K233355 · Cypris Medical · GAW · Jan 12, 2024 · General, Plastic Surgery
Device Facts
Record ID
K233355
Device Name
Cypris eXact Suturing System
Applicant
Cypris Medical
Product Code
GAW · General, Plastic Surgery
Decision Date
Jan 12, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.5010
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Cypris eXact Suture PP (Polypropylene) The Cypris eXact Suture (PP) is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures. Cypris eXact Suture PTFE (Polytetraflouroethylene) The Cypris eXact Suture (PTFE) is indicated for use in all types of soft tissue approximation and/or ligation, including dental and general surgeries. Cypris eXact Suture PDO (Polydioxanone) The Cypris eXact Suture (PDO) is indicated for use in general soft tissue approximation and/or ligation, but not for use in cardiovascular or neurological tissues, microsurgery or ophthalmic surgery. The Cypris eXact 5.1 Suture Placement Device can be used in conjunction with eXact Sutures, which are indicated for use in general soft tissue approximation and/or ligation.
Device Story
System comprises sterile, single-use Cypris eXact Sutures (PP, PTFE, or PDO) and handheld Cypris eXact 5.1 Suture Placement Device. Sutures feature stainless-steel BB needle. Device facilitates surgical suture placement. Used by surgeons in clinical settings for soft tissue approximation/ligation. System provides mechanical means for tissue closure; benefits patient through secure wound approximation. No complex processing or software involved.
Clinical Evidence
Bench testing only. Evaluated suture diameter, tensile strength, and needle attachment per USP requirements. Biocompatibility testing performed per ISO 10993-1:2018 for long-term (>30 days) implant (sutures) and limited contact (<24 hours) device (placement tool). Shelf-life validated via real-time aging.
Indicated for general soft tissue approximation and/or ligation. PP: includes cardiovascular, ophthalmic, neurological. PTFE: includes dental and general. PDO: excludes cardiovascular, neurological, microsurgery, ophthalmic.
Regulatory Classification
Identification
Nonabsorbable polypropylene surgical suture is a monofilament, nonabsorbable, sterile, flexible thread prepared from long-chain polyolefin polymer known as polypropylene and is indicated for use in soft tissue approximation. The polypropylene surgical suture meets United States Pharmacopeia (U.S.P.) requirements as described in the U.S.P. Monograph for Nonabsorbable Surgical Sutures; it may be undyed or dyed with an FDA approved color additive; and 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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January 12, 2024
Cypris Medical % Erin Gontang Senior Consultant Ram+ 2251 San Diego Avenue B-257 San Diego, California 92110
Re: K233355
Trade/Device Name: Cypris eXact Suturing System Regulation Number: 21 CFR 878.4840 Regulation Name: Absorbable Polydioxanone Surgical Suture Regulatory Class: Class II Product Code: NEW, GAW, NBY, GEJ Dated: September 29, 2023 Received: September 29, 2023
Dear Erin Gontang:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
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3
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,
# Yu-chieh Chiu -S
for Tek Lamichhane Assistant Director DHT4B: Division of Infection Control and Plastic and Reconstructive Surgery Devices OHT4: Office of Surgical and Infection Control 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) K233355
Device Name Cypris eXact Suturing System
#### Indications for Use (Describe)
Cypris eXact Suture PP (Polypropylene)
The Cypris eXact Suture (PP) is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures.
Cypris eXact Suture PTFE (Polytetraflouroethylene)
The Cypris eXact Suture (PTFE) is indicated for use in all types of soft tissue approximation and/or ligation, including dental and general surgeries.
Cypris eXact Suture PDO (Polydioxanone)
The Cypris eXact Suture (PDO) is indicated for use in general soft tissue approximation and/or ligation, but not for use in cardiovascular or neurological tissues, microsurgery or ophthalmic surgery.
The Cypris eXact 5.1 Suture Placement Device can be used in conjunction with eXact Sutures, which are indicated for use in general soft tissue approximation and/or ligation.
