K080217 · Moberg Research, Inc. · OMA · Nov 5, 2008 · Neurology
Device Facts
Record ID
K080217
Device Name
COMPONENT NEUROMONITORING SYSTEM
Applicant
Moberg Research, Inc.
Product Code
OMA · Neurology
Decision Date
Nov 5, 2008
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1400
Device Class
Class 2
Attributes
Pediatric, 3rd-Party Reviewed
Indications for Use
The Component Neuromonitoring System™ is intended to monitor the state of the brain by recording and displaying EEG signals, and can also receive and display a variety of vital signs and other measurements from third-party monitoring devices (such as ICP, ECG, SpO2, and others). It also has the optional capability to record and display patient video. The Component Neuromonitoring System is intended for use by a physician or other qualified medical personnel. It is intended for use on patients of all ages within a hospital or medical environment, including the operating room, intensive care unit, emergency room, and clinical research settings.
Device Story
Portable, computer-based system for continuous real-time recording, display, and storage of physiological data. Inputs: EEG signals (up to 16 channels), optional video, and third-party vital signs (ICP, ECG, SpO2) via digital serial interfaces or manual entry. System comprises touchscreen display, computer, Device Interface Module, and EEG amplifier. Operated by physicians or qualified medical personnel in hospital environments. Processes EEG data to compute parameters including aEEG, Total Power, Spectral Edge Frequency, Band Power Percentages, Envelope Amplitude, % Asymmetry, % Suppression, and Inter-Burst Interval. Output displayed as waveforms, trends, numeric readouts, or spectral arrays. Facilitates clinical decision-making by enabling comparison of measurements and time periods. Supports monitoring protocols and embedded reference content for user guidance. Data archival via Ethernet or CD/DVD.
Clinical Evidence
Bench testing only. Validation and verification testing performed to ensure conformance to design requirements. Comparison testing conducted to ensure substantial equivalence of aEEG calculation and display against predicate devices. No clinical trial data presented.
Technological Characteristics
Portable computer-based system with color touchscreen, Device Interface Module, and EEG amplifier. EEG amplifier features 19 inputs (16 EEG, 6 differential pairs for physiological signals). Connectivity: Ethernet, USB (MDport), CD/DVD. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, IEC 60601-2-26. Software includes monitoring protocols and embedded reference content.
Indications for Use
Indicated for monitoring brain state via EEG and vital signs (ICP, ECG, SpO2) in patients of all ages in hospital settings (OR, ICU, ER, research).
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.
Lectromed Cerebral Function Monitor System (k983229)
Submission Summary (Full Text)
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K080217
page ① of 3
# 510(k) Summary
| Submitter: | Moberg Research, Inc.<br>224 South Maple Way<br>Ambler, PA 19002<br>Phone: (215) 283-0860<br>Fax: (215) 283-0859 | NOV - 5 2008 |
|----------------------|------------------------------------------------------------------------------------------------------------------|--------------|
| Contact Person: | Damon Lees | |
| Device Trade Name: | Component Neuromonitoring System™ | |
| Common Name: | EEG Monitor | |
| Classification Name: | Electroencephalograph (21CFR882.1400, Product Code: GWQ) | |
| Date of Preparation: | September 22, 2008 | |
#### Substantially Equivalent Devices:
| Product Name | 510(k) Number | Manufacturer / Submitter |
|-----------------------------------------------|---------------|--------------------------|
| A-2000 EEG Monitor with BIS | k974496 | Aspect Medical |
| Bravo Multi-Modality System | k991054 | Nicolet Biomedical |
| BRM2 Brain Monitor | K033010 | BrainZ Instruments |
| CFM 6000 | k031149 | Olympic Medical |
| HARMONIE-Schwarzer EEG System | k010728 | Stellate Systems |
| Integra Mobius Multi-Modality System | k061640 | Integra NeuroSciences |
| Nervus Monitor | k021185 | Taugagreining HF |
| Neurotrac II-EP | k960170 | Moberg Medical |
| Lectromed Cerebral Function Monitor<br>System | k983229 | Olympic Medical |
#### Indications for Use:
The Component Neuromonitoring System™ is intended to monitor the state of the brain by recording and displaying EEG signals, and can also receive and display a variety of vital signs and other measurements from third-party monitoring devices (such as ICP, ECG, SpO2, and others). It also has the optional capability to record and display patient video.
The Component Neuromonitoring System is intended for use by a physician or other qualified medical personnel. It is intended for use on patients of all ages within a hospital or medical environment, including the operating room, intensive care unit, emergency room, and clinical research settings.
### Device Description:
The Component Neuromonitoring System (CNS) is a portable, computer based system that can continuously record, display, store, and analyze physiological data from multiple monitoring sources
| | Moberg Research, Inc. | |
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in real-time. Electroencephalographic (EEG) data can be recorded from up to 16 electrode locations using the included EEG amplifier. Video can be recorded using an optional video camera. Other data can be recorded from interfaces to third-party monitoring devices, or can be manually entered.
