Post-market surveillance data regarding the interaction of mask magnets with medical implants was used to identify a safety risk, leading to the addition of a new contraindication and an updated warning in the device labeling.
Post-market surveillance; Recall; Safety labeling update; Magnetic interference
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Post-market surveillance (Recall Event #94169); Post-market surveillance / Safety monitoring; Study Period: March 2024
Patients using masks with magnets and individuals in close physical contact with them
Not applicable for this study
Identification of potential risks to patients with active medical or metallic implants due to magnetic fields
Indications for Use
The Sleepnet Mojo 2 Full Face Vented Mask, Veraseal 3 Full Face Vented Mask, and V3 Full Face Vented Mask are intended to be used with positive airway pressure devices, such as CPAP or bi-level, operating at or above 3 cm H2O. The masks are to be used on adult patients (>30 kg.) for whom positive airway pressure therapy has been prescribed.
Device Story
Patient interface masks (Mojo 2, Veraseal 3, V3) for delivery of positive airway pressure therapy; used with CPAP or bi-level devices. Masks provide seal over nose and mouth; include exhalation port for CO2 flushing and anti-asphyxia valve for fault conditions (e.g., power failure). Used in home or hospital/institutional settings by adult patients. Devices are passive until connected to a blower. Magnets in mask/headgear clips facilitate attachment. Updated labeling includes contraindications and warnings regarding magnetic field interference with medical implants (e.g., pacemakers, ICDs) to prevent potential displacement or malfunction of implants. No physical device modifications made.
Clinical Evidence
No clinical data; bench testing only. Performance data from the predicate device was leveraged as the subject device design is identical.
Technological Characteristics
Full face vented masks with gel bladder, mask shell (soft or rigid), exhalation elbow with anti-asphyxia valve, and 4-point headgear. Materials identical to predicate. Permanent magnets (380mT field strength) used in headgear clips. Non-sterile. Cleaning via mild soap/water or isopropyl alcohol. ISO 10993-1 compliant for permanent surface/tissue contact.
Indications for Use
Indicated for adult patients (>30 kg) prescribed non-invasive positive airway pressure therapy (CPAP or bi-level) at or above 3 cm H2O. Contraindicated for patients or individuals in close physical contact with the mask who have active medical or metallic implants (e.g., pacemakers, ICDs, neurostimulators, aneurysm clips, metallic stents, ocular implants, insulin pumps, CSF shunts, cochlear implants, dental implants, metallic cranial plates) that may interact with magnets.
Regulatory Classification
Identification
A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.
Predicate Devices
Mojo 2 Full Face Vented Mask, Veraseal 3 Full Face Vented Mask, V3 Full Face Vented Mask (K190254)
Submission Summary (Full Text)
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
July 10, 2024
Sleepnet Corporation % Paul Dryden President ProMedic. LLC 131 Bay Point Dr NE St. Petersburg, Florida 33704
Re: K241661
Trade/Device Name: Mojo 2 Full Face Vented Mask; Veraseal 3 Full Face Vented Mask; V3 Full Face Vented Mask Regulation Number: 21 CFR 868.5905 Regulation Name: Noncontinuous Ventilator (IPPB) Regulatory Class: Class II Product Code: BZD Dated: June 6, 2024 Received: June 10, 2024
Dear Paul Dryden:
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.
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 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,
Digitally signed by Binoy J.
Binoy J. Mathews -S Mathews -S
Date: 2024.07.10 10:34:29 -04'00'
For
Rachana Visaria Assistant Director
{2}------------------------------------------------
DHT1C: Division of Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental 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) K241661
Device Name Mojo 2, Veraseal 3, V3 Full Face Vented Mask
#### Indications for Use (Describe)
The Sleepnet Mojo 2 Full Face Vented Mask, Veraseal 3 Full Face Vented Mask, and V3 Full Face Vented Mask are intended to be used with positive airway pressure devices, such as CPAP or bi-level, operating at or above 3 om H2O.
