The assignment for the paper is to provide a written summary describing why stimulator (medical device) is safe and effective in VNS therapy system in depression only

 it should have 4 pages excluding references and cover page, AMA format only,  plagiarism free

The paper should cover the  following areas:

1. Introduction
2. Description of       device and indication
3. Safety       summary: “Why does FDA consider       this device to be safe? What measurement was used and why is it       clinically meaningful?”
4. Effectiveness/efficacy       summary: “Why does FDA consider       this device to be effective? What       measurement(s) was/were used and why is it clinically meaningful? 
5. Summary of       peer-review publications/evidence. Do subsequent published reports replicate the data in the       SSED? What new information was       learned?
6. Conclusion
7. References

Summary of and Effectiveness Data

I. GENERAL INFORMATION
Device Generic Name: Stimulator, Vagus Nerve

Device Trade Names: VNS Therapy™ System

VNS Therapy™ Pulse Model 102 Generator
VNS Therapy ™ Pulse Duo Model 1 02R Generator
VNS Therapy™ Programming Wand Model201
VNS Therapy™ Magnet Model 2

20

VNS Therapy™ Software Model 250
VNS Therapy™ Lead Model 30

2

VNS Therapy™ Tunneler Model 402
VNS Therapy™ Accessory Pack Model 502

Applicant’s Name and Address: Cyberonics, Inc.
100 Cyberonics Boulevard
Cyberonics Building
Houston, Texas 7705

8

Premarket Approval Application (PMA) Number: P970003/S50

Date of Panel Recommendation: June 15, 200

4

Date of Notice of Approval to the Applicant: July 15, 200

5

II. INDICATIONS FOR USE
The VNS Therapy System is indicated for the adjunctive long-term treatment of chronic or
recurrent depression for patients

18

years of age or older who are experiencing a major depressive
episode and have not had an adequate response to four or more adequate antidepressant
treatments.

III. CONTRAINDICATIONS, WARNINGS AND PRECAUTIONS
A. Contraindications

• The VNS Therapy System cannot be used m patients after a bilateral or left cervical ·
vagotomy.

• Do not use shortwave diathermy, microwave diathermy or therapeutic ultrasound diathermy
(hereafter referred to as diathermy) on patients implanted with a VNS Therapy System.
Diagnostic ultrasound is not included in this contraindication.

Energy delivered by diathermy may be concentrated into or reflected by implanted products
such as the VNS Therapy System. This concentration or reflection of energy may cause
heating.

Testing indicates that diathermy can cause heating of the VNS Therapy System well above
temperatures required for tissue destruction. The heating of the VNS Therapy System resulting
from diathermy can cause temporary or permanent nerve or tissue or vascular damage. This

8

damage may result in pain or discomfort, loss of vocal cord function, or even possibly death if
there is damage to blood vessels.

Because diathermy can concentrate or reflect its energy off any size-implanted object, the
hazard of heating is possible when any portion of the VNS Therapy System remains
implanted, including just a small portion of the Lead or electrode. Injury or damage can occur
during diathermy treatment whether the VNS Therapy System is turned “ON” or “OFF”.

Diathermy is further prohibited because it may also damage the VNS Therapy System
components resulting in loss of therapy, requiring additional surgery for system explantation
and replacement. All risks associated with surgery or loss of therapy would then be applicable.

Advise your patients to inform all their health care professionals that they should not be
exposed to diathermy treatment.

B. Warnings and Precautions

See Physician Labeling

IV. DEVICE DESCRIPTION
The VNS Therapy System used for vagus nerve stimulation (VNS), consists of the implantable
VNS Therapy Pulse Generator, the VNS Therapy Lead and the external programming system
used to change stimulation settings. The lead and the pulse generator make up the implantable
portion of the VNS Therapy System. Electrical signals are transmitted from the pulse generator to
the vagus nerve by the lead. The software allows a physician to identifY, read and change device
settings. The pulse generator is surgically placed in the left chest. The lead is then connected to
the pulse generator and attached to the left vagus nerve. Patients are provided with magnets that,
by placing the magnet over the implanted pulse generator can deactivate (turn OFF) programmed
stimulation. Programmed stimulation resumes when the magnet is removed.

A. VNS Therapy™ Pulse Generators (Modell02 and l02R)
The VNS Therapy™ Pulse Generators are implantable, multiprogrammable pulse generators that
deliver electrical signals to the vagus nerve. Constant current, capacitively coupled, charge

–

balanced signals are transmitted from the Generator to the vagus nerve by the lead. The pulse
generator is housed in a hermetically sealed titanium case. The pulse generator has a number of
programmable settings including pulse width, magnet-activated output current, output current,
magnet-activated ON time, signal frequency, magnet-activated pulse width, signal ON time and
signal OFF time. The pulse generator has telemetry capability that supplies information about its
operating characteristics, such as parameter settings, lead impedance and history of magnet use.

B. VNS Therapy™ Lead Model 302

The lead delivers electrical signals from the pulse generator to the vagus nerve. The lead has two
helical electrodes on one end and on the other end a 3.2-millimeter (mm) connector. The lead is
insulated with silicone rubber and is non-bifurcated. The lead wire is quadrifilar MP-35N, and the
electrode is a platinum ribbon.

2

“1

C. VNS TherapyTM Tunneler Model 402

The tunneler is designed for use during subcutaneous tunneling and implantation of the lead. The
tunneler consists of 4 basic components: a stainless steel shaft, 2 fluorocarbon polymer sleeves
and a stainless steel bullet tip. The Tunneler is supplied sterile and is for single use only.

D. VNS TherapyTM Programming Wand Model 201

The wand is used to activate, program, reprogram and interrogate the pulse generator.

E. VNS TherapyTM Software Model 250

The programming software is a computer program that permits communication with the
implanted pulse generator. The programmed parameters and operational status can be
interrogated. One or more parameters can be programmed at one time, and the programmed
values are verified and displayed.

F. VNS TherapyTM Accessory Pack Model502

The accessory pack contains replacement components for the VNS Therapy System and includes
a hex screwdriver, test resistors and lead tie downs. These are supplied sterile.

G. VNS TherapyTM Magnet Model 220

Cyberonics provides patients two magnets-a watch-style magnet and a pager-style magnet.
When a magnet is passed over the pulse generator, the magnetic field causes a reed switch within
the pulse generator to close. The magnet is placed over the pulse generator to stop stimulation.

