K250742 · Focused Cryo, Inc. · GEH · Dec 9, 2025 · General, Plastic Surgery
Device Facts
Record ID
K250742
Device Name
Focused Cryotherapy System
Applicant
Focused Cryo, Inc.
Product Code
GEH · General, Plastic Surgery
Decision Date
Dec 9, 2025
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4350
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Focused Cryotherapy System is intended for cryoablative destruction of tissue during surgical procedures. The Focused Cryotherapy System is indicated for use as a cryosurgical tool in the fields of general surgery, dermatology, neurology (including cryoanalgesia), thoracic surgery (with the exception of cardiac tissue), ENT, gynecology, oncology, proctology, and urology. The system is designed to destroy tissue by the application of extreme cold temperatures including prostate and kidney tissue, liver metastases, nerves, tumors, and skin lesions. In addition, the system is intended for use in the following indications: Urology - Ablation of prostate tissue in cases of prostate cancer and Benign Prostate Hyperplasia (BPH) Oncology - Ablation of cancerous or malignant tissue and benign tumors, and palliative intervention. Palliation of pain associated with metastatic lesions involving bone in patients who have failed or are not candidates for standard radiation therapy Dermatology - Ablation or freezing of skin cancers and other cutaneous disorders - Destruction of warts or lesions, angiomas, sebaceous hyperplasia, basal cell tumors of the eyelid or canthus area, ulcerated basal cell tumors, dermatofibromas, small hemangiomas, mucocele cysts, multiple warts, plantar warts, actinic and seborrheic keratosis, cavernous hemangiomas, perianal condylomata, and palliation of tumors of the skin Gynecology - Ablation of malignant neoplasia or benign dysplasia of the female genitalia General surgery - Palliation of tumors of the rectum, anal fissures, pilonidal cysts, and recurrent cancerous lesions, ablation of breast fibroadenomas ENT - Palliation of tumors of the oral cavity and ablation of leukoplakia of the mouth Thoracic Surgery - (with the exception of cardiac tissue) Proctology - Ablation of benign or malignant growths of the anus or rectum Neurology - Freezing of nerve tissue in pain management/cryoanalgesia
Device Story
Cryoablation platform comprising console, single-use stainless steel probes, and software; utilizes high-pressure argon gas via Joule-Thomson effect for rapid cooling; probe tip incorporates heating element for directional ablation; console supports 4 probes in parallel; used in surgical settings by clinicians; provides circumferential or directionally-biased ablation zones; system monitors temperature via internal thermocouples; provides audible/visual alarms and emergency shutoff; facilitates cryonecrosis in tumors (<-40°C) and nerve conduction block (<-20°C); aids in tissue destruction for oncology, urology, dermatology, and pain management.
Clinical Evidence
Bench testing only. Verification included system functionality, mechanical integrity, electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), and software validation (IEC 62304). Validation included human factors (IEC 62366), sterilization (ISO 11135), biocompatibility (ISO 10993), ex-vivo porcine tissue testing for thermal performance, and head-to-head isotherm comparative testing against predicate. No clinical or animal studies performed.
Indicated for cryoablative tissue destruction in general surgery, dermatology, neurology (cryoanalgesia), thoracic surgery (excluding cardiac), ENT, gynecology, oncology, proctology, and urology. Patient populations include those with prostate cancer, BPH, benign/malignant tumors, skin lesions, and metastatic bone pain refractory to radiation.
Regulatory Classification
Identification
(1) Cryosurgical unit with a liquid nitrogen cooled cryoprobe and accessories. A cryosurgical unit with a liquid nitrogen cooled cryoprobe and accessories is a device intended to destroy tissue during surgical procedures by applying extreme cold. (2) Cryosurgical unit with a nitrous oxide cooled cryoprobe and accessories. A cryosurgical unit with a nitrous oxide cooled cryoprobe and accessories is a device intended to destroy tissue during surgical procedures, including urological applications, by applying extreme cold. (3) Cryosurgical unit with a carbon dioxide cooled cryoprobe or a carbon dioxide dry ice applicator and accessories. A cryosurgical unit with a carbon dioxide cooled cryoprobe or a carbon dioxide dry ice applicator and accessories is a device intended to destroy tissue during surgical procedures by applying extreme cold. The device is intended to treat disease conditions such as tumors, skin cancers, acne scars, or hemangiomas (benign tumors consisting of newly formed blood vessels) and various benign or malignant gynecological conditions affecting vulvar, vaginal, or cervical tissue. The device is not intended for urological applications.