The masks are to be used on adult patients (>30 kg.) for whom positive airway pressure therapy has been prescribed.
Veraseal 3 -Disposable single use (hospital/institutional) Single patient, multi-use up to 7 days (hospital/institutional)
V3 -Single patient, multi-use (home)
Mojo 2 -Single patient, multi-use (home or hospital/institutional)
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<br>Page 1 of 10 | |
|--------------------------------|-------------------------------------------------------------------------------------------------------------------|
| Date Prepared: | July 8, 2024 |
| Sponsor: | Sleepnet Corporation<br>5 Merrill Industrial Drive<br>Hampton, NH 03842<br>Tel - 603-758-6625 |
| Sponsor Contact: | Jennifer Kennedy - Director of Regulatory and Quality |
| Submission Correspondent: | Paul Dryden<br>ProMedic, LLC |
| Proprietary or Trade Name: | Mojo 2 Full Face Vented Mask<br>Veraseal 3 Full Face Vented Mask<br>V3 Full Face Vented Mask |
| Common/Usual Name: | Patient Interface |
| Classification Name: | Noncontinuous Ventilator (IPPB)<br>21 CFR 868.5905 |
| Product Code: | BZD |
| Predicate Device: | Mojo 2 Full Face Vented Mask<br>Veraseal 3 Full Face Vented Mask<br>V3 Full Face Vented Mask |
| 510(k): | K190254 |
| Common/Usual Name: | Patient Interface |
| Classification Name: | Noncontinuous Ventilator (IPPB)<br>21 CFR 868.5905 |
| Product Code: | BZD |
| Veraseal 3 | Disposable single use (hospital/institutional)<br>Single patient, multi-use up to 7 days (hospital/institutional) |
| V3 | Single patient, multi-use (home) |
| Mojo 2 | Single patient, multi-use (home or hospital/institutional) |
| <b>Patient Population:</b> | For adult patients (>30 kg). |
| <b>Environments of use:</b> | Home or hospital / institutional environments. |
## Device Description:
The Sleepnet Veraseal 3, V3 and Mojo 2 Full Face Vented masks are identical to the predicate Veraseal 3, V3, and Mojo 2 Full Face Vented masks (K190254).
The subject of this submission is:
- Addition of a contraindication related to magnets on the Mojo 2 Full Face Vented mask .
- . Update to the warning related to magnets on the Mojo 2 Full Face Vented mask
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### Principle of Operation:
The subject devices provide a seal around the nose and mouth, and act as a patient interface for positive pressure air delivery.
### Indications for Use:
The Sleepnet Mojo 2 Full Face Vented Mask, Veraseal 3 Full Face Vented Mask, and V3 Full Face Vented Mask are intended to be used with positive airway pressure devices, such as CPAP or bilevel, operating at or above 3 cm H2O.
The masks are to be used on adult patients (>30 kg.) for whom positive airway pressure therapy has been prescribed.
