February 28, 2017: Department of Health & Human Services
February 28, 2017: Department of Health & Human Services
Medtronic, Inc.
Laura Danielson
Principal Regulatory Affairs Specialist
8200 Coral Sea Street Ne
Mounds View, Minnesota 55112
Re: K163008
Trade/Device Name: Carelink SmartSync Device Manager Pacing System Analyzer
Regulation Number: 21 CFR 870.3605
Regulation Name: Pacing System Analyzer
Regulatory Class: Class II
Product Code: DTA, DTE
Dated: January 25, 2017
Received: January 26, 2017
We have reviewed your Section 510(k) premarket notification of intent to market the device
referenced above and have determined the device is substantially equivalent (for the indications
for use stated in the enclosure) to legally marketed predicate devices marketed in interstate
commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to
devices that have been reclassified in accordance with the provisions of the Federal Food, Drug,
and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA).
You may, therefore, market the device, subject to the general controls provisions of the Act. The
general controls provisions of the Act include requirements for annual registration, listing of
devices, good manufacturing practice, labeling, and prohibitions against misbranding and
adulteration. Please note: CDRH does not evaluate information related to contract liability
warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA),
it may be subject to additional controls. Existing major regulations affecting your device can be
found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may
publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean
that FDA has made a determination that your device complies with other requirements of the Act
or any Federal statutes and regulations administered by other Federal agencies. You must comply
with all the Act's 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 803); good manufacturing practice requirements as set forth in
the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product
radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Page 2 - Laura Danielson
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please
contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041
or (301) 796-7100 or at its Internet address
[Link] Also, please note
the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part
807.97). For questions regarding the reporting of adverse events under the MDR regulation (21
CFR Part 803), please go to
[Link] for the CDRH's Office
of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the
Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301)
796-7100 or at its Internet address
[Link]
Sincerely,
Enclosure
DEPARTMENT OF HEALTH AND HUMAN SERVICES Form Approved: OMB No. 0910-0120
Food and Drug Administration Expiration Date: January 31, 2017
Indications for Use See PRA Statement below.
Device Name
Carelink SmartSync Device Manager Pacing System Analyzer
This section applies only to requirements of the Paperwork Reduction Act of 1995.
*DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the
time to review instructions, search existing data sources, gather and maintain the data needed and complete
and review the collection of information. Send comments regarding this burden estimate or any other aspect
of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services
Food and Drug Administration
Office of Chief Information Officer
Paperwork Reduction Act (PRA) Staff
PRAStaff@[Link]
“An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB number.”
FORM FDA 3881 (8/14) Page 1 of 1 PSC Publishing Services (301) 443-6740 EF
Page 1 of 20
510(k) Summary
Date Prepared: January 13, 2017
510(k) Owner / Address: Medtronic, Inc.
Cardiac Rhythm and Heart Failure
8200 Coral Sea Street
Mounds View, MN 55112
Contact: Laura L. Danielson
Principal Regulatory Affairs Specialist
Telephone: (763) 526-2385
Fax: (651) 367-0603
E-mail: [Link]@[Link]
Trade / Proprietary Name: CareLink SmartSync™ Device Manager
Pacing System Analyzer
Common Name: Pacing System Analyzer
Classification / Class II
Classification Name: Pacing System Analyzer
(21 CFR 870.3605)
Product Code: DTA, DTE
Predicate Devices
The intended use, design, materials and performance of the CareLink SmartSync™ Device
Manager Pacing System Analyzer with associated Applications (Models: D00U001, D00U002,
M01G02, M01A02, M01G01, and M01A01), cables (previously approved) and accessories are
substantially equivalent to the following predicate device:
• Medtronic Model 2290 Lead Analyzer approved on 13MAR2002 P890003/S065.
• Medtronic Model 5311B A-V Pacing System Analyzer cleared on 07MAY1991 K910595.
Device Description
Device Identification:
The following is a list all key device components included in the submission:
• CareLink SmartSync Device Manager base (PSA hardware), Model 24970A
• CareLink SmartSync PSA App, Model D00U002
• CareLink SmartSync Host, Model D00U001
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The following compatible ECG interface cables, ECG cables, and adaptors are available for the
base. These are the same Adaptors and Cables used with the current market approved and
released Model 2290 PSA predicate and are considered medical devices.
ECG cables and leads connect the base to surface electrodes on the patient for the display of live
waveforms. Adaptors allow ECG monitors with phono connectors to be connected to the base.