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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# 510(k) SUMMARY
#### DATE PREPARED
January 12, 2024
# MANUFACTURER AND 510(k) OWNER
Cypris Medical, Inc. 4541 N. Ravenswood Ave. #202 Chicago, IL 60640, USA Phone: +1 888-433-5002
#### OFFICIAL CONTACT
Dan Holton, President & CEO
### REPRESENTATIVE/CONSULTANT
Erin A. Gontang, Ph.D. Allison C. Komiyama, Ph.D., RAC RQM+ 2251 San Diego Ave, Suite B-257 San Diego, CA 92110, USA Phone: +1 412-816-8290 Email: egontang@rqmplus.com akomiyama@rqmplus.com
### DEVICE INFORMATION
| Trade/Proprietary Name | Cypris eXact Suturing System |
|-------------------------|-------------------------------------------------------------------------|
| Common Name | Suturing System |
| Regulatory Class: | II |
| Regulation Number/Name: | 878.4840 Absorbable polydioxanone surgical suture |
| | 878.5010 Nonabsorbable polypropylene surgical suture |
| | 878.5035 Nonabsorbable expanded polytetrafluoroethylene surgical suture |
| | 878.4800 Manual surgical instrument for general use |
| Product Code: | NEW |
| | GAW |
| | NBY |
| | GEJ |
| Classification Panel | General & Plastic Surgery |
| Premarket Review | Office of Health Technology 4 |
| | (Surgical and Infection Control Devices) |
| | Division of Health Technology 4B |
| | (Infection Control and Plastic and Reconstructive Surgery) |
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# PREDICATE DEVICE IDENTIFICATION
The Cypris eXact Suturing System is substantially equivalent to the following predicates:
| 510(k)<br>Number | Predicate Device Name / Manufacturer | Primary<br>Predicate |
|------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------|
| K131224 | Sharpoint Polypropylene Surgical Suture, LOOK Polypropylene<br>Surgical Suture, Quill Polypropylene Knotless Tissue-Closure<br>/ Surgical Specialties Corp. | ✓ |
| K160744 | LOOK PTFE Suture<br>/ Surgical Specialties Corp. | |
| K063680 | Sharpoint PDO (polydioxanone) Sutures<br>/ Surgical Specialties Corp. | |
The predicate devices have not been subject to a design related recall.
# DEVICE DESCRIPTION
The Cypris eXact Suturing System is comprised of the Cypris eXact Suture and the Cypris eXact 5.1 Suture Placement Device. The Cypris eXact Suture and the Cypris eXact 5.1 Suture Placement Device are for use in general soft tissue approximation by surgeons, are single-use, and are provided sterile.
The Cypris eXact Suture is a synthetic, monofilament suture available in three different materials: polypropylene (PP), polydioxanone (PDO), and polytetraflouroethylene (PTFE). The Cypris eXact Suture (PP) is a non-absorbable, sterile surgical suture available in two sizes, USP sizes 3-0 and 4-0. The Cypris eXact Suture (PTFE) is a non-absorbable, sterile surgical suture available in two sizes, USP sizes 2-0 and 3-0. The Cypris eXact Suture (PDO) is an absorbable, sterile surgical suture available in two sizes, USP sizes 3-0 and 4-0. Each 24-inch suture has a stainless-steel BB needle attached to one end of the suture.
Cypris eXact Sutures can be used with the Cypris eXact 5.1 Suture Placement Device, a handheld device used for the placement of a surgical suture.
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# INDICATIONS FOR USE
#### Cypris eXact Suture PP (Polypropylene)
The Cypris eXact Suture (PP) is indicated for use in general soft tissue approximation and/or ligation, including use in cardiovascular, ophthalmic and neurological procedures.
#### Cypris eXact Suture PTFE (Polytetraflouroethylene)
The Cypris eXact Suture (PTFE) is indicated for use in all types of soft tissue approximation and/or ligation, including dental and general surgeries.
#### Cypris eXact Suture PDO (Polydioxanone)
The Cypris eXact Suture (PDQ) is indicated for use in general soft tissue approximation and/or ligation, but not for use in cardiovascular or neurological tissues, microsurgery or ophthalmic surgery.
The Cypris eXact 5.1 Suture Placement Device can be used in conjunction with eXact Sutures, which are indicated for use in general soft tissue approximation and/or ligation.
