Decision catalogueModality pressure-test

361 language is not a free option on tissue technologies

Decision problem

Which claims stay inside a lighter posture — and which processing moves reclassify risk?

Thesis

Homologous-use and minimal-manipulation arguments must match actual processing, or the regulatory and capital model is fiction.

Tissue and HCTP-adjacent opportunities often underwrite timelines on 361-style framing. The claim test is whether processing steps and intended use still support that posture.

The review asks for a plain map: what is done to the tissue, why homologous use holds, and what commercial claims would force a different path. Donor eligibility, tracking, and quality systems should support the supply story at the claimed scale.

When clinical or performance language outruns homologous-use logic, reclassification risk becomes a pre-term-sheet decision trigger — not a post-close surprise.

Claim map

Must-be-true cuts a Decision Sprint memo would force

  • Homologous-use and minimal-manipulation arguments cohere with actual processing
  • Donor, tracking, and quality claims support the commercial supply story
  • Clinical or performance claims do not quietly imply a heavier regulatory burden than modeled

Decision triggers

Outputs from the claim test that should change the conversation

  • Processing steps that break minimal-manipulation assumptions
  • Intended use drifting beyond homologous-use framing
  • Supply and quality systems underspecified for the claimed scale

Sources

Related in the catalogue

Facing this cut on a live $1–10M package?

Scope a Decision Sprint for one opportunity under your deal deadline—claim map, risk register, management questions, and partner briefing.