C3 AND LIFEGARD ICG IMPEDANCE CARDIOGRAPHY MONITORS
Applicant
Analogic Corp.
Product Code
DSB · Cardiovascular
Decision Date
Aug 6, 2004
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2770
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The C3 ICG Monitor is intended to non-invasively monitor a patient's hemodynamic parameters when in the ICG mode. The hemodynamic parameters include: Acceleration Index (ACI), Pre-ejection Period (PEP), Cardiac Index (CI), Stroke Index (SI), Cardiac Output (CO), Stroke Volume (SV), Ejection Time Ratio (ETR), Systemic Vascular Resistance (SVR), Ejection Velocity Index (EVI), Systemic Vascular Resistance Index (SVRI), Heart Rate (HR), Systolic Time Ratio (STR), Heather Index (HI), Thoracic Fluid Content (TFC), Left Cardiac Work Index (LCWI), Thoracic Fluid Volume Index (TFI), Left-ventricular Ejection Time (LVET), Velocity Index (VI). The Impedance Cardiography (ICG) function of the C3 ICG is intended for use under the direct supervision of a licensed healthcare practitioner or personnel trained in its proper use within a facility providing healthcare. The C3 ICG is intended for use on Adult patients that meet the limits specified below: Height: 4 ft 7 ft-6 in (122 229 cm), Weight: 67 350 lb (30 159 kg). When not in the ICG mode, the C3 ICG is intended to provide continuous ECG, heart rate, noninvasive blood pressure (NIBP), functional arterial oxygen saturation (SpOz), respiration rate, temperature and carbon dioxide (CO2) on Adult and Pediatric patients within a hospital or facility providing patient care. These are indications previously cleared under K030931. The LIFEGARD™ ICG Monitor is intended to non-invasively monitor a patient's hemodynamic parameters. The hemodynamic parameters include: Acceleration Index (ACI), Blood Pressure (built-in NIBP), Cardiac Index (CI), Cardiac Output (CO), Heart Rate (HR), Left Cardiac Work Index (LCWI), Left-ventricular Ejection Time (LVET), Pre-ejection Period (PEP), Stroke Index (SI), Stroke Volume (SV), Systemic Vascular Resistance (SVR), Systemic Vascular Resistance Index (SVRI), Systolic Time Ratio (STR), Thoracic Fluid Content (TFC), Velocity Index (VI). The LIFEGARD™ ICG is intended for use under the direct supervision of a licensed healthcare practitioner or personnel trained in its proper use within a facility providing healthcare. The LIFEGARD™ ICG is intended for use on Adult patients that meet the limits specified below: Height: 4 ft 7 ft-6 in (122 229 cm), Weight: 67 350 lb (30 159 kg).
Device Story
C3 ICG and LIFEGARD™ ICG are compact, battery-powered hemodynamic monitors. Inputs include ECG leads, SpO2 sensors, thermistor probes, NIBP cuffs, EtCO2 sampling, and Thoracic Electrical Bioimpedance (TEB) electrodes. Device processes physiological signals to calculate hemodynamic parameters (e.g., Cardiac Output, Stroke Volume, SVR). Output displayed on LCD and printed on 50-mm strip chart. Used in hospitals/clinics by trained healthcare personnel. Output assists clinicians in hemodynamic assessment and patient management. Benefits include non-invasive monitoring of cardiac function.
Clinical Evidence
Clinical study conducted at University of Mississippi Medical Center with 84 patients (75 readable). Compared Analogic C3 ICG to Cardiodynamics BioZ (K974725). Study verified hemodynamic monitoring performance equivalence.
Technological Characteristics
Compact, battery-powered monitors. Sensing: ECG, SpO2, thermistor, oscillometric NIBP, EtCO2, and Thoracic Electrical Bioimpedance (TEB). Connectivity: Standalone with LCD and thermal printer. Standards: IEC 60601-1, IEC 60601-1-2:2001, AAMI/ANSI EC-13, EN 864, EN 865, AAMI/ANSI SP10, IEC 60601-2-30, IEC 60601-2-49, IEC 60068 series.
