Grapefruit USA Inc (GPFT)

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3. Multiple and split predicates: To provide greater assurance that any comparison of a new
device to a predicate is valid and well reasoned, consider (a) issuing guidance on the appropriate
use of multiple predicates, and (b) disallowing the use of “split predicates” (i.e., the use of one
predicate for “intended use” and another for “technological characteristics”).