V. ALTERNATIVE PRACTICES AND PROCEDURES
There are currently three major treatment modalities for which there is substantial evidence of
effectiveness in the treatment of a major depressive episode: pharmacotherapy with
antidepressant drugs (ADDs), specific forms of psychotherapy (including cognitive behavior and
interpersonal therapy), and electroconvulsive therapy (ECT). ADDs are the usual first line
treatment for depression. Clinical trials have demonstrated efficacy for a number of
pharmacologic classes of ADDs. Physicians usually reserve ECT for treatment-resistant cases or
when they determine a rapid response to treatment is desirable.

For those patients who do not respond to initial antidepressant treatment, physicians generally use
one or more of the following strategies: (I) switching to an alternative first-line ADD, (2)
switching to a second-line ADD, (3) adding psychotherapy, a second ADD, or an augmentation
agent. Augmentation agents are drugs that are not generally considered to have significant
antidepressant activity when administered alone, but they can enhance the effectiveness of an
ADD when they are administered in combination with the ADD. Augmentation agents include
drugs such as lithium or atypical antipsychotic drugs. Additional options for treatment-resistant
patients, especially for patients who fa

il

on the above alternatives, include monoamine oxidase
inhibitors and ECT. For treatment-resistant cases that exhibit a marked seasonal pattern, adding
phototherapy to pharmacotherapy may also be an option.

3

(0

VI. MARKETING HISTORY
A. Foreign Marketing History
Since June 1994, the VNS Therapy System has been approved as treatment for epilepsy in all
countries of the European Union. In March 2001 CE Mark Approval was granted for the
treatment of depression in all European Community (EC) countries. Subsequently, in April 2001
Cyberonics began distribution of the VNS System for the treatment of depression in Canada. The
VNS Therapy System has not been withdrawn from marketing in any country outside the United
States for any reason, including those related to the safety or effectiveness.

B. U.S. Marketing History

Since July I 99

7

the VNS Therapy System has been approved for use as an adjunctive therapy in
reducing the frequency of seizures in adults and adolescents over I 2 years of age with medically
refractory partial onset seizures. The VNS Therapy System has not been withdrawn from
marketing in the U.S. for any reason related to the safety or effectiveness.

VII. POTENTIAL ADVERSE EFFECTS OF THE DEVICE ON HEALTH
In addition to the normal risks associated with a surgical procedure, complications associated
with implantation include, but may not be limited to, vagus nerve damage; skin irritation; pain at
the incision site; infection; extrusion or migration of the pulse generator and/or lead dislodgment,
disconnection (from pulse generator), breakage (lead), or corrosion; hematoma; fluid
accumulation; cyst formation; inflammation; and histotoxic reactions. These phenomena may
require device replacement to correct the complication. A pivotal clinical trial of 235 subjects
(D-02) was conducted by the sponsor to evaluate the safety and effectiveness of the device for the
intended use. The number (and percentage) of subjects reporting an event during the 0-3 month
period and during the 9-12 month period is depicted in Table I below.

4

! I

thsand9l2Mont hsTable l -Adverse Events Associated w·Ith VNSTh erapy at 0-3Mon –
Adverse Event 0-3 Months (N-232) 9-12 Months (N-209)

Voice Alteration 135 (58.2%) 1

13

(54.1%)
Increased Cough 55 (23.7%) 13 (6.2%)
Neck Pain 38 (16.4%) 27 (12.9%)
Dyspnea 33 (14.2%) 34 (16.3%)
Dysphagia 31 (13.4%) 9 (4.3%)
Paresthesia 2

6

(11.2%) 9 (4.3%)
Laryngismus 23 (9.9%) 10 (4.8%)
Pharyngitis 14(6.0%) 11 (5.3%)
Nausea 13 (5.6%) 4(1.9%)
Pain 13 (5.6%) 13 (6.2%)
Headache 12 (5.2%) 8 (3.8%)
Insomnia 10(4.3%) 2 (1.0%)
Palpitation 9 (3.9%) 6 (2.9%)
Chest Pain 9 (3.9%) 4 (1.9%)
Dyspepsia 8 (3.4%) 4 (1.9%)
Hypertonia 6 (2.6%) 10 (4.8%)
Hypesthesia 6 (2.6%) 2 (1.0%)
Anxiety 5 (2.2%) 6 (2.9%)
Ear Pain 5 (2.2%) 6 (2.9%)
Eructation 4 (1.7%) 0
Diarrhea 4 (1.7%) 2 (1.0%)
Dizziness 4 (1.7%) 3 (1.4%)
Incision Site Reaction 4 (1.7%) 2 (1.0%)
Asthma 4 (1.7%) 3 (1.4%)
Device Site Reaction 4(1.7%) 0
Device Site Pain 4 (1.7%) 2 (1.0%)
Migraine Headache 4 (1.7%) 2 (1.0%)

VIII. PRE-CLINICAL STUDIES

A. Summary of Non-Clinical Laboratory Studies

l. Pre-Clinical Laboratory and Animal Studies
A summary of these studies can be found in the Summary of Safety and Effectiveness document
for P970003 (epilepsy indication). No additional pre-clinical or animal studies were required for
this application.

2. Risk Analysis
The commercially available system’s risk analysis was re-evaluated for treatment-resistant
depression (TRD). Since subjects undergo the same implantation procedure using the same
system, no new surgical risks were identified. The sponsor evaluated the potential risks associated
with patients who are implanted and are having a TRD episode. The risks associated with this
population include suicide attempt/suicide, manic depressive reaction, anxiety, confusion,
overdose, and worsening depression. No design related mitigation solutions could be developed.

5

IX. SUMMARY OF CLINICAL INVESTIGATIONS

Cyberonics has conducted the following studies to support the use of the VNS System in subjects
with treatment-resistant depression:

• a feasibility trial (D-Ol);
• a randomized, sham-controlled 3-month clinical trial (D-02, acute)
• a long-term (12-and 24-month) open-label extension (D-02, long-term); and
• a long-term (12-month) observational study of subjects receiving standard-of-care

treatments (D-04) for comparison to D-02 long-term.

l. Feasibility Study D-Ol
D-0 I was an open-label, nonrandomized, single arm, multicenter, 60-patient study of VNS in
treatment-resistant major depression. The study included an acute 12-week phase as well as a
subsequent long-term follow-up. Patients were required to maintain a stable antidepressant
medication regimen during the acute phase of the study.

