The Brainz Instruments Ltd BRM3 Brain Monitor is an electroencephalograph or EEG system, as per 21 CFR §882.1400: a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head. - The BRM3 Brain Monitor is intended for use to monitor the state of the brain by acquisition of electroencephalogram (EEG) signals, in clinical environments such as the intensive care unit, and for clinical research. - The BRM3 Brain Monitor is intended for use only with neonatal patients, defined as from birth to 28 days post-delivery, and corresponding to a post-conceptual age of 24 to 46 weeks. - The BRM3 Brain Monitor does not provide any diagnostic conclusion about the patient's condition.
Device Story
BRM3 Brain Monitor is a 3-channel EEG system for neonatal brain monitoring. Inputs: EEG signals via skin electrodes/sensor sets placed on patient head. System components: Data acquisition unit (head stage), monitor (touch-screen PC), data cable, power supply, roll-pole. Operation: Acquires and records electrical brain activity; displays EEG channels and aEEG parameters; provides signal quality indication and file review. Used in clinical environments (e.g., ICU) by healthcare professionals. Output: Real-time EEG/aEEG visualization for clinician review to monitor brain state; does not provide diagnostic conclusions. Benefits: Facilitates continuous neurological monitoring in neonates.
Clinical Evidence
No clinical data. Safety and effectiveness established via bench testing, including performance testing of the new EEG head stage, software verification, comparative analysis of aEEG parameter implementation, and third-party testing for electromagnetic compatibility and electrical safety (IEC 60601).
Indicated for monitoring brain state via EEG signal acquisition in neonatal patients (birth to 28 days post-delivery; 24-46 weeks post-conceptual age) in clinical settings like ICUs or for research. Not for diagnostic use.
Regulatory Classification
Identification
An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.
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K071449
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Image /page/0/Picture/2 description: The image shows the word "BRAINZ" in a bold, sans-serif font. Above the word is a graphic that resembles an electroencephalogram (EEG) reading, with jagged lines representing brain activity. The graphic is positioned directly above the word, creating a visual association between the word "BRAINZ" and the concept of brain activity or intelligence.
#### 7 September 2007
SEP 1 4 2007
## 510(k) SUMMARY
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR §807.92:
(a)(1) Refer to information above and concluding this summary.
#### (a)(2) Name of the Device
Model Number / Name: BRM3 Brain Monitor Classification Name: Electroencephalograph Neurology Devices, 21 CFR §882.1400, Class II, OMA, OMC, OLT
#### (a)(3) Identification of Legally Marketed Devices
| K030489 | BRM2 Brain Monitor | Bra |
|---------|-------------------------------------|-----|
| K033010 | BRM2 Brain Monitor | Bra |
| K983229 | Lectromed Cerebral Function Monitor | Oly |
inz Instruments Ltd inz Instruments Ltd mpic Medical Corp
#### (a)(4) Description of the Device
The BRM3 Brain Monitor is a three-channel electroencephalograph (EEG) system, as per 21 CFR §882.1400: a device used to measure and record the electrical activity of the patient's brain by placing two or more electrodes on the head.
The BRM3 Brain Monitor system consists of a Neonatal Sensor Set (EEG skin electrodes) or Sensor Adaptor Set (electrode adaptor), Data Acquisition Unit (EEG head stage), Data Cable, Monitor, Power Supply Unit, and Roll-Pole. These components have equivalent configuration and functions to those described in 510(k) K030489 and K033010 for the BRM2 Brain Monitor.
Changes to the BRM3 Brain Monitor consist of a new touch-screen panel PC (Monitor), new EEG head stage (Data Acquisition Unit) and new mobile mounting hardware (Roll-Pole). New software features include display of a further EEG channel, display of an aEEG parameter, and improved signal quality indication and file reviewing capacity. User instructions have been updated accordingly.
#### (a)(5) Statement of the Intended Use
The Brainz Instruments Ltd BRM3 Brain Monitor is an electroencephalograph or EEG system, as per 21 CFR §882.1400: a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.
- The BRM3 Brain Monitor is intended for use to monitor the state of the brain by acquisition of . electroencephalogram (EEG) signals, in clinical environments such as the intensive care unt, and for clinical research.
- The BRM3 Brain Monitor is intended for use only with neonatal patients, defined as from birth to 28 days post-delivery, and corresponding to a post-conceptual age of 24 to 46 weeks.
- The BRM3 Brain Monitor does not provide any diagnostic conclusion about the patient's condition.
Image /page/0/Picture/22 description: The image shows contact information for Brainz Instruments Ltd. The address is 25 Carbine Rd, Mt Welling, Auckland 1060, New Zealand. The PO box is 51078, Pakura, Manukau 2140, New Zealand, and the phone number is +64 9 978 8896. The website is www.brainz.com.
