SYNERGEYES SIG (PETRAFOCON A HEM-LARAFILCON A) HYBRID CONTACT LENS
K083921 · Synergeyes, Inc. · HQD · May 20, 2009 · Ophthalmic
Device Facts
Record ID
K083921
Device Name
SYNERGEYES SIG (PETRAFOCON A HEM-LARAFILCON A) HYBRID CONTACT LENS
Applicant
Synergeyes, Inc.
Product Code
HQD · Ophthalmic
Decision Date
May 20, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 886.5916
Device Class
Class 2
Indications for Use
SynergEyes® SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lenses for daily wear are indicated for use in the correction of hyperopic, myopic and astigmatic refractive error including presbyopia, in aphakic and not aphakic, non-diseased eyes. The lenses are indicated for daily wear for the correction of up to +20.00 and -20.00 D in eyes with astigmatism up to 6.00 D. For presbyopia, add powers between +1.00 and +4.00D. The lenses may be disinfected using only a chemical disinfecting system compatible with both hydrogel and rigid gas permeable lenses.
Device Story
SynergEyes SiH is a hybrid contact lens featuring a high-Dk rigid gas permeable (RGP) center (petrafocon A) and a soft silicone-hydrogel skirt (hem-larafilcon A) joined by a proprietary chemical bond. The lens straddles the limbus, focusing light onto the retina. It is prescribed by eye care professionals for daily wear to correct refractive errors. The device is available in spherical, aspheric, front-surface toric, and multifocal designs. Patients benefit from the visual acuity of an RGP lens combined with the comfort of a soft lens. The lens is sterilized via e-beam and requires chemical disinfection compatible with both materials.
Clinical Evidence
Prospective, unmasked, open-label 3-month study of 98 subjects (approx. 2:1 test-to-control ratio). Primary endpoints included safety (adverse events, slit lamp findings) and effectiveness (visual acuity, wearing time). Results showed stable Snellen visual acuity and similar daily wearing times (11.6-13.0 hours) between cohorts. Adverse events were comparable; slit lamp findings and symptom reports (dryness, halos) were slightly higher in the test cohort but deemed acceptable. Study concluded the device is substantially equivalent to the predicate.
Technological Characteristics
Hybrid lens construction: RGP center (petrafocon A, Dk 130) and soft silicone-hydrogel skirt (hem-larafilcon A, 33% water). Diameter 14.5mm; base curves 7.10-9.00mm. Sterilization: e-beam. Proprietary chemical bonding at the junction. UV blocking included. Biocompatibility per ISO 10993.
Indications for Use
Indicated for daily wear correction of hyperopic, myopic, and astigmatic refractive error, including presbyopia, in aphakic and non-aphakic, non-diseased eyes. Corrects up to +/- 20.00 D with astigmatism up to 6.00 D; add powers +1.00 to +4.00 D.
Regulatory Classification
Identification
A rigid gas permeable contact lens is a device intended to be worn directly against the cornea of the eye to correct vision conditions. The device is made of various materials, such as cellulose acetate butyrate, polyacrylate-silicone, or silicone elastomers, whose main polymer molecules generally do not absorb or attract water.
Predicate Devices
SynergEyes™ A & M (paflufocon D hem-iberfilcon A) Hybrid Contact Lens (K051035)
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K083921
# 510 (K) SUMMARY
MAY 20 2009
#### Applicant's Name and Address
SynergEyes, Inc. 2232 Rutherford Road Carlsbad, CA 92008 (760) 476 9410 (760) 476-9340 FAX
Richard Lippman, OD FAAO Vice President Ophthalmic Regulatory Products R.P. Chiacchierini & Associates, LLC 15825 Shady Grove Road Suite 30 Rockville, Maryland 20850 (240) 683-3738 rel@rpcaconsulting.com
#### 1. Identification of device
Common Name: Trade Name:
Contact Person
Classification: Device classification:
Contact Lens SynergEyes™ SiH(petrafocon A hem-larafilcon A) Hybrid Daily Wear Lens Daily Wear Rigid Gas Permeable Contact Lens Class II (21 CFR 886.5916)
# 2. Description of device
The SynergEyes™ SiH (petrafocon A hem-larafilcon A) Hybrid Daily Wear Contact Lens is a combination of high Dk rigid gas permeable contact lens corneal option surrounded by a soft hydrophilic silicone-hydrogel skirt (periphery) that straddles the limbus of the eye :
- in the power range of -20.00 to +20.00 diopters for sphere,
- . cylinder powers up to 6.00 diopters for astigmatism
- with center thickness from 0.12mm to 0.30mm .