The most commonly reported treatment-emergent adverse events, regardless of relationship to
stimulation (in order of frequency) were: voice alteration (75%), neck pain (32%), depression
(27%), headache (27%), dyspnea (23%), dysphagia (18%), increased cough (17%), nausea (15%),
dyspepsia (12%), and dizziness (10%). Seventy-seven (77) events in 38 subjects were rated as
serious (I 0 in acute phase and 67 in long-term follow-up) including 34 reports of worsening
depression and 12 suicide attempts or overdose.

Fifty-nine of the 60 subjects completed the 12-week acute phase and were available for
evaluation of effectiveness. Primary efficacy analysis of the 28-item Hamilton Rating Scale for
Depression (HRSD28 ) at the end of this phase showed 18 (31%) of the 59 evaluable subjects met
response criteria(:::: 50% reduction in score as compared to baseline). In addition, 25 of 55 (45%)
were responders after one year, and 18 of 42 (43%) after two years. Furthermore, after one year
of stimulation, 13 of the 18 acute responders {72%) maintained their response and 12 of the acute
non-responders (29%) became responders. Of the subjects included in the evaluable population,
15%, 27% and 21% reached remission (HRSD28 :5′ I 0) at 12 weeks, I year, and 2 years,
respectively.

2. Pivotal D-02 Study and D-02/D-04 Comparison Study

The acute phase of D-02 was a 12-week, double-blind, randomized, sham treatment-controlled,
multi-center, pivotal study where subjects were implanted with the VNS System and randomized
to either the treatment (stimulation) group or control (sham) group. Two weeks after surgery,
treatment group subjects had the device turned ON and the output current adjusted to a tolerable
level during a 2-week period. Sham subjects were treated identically; however, the output current
of the device was set at 0.00 mA throughout the acute phase. The treatment group subjects’
stimulation parameters remained constant for the remainder of the acute study (8 weeks) but were
permitted to be decreased to accommodate for events possibly related to tolerance. During the
acute phase of the study, antidepressant medications were to remain unchanged from baseline.

After completion of the 12-week acute phase, subjects could continue in an open-label long-term
phase (D-02, long-term), during which time subjects in the treatment group continued VNS
therapy and stimulation was initiated for subjects originally in the sham-control group. Sham
subjects followed the same treatment schedule that the treatment group received during the acute

6

phase. Following the acute phase, changes in concomitant treatments (medications and ECT)
were permitted.

D-04 was a long-term, observational, prospective study designed to collect data regarding usual
standard-of-care (SOC) treatment for TRD in people who were in a major depressive episode at
the time of admission. The usual SOC was defined as the treatment strategy the physician and
subject chose to follow. Clinical depression assessments and quality of life outcomes were
assessed at baseline, 3, 6, 9 and 12 months. D-04 was intended to provide a comparison group for
the D-02 long-term analysis. Safety data were not prospectively collected in D-04.

a) Inclusion/Exclusion Criteria
D-02 and D-04 Inclusion criteria

• Age 18-80
• In a chronic years) current major depressive episode (MOE) and/or have had a

history of recurrent MDEs (> 4 lifetime episodes, including current) per DSM-IV.
• HRSD24 score”:_ 20 at the acute phase baseline.
• Failed 2-6 mood disorder treatments from different treatment categories as determined by

an Antidepressant Resistance Rating (ARR) score of 3 or higher using the modified
version of the Antidepressant Treatment History Form)

• Continuation criteria required an HRSD24 score”:_ 18.
• History of treatment with psychotherapy> 6 weeks without improvement (002 only)
• Stable medication regimen of not more than 5 medications for at least 4 weeks prior to

the baseline visit (002 only)
• Adequate contraception (002 only).

Exclusions for both studies included:
• Atypical depression or psychotic symptoms;
• Schizophrenia, schizoaffective disorder, or delusional disorders;
• Rapid cycling; delirium, dementia, amnestic, or other cognitive disorders;
• Not having an acceptable clinical response due to failure with antidepressant

treatments during the current MOE;
• Recent suicide attempts (or suicide risk/plan) within 12 months;
• Recent alcohol or substance dependence or abuse (other than nicotine);
• Other progressive neurological disease, significant CNS disease or injury;
• Current enrollment in another investigational study or using an investigational device;
• History of, or evidence of, significant brain malformation or significant head injury,

clinically apparent cerebral vascular events, prior brain surgery such as cingulatomy; or
previous implantation with the VNS.

• Myocardial infarction or arrest, general anesthesia within 30 days, ASA Ill or IV,
pacemaker or other implantable stimulator, likely to require MRI or diathermy (D-02
only)

b) Concomitant Mood Disorder Treatments
D-04 subjects were allowed to have mood disorder treatments changed according to the
investigator and subject’s determination of the best treatment regimen. For the D-02 study,
continuation of stable baseline mood disorder treatments was allowed. Changes to these
treatments were not allowed during the 12-week acute phase but were allowed during the long-
term phase, although such changes were discouraged.

7

c) 002 and 004 Study Accountability and Subject Population
D02 Subject Accountability
Of the 235 subjects who were enrolled and randomized in the Acute D-02 study, 2 subjects
withdrew during the acute phase (including I suicide), 2 additional subjects did not complete the
acute study, and 9 were either protocol violations or failed to meet Visit 2 continuation criteria.
Therefore, at the end of the acute phase of the D-02 study, 2

22

subjects were evaluable for
effectiveness with 112 from the treatment group and 110 from the sham-control group.

A total of 233 subjects entered the long-term phase of D-02. During this phase, 28 subjects were
deemed to be not evaluable for effectiveness for the following reasons:

• No effectiveness data included at any long-term visit 4
• Did not meet acute phase continuation criteria 3
• Did not have acute exit HRSD 18 if in sham group

21

A total of 205 subjects were therefore evaluable for effectiveness at the end of the D-02 long-
term phase study (110 from the original treatment group and 95 from the original sham group)
and 209 were evaluable for safety. Of these, 28 did not complete 12 months of follow-up for the
following reasons:

• Withdrew before I year of stimulation

17

• Reached I year but device was ON < 80% of time 6 • Did not have I year assessments/records 5

The most common reason cited for early withdrawal was lack of effectiveness. In the end 177
12-month stimulation completers (103 from the original stimulation group and 74 from the
original sham group) contributed to the effectiveness analysis for the long-term D-02 and D-
02/D-04 comparison.
D04 Subject Accountability
For the 004 study, 138 subjects were enrolled. Of these, II discontinued and 3 only provided
baseline data. As such, 124 subjects were included in the evaluable population for this portion of
the study. Of these 124, 112 were 12-month completers which provided effectiveness data.