• 5437 ECG Interface cable, 6.4 m (20 ft.) – Approved: P890003/S065, 13MAR2002
• 5437A Adaptor – Approved: P890003/S065, 13MAR2002
• 2090EC ECG cable, approximately 2.6 m (103 in.) – Approved: P890003/S065,
13MAR2002
• 2090ECL ECG cable, approximately 5.5 m (215 in.) – Approved: P890003/S065,
13MAR2002
• 9790LA ECG leads, approximately 1 m (40 in.) – Approved: P890003/S027,
29NOV1994
• 9790XLA ECG leads, approximately 1 m (40 in.) – Approved: P890003/S027,
29NOV1994
Medtronic recommends the use of Medtronic-supplied components only. Use of unapproved
components may reduce device effectiveness or impact user or patient safety.
Device Characteristics:
The CareLink SmartSync PSA is comprised of Base, software applications, associated cables and
power cords. The software applications reside on a mobile platform or tablet and pair via
Bluetooth® with the base hardware. The mobile platform is considered non-medical. The
Operating System is also non-medical software that is delivered with and resides on the Mobile
Platform.
The CareLink SmartSync Device Manager base (Model 24970A) is not considered a single-use
device.
The CareLink SmartSync Device Manager base (Model 24970A) is not provided sterile.
Environment of Use:
The base is intended to be used by healthcare professionals only in operating environments under
direct medical supervision.
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• ECG cable connections to collect live cardiac waveform data that can be viewed,
measured, and recorded using the app running on your mobile device.
• Bluetooth® wireless technology to communicate with the app running on your mobile
device.1
The Model 24970A Base contains a microprocessor that maintains the pacing engine logic
function for the PSA.
The PSA hardware within the Base consists of two main integrated circuits (ICs) which provide
a variety of functions as listed below:
• Micro Controller Unit: the microprocessor is used to provide timing support and also
onboard memory for the device.
• Mixed Signal Integrated Circuit: the mixed signal IC chip takes the input signals from the
cables (connected to a lead) and digitizes it for use by the device. This IC is also
responsible for the electrogram (EGM) waveform and power management.
The App is the primary user interface for the device manager system. The App for the CareLink
SmartSync PSA is comprised of four main components:
• A Host Application component that provides the system user interface necessary to
initialize, and set-up the CareLink SmartSync Device Manager and launch the PSA
Clinician Application
• a Platform Application component for the transfer/exchange, storage/retrieval,
electronic conversion, and electronic display of medical device data
• a Common Application component that is a collection of software components that are
utilized by the PSA or Device Applications
• a PSA Application component that is a Mobile Platform Application that allows user to
use the PSA device
The App includes these features:
• Bluetooth® connectivity to pair with the base.
• Integration with the base to start a lead analysis session.
• Mobile device connectivity tools for sharing and printing Analyzer reports.
• Updates to app software using an Internet connection.
The Analyzer tools in the App form the primary user interface to the Base). These tools display
and report on the cardiac lead and ECG data transmitted from the base. Clinicians use this data to
perform these tasks:
• Analyze electrical performance of cardiac leads during implant.
• Assess proper placement of cardiac leads during implant.
• View, measure, and document live cardiac waveforms.
CareLink SmartSync Application Models installed on a clinician’s off-the-shelf non-medical
mobile device. The Operating System is also non-medical software that is delivered with and
resides on the non-medical Mobile Platform.
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The CareLink SmartSync Device Manager provides the essential capabilities for analysis of and
the electrical performance of cardiac leads during device implant in a hospital environment (See
Tables 1 through Table 4).
Table 1: PSA Base Physical Characteristics
Parameter Value
Footprint 548 cm2
Mass 0.91 kg (2.0 lbs.)
Dimensions H x W x D 1.8 in x 9.45 in x 8.2 in
Device identification code Device serial number prefix
“SPM”
Power Source 5V Direct Current provided by
Medical Grade External Power
Supply. PSA Battery info in the
following table.
