K240917 · Wallaby Medical · NRY · Oct 1, 2024 · Cardiovascular
Device Facts
Record ID
K240917
Device Name
Esperance 3+ Aspiration Catheter System
Applicant
Wallaby Medical
Product Code
NRY · Cardiovascular
Decision Date
Oct 1, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.1250
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Esperance 3+ Aspiration Catheter with the Wallaby Aspiration Tubing set and a compatible aspiration pump is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
Device Story
Single-use, non-active, vascular aspiration catheter system; used for revascularization in acute ischemic stroke. Device consists of a variable stiffness, composite catheter with tapered shaft (0.054" to 0.041" ID; 0.066" to 0.050" OD) and hydrophilic coating. Operated by trained physicians in hospital settings under fluoroscopic guidance. Input: vacuum pressure from compatible aspiration pump. Transformation: catheter provides suction path to remove thrombus from intracranial vessels. Output: physical removal of clot. Benefits: restores blood flow in occluded vessels. System includes aspiration tubing, introducer sheath, shaping mandrel, and rotating hemostasis valve.
Clinical Evidence
No clinical data provided. Substantial equivalence established via non-clinical bench testing.
Indicated for revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (internal carotid, middle cerebral M1/M2, basilar, vertebral arteries) within 8 hours of symptom onset. Candidates include patients ineligible for or failing IV t-PA therapy.
Regulatory Classification
Identification
A percutaneous catheter is a device that is introduced into a vein or artery through the skin using a dilator and a sheath (introducer) or guide wire.
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October 1, 2024
Wallaby Medical Rachel McDaid Senior Regulatory Affairs Specialist 22901 Mill Creek Drive Laguna Hills, California 92653
Re: K240917
Trade/Device Name: Esperance 3+ Aspiration Catheter System Regulation Number: 21 CFR 870.1250 Regulation Name: Percutaneous Catheter Regulatory Class: Class II Product Code: NRY Dated: August 30, 2024 Received: August 30, 2024
Dear Rachel McDaid:
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.
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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" (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 QS 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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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.
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/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-regulatory
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assistance/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,
# Naira Muradyan -S
Naira Muradyan, Ph.D. Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional, and Neurodiagnostic 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) K240917
Device Name Esperance 3+ Aspiration Catheter System
#### Indications for Use (Describe)
The Esperance 3+ Aspiration Catheter with the Wallaby Aspiration Tubing set and a compatible aspiration pump is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------|
| <div style="display:flex; align-items:center;"><span>☒</span> Prescription Use (Part 21 CFR 801 Subpart D)</div> | <div style="display:flex; align-items:center;"><span>☐</span> Over-The-Counter Use (21 CFR 801 Subpart C)</div> |
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Image /page/4/Picture/1 description: The image shows the logo for Wallaby Medical. The logo consists of a green and blue circle with a white design inside, followed by the text "沃比医疗" in Chinese characters, with "Wallaby Medical" written below in English. The text is also in green and blue, matching the colors of the circle.
### K240917 510(k) Summary (21 CFR 807.92)
### I. SUBMITTER
Wallaby Medical 22901 Mill Creek Drive Laguna Hills, California 92653
Contact Person: Rachel McDaid Phone: +353 (0)91 740128 Date Prepared: September 30, 2024
### II. DEVICE
Device Trade Name: Esperance 3+ Aspiration Catheter System Common or Usual Name: Catheter, Thrombus Retriever Classification: Class II Regulation Number: 21 CFR 870.1250 Product Code: NRY
### III. PREDICATE DEVICE
Name: Penumbra System MAX Manufacturer: Penumbra, Inc. 510(k) number: K113163
### IV. DEVICE DESCRIPTION
### Device Description:
The Esperance® 3+ Aspiration Catheter is a single-use, vascular catheter consisting of a single lumen, variable stiffness, composite catheter. The device has a tapered shaft with tapered inner diameter (ID) from 0.054'' (proximal) to 0.041'' (distal) and tapered outer diameter (OD) from 0.066'' (proximal) to 0.050'' (distal). It has five different working lengths: 120 cm, 133 cm, 145 cm, 153 cm, and 160 cm. The device is supplied as a kit with the Wallaby Aspiration Tubing Set provided with a single catheter. The distal tip of each catheter is visible under fluoroscopy and the distal shaft of each catheter is designed with an external hydrophilic coating to reduce friction during use. The proximal end of each catheter incorporates a strain relief and a standard luer adapter to facilitate the attachment of accessories. Each catheter has a semi-rigid proximal shaft which transitions into a flexible distal shaft to facilitate the advancement of the catheter in tortuous anatomy.