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## 510(k) Summary Page 3 of 10
| Attributes | Subject - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Predicate - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Explanation of Differences |
|------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------|
| 510(k) | | K190254 | |
| Product Classification | BZD | BZD | Identical |
| CFR | Noncontinuous ventilator (IPPB)<br>CFR 868.5905 | Noncontinuous ventilator (IPPB)<br>CFR 868.5905 | Identical |
| Indications for Use | The Sleepnet Mojo 2 Full Face Vented Mask,<br>Veraseal 3 Full Face Vented Mask, and V3<br>Full Face Vented Mask are intended to be<br>used with positive airway pressure devices,<br>such as CPAP or bi-level, operating at or<br>above 3 cm H2O. | The Sleepnet Mojo 2 Full Face Vented Mask,<br>Veraseal 3 Full Face Vented Mask, and V3<br>Full Face Vented Mask are intended to be<br>used with positive airway pressure devices,<br>such as CPAP or bi-level, operating at or<br>above 3 cm H2O. | Identical |
| | The masks are to be used on adult patients<br>(>30 kg.) for whom positive airway pressure<br>therapy has been prescribed. | The masks are to be used on adult patients<br>(>30 kg.) for whom positive airway pressure<br>therapy has been prescribed. | Identical |
| | Veraseal 3 -<br>Disposable single use (hospital/institutional)<br>Single patient, multi-use up to 7 days<br>(hospital/institutional) | Veraseal 3 -<br>Disposable single use (hospital/institutional)<br>Single patient, multi-use up to 7 days<br>(hospital/institutional) | |
| | V3 -<br>Single patient, multi-use (home or<br>hospital/institutional)<br>Mojo 2 -<br>Single patient, multi-use (home or<br>hospital/institutional) | V3 -<br>Single patient, multi-use (home or<br>hospital/institutional)<br>Mojo 2 -<br>Single patient, multi-use (home or<br>hospital/institutional) | |
| Patient Population | Adult (>30 kg) | Adult (>30 kg) | Identical |
| Patient type | Patients who have been prescribed non-<br>invasive pressure therapy such as CPAP or bi-<br>level therapy | Patients who have been prescribed non-<br>invasive pressure therapy such as CPAP or bi-<br>level therapy | Identical |
| Prescriptive | Yes | Yes | Identical |
| Principle of Operation | Provides a seal over the face (nose and mouth)<br>to allow for delivery of pressurized air from a | Provides a seal over the face (nose and mouth)<br>to allow for delivery of pressurized air from a | Identical |
| Attributes | Subject - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Predicate - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Explanation of Differences |
| | CPAP blower. Includes an exhalation port for<br>flushing out exhaled CO2 during normal<br>operation, and anti-asphyxia valve for flushing<br>out exhaled CO2 during Fault condition (e.g.<br>power failure) | CPAP blower. Includes an exhalation port for<br>flushing out exhaled CO2 during normal<br>operation, and anti-asphyxia valve for flushing<br>out exhaled CO2 during Fault condition (e.g.<br>power failure) | |
| | The device is passive until connected to the<br>CPAP blower | The device is passive until connected to the<br>CPAP blower | |
| Therapy Pressure | Determined by equipment to which it is<br>attached, but typically 3 to 25 cm H2O | Determined by equipment to which it is<br>attached, but typically 3 to 25 cm H2O | Identical |
| Anatomical site | Face (seals around nose and mouth) | Face (seals around nose and mouth) | Identical |
| Environment of Use | The masks are intended for use in the home or<br>hospital/institutional environment. | The masks are intended for use in the home or<br>hospital/institutional environment. | Identical |
| Duration of Use | Veraseal 3<br>Disposable, single patient use<br>Single patient, multi-use up to 7 days<br>Mojo 2<br>Single patient, multi-use<br>V3<br>Single patient, multi-use | Veraseal 3<br>Disposable, single patient use<br>Single patient, multi-use up to 7 days<br>Mojo 2<br>Single patient, multi-use<br>V3<br>Single patient, multi-use | Identical |