The CNS Monitor consists of the following main physical components: a color flat-panel touchscreen display, an integrated computer system, a Device Interface Module, and an EEG Arnolifier. All hardware components of the monitor are mounted on a wheeled pole stand to provide a compact design, convenient use, and ease of transportation. An Ethernet port is located at the base of the system to allow the archival of patient data to a network. A storage basket can hold electrone supplies, and can also hold the EEG amplifier when the system is not in use.
The Device Interface Module contains six digital serial interfaces for connecting to external monitoring devices and four MDport™ (USB) interfaces used for connecting to other CNS components (such as the EEG Amplifier) or to electrically isolated, USB-based, external monitoring devices. The Device Interface Module also contains a CD/DVD drive for archiving patient recordings, for updating the system software, and for other data storage or retrieval purposes.
The EEG Amplifier is small and lightweight and connects to the Device Interface Module with a flexible 15' cord. It has 19 inputs (including Reference, Ground, and auxiliary inputs) and can record from up to 16 EEG electrode sites. Up to 6 inputs can be used as differential pairs for other physiological signals (e.g.: ECG, EOG, respiration, etc.). Continuous impedance checking automatically detects any electrodes that become loose or detached.
Data can be viewed on the CNS Monitor using a variety of display types: waveform, trend, numeric readout, compressed spectral array (CSA), and density spectral array (DSA). Combinations of multiple display types can be configured in a variety of screen layouts to allow the comparison of different measurements or different time periods from the recording.
The CNS Monitor can compute processed parameters from the EEG data, including: Amplitude Integrated EEG (aEEG), Total Power, Spectral Edge Frequency, EEG Band Power Percentages (delta, theta, alpha, beta), Envelope Amplitude, % Asymmetry, % Suppression, and Inter-Burst Interval (IBI).
The CNS Monitor also has several features to enable ease-of-use. It employs monitoring protocols that can step the user through a monitoring procedure and configure a group of settings for the recording (including EEG electrode sites & montage, collected measurements, and display settings). Pre-configured protocols are included on the system and the user can also create their own customized protocols. Embedded reference content can be viewed on the CNS Monitor to assist the user with system features, device connections, electrode application, and other topics.
### Comparison of Technological Characteristics to Predicate Devices:
The Component Neuromonitoring System has the combined technological characteristics of the specified predicate devices. The system can record and display both digital EEG and video. compute various processed parameters from the EEG, and digitally interface to third-party monitoring devices for the collection and storage of other measurements.
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#### Summary of Performance Testing:
The Component Neuromonitoring System has undergone validation and verification testing to ensure conformance to all design requirements. Additionally, the system has undergone comparison testing to ensure the substantial equivalence of the calculation and display of the aEEG.
To ensure safety, the Component Neuromonitoring System will comply with all applicable requirements of IEC60601-1 and IEC60601-1-4, and will also comply with the uparticular requirements for the safety of electroencephalographs established in IEC60601-2-26.
To ensure electromagnetic compatibility, the Component Neuromonitoring System will comply with all applicable requirements of IEC60601-1-2, and will also comply with the particular requirements for the safety of electroencephalographs established in IEC60601-2-26.
#### Conclusion of Substantial Equivalence:
The comparison of technological characteristics and performance testing of the Component Neuromonitoring System demonstrate that its safety, effectiveness, and performance are equivalent to the specified predicate devices.
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Image /page/3/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 bars representing the agency's mission. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the eagle symbol. The logo is in black and white.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Moberg Research, Inc. c/o CITECH Mr. Robert Mosenkis 5200 Butler Pike Plymouth Meeting, Pennsylvania 19462-1298
APR - 9 2012
Re: K080217 Trade/Device Name: Component Neuromonitoring System Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: II Product Code: OMA, GWQ, OLT, MUD, MHX, ORT Dated (Date on orig SE ltr): October 20, 2008 Received (Date on orig SE ltr): October 21, 2008
Dear Mr. Mosenkis:
This letter corrects our substantially equivalent letter of November 5, 2008.
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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Page 2 - Mr. Robert Mosenkis
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/ReportalProblem/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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# 4.0 Indications for Use
510(k) Number (if known):
Device Name: Component Neuromonitoring System
Indications For Use:
The Component Neuromonitoring System™ is intended to monitor the state of the brain by recording and displaying EEG signals, and can also receive and display a variety of vital signs and other measurements from third-party monitoring devices (such as ICP, ECG, SpO2, and others). It also has the optional capability to record and display patient video.
The Component Neuromonitoring System is intended for use by a physician or other qualified medical personnel. It is intended for use on patients of all ages within a hospital or medical environment, including the operating room, intensive care unit, emergency room, and clinical research settings.
Prescription Use × (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
## (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
## Concurrence of CDRH, Office of Device Evaluation (ODE)
Peter Arvan
(Division Sign-Off) Division of General. Restorative. and Neurological Devices
11/4/08
510(k) Number K080217
Moberg Research, Inc.
Component Neuromonitoring System The 510(k) Application
Section 4, Page 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.