Indications for Use
Indicated for adult patients (height 122-229 cm, weight 30-159 kg) for non-invasive hemodynamic monitoring via Impedance Cardiography (ICG). C3 ICG also indicated for continuous ECG, HR, NIBP, SpO2, respiration, temperature, and CO2 monitoring in adult and pediatric patients in hospital/clinical settings.
Regulatory Classification
Identification
An impedance plethysmograph is a device used to estimate peripheral blood flow by measuring electrical impedance changes in a region of the body such as the arms and legs.
Special Controls
*Classification.* Class II (special controls). The device, when it is a body composition analyzer which is not intended to diagnose or treat any medical condition, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.
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K041434
AUG - 6 2004
Image /page/0/Picture/2 description: The image shows the word "ANALOGIC" in a bold, sans-serif font. The letters are all capitalized and black. A registered trademark symbol is located to the right of the letter "C". A black square is located to the right of the word.
#### 510(k) Summary for Analogic Corporation C3 ICG and LIFEGARD™ ICG Hemodynamic Monitors
# Date this Summary was Prepared:
May 26, 2004
# Submitter's Name and Address:
| Submitter's Name: | Analogic Corporation |
|-----------------------|----------------------|
| Address: | 8 Centennial Drive |
| City, State, and Zip: | Peabody, MA 01960 |
| Registration Number: | 1219601 |
#### Contact Person:
| Name: | Donald J Sherratt |
|------------|-------------------------------|
| Title: | Regulatory Affairs Manager |
| Telephone: | (978) 977-3000 extension 3049 |
| Facsimile: | (978) 977-6808 |
| E-mail: | dsherratt@analogic.com |
#### Device Name:
| Proprietary or Trade Name: | C3 ICG |
|-----------------------------|---------------------------|
| Proprietary or Trade Name: | LIFEGARD™ ICG |
| Common Name: | Impedance Plethysmograph |
| Classification Name: | Plethysmograph, Impedance |
| Classification Panel: | Cardiology |
| Product Code: | DSB |
| Code of Federal Regulation: | 870.2770 |
## Predicate Device:
The legally marketed devices to which equivalence is being claimed are:
The C3 Patient Monitor cleared under K0309031, and the Cardiodynamics BioZ System cleared under Premarket Notification K974725. The Impedance Cardiography (ICG) parameter incorporated in the C3 ICG and LIFEGARD™ ICG is substantially equivalent to the Cardiodynamics BioZ System.
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KD-34
# Description of C3 ICG
The C3 ICG is a compact, lightweight device for measuring, processing, printing, and displaying information derived from six physiological measurements:
- Electrocardiogram (ECG). A three lead ECG is acquired and a waveform car. be . displayed real-time on the LCD screen or permanently recorded on the optical strip chart recorder. The design of the ECG function is derived directly from the predicate device, the C3 Patient Monitor.
- Pulse Oximetry (SpO2). Functional Oxygen Saturation is calculated from the ratio of light . transmission through the capillary bed at two wavelengths. The SpO2 subsystem uses software and firmware that is identical to that used in the predicate device, C3 Patient Monitor.
- The temperature is measured using thermistor probes for continuous temperature . measurements. Same as in the predicate device, C3 Patient Monitor.
- Blood pressure is measured non-invasively (NIBP) by the oscillometric method. Same as . in the predicate device, C3 Patient Monitor.
- End-tidal CO2 (EtCO2) This method pulls a constant sample flow of exhaled breath from . the patient, and analyzes it with a remote CO2 sensor built into the measurement system. Same as in the predicate device, C3 Patient Monitor.
- Impedance Cardiograph (ICG). This mode uses Thoracic Electrical Bioimpedance (TEB) .
- An internal thermal printer records waveforms, hemodynamic parameters and tabular . trends on a 50-mm wide strip chart.
The C3 ICG is powered by internal sealed lead-acid batteries or from the mains supply via a battery eliminator. A fully charged battery will power the monitor for two hours.
# Description of LIFEGARD™ ICG
The LIFEGARD™ ICG Patient Monitor is a compact, lightweight device for measuring, processing, storing, and displaying information derived from six physiological measurements:
- Electrocardiogram (ECG). A single lead ECG is acquired and a waveform can be . displayed real-time on the LCD screen or permanently recorded on the thermal strip chart recorder. The design of the ECG function is derived directly from the C3 Patient Monitor with ICG Parameter.