D02 and D04 Subject Demographics
Table 2 lists baseline demographics of the evaluable D-02 and D-04 subjects.

8

IS

T able 2. 002, D04 Comparison of Demol!ra_])hics (Evaluable Subjects)
Parameter Statistic D02 (N=205) D04 (N=l24)
Age (years) Mean 46.3 45.5
Male N (%) 74(36) 39(31)
Female N (%) 131(64) 85(69)
Caucasian N (%) 198(97) 111(90)*
African-American N (%) 3(1) 5(4)
Hispanic N(%) 3(1) 2(2)
Unipolar N (%) 185(90) I 09(88)
Bipolar N (%) 20(1 0) 15(12)
Recurrent N (%) 161(87) 93(85)
Single q,isode N (%) 24(13) 16(15)
Length of Current MDE (mos) Mean (S.D.) 49.9(52.1) 68.6(91.5)
#Failed Trials in Current MDE Mean(S.D.) 3.5(1.3) 3.5(1.3)
Received ECT Lifetime N(%) 108(53%) 32(26%)*
Received ECT, Current MDE N(%) 72(35%) 15(12%)*
Duration of Illness (yrs) Mean (S.D.) 25.5(11.9) 25.8(13.2)
Lifetime episodes of Depression •

0-2 N(%) 50(24) 31(25)
3-5 N(%) 69(34) 36(29)
6-10 N(%) 56(27) 18(15)
>10 N(%) 19(9) 32(26)

No Suicide Attempts in Lifetime N(%) 140(68) 80(65)
Treatment induced (hypo )mania N(%) 16(8) 6(5)
Hospitalizations for Depression Mean (S.D) 2.7(5.4) 2.1(2.9)
ECT Treatment Within past 2yrs N(%) 54(26) 19(15)

* p

d) Safety Data
Acute Phase Adverse Events
Implantation-Related
Some acute phase adverse events were noted and judged to be implant-related (due to the
surgery). These included the following events (based on N=235): Incision Pain, 84 (36%); Voice
Alteration, 78 (33%); Incision Site Reaction 67 (29%); Device Site Pain, 54 (23%); Device Site
Reaction, 33 (14%); Pharyngitis, 31 ( 13%); Dysphagia 26 ( 11%); Hypesthesia,25 (II%); Nausea,
20 (9%); Dyspnea, 20 (9%); Neck Pain,

16

(7%); and Increased Cough,

15

(6%).

Stimulation-Related (Device-Related)
Table 3 reports adverse events during the acute randomized phase of D-02 which occurred in the
active stimulation group at rates=:: 3% and were judged at least possibly related to stimulation.

9

lb

Table 3. lncidenceofT reatment-E mereentAdverse Evcn s t > 3″!.om Acue Phase of D-02· t

Event

Treatment

N (%)

Sham-
control

N (%)
Voice alteration 65 (55%) 3 (3%)
Cough increased 28 (24%) 2 (2%)
Dyspnea 23 (19%) 2 (2%)
Neck pain 19(16%) I (<1%) Dysphagia 15 (13%) 0 Laryngismus 13(11%) 0 Paresthesia 12 (10%) 3 (3%) Pharyngitis 9 (8%) I (<1%) Nausea 8 (7%) I (<1%) Incision Pain 6 (5%) 3 (3%) Headache 5 (4%) I (<1%) Insomnia 4 (3%) 0 Dyspepsia 4 (3%) 0 Diarrhea 3 (3%) 0 Palpitations 3 (3%) I (<1%) Dizziness 3 (3%) 0 Chest Pain 3 (3%) I (<1%)

Duration of Early Adverse Events
For the 7 events which occurred at a frequency 2: 10% in the VNS Therapy group during the acute
randomized phase of the study (Table 3), further analysis was performed to determine how long
these events persisted in subjects. Table 4 shows a cohort of subjects who reported the 7 most
common adverse events during their first 3 months of stimulation and who also had follow-up
visits during months 9 through 12. Numbers in the last 3 columns refer to the number (and
percentage) of subjects who had the event between months 0-3 (second column) who continued to
have the symptom at the latter point.

10

il

Tab!e 4. Persistence of Earlv Stimulation-Related Events Through One Year (N=2 09)
N

Reporting
Event

During
First 3 Mos. 1

N (%)Continuing to Report
Event During Succeeding

Quarters2

Preferred Term 0-3 Mos. 3-6 Mos. 6-9 Mos. 9-12 Mos.

Voice Alteration 135 115 (85%) 101 (75%) 90 (67%)

Cough Increased 55 18 (33%) 15 (27%) II (20%)

Neck Pain 38 17(45%)

19

(50%) 16 (42%)

Dvsonea 35 22 (63%) 18(51%) 16 (46%)

Dvsohagia 31 16 (52%) 10 (32%) 6 (19%)

Paresthesia 26 12 (46%) 6 (23%) 4 (15%)

Larvn2ismus 23 13 (57%) 9 (39%) 5 (22%)
Entnes are the number of subjects who expenenced the AEs between ImplantatiOn and 3 months.

2Number of subjects who continued to experience the same adverse event between months 3 and 6,
months 6 and 9, and months 9 and 12.
Note: Subjects were counted only once within each preferred term and time interval.

Late-Emerging Adverse Events
New adverse events first reported after the first 3 months of stimulation were assessed by the
sponsor. Only event types which were not reported by any subjects during the first 3 months
were included in this data set. Hence, new reports of voice alteration, neck pain, and the like
were not included in this analysis. The new events included syncope (3), gastritis (3), weight
gain (3), deafness (2), colitis (2), and I of each of the following: stridor, hypotension, speech
disorder, back pain, weight loss, arthralgia, myalgia, amblopia, and viral or flu infection.

Serious Adverse Events (SAE)
A serious adverse event was defined as one that resulted in death, was life-threatening, resulted in
or prolonged hospitalization, resulted in a persistent disability, or involved a congenital anomaly.
All events were reported regardless of relationship to VNS Therapy.

SAE During Acute Phase of D-02
In the acute D-02 study, there were 30 SAEs in 27 subjects. One death due to suicide occurred in
an active stimulation subject. The following SAE occurred more than once.

• Worsening Depression 12 events in II subjects (5 treatment, 7 control subjects)
• Site Reaction 2 events in 2 subjects (2 treatment subjects)
• Pneumonia 2 events in 2 subjects (I treatment, I control subject)
• Dehydration 2 events in 2 subjects (I treatment, I control subject)

In addition, the following were reported once in the treatment group alone: asystole, bradycardia,
confusion, abnormal thinking, wound infection, and urinary retention. The following SAE were
reported once in the control group alone: renal failure, vocal cord paralysis, cholecystitis, voice
alteration, and myasthenia.

