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Extract to table / ide-exemption-analysis-memo.docx
ide-exemption-analysis-memo.docx · 1037-00002

Parties

Solstice Biomedical Devices Ltd
Solstice Biomedical Inc
Harkness LLP
Veltrano Clinical Research Organization Inc
Clearwater Institutional Review Board LLC
Meridian Conformity Assessment GmbH
Whitmore Laboratories Inc
Pinnacle Regulatory Consulting Group LLC

Dates

May 12, 2025
April 22, 2025
August 14, 2025
September 15, 2025
September 12, 2024
April 30, 2026
June 18, 2022
March 7, 2024
November 14, 2019
March 15, 2026

Amounts

$4,200,000
$12,000
$485,000

Obligations

All subjects must be adults aged 18 years and older
As a general matter, any clinical investigation of a device — that is, any study involving one or more subjects to determine the safety or effectiveness of a device — must have an approved IDE or qualify for an exemption from the IDE requirements before it may lawfully be conducted in the United States
For such studies, the sponsor must submit a complete IDE application to FDA in accordance with 21 C
Instead, the sponsor must comply with certain specified provisions of Part 812, including requirements for informed consent (21 C
While the energy levels involved are low and are not expected to present a meaningful risk to subjects, these features must be considered in the overall SR/NSR analysis
As part of its review and approval of the study, Clearwater IRB will be required to evaluate the following: • Solstice's risk assessment and NSR determination, including the rationale for concluding that the Lumina CGM System does not present a significant risk to study subjects; • The investigational plan (Protocol SBD-LUM-CL-001), including the study design, primary and secondary endpoints, inclusion and exclusion criteria, study procedures, and data analysis plan; • The informed consent documents, which must comply with the requirements of 21 C