K210572 · Ibramed Equipamentos Medicos · IPF · May 11, 2021 · Physical Medicine
Device Facts
Record ID
K210572
Device Name
Neurodyn V2.0, Neurodyn Aussie V2.0
Applicant
Ibramed Equipamentos Medicos
Product Code
IPF · Physical Medicine
Decision Date
May 11, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5850
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Neurodyn V2.0 Stimulators are intended for: As a FES device: - Stimulation of the muscles in the leg and ankle of partially paralyzed patients to provide flexion of the foot and thus improve the patient's gait. As a TENS device: - Symptomatic relief of chronic (long term) intractable pain - Symptomatic relief of post-traumatic acute pain and post-surgical pain As an Interferential and Premodulated device: - Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain As a Russian device: - Temporary relaxation of muscle spasms - Prevention of disuse atrophy in post-injury type conditions -Increase local blood circulation - Muscle re-education - Maintaining or increasing range of motion As a Burst Modulated Alternating Current (Aussie) device: - Temporary relaxation of muscle spasms - Prevention or retardation of disuse atrophy in post-injury type conditions - Increase local blood circulation - Muscle re-education - Maintaining or increasing range of motion - Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain As a Microcurrent device: - Symptomatic relief of chronic intractable pain - Symptomatic relief of post-traumatic acute pain As a DC/Polarized device: -Relaxation of Muscle Spasm As a High Voltage Pulsed current device: - Muscle re-education - Relaxation of Muscle Spasms - Maintaining or increasing range of motion - Increasing local blood circulation - Prevention or retardation of disuse atrophy Neurodyn Aussie V2.0 Stimulators are intended for: As a Burst Modulated Alternating Current (Aussie) device: - Temporary relaxation of muscle spasms - Prevention or retardation of disuse atrophy in post-injury type conditions - Increase local blood circulation - Muscle re-education - Maintaining or increasing range of motion - Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
Device Story
Neurodyn V2.0 and Aussie V2.0 are multi-channel transcutaneous neuromuscular stimulators. Devices deliver various electrical currents (Aussie, Russian, FES, TENS, Interferential, Microcurrent, DC, High Voltage) to patients via electrodes. Operated by clinicians in hospitals or clinics. Device transforms electrical energy into therapeutic pulses; intensity is adjusted based on patient sensation. Output provides muscle stimulation, pain relief, or re-education. Clinicians use device to manage pain, prevent atrophy, or improve gait. Benefits include non-invasive pain management and physical rehabilitation support.
Clinical Evidence
Bench testing only. Compliance with IEC 60601-1, IEC 60601-1-2, and IEC 60601-2-10 standards demonstrated.
Indicated for patients >=12 years old and >=35 kg requiring muscle stimulation, pain relief, or muscle re-education. Modalities include FES, TENS, Interferential, Premodulated, Russian, Aussie, Microcurrent, DC/Polarized, and High Voltage Pulsed current. Used for chronic intractable pain, acute post-traumatic/post-surgical pain, muscle spasms, disuse atrophy, and gait improvement in partially paralyzed patients.
Regulatory Classification
Identification
A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.
Predicate Devices
Neurodyn Multiwave; Neurodyn Aussie Sport (K131629)
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May 11, 2021
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Ibramed Equipamentos Medicos % Rodrigo Abreu Regulatory Specialist United Regulatory LLC 12343 NW 25th St Coral Springs, Florida 33065
Re: K210572
Trade/Device Name: Neurodyn V2.0, Neurodyn Aussie V2.0 Regulation Number: 21 CFR 890.5850 Regulation Name: Powered muscle stimulator Regulatory Class: Class II Product Code: IPF Dated: February 26, 2021 Received: February 26, 2021
Dear Rodrigo Abreu:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies.combination product submissions. 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
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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) for devices or postmarketing safety reporting (21 CFR 4. Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Patrick Antkowiak, PhD Assistant Director (Acting) DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
#### 510(k) Number (if known) K210572
Device Name Neurodyn V2.0, Neurodyn Aussie V2.0
#### Indications for Use (Describe)
Neurodyn V2.0 Stimulators are intended for:
As a FES device:
- Stimulation of the muscles in the leg and ankle of partially paralyzed patients to provide flexion of the foot and thus improve the patient's gait.
