K030714 · Peak Performance Technologies, Inc. · LXJ · May 16, 2003 · Physical Medicine
Device Facts
Record ID
K030714
Device Name
PEAK MOTUS
Applicant
Peak Performance Technologies, Inc.
Product Code
LXJ · Physical Medicine
Decision Date
May 16, 2003
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5360
Device Class
Class 2
Indications for Use
Computer and video system used to quantify and graphically display human movement patterns and techniques for uses such as assessment and training of limb or body motion in gait analysis, prosthetic design, pre/post rehabilitation evaluation, physical therapy, and the like.
Device Story
System collects, quantifies, and documents human movement in 2D or 3D space. Inputs include real-time video images from off-the-shelf cameras, reflective markers on subjects, and analog sensor data (e.g., force platforms, EMG). Proprietary software running on Windows workstations processes inputs via synchronization boards; calculates kinematic and kinetic parameters (displacements, velocities, accelerations, joint forces, moments, powers). Used in clinical/laboratory environments by clinicians/researchers. Output includes graphical displays (line graphs, x-y plots, stick figures) and printed reports. Assists healthcare providers in gait analysis, prosthetic design, and rehabilitation evaluation; enables objective assessment of movement patterns.
Clinical Evidence
No clinical data provided. Effectiveness demonstrated via in-house testing and reported use by independent third parties in biomechanical research and medical settings.
Technological Characteristics
System comprises Windows-based PC workstation, proprietary synchronization/processing boards, off-the-shelf video cameras, and analog-to-digital interface (up to 64 sensors). Employs optical motion capture (marker-based or markerless) and analog sensor acquisition. Software modules perform kinematic/kinetic calculations. Connectivity via standard PC interfaces. Non-contact, passive sensing.
Indications for Use
Indicated for patients requiring assessment and training of limb or body motion, including gait analysis, prosthetic design, and pre/post rehabilitation evaluation in physical therapy settings.
Regulatory Classification
Identification
Measuring exercise equipment consist of manual devices intended for medical purposes, such as to redevelop muscles or restore motion to joints or for use as an adjunct treatment for obesity. These devices also include instrumentation, such as the pulse rate monitor, that provide information used for physical evaluation and physical planning purposes., Examples include a therapeutic exercise bicycle with measuring instrumentation, a manually propelled treadmill with measuring instrumentation, and a rowing machine with measuring instrumentation.
Special Controls
*Classification.* Class II (special controls). The device, when it is a measuring exerciser or an interactive rehabilitation exercise device for prescription use only, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.
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K030714
MAY 1 6 2003
# Peak Motus Motion Measurement System 510(k) Summary
## Submitter
| Company: | Peak Performance Technologies, Inc.<br>7388 S Revere Pkwy 901, Centennial, Colorado 80112 USA<br>Tel 303 799 8686, Fax 303 799 8690 |
|-------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Larry Scheirman |
| Prepared: | 28 February 2003 |
| Device Name | |
| Trade: | Peak Motus Motion Measurement System |
| Common: | Motion measurement system |
| Classification: | System, Optical Position/Movement Recording |
| Product code: | LXJ |
| Predicate Devices | |
| Trade Name: | CODA mpx30 Motion Analysis System |
| 510(k) Number: | K982425 |
| Manufacturer: | Charnwood Dynamics Ltd |
## Introduction
The Peak Motus Motion Measuring System is a mature product. It has been marketed for years for biomechanical research and performance evaluation. The manufacturer has become aware that the system has demonstrated-value and increasing use in medical settings. Therefore, this 510(k) notification is being submitted to properly notify authorities and recognize the system as a legally marketed medical device.
## Device Description
The system uses off-the-shelf video cameras, sensors, and computers to collect, quantify, and document human movement in two-dimensional or three-dimensional space. The proprietary elements of the system are Peak's software applications, which run on Microsoft Windows, and an interface box, which can mix and synchronize multiple digital and analog inputs when active data capture is used. The system can effect the capture of real-time video images of motion along with associated sensor information, then sequence the coordinate and sensor information for recording on the computer. Alternatively, the system can use video recordings to provide the motion information. Motion and sensor data are recorded, analyzed, and displayed or reported from the computer.
A typical study involves recording the locations of small reflective markers on subjects as movement occurs. This provides instant coordinate data. Coordinate data may also be gathered from digitized video sequences. Analog sensors, such as force platforms or EMG systems, may also be part of the instrumentation during movement. Their information can be
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synchronized, processed, and displayed along with the coordinate information. The system can calculate standard 2-D or 3-D kinematic and kinetic parameters using specific calculation modules. A report generation package displays and reports the data: in raw or processed form. step-by-step, or sequentially.
