Duane DeSisto
Analyst · Suraj Kalia with Rodman & Renshaw
What it is, here -- and far be it from me to put words in the FDA’s mouth. But let me give you a kind of a 10,000 foot level. The way the FDA, I believe, looks at this entire process is that, prior to a couple of years ago, the agency believes that the approval process for 510k devices was flawed. Right? And I can’t describe what those flaws are because I don’t know. But they felt, I think the FDA felt that process. So even though you have a predicate device, even though you go in with all that, they’re starting back at ground zero. And our first inkling of what was changing at the agency is when we went with DexCom with their approved gen 3 sensor and our approved OmniPod, and they went back and said you have to do animal testing, you have do insulin stability testing, and when they went through all the stuff with -- they went through all the stuff with DexCom guys. And that’s when we realized that technically there are no predicate devices. If your device was approved prior to, let’s say, the last 24 months, and don’t hold me to it -- but if your device was approved prior to the last couple of years, there really isn’t -- even through there is a predicate device in the submission, in the agency's eyes there is no predicate device. So you pretty much start all over as if this is the first time the world has ever seen the product. It helps that you have product out there and they can track plain reporting and all the other stuff, so that all helps your cause, but you are back to square one doing everything from insulin -- I think we described it from insulin stability testing on human factors, on everything, even through the product's out there. Okay. I don’t make the rules. My job is to try to and make sure I stay inside and do it as efficiently as possible. But that is -- that really is, and I think if you talk with the DexCom guys and some of the other people in the space, that’s kind of the fundamental change. There really aren’t a lot of real predicate devices prior to the last 2 years. So anyone coming out that points at something that's ’s been out on the market, it's deemed interesting, but not necessarily of merit. So you start as square one.