SAE in the Long-Term Phase of D-02
In the D-02 long-term phase there were 96 SAE . These events are shown in Table 5 below.

II

18;

Table 5- Serious Adverse Events in Long-Term D-02

Event #of Events #Subjects
Worsening Depression
Suicide Attempt
Syncope
Convulsion
GI Disorder
Sudden Unexplained Death
Chest Pain, Abdominal Pain, Peritonitis,
Cholecystitis, Constipation, Dehydration,
Dizziness, Drug Dependence, Manic Depression,
Somnolence, Abnormal Thinking, Overdose,
Accidental Injury, Breast CA, Wound Infection,
Surgical Procedure, Enlarged Uterine Fibroid,
Cholelithiasis

62
7
4
2
2
I

leach
(18)

31
6
3
2
2
l

18

Deaths
Four deaths were reported. One occurred prior to implantation/stimulation. Two deaths occurred
after device implantation and prior to the 12 month follow-up. One was a suicide during the acute
phase (in the treatment group) and one was listed as “undetermined” cause. The latter occurred
approximately 2-3 months after implantation and stimulation. An additional death occurred after
12 months of follow-up and was due to acute brain injury.

Specific Depression-Related Adverse Events
Mania/Hypomania
The Young Mania Rating Scale (YMRS) was used to detect the emergence of mania in the D-02
study. Three (3) subjects had a manic reaction reported. Another 3 had YMRS > 15 during the
long-term phase without an adverse event being reported. Two of the six patients had their event
during the acute phase and 5 of the 6 had a prior history of bipolar disorder or mania. One
subject’s mania was classified as a serious adverse event.

Worsening Depression
In the acute phase there were 12 reports of worsening depression, 5 in the stimulation group [ 4 of
119 subjects] and 7 in the sham group [7 of 116 subjects]. One of the treatment-group reports
occurred prior to stimulation initiation. Following acute phase exit and during the 12-month
period of stimulation, 62 events were reported in 31 subjects. The number of episodes or
worsening depression per patient ranged from 1 to 6. Of note, rates of worsening depression (and
other safety endpoints) were not collected during the 004 study for direct comparison. However,
the item of “hospitalizations for psychiatric illness” which might be used as a surrogate for
worsening depression was captured in D04. The rate of such was 0.23 7 events per patient-year in
the D04 group (n=l24 subjects) compared to 0.284 in the !-year D02 group (n=233 subjects) and
0.314 in the D-02 sham group (n=116 subjects).

Suicidal ideation and Suicide.
One way in which the sponsor analyzed change in suicidal ideation was to look at Item 3 of the
HRSD24 score. During the acute D-02 study, 2.6% of sham subjects and I. 7% of the stimulation
subjects increased their Item 3 score by 2 or more points. During the long-term D-02 phase, 2.8%
of subjects had increased their Item 3 score by at least 2 points at 12 months versus baseline. In

12

1’1

the 0-04 group, this was 1.9%. Conversely, 27% of 0-02 subjects decreased their score by at
least 2 points at 12 months compared to baseline whereas only 9% of 0-04 subjects did.

As noted above, 1 subject committed suicide in the acute phase and 6 attempted suicide during
the 12 months of the long-term stimulation phase of0-02 (n=235). One of the 6 subjects noted in
the long-term phase attempted suicide twice. Although safety data were not formally collected for
the 0-04 study, the health care utilization form documented suicide attempts. There were 3
suicide attepmts in this group through the first year (n=124).

e) Effectiveness Data
002 Acute Study
The primary effectiveness endpoint for the randomized, sham-controlled study was an analysis of
the percent responders decrease in HAM-0 (Hamilton) score from baseline to exit)
between the 2 groups. In an evaluable patient population, 15.3% (17/111) of the active
stimulation group were considered responders as compared to 10.0% of the sham group ( ll/11 0).
This difference was not statistically significant (p=0.238).

Secondary endpoints of the acute phase study assessed changes in other depression scales (IDS-
SR, CGI, MAORS, SF-36). The IDS-SR scale revealed a significant difference in the percent
responders (17.4% versus 7.5%, p=0.032). None of the other scales (CGI, MAORS, YMRS, SF-
36) identified as secondary endpoints, however, showed a statistically significant difference.

After completing the analysis of this acute phase data, an alternate statistical plan for
demonstrating effectiveness was employed that included comparison of 12 month results of the
0-02 continuation phase to the results of the 0-04 observation study (see below).

002 Long-Term Phase
The primary endpoint for the evaluation of the long-term phase of 0-02 was a repeated measures
linear regression analysis performed on the raw HAM-0 (HRS024 ) scores during the first 12
months after initiation of stimulation on the 12 month completer population. This was calculated
as the average of the slopes across the 4 quarters with each quarter having equal weight. As a
secondary endpoint, similar data was assessed using the IOS-SR scale. These results are shown
in Table 6.

T bl a e 6. D-02 L001(-T erm p·nmary ectlveness Resu ts
N Slope p-value

12-Month Completer Population
HAM-D
IDS-SR

12-Month Evaluable Population
HAM-D
IDS-SR

12-Month Intent-to-Treat Population
HAM-D
IDS-SR

177

205

231

-0.47/month
-0.55/month

-0.45/month
-0.52/month

-0 .40/month
-0.45/month

<0.001 <0.001

<0.001 <0.001 <0.001 <0.001

Patients were also assessed in terms of response rates as a secondary endpoint. Again, response
was defined as a 50% of more improvement in a scale’s score at 12 months compared with

13

baseline. Complete response (or remission) was defined as a scoreS 9 for HAM-D and S 14 for
IDS-SR. These results at 12 months are shown below in Table 7.

Table 7. 12-Month Evaluable Respon der and Rem ISS IOU Rates
Response Remission

HAM-D 29.8% 17.1%

IDS-SR 21.7% 15.0%

Sustained Response
The evaluable population was assessed over the last 4 visits of the first year (months 9,
I 0, II, and 12) to ascertain which subjects were “sustained responders” (defined as ::0: I
visit with:::: 50% response and at least an additional 2 visits with ::0: 40% response). Using
this definition, 27% (47/177) of the 12-month completer population were considered
sustained responders.

