The ELI 250 is intended to be a high-performance, 12-lead, multifunctional electrocardiograph. As a resting electrocardiograph, ELI 250 simultaneously acquires data from 12 leads. Once the data is acquired, it can be reviewed and/or stored, and/or printed. It will be a device primarily intended for use in hospitals, but may be used in medical clinics and offices of any size.
Device Story
The ELI 250 is a multi-channel, resting 12-lead electrocardiograph used in hospitals and clinics. It acquires cardiac electrical signals via surface electrodes connected to an internal front-end amplifier. The device features a monochrome or color LCD for waveform preview and a custom keyboard for data entry. It processes acquired data using the VERITAS Interpretive Algorithm to provide automated ECG interpretations. Outputs include on-screen display, thermal printouts in various formats (including Cabrera), and digital storage or transmission via RS-232, LAN, WLAN, or modem. Operated by physicians or trained personnel, the device assists in diagnosing symptomatic patients. The output serves as a clinical decision support tool, requiring physician over-read and integration with other patient data to inform clinical decisions. The device benefits patients by providing rapid, standardized ECG analysis and interpretation.
Clinical Evidence
Clinical data collected from pediatric cardiology centers. ECGs were interpreted by a cardiologist (blind reading) and compared against the VERITAS Pediatric ECG Interpretation algorithm. Metrics calculated include sensitivity, specificity, positive predictive accuracy, and negative predictive accuracy. Results are documented in the Physician's Guide to VERITAS with Adult and Pediatric Resting ECG Interpretation.
Technological Characteristics
12-lead resting electrocardiograph; monochrome or optional color LCD; thermal writer; internal front-end amplifier. Connectivity via RS-232, LAN, WLAN, or modem. Software-based VERITAS Interpretive Algorithm (rule-based/algorithmic). Designed for transport cart mounting.
Indications for Use
Indicated for acquisition, analysis, display, and printing of ECGs in clinical settings by physicians or trained personnel. Intended for adult and pediatric populations. Provides data interpretation for physician consideration; not a sole means of diagnosis. Requires physician over-read and consideration of other patient data. Not for use as a vital signs physiological monitor.
Regulatory Classification
Identification
An electrocardiograph is a device used to process the electrical signal transmitted through two or more electrocardiograph electrodes and to produce a visual display of the electrical signal produced by the heart.
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Image /page/0/Picture/1 description: The image shows the Mortara logo. The logo consists of a heart shape above the word "Mortara" in a bold, sans-serif font. The heart shape is white against a black background, while the word "Mortara" is black.
#### Abbreviated 510(k) Notification
#### 510(k): ELI 250 Electrocardiograph Device Summary
JUL-2 2010
#### Submitter:
Date: May 25, 2010
| Primary Contact: | Chien Hui (Amy) Yang, Regulatory Affairs Engineer<br>(414) 354-1600 Ext. 7727<br>(414) 354-4760 (facsimile)<br>amy.yang@mortara.com |
|------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------|
| Secondary Contact: | Charles Morreale, Regulatory Affairs Manager<br>(414) 354-1600 Ext. 7768<br>(414) 354-4760 (facsimile)<br>chuck.morreale@mortara.com |
| Mortara Instrument, Inc.<br>7865 N. 86 <sup>th</sup> Street<br>Milwaukee, WI 53224 | |
| Trade Name: | ELI 250 Electrocardiograph |
| Common Name: | Electrocardiograph |
|----------------------|-----------------------|
| Classification Name: | Electrocardiograph |
| | (Per 21 CFR 870.2340) |
#### Legally marketed devices to which S. E. is claimed
The Mortara Instrument's ELI 250 Electrocardiograph is the Mortara ELI 200 and is substantially equivalent to the legally marketed predicate devices:
- ELI 200 by Mortara Instrument (K920626) .
- . ELI 200+ Audicor by Mortara Instrument (K031182)
- ELI 350 by Mortara Instrument (K082946) ●
The proposed ELI 250 is a modification of the Mortara predicate device. It will include the addition of Pediatric Criteria for the VERITAS™ Interpretive Algorithm with the current technology resulting in the next generation Mortara ELI 250 Electrocardiograph.
#### Description:
The ELI 250 is multi-channel, resting interpretation electrocardiographs. The ELI 250 simultaneously acquires data from up to 12 leads. Once the data is acquired, it can be reviewed, and/or stored, and/or printed.
The electrocardiogram (ECG) is a graphic description of the electrical activity of the heart. This activity is recorded from the body surface by a group of electrodes positioned at predefined places to reflect the activity from different perspectives. The cardiac data acquired and provided by the ELI 250 is used by trained medical personnel to assist in the diagnosis of symptomatic patients with various rhythm patterns.
