K112319 · Electro-Cap Intl., Inc. · GXY · Jan 27, 2012 · Neurology
Device Facts
Record ID
K112319
Device Name
ELECTRO-CAP SYSTEM
Applicant
Electro-Cap Intl., Inc.
Product Code
GXY · Neurology
Decision Date
Jan 27, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1320
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Electro-Cap System is intended for use in routine clinical and research settings where rapid placement of a number of EEG electrodes is desired.
Device Story
The Electro-Cap System is an EEG electrode positioning device used in clinical and research settings to facilitate rapid, consistent placement of electrodes on the scalp. It consists of a spandex cap with recessed electrodes (tin, silver/silver chloride, gold-plated, or silver) held in plastic mounts. The device acts as a matrix pathway between the scalp (via conductive Electro-Gel) and external EEG recording equipment. It is operated by neurologists or trained technicians. The cap is secured via chin straps or body harnesses. Wires from the electrodes exit the cap to form a cable, which connects to EEG equipment via standard connectors. The device does not perform signal processing or analysis; it serves solely as a passive interface for transmitting electrophysiological signals to data collection devices. It does not transmit electrical current and is not intended for stimulation.
Clinical Evidence
Bench testing only. The device relies on established technological characteristics and compliance with AAMI and IEC standards for electrode positioning systems. No clinical data was required or provided.
Technological Characteristics
Spandex fabric cap; polyethylene electrode mounts; electrodes made of tin, silver, silver/silver chloride, or gold-plated metal. Passive sensing principle; no energy source. Dimensions range from 26cm to 66cm. Connectivity via ribbon cables and D-Sub or touch-proof DIN connectors. Conforms to AAMI EC53-1995 and IEC 60601-1 (Subclause 56.3, c).
Indications for Use
Indicated for use in routine clinical and research settings for rapid placement of EEG electrodes in adults and children.
Regulatory Classification
Identification
A cutaneous electrode is an electrode that is applied directly to a patient's skin either to record physiological signals (e.g., the electroencephalogram) or to apply electrical stimulation.
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# K112319
## JAN 2 7 2012
### 510K summary
| Company Name: | Electro-Cap International, Inc.<br>1011 West Lexington Road<br>P.O. Box 87<br>Eaton, OH 45320 |
|----------------------|-----------------------------------------------------------------------------------------------|
| Contact: | Amy B. Swallows |
| Phone: | 937-456-6099 |
| Fax: | 937-456-7323 |
| Summary Date: | January 19, 2012 |
| Trade Name: | Electro-Cap System |
| Common Name: | EEG Electrode Positioning System |
| Classification Name: | Electrode, Cutaneous |
| Regulation Number: | 21 CFR 882.1320 |
GXY
Trade Name:
Product Code:
Predicate Device(s):
| 510(k) Number: | K780045 |
|----------------|-----------------------------------------------|
| Manufacture: | Electro-Cap International, Inc. |
| Trade Name: | Electro-Cap System |
| 510(k) Number: | K071446 |
| Manufacture: | Electrode Arrays |
| Trade Name: | Electrode Array Cap |
| 510(k) Number: | K000865 |
| Manufacture: | Neuroscan (Neurosoft, Inc.) |
| Trade Name: | Quik-Cap EEG Electrode Positioning System Cap |
| 510(k) Number: | K110223 |
| Manufacture: | Eemagine Medical Imaging Solutions GmbH |
WaveGuard EEG Cap
#### Description of Device 1.0
The Electro-Cap System is an EEG electrode positioning system used to quickly place the standard 20 EEG electrodes and also a large number of electrodes in a uniform and consistent manner on the head and body in order to transmit electrophysiological signals from an individual to data collection devices. The Electro-Cap is made from a spandex type material with recessed electrodes in plastic mounts attached to the cap. The standard cap covers the entire scalp and is held in place with chin straps, or with cap straps attached to a body harness. The Surgical Cap material is cut slightly different to allow the cap to fit securely over the ears to hold
]
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it in place. The spandex type material holds the electrodes securely in position during an EEG recording. Wires are attached to each electrode and exit the cap to form a cable, which is used to connect the cap to the EEG equipment, either through an adapter cable, or in some instances, directly to the equipment with the connector on the cap. The electrical activity of the brain is transferred through the Electro-Gel to the recessed electrode and then to the EEG or computer equipment for evaluation.