To explore whether subjects were receiving benefit that was not fully reflected in these response
rates, subjects were assigned to “clinical benefit” categories prospectively defined as
extraordinary benefit (;e,75% improvement in HRSD24 ), highly meaningful benefit (50-74%),
meaningful benefit (25% -49%), minimal/no benefit (0%-24%), and worsened (<0%). At 12 months, the percentage of evaluable subjects (n= 180) in each of these categories was as follows:

• Extraordinary Benefit 10.6%
• Highly Meaningful Benefit 20.0%
• Meaningful Benefit 25.0%
• Minimal or No Benefit 26.7%
• Worse 17.8%

As can be seen after 12 months, 56% of evaluable D-02 patients were realizing at least a
meaningful clinical benefit. This includes 57 (out of 122) subjects who were originally rated as
minimal to worse at 3 months.

For the long-term D-02 subjects who were considered 1-IRSD responders after 12 months
of stimulation, data depicting scores over time were further analyzed. Table 8 below
describes some long-term response characteristics of these subjects who were regarded as
“responders”.

14

dl

t . fT a ble 8 – HRSD R espon d er Charac ens 1cs
Number of
Subjects

0/o of
Responders

IN=54)
Had :c_ 50% of all assessments as responder
Had :c_ 75% of all assessments as responder
Had last 2 consecutive months as responder

Had last 3 consecutive months as responder

Able to reduce/eliminate antidepressant medications

31
9
34

24

7

57.4%
16.7%

63.0%

44.4%

13.0%

Response by Diagnosis
Separate analyses for both unipolar and bipolar groups were performed and found to show
identical results for the evaluable, ITT, or 12 month completer populations. Most of the unipolar
analyses retained statistical significance although the bipolar group sample size was too small for
most of the outcomes to reach statistical significance.

D02/D04 Comparisons
The efficacy analysis for the 002-004 comparative analysis was the comparison of the change
over time (slope) of the IDS-SR raw scores across 12-months with a repeated measures linear
regression model. A statistically significant difference (p

Figure 2. IDS-SR Scores D-02 Versus D-04 Study Subjects by Quarter
• 45 e
0
!/,
00

,;, !iii
Q

0.()4
0-02

JOL___

Baseline 3 Marth 6 Marth 9 Mori:h 12 Morth

8/L 3 mos 6 mos 9 mos 12 mos
Mean D-
04 Scores

43.0 38.1 37.5 37.3 38.5

Mean D-
02 Scores

43.0 36.9 35.1 33.7 33.7

When the analysis was repeated on the populations representing all implanted 0-02 subjects
compared to all 0-04 subjects having any data (D-02 N = 235; D-04 N = 127), the results
remained statistically significant (p < 0.00 l ).

Baseline demographic and illness characteristic differences were controlled in the repeated
measures linear regression analysis by incorporating the 5-level grouped propensity score. This
5-level grouped propensity score did not contribute to the statistical significance of the outcome

15

(p 0.831 ). Based on this analysis, the observed baseline demographic and illness characteristics
did not contribute to the difference in outcome between the D-02 and D-04 populations.

Secondary Analyses (D-02 vs D-04 Comparison)
IDS-SR and HRSD 24 12-Month Results
Tables 9 and 10 below show results ofiDS-SR and HRSD24 evaluations at 12 months for both the
D-02 and D-04 long-term evaluable populations.

I .D 02ill -04Eva uable Observe dPTable 9. JDS-SR Scores- – opu atwns
D-02 D-04 P-Value

N 180 I 12

Baseline Average
Raw Score (RS) 42.4 43.8

I 2 Month Data
Average RS 32.6 39.2
Median RS 32 40
Average Change -9.8 -4.6 <0.001 LOCF Average Change -9.3 -5.0 <0.001 Median Change -8.5 -3.5 AV& %Change 23.4 8.1 Median % Change 20.6 7.9

Response (%of Subjects) 22 12 0.029
LOCF Response (%of Subjects) 20 12 0.108
Complete Response (% Subjects) 15 4 0.006
LOCF Complete Response(%) 13 3 0.007

I .T bl e 10 HRSD 24 cores- D02ill04Compansons E I ble ObservedPopu allons a S – – va ua
D-02 P-ValueD-04
180N 104

Baseline Average 27.9 27.8
12 Month Data

Average 19.6 22.8
Median 23.5
A veraae Change

19.5
-8.2 -4.9 0.006

LOCF Average Change -7.4 -4.9 0.040
Median Change -7.5 -5.0
Ava. %Change 29.6 16.6
Median % Change 28.4 15.6

Response(% of Subjects) 30 0.003
LOCF Response(% of Subjects)

13
27 13 0.011

Complete Response(% Subjects) 17 7 0.031
LOCF Complete Response(%) 16 7 0.059
I 20 D-04 subjects d1d not have HRSD s performed at thw 12-month vtstl. the 12-month HRSD was added after
study initiation and several sites did not have IRB approval prior to subjects reaching one-year in the study

16

Censored Analysis (D-02 versus D-04 Comparison)
IDS-SR and HRSD24 12-Month Results after Censoring for Concomitant Treatments
Medication changes and ECT treatments were permitted in 002 subjects following the 12-week
acute phase portion of the study. A total of 14 D-02 subjects received ECT during the long-term
phase. ECT was used more frequently in non-responders. Four of the 14 subjects were
responders, two of which were complete responders; none of the subjects were sustained
responders (HRSD24 ). Only one responder received ECT in proximity to the 12-month visit.
Seven (7) D-04 subjects received ECT through 12-months. Two of these 7 were responders at
12-months. To ascertain mood medication changes over the course of the long-term phase, an
antidepressant resistance rating (ARR) score was determined for each medication for each
subject. More D-02 non-responders (77%) and D-04 subjects (81%) than D-02 responders (56%)
added or increased mood medications during the 12 months ofVNS Therapy.

An additional post-hoc analysis was performed comparing 002 and 004 subjects after censoring
the 002 patients at the first time of a significant addition or change in antidepressant treatment
and using the IDS score obtained just prior to this change for all subsequent visits. With this
analysis, the difference observed in the estimated IDS-SR raw scores per month between 002 and
004 evaluable populations at 12 months was -0.183 which was not statistically significant
(p=0.052). In addition, the response rate for the HSRD endpoint decreased from 30% to 19.9%.
This censored rate for HSRD was not statistically different from the 004 group response rate
(13%, p=O.ll8). Differences in response rates using the IDS-SR scale also were not significant
after censoring (18% versus 12%, p=0.085)

Sustained Response at 12 Months
As IDS-SR scores were collected only quarterly in the D-04 group, sustained response for
comparison of the two groups was defined as a 50% improvement or better at the last two
measured quarters (IDS-SR at 9- and 12-months compared to baseline). Statistically significantly
more evaluable D-02 subjects (13%) had sustained response than D-04 subjects (4%) [p = 0.005]
using this definition.