The ELI 250 is designed to be installed on a transport cart. The ELI 250 is able to acquire, analyze, display and print electrocardiograms acquired through its internal Mortara front-end amplifier. The size of the screen will allow preview of the record for the technician to assess the quality of the acquired ECG.
The ELI 250 utilizes a monochrome (or optional color) LCD for display of ECG waveforms, menu options and status information. A custom keyboard is part of the ELI 250 design and allows patient data entry as well as control of the functions and options available for the unit. The ELI 250 custom keyboard will include
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Image /page/1/Picture/1 description: The image shows the logo for Mortara. The logo consists of a stylized heart shape above the word "Mortara". The heart is white and is surrounded by a black border. The word "Mortara" is in a bold, sans-serif font and is also black.
#### Abbreviated 510(k) Notification
alphabetic, numeric, symbol, cursor control and special function keys. The ELI 250 incorporates a thermal writer that allows printouts using several formats available to the user, from the standard to the Cabrera formats. The writer is also used by the unit for real time, continuous rhythm printout.
The ELI 250 will offer storage capability in order to retrieve or transmit stored records. Transmission can be achieved using one of the optional communication media designed in the unit. RS 232, LAN, WLAN, and / or Modem.
#### Intended Use:
The ELI 250 is intended to be a high-performance, 12-lead, multifunctional electrocardiograph. As a resting electrocardiograph, ELI 250 simultaneously acquires data from 12 leads. Once the data is acquired, it can be reviewed and/or stored, and/or printed. It will be a device primarily intended for use in hospitals, but may be used in medical clinics and offices of any size.
#### Indications for Use:
- The device is indicated for use to acquire, analyze, display and print electrocardiograms. ●
- The device is indicated for use to provide interpretation of the data for consideration by a physician. .
- The device is indicated for use in a clinical setting, by a physician or by trained personnel who are acting . on the orders of a licensed physician. It is not intended as a sole means of diagnosis.
- The interpretations of ECG offered by the device are only significant when used in conjunction with a . physician over-read as well as consideration of all other relevant patient data.
- The device is indicated for use on adult and pediatric populations. .
- The device is not intended to be used as a vital signs physiological monitor. .
#### Summary discussion:
The ELI 250 modification includes the addition of pediatric criteria to the VERITAS Interpretive Algorithm that was previously cleared through 510(k) Premarket Notification (K082946). Clinical ECGs were randomly collected from various pediatric cardiology centers. These ECGs were then submitted to a cardiologist for reading without automatic interpretation (blind reading) and in a standard 3x5 format at 10 mm/mV and 25 mm/s. The same ECGs were also interpreted by the VERITAS Pediatric ECG Interpretation algorithm.
This data was utilized to calculate the Sensitivity, Specificity, Positive Predictive Accuracy and Negative Predictive Accuracy for the algorithm. This information is provided within the Physician's Guide to VERITAS with Adult and Pediatric Resting ECG Interpretation.
ELI 250 utilizes the same VERITAS Interpretive Algorithm as the predicate device. The main subject of this 510(k) submission is the evolution of the ELI 250 through a software modification to incorporate the Mortara VERITAS Interpretive Algorithm with pediatric criteria. Therefore, the modified device performs as safety and effectively as the legally marketed predicate device.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" written around the perimeter. Inside the circle is an image of an abstract eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
JUL -- 2 2010
Mortara Instrument, Inc. c/o Chien Hui (Amy) Yang Regulatory Affairs Engineer 7865 North 86th Street Milwaukee, WI 53224
Re: K101403
Trade/Device Name: ELI 250 Electrocardiograph Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiographs Regulatory Class: Class II (two) Product Code: DPS Dated: May 14, 2010 Received: May 19, 2010
#### Dear Ms. Yang:
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. Iisting 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
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Page 2 - Ms. Chien Hui (Amy) Yang
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.
1f you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.tda.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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
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
1/101403 510(k) Number (if known):
## Device Name: Mortara ELI 250 Electrocardiograph
#### Indications for Use:
- The device is indicated for use to acquire, analyze, display and print electrocardiograms.
- The device is indicated for use to provide interpretation of the data for consideration by a physician.
- · The device is indicated for use in a clinical setting, by a physician or by trained personnel who are re device is indicated for use in a simisal obtaing, by a provinced as a sole means of diagnosis.
- · The interpretations of ECG offered by the device are only significant when used in conjunctions deta with a physician over-read as well as consideration of all other relevant patient data.
- · The device is indicated for use on adult and pediatric populations.
- The device is not intended to be used as a vital signs physiological monitor.
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)
Page 1 of 1
W. Ward
Division Sian-C on of Cardiovascular Devices
510(k) Number K10403
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.