- Blood pressure is measured non-invasively (NIBP) by the oscillometric method. Same as . in the predicate device, C3 Patient Monitor.
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- A thermal printer records waveforms, digital vital signs, and tabular trends on a 50-mm . wide strip chart.
The LIFEGARD™ ICG monitor is powered by internal sealed lead-acid batteries. A fully charged battery will power the monitor for two hours.
#### Intended Use:
The purpose and function of the ICG mode of the C3 ICG is to monitor Cardiac Output through the use of Impedance Cardiography (ICG) in adult Males and Fernales.
When not being used for ICG, the C3 ICG can monitor and display continuous ECG, heart rate, non-invasive blood pressure (NIBP), functional arterial oxygen saturation (SpO2;), respiration rate, temperature and carbon dioxide (CO2) on adult and pediatric patients in hospital areas and hospital-type facilities, such as clinics.
The purpose of the LIFEGARD™ ICG is to non invasively monitor Cardiac Output using Impedance Cardiography (ICG) on adult Males and Females and provide continuous ECG, heart rate, non-invasive blood pressure (NIBP), on adult and pediatric patients in hospital areas and hospital-type facilities, such as clinics.
### Comparison of Technological Characteristics:
The design of the C3 ICG Monitor is a product update to the design of the C3 Patient Monitor (K030931). The technological characteristics of the C3 ICG are essentially the same as the predicate device - Cardiodynamics BioZ (K974725). Similarly, the characteristics of the LIFEGARD™ ICG are essentially the same as the predicate device - Cardiodynamics BioZ (K974725).
## Non-clinical Tests Used In Determination Of Substantial Equivalence:
The predicate device - Cardiodynamics BioZ claims compliance with IEC 601-1 and UL 2601-1 that are previous versions of IEC 60601-1 and UL 60601-1 respectively. The predicate's manufacturer has made no claims of compliance with IEC 60601-1-2 so the electromagnetic compatibility of the predicate is unknown.
The design of both the C3 ICG and the LIFEGARD™ ICG have been thoroughly validated at the unit and system level and meets all elements of their respective Requirements Specifications. This included the following non-clinical tests:
- IEC 60601-1 (including Amendments 1 & 2), an FDA recognized consensus standard for . safety of medical electrical equipment.
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- Electromagnetic Compatibility Tests in compliance with IEC 60601-1-2:2001. Emissions . limits meet Group 1 Class B.
- ECG Performance Testing According to AAMI/ANSI EC-13 (C3 ICG only when in . standard ECG mode. When in ICG Mode, ECG is non-standard single lead)
- EtCO2 Function Test According to EN 864/1996 (C3 ICG with CO2 only) .
- SpO2 Tested According to EN865, Pulse Oximeters Particular requirements: 1997 (C3 . ICG only).
- NIBP Functional Testing to AAMI/ANSI SP10, Electronic or Automated . Sphygmomanometers, 2nd Ed .: 1992 and IEC 60601-2-30
- Both new devices were tested to IEC 60601-2-49. .
- Mechanical Shock and Vibration Tests were performed in accordance with the IEC 60068 . series of standards to ensure transport does not damage the devices.
- Shipping Container Transportation Tests were performed in accordance with IEC 60068-. 2-27 to ensure that the packaging of the equipment is not adversely affected during shipping.
- Battery Cycle Testing was performed. .
- Altitude Tests were performed to ensure that operation at higher altitudes does not . adversely affect electrical safety or performance.
- Tests were performed to verify enclosure material robustness and resistance to cleaning . materials commonly used in hospitals.
Both the C3 ICG and LIFEGARD™ ICG passed the applicable tests.
# Conclusions from Non-clinical Testing
The testing of the C3 ICG and LIFEGARD™ ICG monitors demonstrates that the non-clinical performance is substantially equivalent to the predicate devices - Cardiodynamics BioZ (K974725) and C3 Patient Monitor (K030931).
Other Bench Testing has shown that the hemodynamic monitoring performance of the C3 ICG and LIFEGARD™ ICG are substantially equivalent to the Cardiodynamics BioZ monitor.