The electrodes on the standard caps are positioned to the International Ten-Twenty System (10-20) of Electrode Placement. In addition, Electro-Caps with as few as 2 or as many as 256 electrodes, have been built with the placement of the electrodes conforming to the 10-10 American Electrocencephalographic Society positioning system. Electro-Caps are also produced based on customer specified electrode placements, with electrodes made of either tin or silver/silver chloride, gold plated or silver. Dropped wires, small mounts, thin mounts and customized wiring and connectors offer additional options
#### 2.0 Intended Use of Device
The Electro-Cap is intended for use in routine clinical settings where rapid placement of a number of EEG electrodes is desired.
#### 3.0 Predicate Comparison
The Electro-Cap has the same technological characteristics as the predicate devices. It serves as a matrix electrode pathway between the scalp/conductive gel and the EEG recorders. The design of the Electro-Cap System is in conformance with AAMI Standards Specifications for ECG Cables and Lead-Wires and Other Devices that use Patient Cables, EC53-1995, and the IEC Standard 60601-1 Subclause 56.3, (c). Like the predicates the Electro-Cap consists of a stretch fabric cap, metal disk electrodes, electrode holders and electrode lead wires.
Technologically, the Electro-Cap functions in exactly in the same manner as the predicate devices. The electrode holder is a two part component made of Polyethylene which allows the 2 parts to snap together with the fabric between. The electrode lead wires are on the inside of the standard caps giving the technician easy access to the electrodes without interference of the lead wires.
### Available Electro-Cap Options:
A list of the various options which the company offers is shown below. It is important to recognize that all variants carry the same intended use, fundamental scientific technology and clinical considerations:
Size of caps, babies to extra large (26 to 66cm).
Regular or surgical style caps. Special cut (!ow front or back).
Number of electrodes: Density and placement to conform to International 10/20 electrode placement system and /or the 10-10 American Electrocencephalographic Society positioning system.
Ear Slits.
Electrode mounts: Standard, Small and thin.
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Types of electrode drops, detachable/non-detachable.
Size of electrode drops or separate lead wires: 9mm, 6mm, Bio-Potential, Ear clip.
Electrode metals: Tin. Silver/Silver Chloride. Gold Plated or Silver.
Caps with electrode placement holes only.
Caps with electrode mounts only.
Caps with electrodes and electrode mounts only, no lead wires.
Caps with outside wiring on the cap.
Caps complete except for connectors.
All Electro-Caps use the same ribbon cable but may have fewer or more wires in the cable to match the number of electrodes on the cap, individual lead wires or shielded lead wires.
All Electro-Caps use the same type of D-Sub connectors except the connectors may have 10 to 80 pln or sockets, or other commercially available connectors as required by the customer that will allow the caps to be plugged directly into their EEG equipment.
### Accessories:
As stated on the Company's Certificate to Foreign Government as well as listed with the FDA, the Electro-Cap System uses the following accessories:
- E1 Electro-Caps E2 Electro Board Adapter E3 Body Harness E4 Quick Insert Electrodes E5 Ear Electrodes E6 Disposable Sponge Disk E7 Needle/Syringe Kit E8 Special Blunted Needle E12 Head Measuring Tape E13 Cap Straps E16 Ivory Detergent E17 Bio-Potential Electrode E19 Spare Electrode Disk
E20 Spare Electrode Mounts E21 Disk Electrode E22 Extra Placement on Cap E23 Chin Straps E24 Chin Straps Pads E25 Adhesive Electrode Pads E26 Orange Sticks . E27 Disposable ECG Electrode E28 Alligator Clip Adapter E40 Converter Pin/Socket I 1 Infa Caps 1 2 infa Body harness 1 3 Infa Head Measuring Tape
(Please refer to the comparison table on the following three pages.)