- with base curves of 7.10mm to 9.00mm
- � with diameter of 14.50mm
- Add Powers 1.00 to 4.00 (multifocal)
This lens material for the rigid portion is petrafocon A, an upgrade high Dk silicone base RGP material, lathe cut, surrounded by soft hydrophilis silicone-hydrogel copolymer (hem-larafilizon A), sterilized by means of e-beam sterilization. When placed on the human cornea, the SynergEyes™ SiH Hybrid Contact Lens acts as a refracting medium to focus light rays onto the The device is available in the following indications: spherical, toric, and multifocal, with retina. spherical or aspheric surfaces in violet visibility tim the RGP center, and multing, will may device is substantially equivalent to the SyneryEyes™ A and M (paflufocon D hem-iberfilion A) Hybrid Daily Wear Contact Lens predicate devices manufactured by the sponsor, Synerglyes, Inc.
The SynergEyes™ Sill Hybrid Daily Wear Contact Lens center is a highly oxygen permeable (Dk 130) rigid gas material of (petrafocon A). The soft skirt is comprised of silicone-hydrogel copolymer (hem-larafilcon A) of 33% water and 73% polymer.
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SynergEyes™, Inc. Carlsbad, CA 92008
The junction between the rigid material is bound by a proprietary chemical bonding method.
#### 3. Intended use
SynergEyes® SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lenses for daily wear are indicated for use in the correction of hyperopic, myopic and astigmatic refractive error including presbyopia, in aphakic and not aphakic, non-diseased eyes. The lenses are indicated for daily wear for the correction of up to +20.00 and -20.00 D in eyes with astigmatism up to 6.00 D. For presbyopia, add powers between +1.00 and +4.00D. The lenses may be disinfected using only a chemical disinfecting system compatible with both hydrogel and rigid gas permeable lenses.
#### 4. Predicate device
# For Design: Predicate- K051035 SynergEyes™ A & M (paflufocon D hem-iberfilcon A) Hybrid Contact Lens
The SynergEyes™ SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lens design is based on the SynergEyes™ (paflufocon D hem-iberfilcon A) Hybrid Contact Lens. The designs of both lenses are based on a rigid gas permeable center optic and a soft hydrogel skirt with a special proprietary bonding process to join the center and the peripheral portions at the junction of the optic edge where it joins the peripheral ring.
# For Material Similarities: Predicate- K051035, K052560, K033919, K970746
The SynergEyes™ SiH (petrafocon A hem-larafiicon A) Hybrid Contact Lens has a rigid gas permeable center optic portion which is a high Dk (Dk 130) silicone based polymer (petrafocon A) surrounded by a silicone-hydrogel high Dk (Dk 84.2) soft skirt. The predicate lens, the SynergEyes™ A (paflufocon D hem-iberfilcon A) Hybrid Contact Lens has the center materialfluorosilicone acrylate, Paragon HDS material (Dk 100) permeability, surrounded by a hemabased polymer soft ring with Dk 9.1. The materials in both the subject device and predicate device are characterized as Group I low water, non-ionic in nature for their soft portions as the water content for the subject device is 33% and the predicate device is 25.0%. The water content for the rigid portion of both lenses is < 1%.
# For Physical and Optical Properties: Predicate- K050135
The lens being cited as the predicate lens for the subject SynergEves™ SiH (petrafocon A. hemlarafilcon A) Hybrid Contact Lens is the SynergEyes™ A and M (paflufocon D hem iberfilcon A) Hybrid Contact Lens (K051035). The physical and optical properties that characterize both the subject and predicate device are shown in a side-by-side companson chart. Properties such as oxygen permeability for both the center portion and peripheral skirt demonstrate the subject lens material to have a substantially higher permeability in both the RGP center and the soft skirt. Other properties that are compared for similarities and differences include refractive index, wetting angle, specific gravity, Shore Hardness, luminance transmittance, surface charge, surface treatment, water content, base curve, diameter, power range, chord diameter, UV additive,
# 5. Characteristics
The physical and dimensional characteristics of the SynergEyes™ SiH Hybrid Contact Lens are compared to the characteristics of the predicate device SynergEyes™ A and M Hybrid Contact Lens in the following table.