# Clinical Testing
Clinical testing was performed at the University of Mississippi Medical center where an IRB approved protocol was performed. 84 patients were sampled, 75 were readable and met Analogic's protocol (6 unreadable and 3 with abnormal EVI). Since the patients with abnormal EVI were readable, their results are included in any analysis for completeness. The study was to compare the predicate device - Cardiodynamics BioZ (K974725) with the Analogic C3 ICG. The ICG circuitry of the LIFEGARD™ ICG is essentially identical to that of the C3 ICG and bench tests have been carried out to verify that they are essentially identical when used for ICG. This meant that only one model of device was needed for the clinical study.
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Public Health Service
Image /page/4/Picture/2 description: The image is a black and white seal for the Department of Health & Human Services - USA. The seal is circular with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the edge. In the center of the seal is a stylized image of three lines that resemble an eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
AUG - 6 2004
Analogic Corporation c/o Mr. Donald J. Sherratt Regulatory Affairs Manager 8 Centennial Drive Peabody, MA 01960
Re: K041434
K041434
Trade Name: C3 ICG and LIFEGUARD Impedance Cardiography (ICG) Monitors
Trade Name: C3 ICG and LIFEGUARD Impedance Cardiography (ICG) Monitors
Cardional C3 ICG and L Regulation Number: 21 CFR 870.2770 Regulation Name: Impedance Plethysmograph Regulatory Class: II (two) Product Code: DSB Dated: May 26, 2004 Received: May 28, 2004
Dear Mr. Sherratt:
We have reviewed your Section 510(k) premarket notification of intent to market the device We have reviewed your Sectori > ro(x) premainer is substantially equivalent (for the indications referenced anove and have decemblical the devices marketed in interstate
for use stated in the enclosure) to legally marketed predical Device Amendments for use stated in the enclosure) to regally manced produced Device Amendments, or to
commerce prior to May 28, 1976, the enactment of the Federal Food Drug commerce prior in May 20, 1970, the chance with the provisions of the Federal Food, Drug, devices that have been reciassified in accounter approval approval application (PMA).
and Cosmetic Act (Act) that do not require approval of a provisions of the Act . The and Cosmetic Act (Act) that do not require approvate or exampls provisions of the Act. The You may, therefore, market the device, subject to tire genires for amual registration, listing of
general controls provisions of the Act include requirements misbranding and general controls provisions of the rect morate required.
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 If your device is classified (see above) mits existing major regulations affecting your device can
may be subject to such additional controls. Existing major regulation FDA may be subject to such additional controlis. Existing may of of 898. In addition, FDA may
be found in the Code of Federal Regulations, Title 21, Parts 800 to Register be found in the Code of I ederal Regarations) our device in the Federal Register.
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Page 2 – Mr. Donald J. Sherratt
Please be advised that FDA's issuance of a substantial equivalence determination does not mean Please be advised that FDA s issualite of a subscunse or equirements of the Act
that FDA has made a determination that your device of accepcies. You must that FDA has made a determination that your arres by other Federal agencies. You must or any Federal statures and regulations administered of registration and listing (21 l
ocomply with all the Act's requirements, including, but not man reguirements as set comply with all the Act S requirements, including courses on the requirements as set
CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as se CFR Part 807); iabeling (21 CFR Part 820); and 820); and if applicable, the electronic
forth in the quality systems (QS) regulation (21 CFR Pat 820); and 11 CFR 1000-1050 forth in the quality systems (QS) regulation (Sections 531-542 of the Act); 21 CFR 1000-1050.
product radiation control provisions (Sections 531-542 of the Action Section S product radiation control provisions (Scctions 95 described in your Section 510(k)
This letter will allow you to begin marketing your device to a legal This letter will allow you to begin makemig your averal equivale of your device to a legally
premarket notification. The FDA finding of substantial equityices of your device premarket notification. The FDA Inding of substantial equives.