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Materials of Use
The following is a list of exposed materials included in the manufacture of the Model 24970A:
Component Material
Plastic:
SABIC LEXAN EXL-9330 Polycarbonate
White Resin per Medtronic color chip M954239A001
Top Enclosure Base Elastomer Edge:
Eraprene A6060N-SP
Thermoplastic Elastomer
Blue per Pantone 301
Plastic:
SABIC LEXAN EXL-9330 Polycarbonate
White Resin per Medtronic color chip M954239A001
Graphics:
Lid Base Pantone 301 Blue
Elastomer Edge:
Eraprene A6060N-SP
Thermoplastic Elastomer
Blue per Pantone 301
Plastic:
SABIC LEXAN EXL-9330 Polycarbonate
Bottom Enclosure Base White Resin per Medtronic color chip M954239A001
Graphics:
Pantone 301 Blue
Graphics:
Autotex-2(V200)
Polyester
Button:
Membrane Keypad Base Silicone Rubber
60 Shore A
Clear
Top Coat:
Polyurethane
Per color chip Pantone Cool Grey 8
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Component Material
Battery Cover Base SABIC LEXAN EXL-9330 Polycarbonate
White Resin per Medtronic color chip M954239A001
Silicone Rubber 70 Shore A
Foot Rear Base
Color: Pantone Cool Grey 8
Lexan PC 8B35
Device Label Base Polycarbonate
Clear
Lexan PC 8B35
QR Code Label
Polycarbonate
Base
Clear
Hypertronics D02 Housing
PSA Connector
Polyethermide
Base
Black
The device does not include biologics, drugs, or coating additives. The pacing system analyzer is not
intended for patient contact.
AC power requirement
Voltage 100–240 VAC nominal
Frequency 50/60 Hz nominal
Battery
Type AA Alkaline (LR6) or Lithium-ion, non-rechargeable (quantity of 2)
Voltage 1.5 V each
Power Supply
USB Cable
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Charge cradle
Model 24970A
Voltage 5 V 0.8 A
Power 4W
IEC 60529 Degrees of Protection Provided by Enclosures (IP Code)
Temperature Limits
Operating 8%-80%
Storage 15%-93% at 35°C (95°F
Transport 15%-93% at 35°C (95°F)
Altitude
Maximum 3000 m
Connectivity
Conexus wireless telemetry
Frequency range 402-405 MHz
Modulation frequency Frequency shift key
Output power 25 µW EIRP max
Disposal of the base: Return the base to Medtronic for proper disposal. Contact Medtronic at the address or telephone number on
the back cover for information on returning the base.
Electromagnetic compatibility declaration
The following list of accessories is compliant with the requirements of IEC 60601-1-2.
Accessory Maximum length
K163008
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Note 1: At 80 MHz and 800 MHz, the higher frequency range applies.
Note 2: These guidelines may not apply in all situations. Electromagnetic propagation is affected by absorption and reflection
from structures, objects, and people.
a
Field strengths from fixed transmitters, such as base stations for radio (cellular/cordless) telephones and land mobile radios,
amateur radio, AM and FM radio broadcast, and TV broadcast cannot be predicted theoretically with accuracy. To assess the
electromagnetic environment due to fixed RF transmitters, consider an electromagnetic site survey. If the measured field strength
in the location in which the 24970A base is used exceeds the applicable RF compliance level above, observe the 24970A base to
verify normal operation. If abnormal performance is observed, additional measures may be necessary, such as re-orienting or
relocating the 24970A base.
b
Over the frequency range of 150 kHz to 80 MHz, field strengths should be less than 10 V/m.
Recommended separation distances between portable and mobile RF communications equipment and the 24970A base
The 24970A base is intended for use in an electromagnetic environment in which radiated RF disturbances are controlled. The
customer or the user of the 24970A base can help prevent electromagnetic interference by maintaining a minimum distance
between portable and mobile RF communications equipment (transmitters) and the 24970A base as recommended below,
according to the maximum output power of the communications equipment.
Rated maximum output Separation distance according to frequency of transmitter
power of transmitter
150 kHz to 80 MHz 80 MHz to 800 MHz 800 MHz to 2.5 GHz
d = 0.35√P d = 0.35√P d = 0.70√P
0.01 W 0.035 m 0.035 m 0.070 m
0.1 W 0.11 m 0.11 m 0.22 m
1W 0.35 m 0.35 m 0.70 m
10 W 1.1 m 1.1 m 2.0 m
100 W 3.5 m 3.5 m 7.0 m
For transmitters rated at a maximum output power not listed above, the recommended separation distance d in meters (m) can be
estimated using the equation applicable to the frequency of the transmitter, where P is the maximum output power rating of the
transmitter in watts (W) according to the transmitter manufacturer.
Note 1: At 80 MHz and 800 MHz, the separation distance for the higher frequency range applies.
