K-numberK243520
Device nameBullsai Confirm
ApplicantTuring Medical Technologies, Inc.
Product codeQQC
Device classClass II
Decision dateMar 28, 2025
DecisionSubstantially Equivalent
Regulation882.5855
AI Summary extracted from FDA summary PDF · never regenerated
Intended use

Bullsai Confirm is software that assists medical professionals in planning deep brain stimulation (DBS) programming for patients with approved Abbott DBS devices. It visualizes the Volume of Tissue Activated (VTA) relative to patient anatomy by importing MRI and CT images, positioning DBS lead models, and calculating stimulation effects using finite element and neural activation models.

Technological characteristics

Bullsai Confirm uses finite element-based electric field modeling combined with axon-based neural activation modeling to visualize VTA fields. Key differences from the predicate (SureTune4) include: no O-arm imaging support, no physical media import, web-based interface with PDF output instead of Excel exports, no electrophysiological annotations, no anatomical atlas superimposition, and no manual structure segmentation. Both devices support DICOM image import from PACS and allow 2D/3D image navigation and DBS lead model positioning.

Test standards cited

Not stated in this summary.

Substantial equivalence argument

Bullsai Confirm is substantially equivalent because it shares the same intended use (assisting in DBS programming planning), the same core technological approach (finite element and neural activation modeling to visualize VTA), and identical classification and product code as the predicate. Although Bullsai removes several features (O-arm support, manual segmentation, anatomical atlas) and adds cloud-based workflows, these differences represent simplifications and alternative implementation choices that do not introduce new safety or effectiveness questions, as they do not alter the fundamental software function or change how clinicians use visualization data for DBS programming decisions.

Extracted by AI from the official FDA summary PDF →
Source

View the full FDA submission: accessdata.fda.gov

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