CGI-1 (Clinical Global Impression- Improvement)
Thirty-seven percent (37%) of evaluable D-02 subjects were rated as much improved or very
much improved at 12 months compared to D-04 subjects ( 12%; p < 0.001 ).

Other Statistical Analyses of D-02/D-04 Data
An intent-to-treat (ITT) analysis included 231 D-02 subjects and 124 D-04 subjects. The ITT
analysis results of the efficacy model were statistically significant (p < 0.001). An LOCF analysis uses the last available observation for subsequent time points where data are missing. LOCF analyses were performed on all 0-02/D-04 secondary comparisons, and statistical significance was maintained for all comparisons except for the IDS-SR evaluable response rates and HRSD24 evaluable complete response rates; in these latter two analyses, the results were not statistically significant (p=O.l 08 and 0.059 respectively).

Since the D-02 and D-04 studies had some different sites the results were examined from sites
that were only involved in both the D-02 and D-04 studies. This examination (using the HRSD 24 )
yielded results similar to the analysis that included all sites (27% HRSD24 12-month responder
rate for D-02 sites that also participated in D-04 vs. 30% for all D-02 sites). A formal statistical
analysis was not performed because the decreased sample size would not ensure adequate power.

17

J’j

SUPPLEMENTAL DATA
Although not provided in the original PMA, the sponsor submitted additional information to FDA
in a PMA Supplement following the Advisory Panel Meeting. This information is summarized
below.

2-Year Response Rates
The sponsor provided 2-year HRSD effectiveness data on 199 subjects including 42 from D-0 I
(feasibility) and !57 from D-02 (pivotal) representing 75% of the evaluable subjects and 67% of
the implanted patients combined from both studies. Table II below shows HRSD response and
complete response rates at 24 months as well as 3 and 12 months for evaluable subjects.

T I 11 Eva ua I bl – an d D 02 HRSD R esponse Rates 324Montabe e D 01 – – hs
D-02 D-Ol Combined

3 Months
Responder
Complete Responder

12 Months
Responder
Complete Responder

24 Months
Responder
Complete Responder

N=205
30 (14.6%)
15 (7.3%)

N=l81
54 (29.8%)
31 (17.1%)

N=157
51 (32.5%)
27 (17.2%)

N=59
18(31%)
9 (15%)
N=55

25 (45%)
15 (27%)

N=42
18 (43%)
9 (21 %)

N=264
48 (18.2%)
24(9.1%)

N=236
79 (33.5%)
46 (19.5%)

N=l99
69 (34.7%)
36 (18.1 %)

The sponsor further evaluated D-02 subjects at 2 years m terms of ”chmcal benefit” categones
based on changes in HRSD scores. This information is included in Table 12 below.

a e – “Cl’ ene 1t I – U >JCCtsT bl 12 IUICa. I B fi ” at 3, 12 and 24Months for Eva ua ble D 02 S b.
3 Months
(N=205)

12 Months
(N=180)

24 Months
(N=157)

< 25% Improvement (Minimal Benefit) 25-49% Improvement (Meaningful Benefit) 50-74% Improvement (Highly Meaningful Benefit) >75% Improvement
(Extraordinarily Meaningful Benefit)

142 (70%)

33 (16%)

21 (10%)

9 (4%)

80 (44%)

45 (25%)

36 (20%)

19(11%)

69 (43%)

36 (23%)

37 (24%)

15 (10%)

As can be seen in the table above, at 24 months, 57% of evaluable subjects received at least
meaningful benefit and 34% received at least a highly meaningful benefit. In an ITT analysis,
however, these percentages are 38% and 23% respectively.

It should be noted that changes and additions in concomitant medications and ECT were allowed
from 3 months through this 24 month follow-up and the impact of these changes is unknown.

2- Year Sustained Response
An analysis was also performed to evaluate “2-year sustained response.” Sustained response was
defined as having an initial :’:50% reduction in HRSD score at the designated “early” visit (3
months or 12 months) and then maintaining at least a :’:40% reduction at the later visit (I or 2
years, respectively). Of the 30 subjects who were 3-month responders, 18 (60%) maintained

18

responder status at 12 months and 21 (70%) maintained responder status at 24 months. Of the 54
12-month responders, 37 (69%) were also responders at 24 months. Similar rates are seen with
IDS data (61%, 57%, and 85% respectively).

New Analysis of Medication Changes
The sponsor performed an additional analysis on antidepressant medications in D-02 subjects.
For this analysis, evaluable subjects with an increase in antidepressant medication were compared
to subjects who had no increase in antidepressant medication. A total of 48 evaluable subjects
had no increase in antidepressant medication while 157 did have an increase over one year of
VNS therapy. At 12 months, 50% of the subjects without increase in medications were responders
as compared to 23% of the subjects who did have an increase in medications.

2-Year Therapy Continuation Rates
At one year, 98% (59/60) of D-Ol subjects and 90% (2111235) of D-02 subjects continued to
receive VNS therapy. At 2 years, 87% (52/60) of D-Ol subjects and 81% (190/235) of D-02
subjects continued with VNS therapy.

Adverse Event Update
Five (5) new events judged to be related to stimulation were noted between 12 and 24 months that
were not reported in the time prior: back pain, cerebral ischemia, hyperventilation, sinusitis, and
urinary frequency. The rates of the most common non-serious adverse events after 18 and 24
months of follow-up are shown in Table 13 below.

Table 13 Most Common Adverse Events at 18 and 24 Months

Event
18 Months

(N=200)
24 Months

(N=l84)
Voice Alteration 100 (50%) 95 (51.6%)
Neck Pain 27 (13.5%) 28 (15.2%)
Dyspnea 28 (14.0%) 25 (13.6%)
Laryngismus 9 (4.5%) 10 (5.4%)
Pain 15 (7.5%) 10 (5.4%)
Dysphagia 6 (3.0%) 9 (4.9%)
Increased Cough 14 (7.0%) 8 (4.3%)
Pharyngitis 9 (4.5%) 8 (4.3%)
Paresthesia 6 (3.0%) 7 (3.8%)

No reports of mania were recorded between 12 and 24 months of stimulation.