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FDA U.S. FOOD & DRUG ADMINISTRATION
December 9, 2025
Focused Cryo, Inc.
Ryan Kruchten
VP of Engineering
1205 Johnson Ferry Road
Suite 136 - 336
Marietta, Georgia 30068
RE: K250742
Trade/Device Name: Focused Cryotherapy System
Regulation Number: 21 CFR 878.4350
Regulation Name: Cryosurgical Unit And Accessories
Regulatory Class: Class II
Product Code: GEH
Dated: November 7, 2025
Received: November 7, 2025
Dear Ryan Kruchten:
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.
U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov
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K250742 - Ryan Kruchten
Page 2
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 (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-reporting-combination-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-devices/device-advice-comprehensive-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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory-
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K250742 - Ryan Kruchten
Page 3
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,
JAMES H. JANG-S
Digitally signed
by JAMES H. JANG-S
Date: 2025.12.09
00:08:28 -05'00"
For
Colin Kejing Chen, Ph.D.
Acting Assistant Director
DHT4A: Division of General 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120
Expiration Date: 07/31/2026
See PRA Statement below.
Submission Number (if known)
K250742
Device Name
Focused Cryotherapy System
Indications for Use (Describe)
The Focused Cryotherapy System is intended for cryoablative destruction of tissue during surgical procedures. The Focused Cryotherapy System is indicated for use as a cryosurgical tool in the fields of general surgery, dermatology, neurology (including cryoanalgesia), thoracic surgery (with the exception of cardiac tissue), ENT, gynecology, oncology, proctology, and urology. The system is designed to destroy tissue by the application of extreme cold temperatures including prostate and kidney tissue, liver metastases, nerves, tumors, and skin lesions.
In addition, the system is intended for use in the following indications:
Urology
- Ablation of prostate tissue in cases of prostate cancer and Benign Prostate Hyperplasia (BPH)
Oncology
- Ablation of cancerous or malignant tissue and benign tumors, and palliative intervention. Palliation of pain associated with metastatic lesions involving bone in patients who have failed or are not candidates for standard radiation therapy
Dermatology
- Ablation or freezing of skin cancers and other cutaneous disorders
- Destruction of warts or lesions, angiomas, sebaceous hyperplasia, basal cell tumors of the eyelid or canthus area, ulcerated basal cell tumors, dermatofibromas, small hemangiomas, mucocele cysts, multiple warts, plantar warts, actinic and seborrheic keratosis, cavernous hemangiomas, perianal condylomata, and palliation of tumors of the skin
Gynecology
- Ablation of malignant neoplasia or benign dysplasia of the female genitalia
General surgery
- Palliation of tumors of the rectum, anal fissures, pilonidal cysts, and recurrent cancerous lesions, ablation of breast fibroadenomas
ENT
- Palliation of tumors of the oral cavity and ablation of leukoplakia of the mouth
Thoracic Surgery
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- (with the exception of cardiac tissue)
Proctology
- Ablation of benign or malignant growths of the anus or rectum
Neurology
- Freezing of nerve tissue in pain management/cryoanalgesia
Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801 Subpart C)
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FOCUSED CRYO
Focused Cryo, Inc.
101 Nerem St NW
Suite 1000
Atlanta, GA 30313
# PREMARKET NOTIFICATION
K250742 510(k) Summary
Focused Cryotherapy System
The following information is provided as required per 21 CFR 807.92
1. Submitter's Name:
Focused Cryo, Inc.
101 Nerem St. NW
Suite 1000
Atlanta, GA 30313
Contact Name: Mr. Ryan Kruchten, VP of Engineering
Phone: 952-484-3166
E-mail: rkruchten@focusedcryo.com
Date Prepared: December 4, 2025
2. Device Information:
Proprietary Name: Focused Cryotherapy System
Common/Usual Name: Cryosurgical unit and accessories
Classification Name: Cryosurgical unit and accessories
Regulation Number: 21 CFR 878.4350
Product Code: GEH
3. Predicate Devices:
Primary: CRYOCARE TOUCH™ System and Accessories (K201588)
Secondary: Visual-ICE Cryoablation System (K230551)
4. Device Description:
The Focused Cryotherapy System is a cryoablation platform that contains the following components:
- Probe (FC-2021CD01)
- Console (FC-AR401)
- Software
The Focused Cryotherapy System is a cryoablation platform for use in the cryoablation of nerves and tumors. The Probe is a handheld, single use, cryosurgical instrument. The
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Probe utilizes a high-pressure cryogen (argon gas) to freeze target tissues, creating an inflammatory response, and ultimately, cryonecrosis. In use with tumors, temperatures below -40°C is the temperature at which intracellular ice formation occurs which is lethal for cells. When applied to nerves, temperatures below -20°C cause extracellular ice formation along axonal tubes which causes cessation of action potential conduction. When high pressure argon gas is supplied to the Probe via the Console, rapid cooling is achieved via the Joule-Thomson effect. The Probe incorporates a heating element to facilitate directional cryoablation. The Console has combination gas/electrical ports to handle 4 Probes in parallel. The Console contains the Firmware and Software. The System consists of a main chassis (Console) for the cooling system, Firmware, Software, controls, touch screen and Probe ports. Safety measures of the system include audible and visual alarms, safety valves, and emergency shutoff button.