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SynergEyes™, Inc. Carlsbad, CA 92008
| | SynergEyes™<br>Hybrid Contact<br>Lens<br>K051035 | SynergEyes™<br>Hybrid<br>Silicone/Hydrogel<br>Lens<br>(Subject Device) |
|--------------------------|-----------------------------------------------------------------------------|---------------------------------------------------------------------------|
| Lens Characteristics | | |
| Manufacturer | SynergEyes™ Inc. | SynergEyes, Inc. |
| Base Curves | 7.10-9.00mm | 7.10-9.00mm |
| RGP Center | 8.40mm | 8.40mm |
| Optic Zone Diameter | 7.80mm | 7.80mm |
| Lens Designs | Sphere, Aspheric,<br>Front Surface Toric,<br>Multifocal | Sphere, Aspheric,<br>Front Surface Toric,<br>Multifocal |
| Diameters: | 14.5mm | 14.5mm |
| Power Range | -20.00 to + 20.00D | -20.00 to +20.00 |
| Cylinder Range | 0.50 to 6.00D | 0.50 to 6.00D |
| Refractive Index (RGP) | RGP Center:<br>1.442 | RGP Center:<br>1.442<br>S/H Skirt:<br>1.435 |
| Wetting (Contact) Angle | RGP Center:<br>42° | RGP Center:<br>43.19°<br>Soft Skirt:<br>29.40° |
| Specific Gravity (RGP) | 1.10 | 1.15±0.025 |
| Hardness | RGP:<br>74.8<br>Soft Skirt: | RGP:<br>76.0<br>Soft Skirt:<br>53.4<br>Dry-<br>Hydrated- 8.9<br>(Shore A) |
| Indications for Use | Daily Wear | Daily Wear |
| UV Blocking | No | Yes |
| Material | RGP Center:<br>Paflufocon D<br><br>Soft Skirt: iberfilcon<br>A (HEMA, MEMA) | RGP Center:<br>petrafocon A<br><br>Soft Skirt:<br>hem-larafilcon A |
| Tint | Visibility Blue | Visibility violet |
| Soft Skirt Water Content | HEMA Skirt:<br>25% | S/H Skirt (Finished):<br>27.99% |
| Core (RGP) Water Content | < 1% | <1% |
#### 6. Non clinical studies
A battery of pre-clinical studies were performed on the subject device in accordance with the Guidance for Daily Wear Contact Lenses, May 1994.
Toxicology Studies were conducted under GLP and determined that the SynergEyes™ SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lenses were biocompatible for the intended use in accordance with ISO 10993 Standard for the following tests:
- . Cytotoxicity
- . Acute Ocular Irritation
- . Systemic Injection
- . Guinea Pig Maximization
- . 22 Day Ocular Irritation Study in Rabbits
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Physico-chemical Studies including physical, optical and chemical properties as identified in Daily Wear Guidance for Contact Lenses demonstrated equivalent performance to the predicate device as witnessed in the chart listed above.
All pre-clinical and non-clinical studies demonstrated that the final lens subject to extractions and simulated in the above tests performed as expected with no findings related to safety that would be considered as unsafe for human use in the indications set forth for daily wear.
# 8. Clinical data
A three month daily wear clinical study was performed on the subject device. The study was a prospective, unmasked, open label study of a total of 98 subjects, in an approximate 2:1 ratio of test to control.
The test lens was the SynergEyes™ SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lens, and the control lens was the SynergEyes™ A (paflufocon D hem-iberficon A) Hybrid Contact Lens. The study was performed at 8 investigational sites, and was designed to demonstrate that the test lens performed no worse than the control lens on a daily basis.
Eighty seven (87) subjects were randomized and dispensed lenses. The ratio of dispensed Test cohort subjects to dispensed Control cohort subjects was 1.81 to 1. The 90 day study period was completed by 73.2% (41 out of 56) dispensed Test cohort subjects and 87.1% (27 out of 31) dispensed Control cohort subjects.
Nineteen (19) subjects discontinued from the study (15 Test and 4 Control) with the most common reason for discontinuation reported as Subject Decision for the Test cohort (40% or 6/15) and Discomfort for the Control cohort (75% or 3/4). One Test cohort subject was discontinued for , Adverse Event and 1 Test cohort subject was discontinued for Positive Slit Lamp.
| Reason for Discontinuation | Test Cohort | | Control Cohort | | Overall | | |
|----------------------------|-------------|-------|----------------|-------|---------|-------|--|
| Adverse Event | 1 | 6.7% | 0 | 0.0% | ી | 5.3% | |
| Positive Slit Lamp | 1 | 6.7% | 0 | 0.0% | 1 | 5.3% | |
| Comfort Related | 2 | 13.3% | 3 | 75.0% | 5 | 26.3% | |
| Subject Decision | 6 | 40.0% | 1 | 25.0% | 7 | 36.8% | |
| Protocol Violation | 2 | 13.3% | 0 | 0.0% | 2 | 10.5% | |
| Unacceptable Visual Acuity | 2 | 13.3% | 0 | 0.0% | 2 | 10.5% | |
| Lost to Follow-up | 1 | 6.7% | 0 | 0.0% | 1 | 5.3% | |
| Total Discontinued | 15 | | ರ | | 19 | | |
Reasons for Subiect Discontinuation
The demographics of the study subjects enrolled showed a slightly older population (average age: Control 40.6 / Test 37.3) with a greater proportion of female to male ratio: Control 3.9:1. Test 2.9:1) in the Control cohort as compared to the Test cohort. The majority (greater than 87%) of the subjects in the study were Caucasian for both cohorts.