# COMPARISON OF TECHNOLOGICAL CHARACTERISTICS
Cypris Medical believes that the Cypris eXact Suturing System is substantially equivalent to the predicate devices based on the information summarized here:
The Cypris eXact Sutures are equivalent to original equipment manufacturer (OEM) sutures currently produced under the Sharpoint (K131224 and K063680) and LOOK (K160744) brands. The Cypris eXact Suturing System sutures are identical in their final finished form in formulation, processing, sterilization, and geometry to the sutures previously cleared in K131224, K063680, and K160744. Given the Cypris eXact Sutures are identical to the predicate device, share the same intended use, and have equivalent technological performance characteristics, the Cypris eXact Sutures are considered substantially equivalent to the predicates.
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# SUBSTANTIAL EQUIVALENCE
The Cypris eXact Suture - PP (Polypropylene) is substantially equivalent in intended use and fundamental scientific technology as the Sharpoint Polypropylene Surgical Suture, LOOK Polypropylene Surgical Suture, Quill Polypropylene Knotless Tissue-Closure cleared under K131224 (May 16, 2013). The substantial equivalence table for the comparison of the subject and predicate device is provided below.
| | Subject Device | Predicate Device |
|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Cypris Medical, Inc. | Surgical Specialties Corp. |
| | Cypris eXact Suture - PP (Polypropylene) | Sharpoint Polypropylene Surgical Suture,<br>LOOK Polypropylene Surgical Suture, Quill<br>Polypropylene Knotless Tissue-Closure |
| | K233355 | K131224 |
| Indications for Use | The Cypris eXact Suture (PP) is indicated for<br>use in general soft tissue approximation and/or<br>ligation, including use in cardiovascular,<br>ophthalmic and neurological procedures. | Polypropylene suture is indicated for use in<br>general soft tissue approximation and/or<br>ligation, including use in cardiovascular,<br>ophthalmic and neurological procedures. |
| Regulation Number | 21 CFR 878.5010 | 21 CFR 878.5010 |
| Regulation Description | Nonabsorbable polypropylene surgical suture | Nonabsorbable polypropylene surgical<br>suture |
| Product Code/Name | GAW - Suture, Nonabsorbable, Synthetic,<br>Polypropylene | GAW - Suture, Nonabsorbable, Synthetic,<br>Polypropylene |
| Materials | Polypropylene Suture<br>Stainless Steel Needle | Polypropylene Suture<br>Stainless Steel Needle |
| Suture Construction | Monofilament | Monofilament |
| Suture Colorant | Phthalocyaninato (2-) Copper | Phthalocyaninato (2-) Copper |
| Suture Size(s) | USP sizes 3-0 and 4-0 | USP sizes 3-0 and 4-0 |
| Suture Diameter | All suture sizes meet USP <861><br>requirements for nonabsorbable surgical<br>sutures | All suture sizes meet USP <861><br>requirements for nonabsorbable surgical<br>sutures |
| Suture Tensile Strength | All suture sizes meet USP <881><br>requirements for nonabsorbable surgical<br>sutures | All suture sizes meet USP <881><br>requirements for nonabsorbable surgical<br>sutures |
| Needle Attachment<br>Strength | All suture sizes meet USP <871><br>requirements for nonabsorbable surgical<br>sutures | All suture sizes meet USP <871><br>requirements for nonabsorbable surgical<br>sutures |
| Sterilization Method | Ethylene Oxide (EtO) | Ethylene Oxide (EtO) |
| Biocompatibility | Cytotoxicity, Sensitization, Irritation, Acute<br>Systemic Toxicity, Material-Mediated<br>Pyrogenicity, Subacute and Subchronic<br>Toxicity, Chronic Toxicity, Genotoxicity,<br>Carcinogenicity, and Implantation | Cytotoxicity, Sensitization, Irritation, Acute<br>Systemic Toxicity, Material-Mediated<br>Pyrogenicity, Subacute and Subchronic<br>Toxicity, Chronic Toxicity, Genotoxicity,<br>Carcinogenicity, and Implantation |
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Cypris eXact Suture - PTFE (Polytetraflouroethylene) is substantially equivalent in intended use and fundamental scientific technology as the LOOK PTFE Suture cleared in K160744 (July 13, 2016). The substantial equivalence table for the comparison of the subject and predicate device is provided below.