## 5. Indications for Use:
The Focused Cryotherapy System is intended for cryoablative destruction of tissue during surgical procedures. The Focused Cryotherapy System is indicated for use as a cryosurgical tool in the fields of general surgery, dermatology, neurology (including cryoanalgesia), thoracic surgery (with the exception of cardiac tissue), ENT, gynecology, oncology, proctology, and urology. The system is designed to destroy tissue by the application of extreme cold temperatures including prostate and kidney tissue, liver metastases, nerves, tumors, and skin lesions.
In addition, the system is intended for use in the following indications:
### Urology
- Ablation of prostate tissue in cases of prostate cancer and Benign Prostate Hyperplasia (BPH)
### Oncology
- Ablation of cancerous or malignant tissue and benign tumors, and palliative intervention. Palliation of pain associated with metastatic lesions involving bone in patients who have failed or are not candidates for standard radiation therapy
### Dermatology
- Ablation or freezing of skin cancers and other cutaneous disorders
- Destruction of warts or lesions, angiomas, sebaceous hyperplasia, basal cell tumors of the eyelid or canthus area, ulcerated basal cell tumors, dermatofibromas, small hemangiomas, mucocele cysts, multiple warts, plantar warts, actinic and seborrheic keratosis, cavernous hemangiomas, peri-anal condylomata, and palliation of tumors of the skin
### Gynecology
- Ablation of malignant neoplasia or benign dysplasia of the female genitalia
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General surgery
- Palliation of tumors of the rectum, anal fissures, pilonidal cysts, and recurrent cancerous lesions, ablation of breast fibroadenomas
ENT
- Palliation of tumors of the oral cavity and ablation of leukoplakia of the mouth
Thoracic Surgery
- (with the exception of cardiac tissue)
Proctology
- Ablation of benign or malignant growths of the anus or rectum
Neurology
- Freezing of nerve tissue in pain management/cryoanalgesia
6. Comparison of Technological Characteristics with the Predicate Device:
At a high level, the subject device differs from the predicate as a result of the following characteristics:
- Electrical heating element
- Directionally-biased ablation zones
- Cryogen pressure utilized
Length of the cryoprobe active region
The table below includes a high level comparison of the Subject and Predicate Devices:
Table 1 - Predicate and Subject Device Comparison - Focused Cryotherapy System
| Characteristic | Subject Device: Focused Cryotherapy System | Secondary Predicate Device: Visual-ICE Cryoablation System | Primary Predicate Device: Cryocare Touch System | Comparison Between Subject and Predicate Devices |
| --- | --- | --- | --- | --- |
| 510(k) Number | K250742 | K230551 | K201588 | N/A |
| Manufacturer | Focused Cryo, Inc. | Boston Scientific | Varian Medical Systems | N/A |
| Regulation | 21 CFR 878.4350 | 21 CFR 878.4350 | 21 CFR 878.4350 | Same |
| Product Code | GEH | GEH | GEH | Same |
| Classification | Class II | Class II | Class II | Same |
| Device Type | Cryosurgical Unit and Accessories | Cryosurgical Unit and Accessories | Cryosurgical Unit and Accessories | Same |
| Intended Use | Freeze/ablate tissue by the application of extreme cold temperatures | Freeze/ablate tissue by the application of extreme cold temperatures | Freeze/ablate tissue by the application of extreme cold temperatures | Same |
| Indications for Use | The Focused Cryotherapy System is intended for cryoablative destruction of tissue during surgical procedures. The Focused Cryotherapy System is indicated for use as a | The Visual-ICETM Cryoablation System is intended for cryoablative destruction of tissue during surgical procedures. The Visual-ICETM Cryoablation System is indicated for use as | The CRYOCARE TOUCH™ System is intended for use in open, minimally invasive or endoscopic surgical procedures in the areas in general surgery, urology, | The Subject Device has the same indications for use as the Secondary Predicate, except for the addition |