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
rs the latest of the many of 1610 - Alancel assements the regulation entitl If you desire specific advice for your de need on our and note the regulation entitled, the regulation entitled, the local of the contact the Office of Complance at (501) 591 107 (21CFR Part 807.97). You may obtain
"Misbranding by reference to premarket notification" (21CFR Pact 807.97). "Misbranding by relerence to premance noulities under the Act from the Division of Small
other general information on your responsibilities under the Act from worker (800) 63 other general information on your responsion.com its toll-free number (800) 638-2041 or
Manufacturers, International and Consumer Assistance at its toll-demanain html Manufacturers, International and Consulter Prossow.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Neil R, Ojde
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### Indications For Use Form (1)
510(k) Number (if known): K041434
Device Name: C3 ICG
Indications For Use:
The C3 ICG Monitor is intended to non-invasively monitor a patient's hemodynamic parameters when in the ICG mode. The hemodynamic parameters include:
| Acceleration Index (ACI) | Pre-ejection Period (PEP) |
|---------------------------------------|-------------------------------------------|
| Cardiac Index (CI) | Stroke Index (SI) |
| Cardiac Output (CO) | Stroke Volume (SV) |
| Ejection Time Ratio (ETR) | Systemic Vascular Resistance (SVR) |
| Ejection Velocity Index (EVI) | Systemic Vascular Resistance Index (SVRI) |
| Heart Rate (HR) | Systolic Time Ratio (STR) |
| Heather Index (HI) | Thoracic Fluid Content (TFC) |
| Left Cardiac Work Index (LCWI) | Thoracic Fluid Volume Index (TFI) |
| Left-ventricular Ejection Time (LVET) | Velocity Index (VI) |
The Impedance Cardiography (ICG) function of the C3 ICG is intended for use under the direct The minionalies curationer practitioner or personnel trained in its proper use within a super in on facility providing healthcare. The C3 ICG is intended for use on Adult patients that meet the limits specified below:
- > Height: 4 ft 7 ft-6 in (122 229 cm)
- > Weight: 67 350 lb (30 159 kg)
When not in the ICG mode, the C3 ICG is intended to provide continuous ECG, heart rate, noninvasive blood pressure (NIBP), functional arterial oxygen saturation (SpOz), respiration rate, temperature and carbon dioxide (CO2) on Adult and Pediatric patients within a hospital or facility providing patient care. These are indications previously cleared under K030931.
| Prescription Use<br>(Part 21 CFR 801 Subpart D | <span style="text-align:center">X</span> | AND/OR | Over-The-Counter Use<br>(21 CFR 801 Subpart C) |
|------------------------------------------------|------------------------------------------|--------|------------------------------------------------|
|------------------------------------------------|------------------------------------------|--------|------------------------------------------------|
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY)
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of Cardiovascular Devices
for BD2
| 510(k) Number | K041434 |
|---------------|---------|
|---------------|---------|
Analogic Corporation C3 ICG and LIFEGARD™ ICG 510(k)
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## Indications For Use Form (2)
510(k) Number (if known): K041434
Device Name: LIFEGARD™ ICG
Indications For Use:
The LIFEGARD™ ICG Monitor is intended to non-invasively monitor a patient's hemodynamic parameters. The hemodynamic parameters include:
| Acceleration Index (ACI) |
|-------------------------------------------|
| Blood Pressure (built-in NIBP) |
| Cardiac Index (CI) |
| Cardiac Output (CO) |
| Heart Rate (HR) |
| Left Cardiac Work Index (LCWI) |
| Left-ventricular Ejection Time (LVET) |
| Pre-ejection Period (PEP) |
| Stroke Index (SI) |
| Stroke Volume (SV) |
| Systemic Vascular Resistance (SVR) |
| Systemic Vascular Resistance Index (SVRI) |
| Systolic Time Ratio (STR) |
| Thoracic Fluid Content (TFC) |
| Velocity Index (VI) |
The LIFEGARD™ ICG is intended for use under the direct supervision of a licensed healtheare The Lir LOAND - TOO is michood for assessment or facility providing healthcare. practified or personner transed in the proper and h patients that meet the limits specified below:
- Height: 4 ft 7 ft-6 in (122 229 cm) A
- Weight: 67 350 lb (30 159 kg) A
| Prescription Use<br>(Part 21 CFR 801 Subpart D | X | AND/OR | Over-The-Counter Use<br>(21 CFR 801 Subpart C) |
|------------------------------------------------|---|--------|------------------------------------------------|
|------------------------------------------------|---|--------|------------------------------------------------|
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY)
Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off)
Division of Cardiovascular Devices
| 510(k) Number | K041434 |
|---------------|---------|
|---------------|---------|
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.