The Esperance 3+ Aspiration Catheter System is a non-active, surgically invasive device intended for short term use within the neurovasculature.
### Environment of Use:
The Esperance 3+ Aspiration Catheter System is solely intended for use by trained physicians in a healthcare facility/hospital.
### V. INDICATIONS FOR USE
The Esperance 3+ Aspiration Catheter with the Wallaby Aspiration Tubing set and a compatible aspiration pump is intended for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within internal carotid, middle cerebral – M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy are candidates for treatment.
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Image /page/5/Picture/1 description: The image shows the logo for Wallaby Medical. The logo features a green and blue gradient circle with a white abstract design inside. To the right of the circle is the company name in both Chinese and English. The English name, "Wallaby Medical," is written in a green and blue gradient font.
The Indications for Use statement of the subject device is similar to the predicate device. The differences do not raise new or different questions of safety or effectiveness.
## Table 1: Comparison of Indications for Use of the Esperance 3+ Aspiration Catheter System with the predicate and reference devices
| Parameter | Reference Device<br>Esperance Aspiration<br>Catheter System (K211697) | Predicate Device<br>Penumbra System MAX<br>(K113163) | Subject Device<br>Esperance 3+ Aspiration<br>Catheter System<br>(K240917) | |
|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| Indications for<br>Use | The Esperance Aspiration<br>Catheter with the Medela<br>Dominant Flex Surgical<br>Suction Pump and<br>Wallaby Aspiration Tubing<br>set is intended for use in<br>the<br>revascularization of<br>patients with acute<br>ischemic stroke secondary<br>to intracranial large vessel<br>occlusive disease (within<br>internal carotid, middle<br>cerebral – M1 and M2<br>segments, basilar, and<br>vertebral arteries) within 8<br>hours of symptom onset.<br>Patients who are ineligible for<br>intravenous tissue<br>plasminogen activator (IV-<br>tPA) or who fail IV t-PA<br>therapy are candidates for<br>treatment. | The Penumbra System<br>is intended for use in<br>the revascularization of<br>patients with acute<br>ischemic stroke<br>secondary to<br>intracranial large vessel<br>occlusive disease (in<br>the internal carotid,<br>middle cerebral – M1<br>and M2 segments,<br>basilar, and vertebral<br>arteries) within 8 hours<br>of symptom onset. | The Esperance 3+<br>Aspiration Catheter with<br>the Wallaby Aspiration<br>Tubing set and a<br>compatible aspiration<br>pump is intended for use<br>in the revascularization<br>of patients with acute<br>ischemic stroke<br>secondary to intracranial<br>large vessel occlusive<br>disease (within internal<br>carotid, middle cerebral<br>– M1 and M2 segments,<br>basilar, and vertebral<br>arteries) within 8 hours of<br>symptom onset. Patients<br>who are ineligible for<br>intravenous tissue<br>plasminogen activator (IV<br>t-PA) or who fail IV t-PA<br>therapy are candidates for<br>treatment. | |
| Parameter | Reference Device<br>(K211697) | Predicate Device<br>(K113163) | Subject Device<br>(K240917) | |
| Device Name | Esperance Aspiration<br>Catheter System | Penumbra System<br>MAX | Esperance 3+ Aspiration<br>Catheter System | |
| Model # | ASP6F131KIT<br>ASP6F125KIT<br>ASP6F115KIT<br>ASP6F131<br>ASP6F125<br>ASP6F115 | 6F<br>3MAXC | ASP3F160KIT<br>ASP3F153KIT<br>ASP3F145KIT<br>ASP3F133KIT<br>ASP3F120KIT | |
