This transmission software will transfer ECG, ambulatory blood pressure, EKG, spirometry and any other data files from a remote site to a central station for analysis using modem, cable modem, ISDN lines, T1 lines, DSL, Internet or Intranet for analysis and send the analyzed data back to the remote site from the central site using the same transmission media.
Device Story
Netlink/Netscan is a software accessory for Northeast Monitoring's Holter for Windows Holter Scanner. It facilitates the transmission of cardiac data (ECG, ambulatory blood pressure, EKG, spirometry) from remote sites to a central analysis site. Data is transferred via modem, cable modem, ISDN, T1, DSL, Internet, or Intranet. The system uses encrypted, password-protected channels with automated data integrity checks and retransmission protocols to prevent loss or corruption. At the central site, the Holter for Windows software analyzes the data; results are then transmitted back to the remote site. Trained medical personnel at the remote site interpret the analyzed data to diagnose patients. The device enables remote clinical workflows, allowing for centralized analysis of patient data collected at disparate locations.
Clinical Evidence
No clinical data provided. Substantial equivalence is based on technological comparison and performance characteristics of the transmission system.
Technological Characteristics
Software-based transmission system operating on IBM PC AT compatible hardware (minimum 550MHz Pentium, 256MB RAM at remote site). Connectivity includes modem, cable modem, ISDN, T1, DSL, Internet, and Intranet. Data is encrypted and password-protected. Includes automated data integrity checks and retransmission logic.
Indications for Use
Indicated for the transmission of ECG, ambulatory blood pressure, EKG, spirometry, and other data files between remote sites and a central station for analysis by trained medical personnel to diagnose patients with cardiac rhythm patterns.
Regulatory Classification
Identification
A telephone electrocardiograph transmitter and receiver is a device used to condition an electrocardiograph signal so that it can be transmitted via a telephone line to another location. This device also includes a receiver that reconditions the received signal into its original format so that it can be displayed. The device includes devices used to transmit and receive pacemaker signals.
Predicate Devices
PaceArt HomeTrak Plus EASI Event Recorder System (K982090)
Reference Devices
Northeast Monitoring's Holter for Windows Holter Scanner (K930564)
Submission Summary (Full Text)
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K020213/ page 1 of 3
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510 (k) Summary
Submitter:
APR - 5 2002
| Mark Rosoff, President | |
|--------------------------|-----------------------------------------------------------------------------------|
| Rozinn Electronics, Inc. | |
| 71-22 Myrtle Avenue | |
| Telephone: | 718-386-5526 |
| Fax: | 718-366-4574 |
| E-mail: | mark@rozinn.com |
| Contact: | Mark Rosoff |
| Date of Summary: | 11-07-01 |
| Name of Device: | Netlink/Netscan |
| Common Name: | ECG Transmission System |
| Classification Name: | Transmitters and receivers, Electrocardiograph telephone<br>(per 21 CFR 870.2920) |
Substantial Equivalence claimed to legally marketed device: PaceArt HomeTrak Plus EASI Event Recorder System- 510(k) K982090
## Description of Device:
Netlink/Netscan is an accessory to Northeast Monitoring's Holter for Windows Holter Scanner (K930564) that sends recorded cardiac ECG data from remote sites to a central site using standard TCP/IP transfer protocols and where the central site is equipped with Northeast Monitoring's Holter for Windows Holter Scanner for analysis. equipped Monitoring's Holter for Windows Holter Scanner software analyzes the ECG and provides reports on a variety of cardiac data. The cardiac data which is analyzed and provides reports on eforms and patterns of consecutive waveforms. The analysis is then returned to the remote site and interpreted by trained medical personnel to diagnose patients with cardiac rhythm patterns.
Netlink/Netscan is an accessory that provides a means to transmit data to and from Northeast Monitoring's Holter for Windows Holter Scanning System . Data can be transferred via modem, cable modems, ISDN lines, T1 lines, DSL, Internet or Intranet. All transferred data is encrypted and is only accessed through a password controlled by the remote and central sites. Netlink/Netscan software contains data checks to prevent the loss or corruption of data during transmission. Nelink/Netscan will resend data if transmission is interrupted.