Serious Adverse Events
Table 14 below depicts the updated number of events of worsening depression and suicide
attempts by the quarter in which the event was reported known to the sponsor as of IOil 0/03.

19

timu a!Io nTable 14 Worsening Depression and Suicide Attempts per Quarter ofS I ·

Quarter after Start of Stimulation

Number of
Events of

Worsening
Depression

Number
of Suicide
Attempts

Year I

Year2

I st
2″d
3’d
4’h
5’h
6’h
7’h
gth

TOTAL

13
19
13
14
8
6
5
5

83

2
3
2
I
I
0
I
0

10

The 83 events of worsening depression were reported in 38 subjects and the 10 suicide attempts
were reported in 9 subjects.

SAFETY DATA FROM EPILEPSY EXPERIENCE (Studies and Post Marketing Data)

The VNS Device has been approved and marketed in the United States for the treatment of
refractory epilepsy since 1997. A summary of safety issues related to that use are provided here.

Therapeutic Side Effects and Tolerability

In the two randomized, double-blind, controlled epilepsy studies the following adverse events
were found to occur more frequently acutely, in either High or Low stimulation, than in baseline
in at least one of the two studies (E-03 Low Group Rate, E-05 High Group Rate): These results
are shown in Table 15 below.

Table 15. Adverse Events in Epilepsy Studies

Event E-03 Low Group’ E-05 High Group’
Voice Alteration 38.6% 72.6%
Cough 12.3% 52.6%
Throat Pain 7.0% 42.1%

–

Not Re[Jorted 33.7%
10.5% 27.4%

Paresthesia —- — -· 15.8% 24.2%
Dyspepsta ___ . _ Not Reported 21.1%

·-
Vomiting ——- 1.8% 17.9%
Infection 3.5% 14.7%
H1gh Group defined as receiving thcrapeultc stimulatwn

Analysis of Recent MDR Reports Submitted to FDA
An analysis was performed by FDA’s Office of Biometrics and Surveillance (OSB) on all
medical device reports (MDR) submitted for the VNS Epilepsy indication from July 1, 1997
through October 8, 2004. This analysis included 2,887 reports, 2,453 of which were reported
from sites within the United States. It should be noted that during this time, a total of 32,065
VNS Therapy device implants and 80,144 device years of implant experience had occurred.

20

Submission or an MDR report does not constitute an admission that medical personneL user
facility, importer, distributor, manufacturer, or product caused or contributed to the events listed.

Deaths
A total of 524 deaths have been reported to FDA. Of these, I02 (20%) were of an “unknown
cause.” Of those deaths with a reported cause the following were the most common etiologies:

• seizure disorder ( 152; 29%) including sudden unexplained death in elipepsy and status
epilepticus;

• respiratory events (99; 19%) including pneumonia, pulmonary edema, hypoxia;
• cardiac events (51; 10%) including cardiopulmonary arrest, infarction, and arrhythmias;
• neurovascular events (24; 5%) including stroke and cerebral hemorrhage
• malignancy (19; 3%) including brain and colon.

Nine (9) of the deaths were reported from suicide and 39 occurred during sleep.

Serious Injuries
A total of l ,644 serious injuries have been reported by the sponsor. The most frequently reported
serious injury was infection (525; 32%). Approximately 40% of these were known to have
required device explantation. The second most common serious injury reported was increased
seizure activity (324; 20%). Others included:

• vagus nerve injury (181; II%) including vocal cord paralysis (109) and hoarseness (71);
• respiratory injuries (141; 9%) including sleep apnea (33), dyspnea (50), and aspiration

(14);
• cardiac events (123; 8%) including tachycardia, bradycardia, palpitations, hypertension,

hypotension, syncope, and asystole;
• pain (81; 5%) including chest and neck pain;
• gastrointestinal events (60; 4%) including dysphagia (24) and weight loss (24);
• depression (21; I%)

Of the 1,644 reports of serious InJUry, 694 (42%) were associated with subsequent device
explantation in that subject.

Device Malfunctions
A total of 708 device malfunctions have been reported through the MDR system. Some of the
most common malfunctions reported were high lead impedance (351), lead breakage (116),
device failure (44), and device migration (20).

IX. CONCLUSIONS DRAWN FROM STUDIES

In conclusion, CDRH believes that the PMA applicant has provided reasonable assurance
of safety and effectiveness based on valid scientific evidence as required by statute and
regulation for the approval of a Class III medical device. CDRH has come to this
conclusion because the sponsor has provided data that were systematically collected and
analyzed which showed significant improvement from baseline over one and two years
for a definable subset of the target population, and comparative data against a reasonably
matched control which also showed sustained improvement over time.

21

X. PANEL RECOMMENDATION
On June 15, 2004, the Neurological Devices Panel, by a vote of 5-2, recommended that
the Pre-Market Approval Application (PMA) for the VNS Therapy System for the
treatment of chronic or recurrent treatment-resistant depression be found approvable with
the following conditions:

I. Patients should have failed four or more trials of traditional treatment
modalities for treatment-resistant depression (medications and ECT) prior to
use of the device.

2. The device will be implanted by surgeons with appropriate training.
3. Training regarding device electronic programming will be provided for

primary care providers.
4. Additional patient labeling for use of the device and identification card be

provided.
5. A patient registry to collect clinical data will be established.
6. The physician labeling be revised regarding the following: 12 month open

label follow-up, the variable effect of treatment, patient selection, and deletion
of imaging claims.

XI. CDRH DECISION
CDRH concurred with the Panel’s recommendation of June 15, 2004, and issued a letter to
Cyberonics, Inc. on February 2, 2005, advising that its PMA was approvable subject to

I. Submission of complete protocols for two post-market clinical studies:
a. A !-year, randomized dose-ranging study and
b. A 5-year observational registry study.

2. Revised physician and patient labeling
3. Resolution of Good Manufacturing Processes (GMP) inspection issues
4. Resolution of Bioresearch monitoring issues

In an amendment received by FDA on March 11, 2005, Cyberonics, Inc. submitted the
required data. FDA issued an approval order on July 15,2005. The applicant’s
manufacturing facility was inspected on June I 0, 2005 and was found to be in compliance
with the Quality System Regulation (21 CFR 820).

XII. APPROVAL SPECIFICATIONS
Directions for use: See the labeling.

Hazards to Health from Use of the Device: See Indications, Contraindications, Warnings,
precautions and Adverse Events in the labeling.

Postapproval Requirements and Restrictions: See approval order.

22