| | Subject Device | Predicate Device |
|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Cypris Medical, Inc. | Surgical Specialties Corp. |
| | Cypris eXact Suture - PTFE<br>(Polytetraflouroethylene) | LOOK PTFE Suture |
| | K233355 | K160744 |
| Indications for Use | The Cypris eXact Suture (PTFE) is indicated<br>for use in all types of soft tissue<br>approximation and/or ligation, including<br>dental and general surgeries. | PTFE (polytetrafluoroethylene) suture is<br>indicated for use in all types of soft tissue<br>approximation and/or ligation, including<br>dental and general surgeries. |
| Regulation Number | 21 CFR 878.5035 | 21 CFR 878.5035 |
| Regulation Description | Nonabsorbable expanded<br>polytetrafluoroethylene surgical suture | Nonabsorbable expanded<br>polytetrafluoroethylene surgical suture |
| Product Code/Name | NBY - Suture, Surgical, Nonabsorbable,<br>Expanded, Polytetraflouroethylene | NBY - Suture, Surgical, Nonabsorbable,<br>Expanded, Polytetraflouroethylene |
| Materials | Polytetraflouroethylene Suture<br>Stainless Steel Needle | Polytetraflouroethylene Suture<br>Stainless Steel Needle |
| Suture Construction | Monofilament | Monofilament |
| Suture Colorant | None | None |
| Suture Size(s) | USP sizes 2-0 and 3-0 | USP sizes 2-0 and 3-0 |
| Suture Diameter | All suture sizes meet USP <861><br>requirements for nonabsorbable surgical<br>sutures | All suture sizes meet USP <861><br>requirements for nonabsorbable surgical<br>sutures |
| Suture Tensile Strength | All suture sizes meet USP <881><br>requirements for nonabsorbable surgical<br>sutures | All suture sizes meet USP <881><br>requirements for nonabsorbable surgical<br>sutures |
| Needle Attachment<br>Strength | All suture sizes meet USP <871><br>requirements for nonabsorbable surgical<br>sutures | All suture sizes meet USP <871><br>requirements for nonabsorbable surgical<br>sutures |
| Sterilization Method | Ethylene Oxide (EtO) | Ethylene Oxide (EtO) |
| Biocompatibility | Cytotoxicity, Sensitization, Irritation, Acute<br>Systemic Toxicity, Material-Mediated<br>Pyrogenicity, Subacute and Subchronic<br>Toxicity, Chronic Toxicity, Genotoxicity,<br>Carcinogenicity, and Implantation | Cytotoxicity, Sensitization, Irritation, Acute<br>Systemic Toxicity, Material-Mediated<br>Pyrogenicity, Subacute and Subchronic<br>Toxicity, Chronic Toxicity, Genotoxicity,<br>Carcinogenicity, and Implantation |
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Cypris eXact Suture - PDO (Polydioxanone) is substantially equivalent in intended use and fundamental scientific technology as the Sharpoint PDO (polydioxanone) Sutures cleared in K063680 (May 9, 2007). The substantial equivalence table for the comparison of the subject and predicate device is provided below.