As a TENS device:
- Symptomatic relief of chronic (long term) intractable pain
- Symptomatic relief of post-traumatic acute pain and post-surgical pain
As an Interferential and Premodulated device:
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
As a Russian device:
- Temporary relaxation of muscle spasms - Prevention of disuse atrophy in post-injury type conditions -Increase local blood circulation - Muscle re-education
- Maintaining or increasing range of motion
As a Burst Modulated Alternating Current (Aussie) device:
- Temporary relaxation of muscle spasms
- Prevention or retardation of disuse atrophy in post-injury type conditions
- Increase local blood circulation
- Muscle re-education
- Maintaining or increasing range of motion
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
As a Microcurrent device:
- Symptomatic relief of chronic intractable pain - Symptomatic relief of post-traumatic acute pain
As a DC/Polarized device: -Relaxation of Muscle Spasm
As a High Voltage Pulsed current device:
- Muscle re-education
- Relaxation of Muscle Spasms
- Maintaining or increasing range of motion
- Increasing local blood circulation
- Prevention or retardation of disuse atrophy
Neurodyn Aussie V2.0 Stimulators are intended for:
As a Burst Modulated Alternating Current (Aussie) device:
- Temporary relaxation of muscle spasms
- Prevention or retardation of disuse atrophy in post-injury type conditions
- Increase local blood circulation
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- Muscle re-education
- Maintaining or increasing range of motion
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
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)
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Ibramed Fouinamentos Médicos Av. Dr. Carlos Burgos, 2800 - Jardim Itália, SP, 13901-080 Brazil 3817 9633
510(k) SUMMARY
May 10, 2021
- A) Submitter's Name: Ibramed Equipamentos Médicos
Owner / Operator Registration Number: 3010362721
Manufacture Registration Number: 3010362721
- B) Address: Av. Dr. Carlos Burgos, 2800 Jardim Itália, Amparo SP, 13901-080 Brazil
- C) Phone and Fax Numbers
Phone: + 55 19 3817 9633
- D) Contact Person:
Fábio Alexandre Pinto
Tel.: +55 19 3817-9636
- E) Preparation Date: May 10, 2021
- F) Classification Name: Powered Muscle Stimulator
Common / Usual Name: Powered Muscle Stimulator
Proprietary Name: Neurodyn V2.0; Neurodyn Aussie V2.0
Product Code: IPF
Class: Class II
Regulation: 21 CFR 890.5850
#### G) Device Description
NEURODYN v2.0 is a transcutaneous neuromuscular stimulator of four channels with independent controls for treatments with: AUSSIE CURRENT (with Medium Frequency Current modulated in Burst), RUSSIAN CURRENT (Medium Frequency Current modulated in Burst), FES CURRENT (Functional Electrical Stimulation),TENS CURRENT(Transcutaneous Electrical Nerve Stimulation), INTERFERENTIAL CURRENT (IFC-T), PREMODULATED INTERFERENTIAL CURRENT (IFC-B) BIPOLAR (Medium Frequency Current modulated in Amplitude), and with two independent control channels for the treatments with: MICROCURRENT (Microcurrent Electrical Neuromuscular Stimulation), DIRECT CURRENT /POLARIZED CURRENT and HIGH VOLTAGE PULSED CURRENT (High Volt Pulsed Current).
NEURODYN AUSSIE V2.0 transcutaneous neuromuscular stimulator is a four-channel stimulator with independent controls for current therapy used in AUSSIE CURRENT (Burst Modulated Medium Frequency).