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K020213/Page
2 of 3
# Intended use of Device:
This transmission software will transfer ECG, ambulatory blood pressure, EKG, spirometry and any other data files from a remote site to a central station for analysis using modem, cable modem, ISDN lines, T1 lines, DSL, Internet or Intranet for analysis and send the analyzed data back to the remote site from the central site using the same transmission media.
Comparison of Technology characteristics compared to predicate device:
| Specifications | Predicate Device<br>Paceart HomeTrak Plus<br>EASI Event Recorder<br>System | New Device<br>Netlink/Netscan<br>Central Site |
|----------------|----------------------------------------------------------------------------|-----------------------------------------------|
| Type | IBM PC AT Compatible | IBM PC AT Compatible |
| CPU | 166 Mhz Pentium or greater | 550MHz Pentium or greater |
| RAM | 2 Mbytes Minimum | 2 Mbytes Minimum |
| Hard disk | 2.1 Gbytes Minimum | 2.1 Gbytes Minimum |
| Display | SVGA | SVGA |
| Modem | 28.8K with dedicated line | Yes |
| Cable Modem | No | Yes |
| Internet | No | Yes |
| ISDN Line | No | Yes |
| T1 Line | No | Yes |
| DSL | No | Yes |
| Specifications | Predicate Device<br>Paceart HomeTrak Plus<br>EASI Event Recorder<br>System | New Device<br>Netlink/Netscan<br>Remote Site |
| Type | IBM PC AT Compatible | IBM PC AT Compatible |
| CPU | 166 Mhz Pentium or greater | 550 MHz Pentium or greater |
| RAM | 32 Mbytes Minimum | 256 Mbytes Minimum |
| Hard disk | 2.1 Gbytes Minimum | 2.1 Gbytes Minimum |
| Display | SVGA | SVGA |
| Modem | 28.8K with dedicated line | Yes |
| Modem Cable | No | Yes |
| Internet | No | Yes |
| ISDN Line | No | Yes |
| T1 Line | No | Yes |
| DSL | No | Yes |
| Network Card | No | Yes |
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K020213/\$\frac{page}{3 of 3}\$
Conclusion:
The only difference between the Netlink/Netscan and the Paceart HomeTrak Plus EASI Event Recorder System is the use of transmission systems used. The Netlink/Netscan will transmit data using Internet, ISDN Lines, DSL, T1 Lines, Cable Modem and Modem whereas the PaceArt HomeTrak Plus EASI Event Recorder System only transmits data using a modem. In summary the performance between the two systems were nearly identical and supports the claim that they are substantially equivalent.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
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Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
APR = 5 2002
Mr. Mark Rosoff President Rozinn Electronics, Inc. 71-22 Myrtle Avenue Glendale, NY 11385-7254
Re: K020213
Trade Name: Netlink/Netscan Regulation Number: 21 CFR 870.2920 Regulation Name: Telephone Electrocardiograph Transmitters and Receivers Regulatory Class: Class II (two) Product Code: DXH Dated: January 11, 2002 Received: January 22, 2002
Dear Mr. Rosoff:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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## Page 2 - Mr. Mark Rosoff
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must corply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set Of It Fat 607), and may (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally premated predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4646. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
ch
Bram D. Zuckerman, M.D. Acting Director Division of Cardiovascular and Respiratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# STATEMENT OF INDICATIONS FOR USE
K020213 510(K) Number (if known):
Device Name: Netlink/Netscan
Indications for Use:
The Netlink/Netscan is a transmission software which will transmit ECG, ambulatory blood pressure, EKG, spirometry, and any other data files from a remote site to a central station for analysis using a modem, cable modem, ISDN line, T1 lines, DSL, Internet or Intranet and send the analyzed data back to the remote site from the central * site using the same transmission media.
Division of Cardiovasc
510(k) Number K020213
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Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.