| Useful life | Veraseal 3 -<br>Single patient use disposable<br>Up to 7 days<br>V3 -<br>Single patient use - 6 months<br>Mojo 2 -<br>Single patient use - 6 months | Veraseal 3 -<br>Single patient use disposable<br>Up to 7 days<br>V3 -<br>Single patient use - 6 months<br>Mojo 2 -<br>Single patient use - 6 months | Identical |
| Non-sterile | Yes | Yes | Identical |
| Cleaning methods | • Mild Soap (such as Ivory) and water<br>• Isopropyl alcohol | • Mild Soap (such as Ivory soap) and<br>water<br>• Isopropyl alcohol | Identical |
| Attributes | Subject - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Predicate – Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Explanation of Differences |
| Features | | | |
| Available sizes | 4 | 4 | Identical |
| Shape | Identical | Identical | Identical |
| Incorporates an Exhaust<br>elbow | Yes | Yes | Identical |
| Components of mask | • Mask shell (soft or rigid)<br>• Gel bladder<br>• Exhalation elbow with Anti-asphyxia<br>valve<br>• 4-point headgear | • Mask shell (soft or rigid)<br>• Gel bladder<br>• Exhalation elbow with Anti-asphyxia<br>valve<br>• 4-point headgear | Identical |
| Shell design | Veraseal 3 and V3<br>Rigid<br>Mojo 2<br>Soft | Veraseal 3 and V3<br>Rigid<br>Mojo 2<br>Soft | Identical |
| Patient Contact per<br>ISO 10993-1 | Surface contact, skin<br>Externally Communicating, Tissue<br>Permanent Duration of Use | Surface contact, skin<br>Externally Communicating, Tissue<br>Permanent Duration of Use | Identical safety profile and<br>materials |
| Contraindications | New Contraindication (Mojo 2 only)<br>Do not use this mask if you or anyone<br>(example: household members, bed<br>partners, caregivers, etc.) in close physical<br>contact with your mask has an active<br>medical implant or metallic implant that<br>will interact with magnets. Implant<br>examples include, but are not limited to,<br>pacemakers, implantable cardioverter<br>defibrillators (ICD), neurostimulators,<br>aneurysm clips, metallic stents, ocular<br>implants, insulin/infusion pumps, cerebral | None | New as per recall event<br>#94169. Original K190254<br>labeling available in Section<br>006_Labeling. |
| Attributes | Subject - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Predicate – Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Explanation of Differences |
| | spinal fluid (CSF) shunts, embolic coils,<br>metallic splinter, implants to restore<br>hearing or balance with implanted<br>magnets (such as cochlear implants), flow<br>disruption devices, contact lenses with<br>metal, dental implants, metallic cranial<br>plates, screws, burr hole covers, bone<br>substitute device, magnetic metallic<br>implants/electrodes/valves placed in upper<br>limbs, torso, or higher, etc. If you have<br>any questions regarding the implant,<br>consult your physician or the<br>manufacturer of your implant. | | |
| Warning | Updated Warning: (Mojo 2 only)<br>Magnets are used in the mask and headgear<br>clips with a field strength of 380mT. With<br>the exception of the devices identified in<br>the contraindication, ensure that the mask<br>is kept at least 6 inches (approx.16 cm)<br>away from any other medical implants or<br>medical devices that can be impacted by<br>the magnetic fields to avoid possible<br>effects from localized magnetic fields. For<br>instance, the functioning of implants may<br>change, or implants may move within the<br>body due to magnetic attraction/repulsion.<br>This applies to you or anyone in close<br>physical contact with your mask. | | Updated as per recall event<br>#94169. Original K190254<br>labeling available in Section<br>006_Labeling. |
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## 510(k) Summary Page 4 of 10
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## 510(k) Summary Page 5 of 10