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| | cryosurgical tool in the fields of general surgery, dermatology, neurology (including cryoanalgesia), thoracic surgery (with the exception of cardiac tissue), ENT, gynecology, oncology, proctology, and urology. The system is designed to destroy tissue by the application of extreme cold temperatures including prostate and kidney tissue, liver metastases, nerves, tumors, and skin lesions. In addition, the system is intended for use in the following indications: Urology • Ablation of prostate tissue in cases of prostate cancer and Benign Prostate Hyperplasia (BPH) Oncology • Ablation of cancerous or malignant tissue and benign tumors, and palliative intervention. Palliation of pain associated with metastatic lesions involving bone in patients who have failed or are not candidates for standard radiation therapy Dermatology • Ablation or freezing of skin cancers and other cutaneous disorders • Destruction of warts or lesions, angiomas, sebaceous hyperplasia, basal cell tumors of the eyelid or canthus area, ulcerated basal cell tumors, dermatofibromas, small hemangiomas, mucocele cysts, multiple warts, plantar warts, actinic and seborrheic keratosis, cavernous hemangiomas, peri-anal condylomata, and palliation of tumors of the skin Gynecology • Ablation of malignant neoplasia or benign dysplasia of the female genitalia a cryosurgical tool in the fields of general surgery, dermatology, neurology (including cryoanalgesia), thoracic surgery (with the exception of cardiac tissue), ENT, gynecology, oncology, proctology, and urology. The system is designed to destroy tissue by the application of extreme cold temperatures including prostate and kidney tissue, liver metastases, tumors, and skin lesions. The Visual-ICE Cryoablation System has the following specific indications: • Urology Ablation of prostate tissue in cases of prostate cancer and Benign Prostate Hyperplasia (BPH) • Oncology Ablation of cancerous or malignant tissue and benign tumors, and palliative intervention. Palliation of pain associated with metastatic lesions involving bone in patients who have failed or are not candidates for standard radiation therapy • Dermatology Ablation or freezing of skin cancers and other cutaneous disorders Destruction of warts or lesions, angiomas, sebaceous hyperplasia, basal cell tumors of the eyelid or canthus area, ulcerated basal cell tumors, dermatofibromas, small hemangiomas, mucocele cysts, multiple warts, plantar warts, actinic and seborrheic keratosis, cavernous hemangiomas, peri-anal condylomata, and palliation of tumors of the skin • Gynecology Ablation of malignant neoplasia or benign dysplasia of the female genitalia • General surgery | gynecology, oncology, neurology, dermatology, ENT, proctology, pulmonary surgery and thoracic surgery. The system is designed to freeze/ablate tissue by the application of extreme cold temperatures including prostate and kidney tissue, liver metastases, tumors, skin lesions, and warts. In addition, the system is intended for use in the following indications: General Surgery • Destruction of warts or lesions • Palliation of tumors of the oral cavity, rectum and skin • Ablation of breast fibroadenomas • Ablation of leukoplakia of the mouth, angiomas, sebaceous hyperplasia, basal cell tumors of the eyelid or canthus area, ulcerated basal cell tumors, dermatofibromas, small hemangiomas, mucocele cysts, multiple warts, plantar warts, hemorrhoids, anal fissures, perianal condylomata, pilonidal cysts, actinic and seborrheic keratoses, cavernous hemangiomas, recurrent cancerous lesions Urology • Ablation of prostate tissue in cases of prostate cancer and benign prostatic hyperplasia Gynecology • Ablation of malignant neoplasia or benign dysplasia of the female genitalia Oncology • Ablation of cancerous or malignant tissue • Ablation of benign tumors • Palliative intervention Neurology | of the neurology indication, which it shares with the Primary Predicate. |
| --- | --- | --- | --- |
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| | General surgery
• Palliation of tumors of the rectum, anal fissures, pilonidal cysts, and recurrent cancerous lesions, ablation of breast fibroadenomas
ENT
• Palliation of tumors of the oral cavity and ablation of leukoplakia of the mouth
Thoracic Surgery
• (with the exception of cardiac tissue)
Proctology
• Ablation of benign or malignant growths of the anus or rectum
Neurology
• Freezing of nerve tissue in pain management/cryoanalgesia | Palliation of tumors of the rectum, anal fissures, pilonidal cysts, and recurrent cancerous lesions, ablation of breast fibroadenomas
• ENT
Palliation of tumors of the oral cavity and ablation of leukoplakia of the mouth
• Thoracic Surgery
(with the exception of cardiac tissue)
• Proctology
Ablation of benign or malignant growths of the anus or rectum | • Freezing of nerve tissue in pain management/cryoanalgesia
Dermatology
• Ablation or freezing of skin cancers and other cutaneous disorders
Proctology
