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Interesting. Thanks for the information.

Connie & Reaghan

> Hi Connie,

>

> As strange as this may sound, that is pretty much all Orthomerica

(STAR

> Band, was OPI Band) and Gillette Children's (Craniocap) had to do

to get FDA

> approval. For example, on bottom of page 2 for the Craniocap pdf

file

> http://www.fda.gov/cdrh/pdf/k000861.pdf and page 4 of the

Orthomerica pdf

> file http://www.fda.gov/cdrh/pdf/k001167.pdf, the FDA approval

letter states

> " The FDA finding of substantial equivalence for your device to the

legally

> marketed predicate device results in a classification of your

device and

> thus, permits your device to proceed to market. " The predicate

device is the

> DOC band (see below). That means that Orthomerica and Gillette

Children's

> could simply cite research conducted by Cranial Technologies. Take

a look

> for yourself:

>

> Cranial Tech

> Summary/Approval

> http://www.fda.gov/cdrh/pdf/k964992.pdf

>

> Orthomerica (STAR Band, was OPI Band)

> http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfPMN/pmn.cfm?

ID=915

> Note " Decision: SUBSTANTIALLY EQUIVALENT "

> Summary/Approval

> http://www.fda.gov/cdrh/pdf/k001167.pdf

> Note page 1 section B, the " Predicate Device is the Doc Band "

>

> Gillette Children's (Craniocap)

> http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfPMN/pmn.cfm?

ID=676

> Note " Decision: SUBSTANTIALLY EQUIVALENT "

> Summary/Approval

> http://www.fda.gov/cdrh/pdf/k000861.pdf

> Note page 1, the " Predicate Device is the Doc Band "

>

> The " intend uses " for Orthomerica (STAR Band, was OPI Band) and

Gillette

> Children's (Craniocap) are taken almost verbatim from the DOC

band. And

> believe it or not, the research described in the Orthomerica

document, is

> research conducted by Cranial Technologies. The " Researchers

studying the

> effects of treatment... with 12, 18 and 24 month follow-ups... "

(page 2 of

> http://www.fda.gov/cdrh/pdf/k001167.pdf) are Littlefield, and

others

> (articles available at

http://www.plagiocephaly.org/resources/default.htm

> and http://www.cranialtech.com/infocenter/infocent.htm).

>

> LET ME BE VERY CLEAR ON THIS, I'm not saying there's anything wrong

with

> predicate approval of these devices. However, let's give credit

where

> credit is due. These devices are available because of Cranial

Tech's

> investment in a system of monitoring and quality assurance.

>

>

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