Brainz Instruments USA la
Suite 1700
8850 Stanford Blvd.
Columbia MD 21045
United States
Tel +1-410-312-0324
TOLL FREE 1-877-312-03-
Fax +1-410-312-0328
The image doesn't contain any discernible text.
Brainz Instruments UK Ltd
Fountain Court
2 Victoria Square
Victoria Street
St Albans
Hertfordshire AL1 3TF
United Kingdom
Tel +44 1727 884 784
Image /page/0/Picture/26 description: The image is a square with a grainy texture. The center of the image is a lighter shade of gray, and the words "see inside" are written in a simple, sans-serif font. The text is also a lighter shade of gray, blending in with the background.
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## (a)(6) Technological Characteristics Summary
The technological characteristics of the BRM3 Brain Monitor are equivalent to the predicate devices listed above. The system uses similar components for the touch-screen panel PC display unit, EEG head stage electronics module mounting hardware. Technical equivalence has been established to ensure accuracy of the aEEG parameter implementation. Software is updated for compatibility with those changes, and the same skin electrodes are used as previously notified in 510(k) K033010.
### (b)(1) Discussion of the Non-Clinical Tests
Non-clinical testing of the BRM3 Brain Monitor has been carried out to cover the changes to the system. These include performance testing of the new EEG head stage electronics module, full software verification procedures for updated device functionality, comparative results of the aEEG parameter implementation, and third-party testing of the entire system for compliance to IEC 60601 standards for electromagnetic compatibility, electrical safety, particular requirements for electroencephalographs, and US national requirements. This established correct functionality of the BRM3 Brain Monitor system according to requirements, and is equivalent to the predicate devices.
## {b)(2)_Discussion of the Clinical Tests
Clinical testing was not required to demonstrate the safety and effectiveness of the modifications involved in the BRM3 Brain Monitor. The changes to hardware, electronics, and software have been adequately assessed by establishing technical equivalence and bench testing as above.
# (b)(3) Conclusions Demonstrating Safety, Effectiveness and Performance
The testing carried out for the BRM3 Brain Monitor indicates that it meets design and performance functional requirements. The software verification demonstrates that the modified device features are effective, and the hardware / electronics configuration functions equivalently to the predicate devices.
This information indicates that the BRM3 Brain Monitor is equivalent to the predicate devices in terms of device safety, effectiveness and performance.
signed:
Chris Mander
cerations Manager rainz Instruments Ltd
te: 7 Sept 2007
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three lines forming its body and wings. The eagle is facing right. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Brainz Instruments Ltd. c/o Mr. Morten Simon Christensen Underwriters Laboratories, Inc. Staff Engineer & FDA Office Coordinator 455 East Trimble Road San Jose, California 95131-1230
APR - 9 2012
Re: K071449
Trade/Device Name: BRM3 Brain Monitor Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: II Product Code: OMA, OMC, OLT Dated (Date on orig SE ltr): August 13, 2007 Received (Date on orig SE ltr): August 14, 2007
Dear Mr. Christensen:
This letter corrects our substantially equivalent letter of September 14, 2007.
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 (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 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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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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm,
Sincerely yours,
Kesia Alexander
Malvina B. Eydelman, M.D. Director Division of Ophthalmic. Neurological. and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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11 June 2007
| 510(k) Number: | K071449 |
|----------------------|--------------------|
| Device Name: | BRM3 Brain Monitor |
| Indications for Use: | |
The Brainz Instruments Ltd BRM3 Brain Monitor is an electroencephalograph or EEG system, as per 21 CFR §882.1400: a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.
- The BRM3 Brain Monitor is intended for use to monitor the state of the brain by acquisition of electroencephalogram (EEG) signals, in clinical environments such as the intensive care unit, and for clinical research.
- The BRM3 Brain Monitor is intended for use only with neonatal patients, defined as from birth to 28 days post-delivery, and corresponding to a post-conceptual age of 24 to 46 weeks.
- The BRM3 Brain Monitor does not provide any diagnostic conclusion about the patient's condition.
| Prescription Use (21 CFR 801 Subpart D) | <div> <span style="text-decoration: underline;">✓</span> </div> | AND/OR | Over-The-Counter Use (21 CFR 801 Subpart C) |
|-----------------------------------------|-----------------------------------------------------------------|--------|---------------------------------------------|
|-----------------------------------------|-----------------------------------------------------------------|--------|---------------------------------------------|
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of General, Restorative, and Neurological Devices
| 510(k) Number | K071449 |
|---------------|---------|
|---------------|---------|
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.