| | ASP5F131KIT<br>ASP5F125KIT<br>ASP5F115KIT<br>ASP5F131<br>ASP5F125<br>ASP5F115 | 5F | | |
| 510(k) Number | K211697 | K113163 | K240917 | |
| Classification | Class II | Class II | Class II | |
| Product Code | NRY | NRY | NRY | |
| Device<br>Design/Materials | Nitinol braided shaft,<br>nitinol coil, polymeric<br>exterior | Stainless steel and<br>Nitinol coiled shaft,<br>polymeric exterior | Inner shaft:<br>Stainless steel braided<br>shaft, Nitinol coil<br>Outer layer:<br>Polymeric exterior Tecoflex<br>(thermoplastic<br>polyurethane), Pellethane<br>(thermoplastic<br>polyurethane), Pebax<br>(polyether block amide),<br>Vestamid (polyamide)<br>Inner layer: PTFE<br>Hub: Polyamide | |
| Wire<br>Reinforcement | Nitinol coil and braid | Stainless steel and<br>Nitinol coiled shaft | Stainless steel<br>braided shaft,<br>Nitinol coil | |
| Strain Relief | Thermoplastic<br>vulcanizate,<br>polypropylene | Unknown | Silicone | |
| Colorant | Natural or Green or<br>Blue | Unknown | Green/Blue/White | |
| | Tip Configuration | | | |
| | Straight, steam shapeable by user | Straight, steam shapeable by user | Straight, steam shapeable by user | |
| Marker Band Material/ Radiopacity | Radiopaque C-cut Platinum/Iridium | Radiopaque | Radiopaque Platinum/Iridium | |
| Hub Material | Nylon | Unknown | Polyamide | |
| Coating and Length | Hydrophilic coating Length: 60 cm | Hydrophilic coating Length: 95 cm | Hydrophilic coating Length: 100 cm | |
| Working Length | 115 cm<br>125 cm<br>131 cm | 153 cm | 120 cm<br>133 cm<br>145 cm<br>153 cm<br>160 cm | |
| Outer Diameter | 6F 0.084" Distal<br>0.084" Proximal<br>5F 0.065" Distal<br>0.069" Proximal | 0.050" Distal<br>0.062" Proximal | 0.050" Distal<br>0.066" Proximal | |
| Inner Diameter | 6F 0.070"<br>5F 0.054" | 0.035" min | 0.041" Distal<br>0.054" Proximal | |
| Use | Single Use Device | Single Use Device | Single Use Device | |
| Sterilization | Ethylene Oxide | Ethylene Oxide | Ethylene Oxide | |
| Shelf Life | 12 months | Unknown | 12 months | |
| Accessory Devices | Aspiration Tubing<br>Introducer Sheath<br>Shaping Mandrel<br>Rotating Haemostasis Valve | Aspiration Tubing<br>Introducer Sheath<br>Shaping Mandrel<br>Rotating Haemostasis Valve | Aspiration Tubing<br>Introducer Sheath<br>Shaping Mandrel<br>Rotating Haemostasis Valve | |
| Aspiration Tubing Dimensions | 112 inch length<br>Tubing ID = 0.110 inch<br>Integrated valve for vacuum control | 112 inch length<br>Tubing ID = 0.110 inch | 112 inch length<br>Tubing ID = 0.110 inch<br>Integrated valve for vacuum control | |
| Aspiration Tubing Materials | Polyurethane & Nylon | Polyurethane & Nylon | Polyurethane & Nylon | |
| Packaging Components/ Configuration | Device is stored within a HDPE packaging hoop<br>Packaging hoop is contained within a sterile barrier Tyvek to nylon pouch<br>Packaged within a shipping carton | Supplied within a dispenser hoop<br>Dispenser hoop is contained within a sterile barrier pouch<br>Packaged within a shipping carton | Device is stored within a HDPE packaging hoop<br>Packaging hoop is contained within a sterile barrier Tyvek to nylon pouch<br>Packaged within a shipping carton | |
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Image /page/6/Picture/1 description: The image shows the logo for Wallaby Medical. The logo consists of a green and blue circle with a white design inside, followed by the text "Wallaby Medical" in green and blue. Above the text are Chinese characters in blue and green.
# VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
# Table 2: Comparison of technological characteristics of the Esperance 3+ Aspiration Catheter System with predicate and reference devices
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Image /page/7/Picture/0 description: The image shows the logo for Wallaby Medical. The logo features a green and blue color scheme. To the left is a green circular graphic with a white design inside. To the right of the graphic is the company name, with the Chinese characters above the English name.
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Image /page/8/Picture/1 description: The image contains the logo for Wallaby Medical. The logo consists of a circular graphic on the left, with a stylized image inside. To the right of the graphic is the company name in both Chinese and English. The English name, "Wallaby Medical", is written in a smaller font size below the Chinese characters.
### VII. PERFORMANCE DATA
### Biocompatibility
Biocompatibility testing for the Esperance 3+ Aspiration Catheter System was conducted based on International Organization for Standardization (ISO) 10993-1:2018 "Biological Evaluation of Medical Devices - Part 1: Evaluation and testing within a risk management process," and the FDA guidance document "Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices -Part 1: Evaluation and testing within a risk management process"" (2020).
Table 3 below summarizes biocompatibility testing performed on the Esperance 3+ Aspiration Catheter System and accessories to be marketed with the device.
| Test | Test Description | Conclusion |
|--------------------------------------------|-------------------------------------------------------------|---------------------------------------------------------------------------|
| | Esperance 3+ Aspiration Catheter Test Results | |
| Cytotoxicity<br>ISO 10993-5 | MTT- L929 Cytotoxicity Study | No cytotoxic effect. |
| Skin Irritation<br>ISO 10993-10 | ISO Intracutaneous Irritation | No sensitization indicated. |
| Sensitization<br>ISO 10993-10 | ISO Guinea Pig Maximization<br>Sensitization | No sensitization indicated. |
| Systemic Toxicity<br>ISO 10993-11 | ISO Acute Systemic Toxicity | No acute systemic toxicity indicated. |
| | ISO Material Mediated Rabbit<br>Pyrogen (GLP) | Esperance 3+ Aspiration Catheter is<br>deemed non-pyrogenic. |
| Hemocompatibility<br>ISO 10993-4 | Hemolysis (ASTM method) Indirect<br>Extract | No hemolysis indicated. |
| | ASTM Hemolysis - Direct Contact<br>and Extract Method (GLP) | No hemolysis indicated. |
| | Complement Activation | Esperance 3+ Aspiration<br>Catheter is deemed comparable<br>to predicate. |
| | Thromboresistance Evaluation | Esperance 3+ Aspiration Catheter is<br>deemed comparable to predicate. |
| | Partial Thromboplastin Time | Esperance 3+ Aspiration Catheter is<br>deemed comparable to predicate. |
| Accessory Test Results - Introducer Sheath | | |
| Cytotoxicity<br>ISO 10993-5 | ISO MEM elution- L929 | No cytotoxic effect. |
| Sensitization<br>ISO 10993-10 | ISO Guinea Pig Maximization<br>Sensitization | No sensitization indicated. |
| Skin Irritation<br>ISO 10993-10 | ISO Intracutaneous Irritation | No sensitization indicated. |
| Systemic Toxicity<br>ISO 10993-11 | Systemic Toxicity - Acute<br>Systemic Injection | No acute systemic toxicity indicated. |
#### Table 3: Biocompatibility Testing Results for the Esperance 3+ Aspiration Catheter System
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Image /page/9/Picture/0 description: The image shows the logo for Wallaby Medical. The logo consists of a green and blue gradient design. On the left is a green circle with a white design inside. To the right of the circle is the company name in both Chinese and English. The Chinese characters are in blue, and the English name "Wallaby Medical" is in green.