#### H) Substantial Equivalence:
The Neurodyn V2.0 is equivalent with the following products:
| Predicate<br>type | 510(k)<br>Number | Model | Company |
|------------------------|------------------|-------------------------------------------|------------------------------|
| Predicate | K131629 | Neurodyn Multiwave; Neurodyn Aussie Sport | Ibramed Equipamentos Médicos |
| Secondary<br>Predicate | K031077 | Vectra Genesis | Chattanooga |
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Ibramed Equipamentos Médicos
Av. Dr. Carlos Burgos, 2800 - Jardim Itália,
Amparo - SP, 13901-080 Brazil
Ph: + 55 19 3817 9633
## I) Indications for Use
## 1. Subject device: Neurodyn V2.0, Neurodyn Aussie V2.0
### Neurodyn V2.0 Stimulators are intended for:
As a FES device:
- Stimulation of the muscles in the leg and ankle of partially paralyzed patients to provide flexion of the foot and thus improve the patient's gait.
As a TENS device:
- Symptomatic relief of chronic (long term) intractable pain
- Symptomatic relief of post-traumatic acute pain and post-surgical pain
### As an Interferential and Premodulated device:
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
As a Russian device:
- Temporary relaxation of muscle spasms - Prevention or retardation of disuse atrophy in post-injury type conditions - Increase local blood circulation - Muscle re-education - Maintaining or increasing range of motion
As a Burst Modulated Alternating Current (Aussie) device:
- Temporary relaxation of muscle spasms
- Prevention or retardation of disuse atrophy in post-injury type conditions
- Increase local blood circulation
- Muscle re-education
- Maintaining or increasing range of motion
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
As a Microcurrent device:
- Symptomatic relief of chronic intractable pain - Symptomatic relief of post-traumatic acute pain and post surgical pain
As a DC/Polarized device:
- -Relaxation of Muscle Spasm
As a High Voltage Pulsed current device:
- Muscle re-education
- Relaxation of Muscle Spasms
- Maintaining or increasing range of motion
- Increasing local blood circulation
- Prevention or retardation of disuse atrophy
## Neurodyn Aussie V2.0 Stimulators are intended for:
As a Burst Modulated Alternating Current (Aussie) device:
- Temporary relaxation of muscle spasms
- Prevention or retardation of disuse atrophy in post-injury type conditions
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lardim Itália
- Increase local blood circulatio
- Muscle re-education
- Maintaining or increasing range of motion
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
### 2. Predicate: Neurodyn Multiwave; Neurodyn Aussie Sport
### Neurodyn Multiwave-Indications for Use:
As a FES device:
- Stimulation of the muscles in the leg and ankle of partially paralyzed patients to provide flexion of the foot and thus improve the patient's gait.
As a TENS device:
- Symptomatic relief of chronic (long term) intractable pain
- Symptomatic relief of post-traumatic acute pain and post surgical pain
As an Interferential and Premodulated device:
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
As a Russian device:
- Temporary relaxation of muscle spasms - Prevention or retardation of disuse atrophy in post-injury type conditions - Increase local blood circulation - Muscle re-education
- Maintaining or increasing range of motion
As a Burst Modulated Alternating Current (Aussie) device:
- Temporary relaxation of muscle spasms
- Prevention or retardation of disuse atrophy in post-injury type conditions
- Increase local blood circulation
- Muscle re-education
- Maintaining or increasing range of motion
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
As a Microcurrent device:
- Symptomatic relief of chronic intractable pain - Symptomatic relief of post-traumatic acute pain and post surgical pain
As a DC/Polarized device: -Relaxation of Muscle Spasm
## Aussie Sport- Indications for Use:
As a Burst Modulated Alternating Current (Aussie) device:
- Temporary relaxation of muscle spasms
- Prevention or retardation of disuse atrophy in post-injury type conditions
- Increase local blood circulation
- Muscle re-education
- Maintaining or increasing range of motion
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Ibramed Equipamentos Médicos Av. Dr. Carlos Burgos, 2800 - Jardim Itália, Amparo - SP, 13901-080 Brazil Ph: + 55 19 3817 9633
- Symptomatic relief of chronic intractable pain, acute post traumatic pain, or acute post traumatic surgical pain
## 3. Secondary Predicate Device: Vectra Genesis
Indications for Use for High Voltage current device:
- Muscle re-education
- Relaxation of Muscle Spasms
- Maintaining or increasing range of motion
- Increasing local blood circulation
- Prevention or retardation of disuse atrophy
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Ibramed Equipamentos Médicos gos, 2800 - Jardim Itália, 1-080 Brazil
#### K) Technological Characteristics Comparison:
The predicate device used to establish squivalence for the Neurodyn Aussie V2.0 device is outlined below. This section of this submission will provide a comparison of dechnical specifications of the Neurodyn V2.0 to each of the predicate devices stratified by functional modality.
