<br>ble | Absorbable | Same | Absorbable/<br>Nonabsorba<br>ble | Absorbable | Absorbable |
| Braided/Mon<br>ofilament | Monofilament | Same | Braided/Mon<br>ofilament | Monofilament | Monofilament |
| Barbed/Not<br>Barbed | Not Barbed | Same | Barbed/Not<br>Barbed | Not Barbed | Same |
| Suture Size | The proposed<br>device is<br>available in 6-<br>0, 5-0, 4-0,3-<br>0,2-0, 0, 1<br>and 2, which<br>are the sizes<br>identified in<br>the currently<br>recognized<br>United States<br>Pharmacopoe<br>ia.<br>Sutures are<br>U.S.P. except<br>for diameters.<br>All suture<br>sizes are<br>oversized | Similar. The<br>proposed<br>device is<br>available in 6-<br>0, 5-0, 4-0,3-<br>0,2-0, 0, and<br>1, which are<br>the sizes<br>identified in<br>the currently<br>recognized<br>United States<br>Pharmacopoe<br>ia.<br>Sutures are<br>U.S.P. except<br>for diameters.<br>All suture<br>sizes are over<br>sized | Suture Size | The proposed<br>device is<br>available in 7-<br>0, 6-0,5-0, 4-<br>0,3-0,2-0, 0, 1<br>and 2, which<br>are the sizes<br>identified in<br>the currently<br>recognized<br>United States<br>Pharmacopoe<br>ia.<br>Sutures are<br>U.S.P. except<br>for diameters.<br>All suture<br>sizes are<br>oversized | Same |
| Length of<br>Suture | 30, 45, 50, 60,<br>70, 75, 90,<br>150, 250cm | 30cm, 45cm,<br>60cm, 75cm,<br>90cm, 100cm,<br>120cm,<br>150cm,<br>180cm,<br>200cm,<br>250cm,<br>280cm,<br>300cm,<br>320cm.<br>360cm and<br>390cm | Length of<br>Suture | 20, 23, 30, 35,<br>45, 60, 70, 75,<br>90, 150cm | Not known |
| Diameter of<br>Suture | Oversize | Oversize | Diameter of<br>Suture | Oversize | Same |
| Tensile<br>strength | The tensile<br>strengths of<br>proposed<br>device comply | Same | Tensile<br>strength | The tensile<br>strengths of<br>proposed<br>device comply | Same |
| | with the<br>tensile<br>requirement<br>listed in USP<br><881> Tensile<br>Strength | | | with the<br>tensile<br>requirement<br>listed in USP<br><881> Tensile<br>Strength | |
| Needle<br>Attachment | The bond<br>between<br>suture and<br>needle of the<br>applicant<br>device meet<br>the<br>requirements<br>defined in<br>USP <871>. | Same | Needle<br>Attachment | The bond<br>between<br>suture and<br>needle of the<br>applicant<br>device meet<br>the<br>requirements<br>defined in<br>USP <871>. | Same |
| Needle | | | | | |
| Material | Stainless<br>Steel | Same | Material | Stainless<br>Steel | Same |
| Needle type | Taper point,<br>Reverse<br>Cutting,<br>Conventional<br>cutting, Taper<br>cutting,<br>Spatula, Blunt<br>point | Similar. Taper,<br>Cutting, Blunt | Needle type | Taper point,<br>Reverse<br>Cutting,<br>Conventional<br>cutting, Taper<br>cutting,<br>Spatula, Blunt<br>point | Similar. Not<br>known |
| Biocompatibi<br>lity | Comply with<br>ISO 10993-5<br>and ISO<br>10993-10 | Same | Biocompatibi<br>lity | Comply with<br>ISO 10993-5<br>and ISO<br>10993-10 | Same |
Table. Comparison of Technology Characteristics
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K173779 page 7 of 9
Image /page/10/Picture/1 description: The image shows the text "WISE COMPANY Inc." in a light tan color. The text is horizontally aligned and appears to be a company logo or heading. The font is a serif typeface, giving it a professional and classic look.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
Image /page/10/Picture/5 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized "W" that resembles a heartbeat line in a gold color. Below the logo, the text "WISE COMPANY Inc." is written in a serif font, and below that, the Korean translation "와이즈컴퍼니(주)" is written in a smaller font.
{11}------------------------------------------------
Image /page/11/Picture/0 description: The image shows the logo for WISE COMPANY Inc. The logo consists of a stylized line graph above the company name. Below the company name, the Korean translation of the company name, 와이즈컴퍼니(주), is written in Korean characters. The logo is simple and modern.
## K173779 page 8 of 9
# WISE COMPANY Inc.
#1005, 11–19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
{12}------------------------------------------------
K173779 page 9 of 9
Image /page/12/Picture/1 description: The image shows the logo for WISE COMPANY Inc. The logo features a stylized line that resembles a heartbeat or a mountain range. Below the line, the text "WISE COMPANY Inc." is displayed in a simple, sans-serif font, and below that is the Korean translation of the company name, "와이즈컴퍼니(주)".
# WISE COMPANY Inc.
#1005, 11-19, Gamasan-ro 27-gil,
Guro-gu, Seoul, Republic of Korea Tel: +82 2 831 3615 info@wisecompany.org
The proposed devices, REXMONO & PDREX, are determined to be Substantially Equivalent (SE) to the predicate devices.
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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.