The Peak Motus system may include software modules, such as
- * Advanced video or 3D-optical-motion-capture module
- * 2D and/or 3D kinematic calculation and display software
- * Analog acquisition module
- * 3D pan and tilt module
- * KineCalc mathematical analysis module
- * Peak Motus Gait Analysis Template
Its hardware comprises a Microsoft Windows computer workstation with proprietary synchronizing and processing boards, and a variety of equipment setups, including
- * Purchased cameras, VCRs, lights, calibration frames, high-speed video
- * Video, optical-capture, and analog-acquisition boards
- * Event synchronization unit
- Analog EMG and force-platform systems and analog-to-digital interface unit (accepts up to 64 sensors)
Movement tracking can be done with or without markers in virtually any collection environment—indoors, outdoors, or even under water. For most medical applications, the tracking is done indoors in a controlled laboratory environment with markers.
The Peak Motus System has standard data reduction algorithms for editing, filtering and calculating linear and anqular displacements, velocities, and accelerations. Specialized templates are available for custom calculations: for example, the Peak Motus 3D Gait Analysis Template provides industry-standard gait-analysis calculations such as body segment angles. joint forces, moments, and powers.
The systems' report and display package can print standard reports or can display data on the computer screen through a multimedia-display tool. Parametric data created with the system may be displayed as line graphs, x-y plots, bar graphs, stick figures (with vector overlays), text, and data tables.
## Indications for Use
Computer and video system used to quantify and graphically display human movement patterns and techniques for uses such as assessment and training of limb or body motion in gait analysis, prosthetic design, pre/post rehabilitation evaluation, physical therapy, and the like.
## Summary of Technological Characteristics
The Peak Motus Motion Measurement System is substantially equivalent to the CODA mpx30 system from Charnwood Dynamics. Both systems acquire motion patterns by optical capture directly linked into a PC computer in real time; using multiple cameras to gather threedimensional information. In addition, the Peak Motus can acquire these patterns from recorded video. Both systems provide standard biomechanical kinetic analyses: displaying the data in tables and graphs on-screen and in printed reports.
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## Summary of Non-Clinical Performance
#### Safety
Safety is not an issue with the system. The system uses commonly available consumer and technical equipment with demonstrated safety. The equipment are passive sensing and recording devices; most of which never contact the subject.
#### Effectiveness
Extensive in-house testing has demonstrated the effectiveness of this system.
#### Summary of Clinical Performance
In-house and clinical testing by independent third parties has been reported that demonstrates the system's effectiveness and fitness for use in this application.
#### Equivalence to Predicate Devices
The Peak Motus Motion Measurement System is substantially equivalent to the CODA mpx30 system as a means of measuring the general three-dimensional movements of subjects, including such activities as walking. Both systems provide a non-intrusive optical method of measuring the movement. Both systems acquire the movement data into a host PC, which then analyzes and displays motion data onscreen or in printed reports. Specific, standard gait analysis and other analysis programs are available for these calculations and reports.
The CODA system uses proprietary cameras and LED markers with automatic identification while the Peak Motus system can be used with or without markers with standard video equipment. In addition, the Peak Motus system can use recorded video images to obtain motion information and can incorporate concurrent analog sensor data with its measurements.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles forming a wing-like shape, which is a common symbol associated with the department.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. Larry Scheirman President Peak Performance Technologies, Inc. 7388 S. Revere Parkway 901 Centennial, CO 80112
Re: K030714
Trade/Device Name: Peak Motus Motion Measurement System Regulatory Class: Unclassified Product Code: LXJ Dated: February 28, 2003 Received: March 6, 2003
Dear Mr. Scheirman:
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.
MAY 1 6 2003
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.
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 comply 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 forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 - Mr. Larry Scheirman
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 marketed 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), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act 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/cdrf/dsma/dsmamain.html
Sincerely yours,
Mark A. Melluson
Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Supplement:
510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________
Peak Motus Motion Measurement System Device Name: __
Indications for Use:
Computer and video system used to quantify and graphically display human movement patterns and techniques for uses such as assessment and training of limb or body motion in gait analysis, prosthetic design, pre/post rehabilitation evaluation, physical therapy, and the like.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
L. Mark N. Milliken
Restorative
510(k) Number
(Optional Format 3-10-98)
Page 1 of 1
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.