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## 510(k) Summary Page 6 of 10
{10}------------------------------------------------
## 510(k) Summary Page 7 of 10
| Attributes | Subject – Mojo 2, Veraseal 3, V3 Full Face Vented Mask | | Predicate – Mojo 2, Veraseal 3, V3 Full Face Vented Mask | | Explanation of Differences |
|---------------------------------------|--------------------------------------------------------------------|------------|--------------------------------------------------------------------|------------|----------------------------|
| | | | | | |
| CO2 washout profile<br>ISO 17510:2015 | Veraseal 3 / V3 / Mojo 2 -<br>Setting etCO2(%increase vs baseline) | | Veraseal 3 / V3 / Mojo 2 -<br>Setting etCO2(%increase vs baseline) | | Identical |
| | 3 cmH2O | 6.0 (15 %) | 3 cmH2O | 6.0 (15 %) | |
| | 5 cmH2O | 6.0 (15 %) | 5 cmH2O | 6.0 (15 %) | |
| | 10 cmH2O | 5.8 (12 %) | 10 cmH2O | 5.8 (12 %) | |
| | SingleFault1 | 6.3 (21 %) | SingleFault1 | 6.3 (21 %) | |
| | SingleFault2 | 7.7 (48 %) | SingleFault2 | 7.7 (48 %) | |
| Dead space (nominal ml) | Mojo 2 | | Mojo 2 | | Identical |
| Small | 179 ml | | 179 ml | | |
| Medium | 190 ml | | 190 ml | | |
| Large | 207 ml | | 207 ml | | |
| Ex-Large (XL) | 220 ml | | 220 ml | | |
| | Veraseal 3 / V3 | | Veraseal 3 / V3 | | |
| | 184 ml | | 184 ml | | |
| | 193 ml | | 193 ml | | |
| | 209 ml | | 209 ml | | |
| | 220 ml | | 220 ml | | |
| Exhaust - pressure / flow | Mojo 2 | | Mojo 2 | | Identical |
| | Pressure (cmH2O) | Flow (lpm) | Pressure (cmH2O) | Flow (lpm) | |
| | 3 | 20.50 | 3 | 20.50 | |
| | 10 | 36.30 | 10 | 36.30 | |
| | 20 | 52.80 | 20 | 52.80 | |
| | Veraseal 3 / V3 | | Veraseal 3 / V3 | | |
| | Pressure (cmH2O) | Flow (lpm) | Pressure (cmH2O) | Flow (lpm) | |
| | 3 | 21.50 | 3 | 21.50 | |
| | 10 | 36.80 | 10 | 36.80 | |
| | 20 | 54.40 | 20 | 54.40 | |
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## 510(k) Summary Page 8 of 10
| Attributes | Subject - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Predicate - Mojo 2, Veraseal 3, V3 Full<br>Face Vented Mask | Explanation of Differences |
|-----------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|
| Pressure AAV<br>Opening / closing | Mojo 2<br>Opening - 1.35 cm H2O<br>Closing - 1.72 cm H2O<br>Veraseal 3 / V3<br>Opening - 1.45 cm H2O<br>Closing - 1.80 cm H2O | Mojo 2<br>Opening - 1.35 cm H2O<br>Closing - 1.72 cm H2O<br>Veraseal 3 / V3<br>Opening - 1.45 cm H2O<br>Closing - 1.80 cm H2O | Identical |
| AAV Inspiratory/Expiratory<br>Resistance in Single Fault<br>Condition | Mojo 2<br>Inspiratory - 0.8 cm H2O<br>Expiratory - 0.8 cm H2O<br>Veraseal 3/ V3<br>Inspiratory - 0.8 cm H2O<br>Expiratory - 0.8 cm H2O | Mojo 2<br>Inspiratory - 0.8 cm H2O<br>Expiratory - 0.8 cm H2O<br>Veraseal 3/ V3<br>Inspiratory - 0.8 cm H2O<br>Expiratory - 0.8 cm H2O | Identical |
| Resistance to Flow | Mojo 2<br>50 lpm - 0.25 cm H2O<br>100 lpm - 0.50 cm H2O<br>Veraseal 3/ V3<br>50 lpm - 0.23 cm H2O<br>100 lpm - 0.48 cm H2O | Mojo 2<br>50 lpm - 0.25 cm H2O<br>100 lpm - 0.50 cm H2O<br>Veraseal 3/ V3<br>50 lpm - 0.23 cm H2O<br>100 lpm - 0.48 cm H2O | Identical |
| Sound Pressure and sound<br>Power Level | Mojo 2<br>Sound Pressure - 30.07 dBA<br>Sound Power - 33.09 dBA<br>Veraseal 3/ V3<br>Sound Pressure - 29.98 dBA<br>Sound Power - 32.99 dBA | Mojo 2<br>Sound Pressure - 30.07 dBA<br>Sound Power - 33.09 dBA<br>Veraseal 3/ V3<br>Sound Pressure - 29.98 dBA<br>Sound Power - 32.99 dBA | Identical |
{12}------------------------------------------------
### Substantial Equivalence Discussion
The table above compares the key features of the subject devices with the identified predicate - K190254. The subject and predicate devices are identical- the only difference between the devices within this submission is the addition of a contraindication and warning pertaining to the presence of permanent magnets within the mask.