Note 2: These guidelines may not apply in all situations. Electromagnetic propagation is affected by absorption and reflection
from structures, objects, and people.
K163008
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Pacing System
Analyzer Model
2290
Same
Class III Class III
Class II
K163008
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Same
General Description
Manager is a microprocessor-based based accessory that installs into A-V Pacing System Analyzer
Device. The device is designed to the programmer. The Analyzer is (PSA) is a hand-held
analyze the electrical designed to analyze the microprocessor based device
performance of a cardiac lead electrical performance of a designed to test the
system, using the mobile device cardiac lead system, and uses electrical performance of the
platform and associated the programmer as a control pulse generator and the
applications as a control and display and display platform. The pacing lead system at the
platform. Analyzer can be operated time of pacemaker
"concurrently" with the implantation and during
Programmer desktop. That is, you invasive pacemaker
can switch to an analyzer session troubleshooting or
from the Select Model screen on evaluation procedures. The
the Programmer desktop, and you model 5311B A-V PSA
can toggle back and forth between combines the functions for a
an analyzer session and the Select multimode external pulse
Model screen using icons on the generator, a digital measuring
task bar. device, and a data processor
to provide the following
capabilities:
• External single and dual
chamber pacing in one of 10
selectable pacing modes to
support he patient during
pacemaker implantation and
pacing system test
procedures. The 5311B PSA
provides unipolar or bipolar
pacing for both single and
dual chamber applications.
• Measurement of cardiac
stimulation thresholds for
voltage and current or pulse
width.
• P-wave/R-wave analysis for
evaluation of the cardiac
signals detected by the
pacing lead system.
Information provided
includes the filtered and
unfiltered voltage amplitude
and the slew rate of the
detected depolarization
signal and an intracardiac
electrogram taken from the
pacing lead.
• A test for retrograde
conduction during evaluation
of a dual-chamber lead
system. This test is a feature
of the intracardiac
electrogram function.
• Automatic calculation of
pulse energy and lead
resistance from measured
pulse parameters.
• Implantable pulse generator
(IPG) tests include
determination of the pacing
mode and measurement of
the pacing mode and
measurement of up to 11
pacing parameters.
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Same
General Description (Con’t.)
K163008
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Same
The base is intended to be used by troubleshooting or
healthcare professionals only in diagnostic procedures. The
operating environments under direct Model 5311B A-V PSA is
medical supervision. designed to pace the patient
externally during pacing
system test and implantation
procedures. The pacing and
test functions of the Model
5311B A-V PSA are intended
for both single- and dual-
chamber pacemaker
applications.
DTA, DTC KRG and OSR DTC This medical
21 CFR 870.3720 21 CFR 870.3630 device has been
Product
Code
Same
21 CFR 870.3630 reclassified to
New Class II
21 CFR 870.3605 18APR2016
21CFR870
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Same
Features
these tasks: and R-wave amplitudes and PSA operating mode. For Pacing System
• Analyze electrical performance of slew rates pacing and lead system tests, Analyzer Model
cardiac leads during implant. ■ Automatic lead impedance the Model 5410 Surgical Cable 2290
measurement is used to connect the PSA to
• Assess proper placement of ■ Real-time display of atrial and an indwelling lead system.
cardiac leads during implant. ventricular EGM • Pacing Mode and Parameter
• View, measure, and document ■ Rapid atrial stimulation to 800 Adjustment
live cardiac waveforms. min-1 (ppm) • Emergency VVI Pacing
The PSA app includes these ■ Advanced analysis features,
including antegrade and • Stimulation Threshold
features for the analysis of cardiac
retrograde conduction tests, Measurement
leads:
and a pulse width versus • Lead System Resistance
• Dual and single chamber pacing amplitude threshold analysis • Filtered P-Wave / R-Wave
modes. ■ Measurement reports Amplitude
• Automatic measurement of P- Safety features
• Pulse Energy
wave and R-wave amplitudes. The Analyzer has the following
safety features: • Slew Rate and Unfiltered
• Lead impedance measurement.
■ Backup battery in the event of a Signal Amplitude
• Real-time display of atrial and power loss • Intracardiac Electrogram
ventricular EGM and ECG ■ Electrical isolation from the • Retrograde Conduction
waveforms. programmer
Test Function
• Rapid atrial stimulation to 850 ■ Emergency VVI pacing
• Inhibit Function
min−1 (ppm).