| | Subject Device | Predicate Device |
|-------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Cypris Medical, Inc. | Surgical Specialties Corp. |
| | Cypris eXact Suture - PDO (Polydioxanone)<br>K233355 | Sharpoint PDO (polydioxanone) Sutures<br>K063680 |
| Indications for Use | The Cypris eXact Suture (PDO) is indicated for<br>use in general soft tissue approximation and/or<br>ligation, but not for use in cardiovascular or<br>neurological tissues, microsurgery or<br>ophthalmic surgery. | Sharpoint PDO sutures are indicated for use<br>in general soft tissue approximation and/or<br>ligation, but not for use in cardiovascular,<br>or neurological tissues, microsurgery or<br>ophthalmic surgery. |
| Regulation Number | 21 CFR 878.4840 | 21 CFR 878.4840 |
| Regulation Description | Absorbable polydioxanone surgical suture | Absorbable polydioxanone surgical suture |
| Product Code/Name | NEW - Suture, Surgical, Absorbable,<br>Polydioxanone | NEW - Suture, Surgical, Absorbable,<br>Polydioxanone |
| Materials | Polydioxanone Suture<br>Stainless Steel Needle | Polydioxanone Suture<br>Stainless Steel Needle |
| Suture Construction | Monofilament | Monofilament |
| Suture Colorant | D&C No.2 | D&C No.2 |
| Suture Size(s) | USP sizes 3-0 and 4-0 | USP sizes 3-0 and 4-0 |
| Suture Diameter | All suture sizes meet USP <861> requirements<br>for absorbable surgical sutures | All suture sizes meet USP <861><br>requirements for absorbable<br>surgical sutures |
| Suture Tensile Strength | All suture sizes meet USP <881> requirements<br>for absorbable surgical sutures | All suture sizes meet USP <881><br>requirements for absorbable<br>surgical sutures |
| Needle Attachment<br>Strength | All suture sizes meet USP <871> requirements<br>for absorbable surgical sutures | All suture sizes meet USP <871><br>requirements for absorbable<br>surgical sutures |
| Sterilization Method | Ethylene Oxide (EtO) | Ethylene Oxide (EtO) |
| Biocompatibility | Cytotoxicity, Sensitization, Irritation, Acute<br>Systemic Toxicity, Material-Mediated<br>Pyrogenicity, Subacute and Subchronic<br>Toxicity, Chronic Toxicity, Genotoxicity,<br>Carcinogenicity, and Implantation. | Cytotoxicity, Sensitization, Irritation, Acute<br>Systemic Toxicity, Material-Mediated<br>Pyrogenicity, Subacute and Subchronic<br>Toxicity, Chronic Toxicity, Genotoxicity,<br>Carcinogenicity, and Implantation. |
#### SUMMARY OF NON-CLINICAL TESTING
The Cypris eXact Sutures were tested in accordance with the requirements of USP - absorbable and non-absorbable surgical sutures for suture diameter, tensile strength, and needle attachment, and meet the requirements of the Guidance for Industry and FDA Staff: Surgical Sutures - Class II Special Controls Guidance Document for Industry and FDA Staff (issued June 3, 2003). The Cypris eXact 5.1 Suture Placement Device was tested to evaluate the integrity of the sterile barrier and the functionality of the device following 3 years of real-time aging. While the shelflife of the Cypris eXact 5.1 Suture Placement Device is 3 years, the Cypris eXact Sutures have a shelf-life of 5 years.
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All materials used in the fabrication of the Cypris eXact Sutures were evaluated through biocompatibility testing as outlined in ISO 10993-1:2018 – Biological Evaluation of Medical Devices – Part I: Evaluation and Testing for an implanted device with Long Term (> 30 days) contact with tissue. The following biocompatibility endpoints were evaluated for the Cypris eXact Sutures: cytotoxicity, sensitization, acute systemic toxicity, material-mediated pyrogenicity, subacute and subchronic toxicity, chronic toxicity, genotoxicity, carcinogenicity, and implantation. The Cypris eXact 5.1 Suture Placement Device underwent biocompatibility testing as an external communicating device with limited contact (<24 hours) with tissue. The following biocompatibility endpoints were evaluated for the Cypris eXact 5.1 Suture Placement Device: cytotoxicity, sensitization, irritation, acute systemic toxicity, and material-mediated pyrogenicity.
# CONCLUSION
The Cypris eXact Sutures are substantially equivalent to the predicate devices because there are no differences in technological or performance characteristics between them. Biocompatibility data and the results of performance testing also demonstrate the substantial equivalence of the Cypris eXact Sutures to that of the predicate devices. Furthermore, the Cypris eXact Sutures demonstrate conformance with the USP. ISO, and FDA's Guidance for Surgical Sutures. The Cypris eXact Sutures can be used with the Cypris eXact 5.1 Suture Placement Device.
The Cypris eXact Suturing System is considered substantially equivalent to the predicate devices based on the testing performed, same intended use, and identical technological characteristics. The subject device does not raise new issues of safety or performance compared to the predicate devices.
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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.