#### Indications for Use -
The indications for use are identical for the subject device when compared to the predicate device - K190254. Discussion - The indications for use are identical.
#### Technology and construction -
The technology and principle of operation is identical for the subject device when compared to the predicate device - K190254.
Discussion - Both the subject and predicate device have identical principles of operation.
#### Environment of Use -
The environments of use are identical to the predicate device - K190254. Discussion - The environments of use are the identical.
#### Patient Population -
The patient population is identical to the predicate device - K190254. Discussion - The subject and predicate device patient populations are identical.
### Non-Clinical Testing Summary -
#### Bench testing -
No new performance testing was conducted on the subject device, since the device designs are identical to the predicates.
Discussion - The performance test results from the predicate device were leveraged for the subject device.
#### Biocompatibility -
There has been no change in the materials - the subject and predicate device utilize the same materials.
Discussion - The biocompatibility test results from the predicate device were leveraged for the subject device.
#### Reprocessing -
There has been no change in the reprocessing - the subject and predicate device utilize the same reprocessing instructions.
Discussion - The reprocessing test results from the predicate device were leveraged for the subject device.
{13}------------------------------------------------
#### Discussion of Differences
The subject device includes a new contradiction and updated warning, which was not included in the predicate device – K190254. There are no other differences between the subject and predicate devices.
In March 2024, Sleepnet underwent a voluntary recall (Event 94169) of its masks that contained magnets. Specifically, the subject device was part of this recall. This recall was initiated based on information obtained from post market surveillance indicating a possible risk to patients and anyone in close physical contact with the subject device, having an active medical implant or metallic implant that can be impacted by the magnetic field.
The magnets in these masks provide a quick and easy method of attaching and detaching the mask from the headgear. However, when a magnet comes into close proximity to certain medical implants or metallic implants, it could interfere with the performance or the position of the implant. This could potentially lead to serious injury or death.
Therefore. Sleepnet intends to update its contraindications and warnings as a proactive measure to provide additional safety information to patients and healthcare professionals. To date, there has been no Medical Device Reports associated with the Sleepnet masks with magnets.
Modifications Made to device: No modifications have been made to the device.
Modifications to Labeling:
The Instructions for Use (IFU) have been updated with the following new contraindication and revised warning statement.
#### New Contraindication
Do not use this mask if you or anyone (example: household members, bed partners, caregivers, etc.) in close physical contact with your mask has an active medical implant or metallic implant that will interact with magnets. Implant examples include, but are not limited to, pacemakers, implantable cardioverter defibrillators (ICD), neurostimulators, aneurysm clips, metallic stents, ocular implants, insulin/infusion pumps, cerebral spinal fluid (CSF) shunts, embolic coils, metallic splinter, implants to restore hearing or balance with implanted magnets (such as cochlear implants), flow disruption devices, contact lenses with metal, dental implants, metallic cranial plates, screws, burr hole covers, bone substitute device, magnetic metallic implants/electrodes/valves placed in upper limbs, torso, or higher, etc. If you have any questions regarding the implant, consult your physician or the manufacturer of your implant.
{14}------------------------------------------------
### Updated Warning
Magnets are used in the mask and headgear clips with a field strength of 380mT. With the exception of the devices identified in the contraindication, ensure that the mask is kept at least 6 inches (approx.16 cm) away from any other medical implants or medical devices that can be impacted by the magnetic fields to avoid possible effects from localized magnetic fields. For instance, the functioning of implants may change, or implants may move within the body due to magnetic attraction/repulsion. This applies to you or anyone in close physical contact with your mask.
#### Discussion of Differences
Apart from the contraindication and updated warning above, there are no other differences between the subject devices and the predicate K190254 devices.
### Substantial Equivalence Conclusion
The Sleepnet Mojo 2 Full Face Vented Mask, Veraseal 3 Full Face Vented Mask, and V3 Full Face Vented Mask have identical indications, technological characteristics and principles of operation and performance to the predicate and performance testing demonstrates that the subject device is substantially equivalent to the predicate.
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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.