A total of 5 adverse events were reported for 5 eyes during the study with 4 adverse events reported for the Test cohort and 1 adverse event reported for the Control cohort. Three (3) of the 5 adverse events (2 Test/ 1 Control) were reported as serious adverse events. Of the 2 Test cohort serious adverse events, 1 was a minor abrasion where the investigator noted a grade 1 (trace) infiltrate and 1+ cells in the anterior chamber, all of which had cleared in 4 days. The second serious adverse event was a microbial keratitis which was treated and cleared. The
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SynergEyes™, Inc. Carlsbad, CA 92008
single serious adverse event reported for the Control cohort was liver failure related to the use of homeopathic products.
Slit lamp findings reported during the study were compared between the Test and the Control cohorts and related to the baseline rates as well. Results of the slit lamp examinations showed the Test cohort eyes presenting with more staining overall when compared to the Control cohort examinations. All other slit lamp findings were reported a similar rates and severities when looking at the overall visit combined findings for both the Test and the Control cohorts.
Symptoms problems and complaints were compared between the Test and the Control cohorts and reviewed against the baseline proportions as well. The Test cohort eyes reported proportionately greater symptoms (1.1% for itching/burning to 16.1% for dryness) when compared to the Control cohort eyes except for excessive tearing (essentially equal) and variable vision (3.6% Control). Most of the differences in symptoms rates were small (3.7% or less) except for halos (8.6% Test) and dryness (16.1% Test).
Snellen visual acuity with contact lenses remained stable throughout the study for both the test and the control cohorts with only 2 Test cohort eyes and 2 Control cohort eyes reporting 2 or line drops of Snellen lens visual acuity with the contact lenses at the final visit.
Average daily wearing times were similar between the two cohorts and remained stable during the study and averaged between 11.6 to 13.0 hours per day for the Test cohort and 12.1 to 12.8 hours per day for the Control cohort.
Lens deposit evaluations and fitting evaluations provided similar results between the two cohorts. Lens replacements indicated that the Test lenses were replaced more frequently for parameter change and the Control lenses were replaced more frequently for discomfort.
In conclusion, the evaluation of primary safety variables and effectiveness of the test product SynergEyes™ SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lens, support a conclusion of substantial equivalence between the test and control lens evaluated in the study.
# 9. Risk and Benefits:
The risks of the subject device are the same as those normally attributed to the wearing of RGP and soft (hydrophilic) contact lenses on a daily wear base. The benefits to the patient are the same as those for other RGP and soft (hydrophilic) contact lenses. The subject device has characteristics associated with it that should favor the risk benefit ratio in favor of the new device. Overall, the risks and benefits associated with daily wear contact lenses are the same as for other daily wear contact lenses and raise no additional concerns for safety or effectiveness.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/5/Picture/1 description: The image is a circular seal for the Department of Health & Human Services - USA. The seal features the department's logo, which is a stylized caduceus, a symbol of medicine and healing. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the perimeter of the circle.
Public Health Service
MAY 20 2009
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SynergEyes, Inc. c/o Richard E. Lippman, O.D., F.A.A.O. Vice President for Ophthalmic Product Regulatory Affairs R.P. Chiacchierini & Associates, LLC 15825 Shady Grove Road, Suite 30 Rockville, Maryland 20850
Re: K083921
Trade/Device Name: SynergEyes™ SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lenses Regulation Number: 21 CFR 886.5916 Regulation Name: Rigid Gas Permeable Contact Lens Regulatory Class: Class II Product Code: HQD Dated: May 8, 2009 Received: May 11, 2009
Dear Dr. Lippman:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0115. 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 contact the CDRH/Office of Surveillance and Biometrics/Division of Postmarket Surveillance at 240-276-3464. For more information regarding the reporting of adverse events, please go to http://www.fda.gov/cdrh/mdr/.
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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours.
Malvina B. Eglehmis, m.s.
Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# INDICATIONS FOR USE STATEMENT
510(k) Number (if known) K083921
Device Name: SynergEyes® SiH (petrafocon A hem-larafilcon A)) Hybrid Contact Lens
# Indication for Use
SynergEyes® SiH (petrafocon A hem-larafilcon A) Hybrid Contact Lenses for daily wear are indicated for use in the correction of hyperopic, myopic and astigmatic refractive error including presbyopia, in aphakic and not aphakic, non-diseased eyes. The lenses are indicated for daily wear for the correction of up to +20.00 and -20.00 D in eyes with astigmatism up to 6.00 D. For presbyopia, add powers between +1.00 and +4.00D. The lenses may be disinfected using only a chemical disinfecting system compatible with both hydrogel and rigid gas permeable lenses.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
Over-the -counter-use OR
Thyphith
(Division Sign-Off) Division of Ophthalmic and Ear, Nose and Throat Devices
510(k) Number K083921
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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.