• Ablation of benign or malignant growths of the anus or rectum
• Ablation of hemorrhoids
Thoracic Surgery
• Ablation of cancerous lesions | |
| --- | --- | --- | --- | --- |
| Mechanism of Action / Principle of Operation | Joule-Thomson Effect | Joule-Thomson Effect | Joule-Thomson Effect | Same |
| Freeze Gas | Argon | Argon | Argon | Same |
| Operating Pressure (psi) | 3500 | 3500 | 3200 | Same as Secondary Predicate |
| Thaw Mechanism | Heating element based | Heating element based | Helium | Same as Secondary Predicate |
| Number of Simultaneously Active Probes / Channels | 4 channels/active needle ports | 8 channels/active needle ports | 8 channels/active needle ports | The Subject Device supports fewer cryoprobes for simultaneous operation. |
| Console Freeze Modes | Circumferential, Directional | Circumferential | Circumferential | The Subject Device has a second operating mode that produces a directionally biased ablation zone. |
| User Interface | Touchscreen | Touchscreen | Touchscreen and remote keypad | Same as Secondary Predicate |
| Probe Temperature Sensor | Internal Thermocouple at Tip | Internal Thermocouple at Tip | Internal Thermocouple at Tip | Same |
| Temperature Feedback | Software Enabled | Software Enabled | Software Enabled | Same |
| Probe Diameter | 2.1 mm | 1.5 and 2.1 mm | 1.7 and 2.4 mm | Same as one configuration of |
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| | | | | Secondary Predicate. |
| --- | --- | --- | --- | --- |
| Probe Length | 20 cm | 10, 17.5, and 23 cm | 7, 15, and 23 cm | Similar to Predicate devices. Probe Length is within the bounds of predicate probe lengths. |
| Probe Tip | Trocar | Trocar | Trocar | Same |
| Probe Material | Stainless Steel | Stainless Steel | Stainless Steel | Same |
| Probe Sterility | Sterile, Single-Use | Sterile, Single-Use | Sterile, Single-Use | Same |
7. Performance Data (Non-Clinical Testing):
Verification and validation testing was conducted in accordance with applicable international standards and internal requirements to ensure safety, effectiveness, and compliance.
Verification testing included the following:
- System Verification: Confirmed proper functionality of Probes, Console, and Software
- Mechanical Testing: Evaluated gas components, Probe integrity, and packaging durability
- Electrical Safety & EMC Testing: Conducted per IEC 60601-1 and IEC 60601-1-2 standards
- Software Verification & Validation: Developed per IEC 62304 and FDA software guidance, verified all software requirements
- Biocompatibility Testing: Conducted per ISO 10993 series
Validation testing included the following:
- Human Factors Testing: Assessed usability per IEC 60601-1-6, IEC 62366 and FDA human factors guidance
- Sterilization Validation: Ensured compliance with ISO 11135 and related standards.
- Ex-Vivo Tissue Testing: Testing was performed in porcine tissue samples to validate device tissue effects and quantify thermal performance and temperature-time histories.
- Isotherm Comparative Testing: Head-to-head comparison testing was performed with the predicate device to demonstrate substantially equivalent isothermal contours.
All performance tests met predefined acceptance criteria, demonstrating that the Focused Cryotherapy System is as safe and effective as the predicate device. No new risks to safety or effectiveness were identified. No animal or clinical studies were included in this submission.
8. Determination of Substantial Equivalence to the Predicate Device:
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A subset of technological characteristics and features of the subject device differs from the predicate device. However, these differences do not raise different questions of safety and effectiveness when compared to the predicate devices. Performance data demonstrate that the subject device is as safe and effective as the predicate devices for the same intended use, thereby supporting a determination of substantial equivalence. The subject device has the same intended use as the predicate devices.
9. Conclusion:
The assessment following the outcomes observed in the performance testing and design verification and design validation determines that the Focused Cryotherapy System conforms to the defined user needs and intended uses in both circumferential and directional ablation modes. Focused Cryo, therefore, considers the Focused Cryotherapy System to be safe and effective and to perform at least as well as the predicate devices.
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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.