| | Material Mediated Pyrogenicity<br>Test | Test articles are deemed non-<br>pyrogenic. |
|----------------------------------------------------|-----------------------------------------------|---------------------------------------------|
| Hemocompatibility<br>ISO 10993-4 | ASTM Hemolysis -Extract Method | No hemolysis indicated. |
| Accessory Test Results - Wallaby Aspiration Tubing | | |
| Cytotoxicity<br>ISO 10993-5 | MTT- L929 Cytotoxicity Study | No cytotoxic effect. |
| Skin Irritation<br>ISO 10993-10 | ISO Intracutaneous Irritation | No sensitization indicated. |
| Sensitization<br>ISO 10993-10 | ISO Guinea Pig Maximization<br>Sensitization | No sensitization indicated. |
| Accessory Test Results - Rotating Hemostasis Valve | | |
| Cytotoxicity<br>ISO 10993-5 | ISO MEM elution- L929 | No cytotoxic effect. |
| Skin Irritation<br>ISO 10993-10 | ISO Intracutaneous Irritation | No sensitization indicated. |
| Sensitization<br>ISO 10993-10 | ISO Guinea Pig Maximization<br>Sensitization | No sensitization indicated. |
| Systemic Toxicity<br>ISO 10993-11 | ISO Acute Systemic Toxicity | No acute systemic toxicity indicated. |
| | ISO Material Mediated Rabbit<br>Pyrogen (GLP) | RHV is deemed non- pyrogenic. |
| Hemocompatibility<br>ISO 10993-4 | ASTM Hemolysis -Extract Method | No hemolysis indicated. |
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Image /page/10/Picture/0 description: The image contains the logo for Wallaby Medical. The logo consists of a green and blue gradient circle with a white abstract design inside. To the right of the circle is the company name in both Chinese characters and English. The English name "Wallaby Medical" is written in a smaller font size below the Chinese characters.
### Sterilization
The Esperance 3+ Aspiration Catheter System is sterilized by Ethylene Oxide. Sterilization takes place in Steris Sterilization Technologies (Suzhou) Ltd., Jiangsu, China. The sterilization cycle was verified to ensure a sterility assurance level (SAL) of 10-6.
The Esperance 3+ Aspiration Catheter System has been adopted into an existing validated cycle per EN ISO 11135:2014 and AAMI TIR28:2009.
### Standards utilized in regards to sterilization:
ISO 11135:2014 "Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices."
FDA guidance documents utilized in regards to sterilization:
"Submission and Review of Sterility Information in Premarket Notification (510(k)) Submissions for Devices Labelled as Sterile" (2016).
The sterilization cycle has been validated via the half cycle method.
### Shelf Life
Shelf life conditioning has been completed and testing has been performed on devices subjected to an accelerated aging (AA) process to represent 1 year of aged units. Devices subjected to 1 year AA were tested to ensure design and performance specification requirements were met after the one year shelf life that the Esperance 3+ Aspiration Catheter System will have at commercialization. Aging studies for the Esperance 3+ Aspiration Catheter System have established that the catheters and packaging remain functional for the labeled use by date. Aging studies for packaging integrity, seal strength, and device functionality were performed and met all acceptance criteria.
### FDA guidance documents utilized in regards to shelf life:
"Coronary, Peripheral, and Neurovascular Guidewires – Performance Tests and Recommended Labeling" (2019).
### Non-Clinical Performance Data
The following non-clinical performance tests were performed to support the substantial equivalence determination as summarized below.
