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COMPLETE CONTROL System Gen2

Coapt, LLC • Neurology • 05/24/2019

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

The COMPLETE CONTROL System Gen2 is engineered to offer upper extremity amputees intuitive and seamless control over their powered myoelectric prostheses through non-invasive means. It achieves this by utilizing pattern recognition algorithms to interpret EMG signals from cutaneous electrodes, simplifying user calibration via features like a mobile application, and enhancing overall system integration and efficiency.

Summary

The COMPLETE CONTROL System Gen2 is an advanced control solution specifically designed for upper extremity amputees using powered myoelectric prostheses. Its core methodology involves pattern recognition technology that non-invasively acquires and interprets user-specific muscle signals (EMG) from cutaneous electrodes, translating these signals into prosthesis movements. This system aims to provide users with intuitive control, eliminate the need for control switching, and allow for quick and powerful recalibration, simplifying electrode placement and enhancing interaction with industry-standard prostheses. Key components include the COMPLETE CONTROLLER main processor, device and EMG interface cables, a COMPLETE CALIBRATE button, a fabrication aid, a socket cut-out template, the COMPLETE CONTROLROOM Application (for PC and mobile), and a COMPLETE COMMUNICATOR Dongle. Compared to its predicate, the Gen2 system incorporates several enhancements, including the integration of signal amplification, filtering, and EMG transmission functions (previously in a separate CO-AMP unit) into the main COMPLETE CONTROLLER. This optimization, along with a change to cast Polyurethane for the enclosure material from Polyjet, contributes to a slightly smaller footprint and significantly reduced power consumption (less than half of the predicate), while also supporting an expanded operating voltage range (5.0-20.0 VDC). A significant usability improvement is the addition of a mobile application, allowing users to easily recalibrate their prosthesis without needing a computer. The system retains the same core algorithms and indications for use as its predecessor—exclusively for external prosthetic fittings of the upper limbs—and has successfully passed non-clinical performance testing for electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), and various internal validation tests covering cabling, power, connectivity, inputs/outputs, calibration, pattern recognition, and file saving.

AI Regulatory Concerns

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Keywords

Myoelectric prosthesisPattern recognitionUpper limb amputeeCutaneous electrodeEMGProsthetic controlRecalibrationNon-invasiveEmbedded systemMobile application

Device Metadata

Submission Number
K191083
Company
Coapt, LLC
Panel
Neurology
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does the pattern recognition algorithm adapt to changes in muscle signals due to user fatigue or minor electrode shifts over prolonged daily use?; What is the typical learning curve for a new user to achieve proficient control with the COMPLETE CONTROL System Gen2, and how does the new mobile application specifically facilitate this learning and recalibration process?; Beyond the listed compatible prosthetic components in the user manual, what are the technical interface requirements or limitations for integrating the COMPLETE CONTROL System Gen2 with other third-party prosthetic hands, elbows, or wrists?; How does the performance of the cast Polyurethane enclosure, chosen for its production cost and finish, compare to the previous Polyjet material in terms of long-term durability, impact resistance, and stability within the prosthetic socket environment?; What specific advancements in the integrated signal amplification, filtering, and EMG signal transmission within the COMPLETE CONTROLLER contribute to the system's reduced power consumption and potentially improved signal-to-noise ratio compared to the predicate's separate Co-Amp unit?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score20/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan⚠ Not mentioned in summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(connectivity)
✓ Detected
HBOMHardware Bill of Materials(processor, embedded)
✓ Detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials(environment)
✓ Detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM, HBOM, OBOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Postmarket cybersecurity monitoring plan not clearly documented in AI-generated device summary.

• Not detected in AI-generated device summary: SBOM, CBOM, VDR/VEX. These may be present in the full FDA submission.

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COMPLETE CONTROL System Gen2 - Coapt, LLC | ESL FDA AI Device Intelligence