| Device name | Neurodyn_V2.0;<br>Neurodyn Aussie_V2.0 | Neurodyn Multiwave;<br>Neurodyn Aussie Sport | Vectra Genesis | SE Discussion of the<br>differences |
|-------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| K Number | K210572 | K131629 | K031077 | N/A |
| Manufacturer | Ibramed | Ibramed | Chattanooga | N/A |
| Population target | Patients must be at least<br>12 years of age and<br>Patients must weigh at<br>least 35 kg. | Patients must be at least<br>12 years of age and<br>Patients must weigh at<br>least 35 kg. | Not stated in the Manual | Identical when compared<br>with Neurodyn |
| Environment | Hospitals, Clinics, o<br>medical environment | Hospitals, Clinics, o<br>medical environment | Hospitals, Clinics, o<br>medical environment | Identical |
| Technological<br>characteristics Medium-<br>frequency alternating<br>current (MFAC) | Identical | Identical | Similar | N/A |
| Housing Material | ABS plastic panel LCD<br>display | ABS plastic panel LCD<br>display | Not stated in the Manual | N/A |
| Dimensions W x H x D<br>(in) | Neurodyn V2.0 14.6 x 4.9<br>x 12.4<br>Aussie: 10.6 x 4.9 x 10.4 | 6.8 x 4.9 x 12.4 | 11.38 x 8.75 x 12.75 | N/A |
| Weight | 5Lb | 5Lb | 7Lb | N/A |
| Number of Channels | Up to 4 | Up to 4 | Up to 4 | Identical |
| Temperature range<br>during transport and<br>storage | 41°F-122°F | 41°F-122°F | 59° F and 104° F | The ranges are very<br>similar not affecting the<br>substantial equivalence. |
| Environment operating<br>temperature range | 41°f-113°f | 41°F-113°F | No specified | The ranges are very<br>similar not affecting the<br>substantial equivalence. |
| Performance | Identical | Identical | Identical | Identical |
| Biocompatibility | FDA cleared electrodes | FDA cleared electrodes | FDA cleared electrode | Identical |
| Mechanical safety | Identical | Identical | Identical | Identical |
| Anatomical Sites | Identical | Identical | Similar | N/A |
| Burst Modulated<br>Alternating Current<br>( Russian ) | Yes | Yes | Yes | Identical |
| Burst Modulated<br>Alternating Current<br>(Aussie) | Yes | Yes | No | Vectra does not have the<br>Aussie current but the<br>Neurodyn contains,<br>supporting the<br>substantial equivalence. |
| Interferential | Yes | Yes | Yes | Identical |
| Microcurrent | Yes | Yes | Yes | Identical |
| TENS | Yes | Yes | Yes | Identical |
| FES | NEURODYN_V2.0: Yes<br>NEURODYN AUSSIE_V2.0:<br>No | Yes | No | Vectra does not have the<br>FES current but the<br>Neurodyn contains,<br>supporting the<br>substantial equivalence. |
| Premodulated | Yes | Yes | Yes | Identical |
| High Volt | Yes | No | Yes | Neurodyn does not have<br>the HV current but the<br>Vectra contains, |
| | | | | supporting the<br>substantial equivalence. |
| Method of current<br>isolation | Double Isolation | Double Isolation | Double Isolation | Identical |
| Patient leakage control-<br>normal condition | NEURODYN_V2.0: 0.0044<br>mA<br>NEURODYN AUSSIE_V2.0:<br>0.0134 mA | 0.0508mA | 100µA | It is between the<br>standard acceptance<br>range, supporting the<br>substantial equivalence. |
| Patient leakage control-<br>single fault condition | NEURODYN_V2.0: 0.0124<br>mA<br>NEURODYN AUSSIE_V2.0:<br>0.0008 mA | 0.0252mA | 500µA | It is between the<br>standard acceptance<br>range, supporting the<br>substantial equivalence. |
| Number of output mode | NEURODYN_V2.0: 8<br>NEURODYN AUSSIE_V2.0:<br>1 | 7 | 10 | Number of modalities<br>that the equipment<br>provides, the modalities<br>are independent and do<br>not need each other to<br>carry out the treatment,<br>limiting only the number<br>of treatments performed<br>according to the supplied<br>currents. |
| Synchronous or<br>Alternating? | Synchronous | Synchronous | Synchronous | Identical |
