Response to FCC request for information

0257-EX-ST-2005 Text Documents

DexCom, Inc.

2005-05-24ELS_71021

File No. 0257-EX-ST-2005
Reference Number: 3658

            SUPPLEMENT TO APPLICATION FOR EXPERIMENTAL
                   SPECIAL TEMPORARY AUTHORITY

      DexCom, Inc. herein supplements its above-referenced application for
new experimental Special Temporary Authority (“STA”) to provide information
requested in correspondence on May 19, 2005.

        As stated in its initial application, DexCom has been developing a
breakthrough implantable blood glucose monitoring system, allowing
convenient and low cost control of diabetes up to now not possible. DexCom is in
the process of pursuing clinical studies and seeks experimental authorization to
use the devices identified in the application at and in home environments around
various major medical facilities in the United States. DexCom’s system, expected
to cost less than $30 for the short term sensor, represents a low-cost, medically-
valuable and efficient alternative to presently-available blood glucose monitoring
techniques. Bringing DexCom’s blood glucose monitoring devices to market as
soon as possible will reap enormous public heath benefits.

        In its efforts to bring its glucose monitoring devices to the market,
DexCom, in addition to seeking permanent FCC equipment authority, is also
required to work with the FDA in order to gain certification for its devices.
Owing to the significant public health concerns of diabetes, the FDA has already
granted DexCom expedited review of its pre-market approval and, in doing so,
has stated in its requirements for gaining final certification that DexCom’s short
term clinical trials must include 100 people per study. For the approvals that
DexCom is seeking from the FDA, it will also need to conduct up to
five studies, so a total of 500 transmitters at various locations is required to fully
implement DexCom’s clinical studies.

        Given the large number of patients required in each study, DexCom had
to engage a sufficient number of medical programs that were willing to commit
their physicians and patients to the development of the equipment. Authority to
operate is accordingly herein sought by the FCC consistent with the list of
facilities identified in DexCom’s application, as it seeks to gain additional
technical knowledge as to the functionality of its system while satisfying the
important additional FDA requirements.

      DexCom’s devices have the capability of transmitting blood glucose data
continuously. The bulk of DexCom’s proposed experimental operations would
involve patients who use a short-term sensor, which has the glucose sensing


system under the skin, but the electronics are on the outside of the body. In the
case of only twenty units will there be the use of a long-term sensor that is
implanted in a patient. Both devices use sensors that obtain blood glucose
measures, which are then transmitted every five minutes (288 transmissions a
day) by wireless RF telemetry to a cell-phone sized receiver that a patient carries
with him or her. Patients can, at a push of a button, learn their current blood
glucose levels as well as chart their recent blood glucose levels to determine how
well they are maintaining constant blood glucose levels.

        The frequent transmissions are necessary to allow patients to receive
sufficient information regarding their blood glucose levels to monitor and react
to those levels by, for example, injecting insulin. Likewise, the large pool of
devices requested in the instant STA request are needed to allow the collection of
a series of blood glucose measurements and trends with a frequency that
heretofore has not been possible. DexCom maintains that authority to permit it
to operate up to 500 units at the various medical facilities identified on its
application and in the neighboring home environments is warranted in light of
the critical technical information this experimentation will provide and with
regard to the public health implications of the use of those devices as DexCom
prepares them for certification and marketing.



Document Created: 2005-05-24 22:51:30
Document Modified: 2005-05-24 22:51:30

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