• Rapid Stimulation
• Advanced pulse width versus
amplitude pacing threshold
tests.
• Measurement reports.
The base includes these features:
• Analyzer hardware and patient
cable connections to support
electrical assessment of cardiac
leads during implant.
• ECG cable connections to collect
live cardiac waveform data that
can be viewed, measured, and
recorded using the app running
on your mobile device.
• Bluetooth® wireless technology
to communicate with the app
running on your mobile device.
• A cradle to charge the Medtronic
24967 Patient Connector (The
24967 patient connector is not
the subject of this submission).
• Optional USB connectivity to
charge the patient connector.
(The 24967 patient connector is
not the subject of this
submission).
5 year warranty 10 years 1 year warranty NA
Longevity
NA
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Length: 8.203” +/- 5% Width: 9.450” When installed the Analyzer will
Same
+/- 5% Thickness: 1.810” +/- 5%. not change the physical size of the
Model 2090 Programmer.
The Base will have a maximum
footprint of:
548 cm2.
The Base Station shall have a 16 ounces (1 lbs.). 1.5 kg (3.3 lbs.) All
maximum weight of 0.91 kilograms
Mass
Same
(2.0 lbs.).
No No No All
Compatibility
Same
MRI
Within the
Pacing System
range but
Basic
Same
Rate
Analyzer Model
2290
Analyzer Model
Similar
Rate
2290
Analyzer Model
Similar
2290
Same
Analyzer Model
2290
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Difference
24970A) and Applications P890003/S065 (Model 5311B)
Parameter
(D00U002, D00U001,
K910595 07MAY1991
Device
Analyzer Model
Similar
2290
Analyzer Model
P i d
Similar
Ventricular: 233 or 325 ms 2290
depending on mode
No Yes Yes NA
Slew
Rate
NA
VOO; VVI; AOO; AAI; DOO; DDD; VOO, VVI,AOO, AAI, DOO, DDD, VVI, VVT, VOO, AAI, AAT, All
(excluding VVV
DDI; ODO; OOO VDD, ODO AOO, DDD, DVI, DOO, VDD
Pacing
Modes
mode)
Same
Model 2292 Analyzer Surgical Model 2292 Analyzer Surgical The Model 5311B A-V PSA is Medtronic
Same
Accessories
Performance Data
The following performance data were provided in support of the substantial equivalence
determination.
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Biocompatibility testing
The biocompatibility evaluation for the CareLink SmartSync Device Manager, Pacing System
Analyzer Base, Model 24970A was conducted in accordance with the FDA Blue Book Memorandum
#G95-1 “Use of International Standard ISO-10993, ‘Biological Evaluation of Medical Devices Part
1: Evaluation and Testing,’” May 1, 1995, and International Standard ISO 10993-1 “Biological
Evaluation of Medical Devices − Part 1: Evaluation and Testing Within a Risk Management
Process,” as recognized by FDA. The device was justified by similarity to the Medtronic Model
24967 patient connector (K163460). The battery of testing for materials used in the Model 24970A
included the following tests:
• Cytotoxicity
• Sensitization
• Irritation
The Model 24970A is considered non-tissue or patient contacting.
Electrical safety and EMC testing were conducted on the CareLink SmartSync Device Manager,
Pacing System Analyzer Base, Model 24970A, associated applications and non-medical mobile
platform (i.e. Tablet) with associated cables as necessary for test. The system complies with the IEC
60601-1, standards for safety and the IEC 60601-1-2 third and fourth edition versions of the standard
for EMC.
Mechanical Testing
The following is a list of testing performed:
• Inspection of the required mechanical design features and function
• Workmanship inspection concerning all external surfaces that can cause injury such as
sharp edges or pinch points
• Product labeling inspection
• Forces required to activate controls
• Chemical resistance testing for effects of repeat cleaning cycles
• Environmental and drop testing
• Reliability testing of buttons, electrical contacts, user connector insertions, and
replaceable or moving mechanical components
• Performance and robustness testing of the Articulated Lid
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Animal Study
There were no formalized animal studies performed for this 510(k) submission.
Clinical Studies
There were no formalized clinical studies performed for this 510(k) submission.
Conclusions
The non-clinical data, the hardware and software verification and validation support and demonstrate
that the CareLink SmartSync Device Manager, Pacing System Analyzer Base, Model 24970A should
perform as intended in the specified use conditions and is substantially equivalent to the predicate
device.
K163008