| Method of Channel<br>isolation | Output transformation with<br>isolation to 1000V | Output transformation<br>with isolation to 1000V | Not Stated in the Manual | Identical when compared<br>with Neurodyn |
| Regulated current or<br>regulated voltage? | Only Current | Only Current | Optional | Circuit regulated in<br>current or voltage does |
| | | | Current or Voltage | not interfere in<br>performance, but circuit<br>regulated in current is<br>more common. |
| Software Microprocessor | Yes | Yes | Yes | Identical |
| Automatic overload trip | No | No | Not Stated in the Manual | Identical when compared<br>with Neurodyn |
| Automatic no-load trip | No | No | Not Stated in the Manual | Identical when compared<br>with Neurodyn |
| Automatic shut off | Yes | Yes | Yes | Identical |
| Patient override control? | Yes | Yes | Yes | Identical |
| Indicator Display<br>On/off Status? | Yes | Yes | Yes | Identical |
| Indicator Display<br>Voltage/Current Level? | NEURODYN_V2.0: Aussie 0<br>to 120mA (Ipp)<br>NEURODYN AUSSIE_V2.0:<br>Aussie 0 to 120mA (Ipp) | Aussie 0 to 120mA (Ipp) | No | Identical when compared<br>with Neurodyn |
| | NEURODYN_V2.0: Russa 0<br>to 120mA (Ipp) | Russa 0 to 120mA (Ipp) | Russian 0 to 100 mA | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not<br>have fixed parameter, it<br>is according to the<br>sensorial of each patient. |
| | NEURODYN_V2.0: TENS 0<br>to 120mA (Ipp) | TENS 0 to 120mA (Ipp) | Tens 0 to 80 mA | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not |
| NEURODYN_V2.0: FES 0 to<br>120mA (Ipp) | FES 0 to 120mA (Ipp) | No | have fixed parameter, it<br>is according to the<br>sensorial of each patient.<br>Identical when compared<br>with Neurodyn | |
| NEURODYN_V2.0:<br>Interferential TP 0 to<br>120mA (Ipp) | Interferential TP 0 to<br>120mA (Ipp) | Interferential 0 to 100<br>mA | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not<br>have fixed parameter, it<br>is according to the<br>sensorial of each patient. | |
| NEURODYN_V2.0:<br>Interferential BP 0 to<br>120mA (Ipp) | Interferential BP 0 to<br>120mA (Ipp) | Interferential 0 to 100<br>mA | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not<br>have fixed parameter, it<br>is according to the<br>sensorial of each patient. | |
| NEURODYN_V2.0: Micro<br>Current 0 to 990μA (Ip) | Micro Current 0 to 990µA<br>(Ip) | Micro Current 0 to 100 µA | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not<br>have fixed parameter, it<br>is according to the<br>sensorial of each patient. | |
| NEURODYN_V2.0:<br>Polarized/ Direct Current 0<br>to 30 mA (Ip) | Polarized/ Direct Current<br>0 to 30 mA (Ip) | Direct Current 0 to 4 mA | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not<br>have fixed parameter, it<br>is according to the | |
| | | | | is according to the<br>sensorial of each patient. |
| | High Volt 0 to 400 V | | High Volt 0 to 500V | Characteristics of the<br>circuit, does not interfere<br>in the performance, since<br>the intensity does not<br>have fixed parameter, it<br>is according to the<br>sensorial of each patient. |
| Locking feature | Keyboard lock safety<br>feature | Keyboard lock safety<br>feature | Keyboard lock safety<br>feature | Identical |
| Treatment timer | Treatment timer with auto<br>shut off 1-60 minutes | Treatment timer with auto<br>shut off 1-60 minutes | Treatment timer with auto<br>shut off 1-60 minutes | Identical |
| Voltage Input Range and<br>Frequency | 100-240VAC, 50/60Hz | 100-240VAC, 50/60Hz | 100-240VAC, 50/60Hz | Identical |
| Safety standards<br>requirements<br>biocompatibility | IEC 60601-1<br>IEC 60601-1-2<br>IEC 60601-2-10<br>21 CFR 898 | IEC 60601-1<br>IEC 60601-1-2<br>IEC 60601-2-10<br>21 CFR 898 | IEC 60601-1<br>IEC 60601-1-2<br>IEC 60601-2-10<br>21 CFR 898 | Identical |