### PERFORMANCE TESTING - BENCH
A full suite of bench performance testing was carried out on the Esperance 3+ Aspiration Catheter System. The results of this testing demonstrated compliance to all the design attributes and that the device performs as intended. Table 4 below summarizes the bench performance tests and results.
| Test | Test Method Summary | Results |
|----------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|
| Dimensional<br>Verification (Working<br>Length, Coating<br>Length, ID, OD) | The dimensions of the catheter and the<br>introducer sheath are measured. | All samples met the<br>acceptance criteria. |
| Test | Test Method Summary | Results |
| Navigability | The device is tested for its ability to reach target<br>site in an anatomical model in comparison to the<br>predicate. | All samples met the<br>acceptance criteria. |
| Clot Removal | The subject device is tested for its ability to<br>aspirate clots in an anatomical model in<br>comparison to the predicate. | All samples met the<br>acceptance criteria. |
| Kink Resistance | The catheter is tested at different locations<br>for its ability to bend to clinically relevant<br>radii without kinking in comparison to<br>predicate. | All samples met the<br>acceptance criteria. |
| Lubricity | The catheter's hydrophilic coating lubricity is<br>tested by applying force to the coated<br>section of the catheter and measuring the<br>frictional force in comparison to the<br>predicate. | All samples met the<br>acceptance criteria. |
| Coating Integrity | The coated length of the catheter is<br>inspected for defects post simulated use in<br>comparison to the predicate. | All samples met the<br>acceptance criteria. |
| Torque Strength | The catheter and predicate were evaluated<br>for torque strength by rotating the test<br>sample within an anatomical model until<br>failure while the distal tip was not free to<br>rotate. | All samples met the<br>acceptance criteria. |
| Delivery and Retrieval<br>Force | The subject device is tested for its ability to<br>reach and be retracted from a target site in<br>an anatomical model with application of<br>force below a specified value. Delivery and<br>retrieval forces were also compared to the<br>predicate device. | All samples met the<br>acceptance criteria. |
| Vacuum Resistance | The device is tested for its ability to<br>withstand a specified vacuum pressure for a<br>specified time without damage, lumen<br>collapse, or kink. | All samples met the<br>acceptance criteria. |
| Aspiration Flow Rate | The aspiration flow rate of the subject device<br>at a specified vacuum pressure was<br>measured in comparison to the predicate. | All samples met the<br>acceptance criteria. |
| Elongation<br>to<br>Failure | The catheter elongation at break was<br>obtained from the shaft tensile testing data. | All samples met the<br>acceptance criteria. |
| Test | Test Method Summary | Results |
| Tip Stiffness | The catheter tip is tested by bending in a test<br>fixture and measuring the maximum load<br>that caused deflection. Tip stiffness was also<br>compared to the predicate. | All samples met the<br>acceptance criteria. |
| Atraumatic Distal Tip | The catheter tip is inspected for smoothness. | All samples met the<br>acceptance criteria. |
| Tip Shaping Ability | The distal tip of the catheter is shaped using<br>the shaping mandrel supplied with the<br>Esperance 3+ Aspiration Catheter System and<br>the distal tip is assessed for damage and the<br>ability to hold the tip shape. | All samples met the<br>acceptance criteria. |
| Introducer Sheath<br>Compatibility | The supplied introducer sheath is tested for<br>compatibility with the Esperance 3+<br>Aspiration Catheter System. | All samples met the<br>acceptance criteria. |
| Device Compatibility | An appropriately sized guidewire is delivered<br>and retrieved through the catheter. The<br>catheter is delivered and retrieved through<br>an appropriately sized sheath. | All samples met the<br>acceptance criteria. |
| Surface Defects | The catheter and introducer sheath are<br>examined under magnification for<br>extraneous matter. | All samples met the<br>acceptance criteria. |
| Tensile Force | The peak tensile force of the subject catheter<br>is measured at different locations in<br>comparison to the predicate. | All samples met the<br>acceptance criteria. |
| Liquid Leakage | The subject catheter is tested for leakage per<br>ISO 10555-1 and compared to the reference<br>device. | All samples met the<br>acceptance criteria. |
| Air Leak | The subject catheter is tested for air leakage<br>per ISO 10555-1 and compared to the<br>reference device. | All samples met the<br>acceptance criteria. |
| Static Burst | The subject catheter is tested to withstand a<br>specified static pressure. | All samples met the<br>acceptance criteria. |
| Test | Test Method Summary | Results |
| Power Injection | The distal tip of the catheter was blocked,<br>and fluid was injected into the lumen using a<br>power injector until the catheter burst.…
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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.