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Image /page/11/Picture/0 description: The image shows the logo for IBRAMED. The logo consists of a stylized blue and black graphic above the word "IBRAMED" in black, sans-serif font. The graphic resembles a bow tie or a stylized hourglass shape, with three horizontal blue bars on the top and bottom, and a black vertical bar in the center.
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Image /page/12/Picture/0 description: The image shows the logo for IBRAMED. The logo consists of a stylized blue and black design above the word "IBRAMED" in black, bold letters. The design features two sets of curved blue shapes on the top and bottom, with a black hourglass shape in the center.
Ibramed Equipamentos Médicos
Av. Dr. Carlos Burgos, 2800 - Jardim Itália,
Amparo - SP, 13901-080 Brazil
Ph: + 55 19 3817 9633
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Image /page/13/Picture/0 description: The image shows the logo for IBRAMED. The logo consists of a stylized blue and black graphic above the word "IBRAMED" in black, sans-serif font. The graphic resembles a bow tie or a stylized hourglass shape, with three horizontal blue bars on the top and bottom, and a black vertical bar in the center.
Conclusion: The Neurodyn V2.0 device and the predicate devices are substantially equivalent when comparing the indications for use, and technological properties. The differences shown in the comparison do not affect the substantial equivalence.
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Image /page/14/Picture/0 description: The image shows the logo for Ibramed. The logo consists of a stylized blue and black symbol to the left of the word "IBRAMED" in blue. To the right of the logo is the text "Ibramed" followed by an address and phone number, beginning with "Ph: + 55".
bramed Equipamentos Médicos Carlos Burgos, 2800 - Jardim Itália, 3901-080 Brazil า: + 55 19 3817 9633
## L) Applicable Standards:
Neurodyn V2.0 was developed, as well produced in compliance with recognized international regulations and standards for the medical device industry.
IEC 60601-1 - Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
IEC 60601-1-2 - Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances -Requirements and tests
IEC 60601-2-10 - Medical electrical equipment - Part 2-10: Particular requirements for the basic safety and essential performance of nerve and muscle stimulators
## Conclusion:
Based on compliance with the international standard and regulation mentioned above, the device Neurodyn V2.0 demonstrate substantial equivalence to the predicates above.
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Image /page/15/Picture/0 description: The image shows the logo and contact information for Ibramed Equipamentos Médicos. The logo features a stylized blue and black design with the word "BRAMED" underneath. The contact information includes the address "Av. Dr. Carlos Burgos, 2800 - Jardim Itália, Amparo - SP, 13901-080 Brazil" and the phone number "Ph: + 55 19 3817 9633".
## M) Non-clinical Testing:
In order to study the performance of the product, pre-clinical tests were performed according to the table below.
#### Test Performance
IEC 60601-1 - Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
IEC 60601-2-10 - Medical electrical equipment - Part 2-10: Particular requirements for the basic safety and essential performance of nerve and muscle stimulators
IEC 60601-1-2 - Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
Conclusion: Based on compliance with the international standard and regulation mentioned above, the device Neurodyn V2.0 demonstrates equivalency to the predicate device.
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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.