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## 4.0 SPECIFICATIONS/COMPARISONS TO PREDICATE DEVICES
..
Table 4.0 compares features and specifications of the proposed Electro-Cap System, including additional research features of any Trans to compress and use y Cap manufactured by Electroce Arrays and WaveGuard EEG Cap by Econopiae Medical Indones Online and the Quik Cap by Neuroscan, Inc.
| | | Table 4.0: Comparison to Predicate Devices | | | | | |
|-----------------------|----------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------|--|
| Feature | ELECTRO-CAP<br>SYSTEM<br>510(k) # K112319 | Electro-Cap System<br>(Predicate)<br>510(k) # K780045 | Electrode-Array Cap<br>(Predicate)<br>510(k) # K071446 | Eemagine Medical<br>Imaging Solutions<br>GmbH (Predicate)<br>510(k) # K110223 | Quik-Cap<br>Neuroscan, Inc.<br>(Predicate)<br>510(k) # K000865 | Substantial<br>Equivalence<br>Comments | |
| Indication for Use | The Electro-Cap is<br>intended for use in<br>routine clinical<br>settings where rapid<br>placement of a<br>number of EEG<br>electrodes is desired. | The Electro-Cap is<br>intended for use in<br>routine clinical settings<br>where rapid placement<br>of a number of EEG<br>electrodes is desired. | The Electrode Array<br>Cap is intended for<br>routine clinical<br>settings where rapid<br>placement of large<br>numbers of EEG<br>electrodes is desired. | This is an EEG electrode<br>set intended for intended<br>for routine clinical<br>settings where rapid<br>placement of large<br>numbers of EEG<br>electrodes is desired. | The Quik-Cap is<br>intended for the same<br>use as the predicate<br>Electro-Cap and is<br>intended for routine<br>clinical settings where<br>rapid placement of<br>large numbers of EEG<br>electrodes is desired. | Electro-Cap has the<br>same/equivalent<br>Indication for Use as<br>predicates | |
| Environment of<br>Use | Electrophysiological | Electrophysiological | Electrophysiological | Electrophysiological | Electrophysiological | Same as predicates | |
| Intended user | Neurologists | Neurologists | Neurologists | Neurologists | Neurologists | Same as predicates | |
| Target Patient | Adults and Children | Adults and Children | Adults and Children | Adults and Children | Adults and Children | Same as predicates | |
| Where Used | On the head | On the head | On the head | On the head | On the Head | Same as predicates | |
| Number of<br>Contacts | 2 - 256 | 20 | 1 to 256 | 1 to 256 | 12 to 256 | Same as/equivalent<br>the predicates | |
| Size of Caps | Various- babies to<br>Large<br>26 cm to 66 cm | Various- Extra Small to<br>Large<br>46cm to 62 cm | Various- children to<br>Large<br>44 cm to 62 cm | Various- babies to Large<br>25cm to 61 cm | Various- babies to<br>Large<br>34cm to 65 cm | Same as/equivalent<br>the predicates | |
| Style of Caps | Full Head Cap | Full Head Cap | Full Head Cap | Full Head Cap | Full Head Cap | Same as predicates | |
| Ear Slits | Yes | No | Yes | Yes | Yes | Same as/equivalent<br>the predicates | |
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## 4.0 SPECIFICATIONS/COMPARISONS TO PREDICATE DEVICES
| Cap Material | Spandex | Spandex | Light Duty Lycra | Elastic Coolmax | Heavy Duty Lycra | Same as/equivalent<br>the predicates |
|-----------------------------|-------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|-------------------------------------|----------------------------------------------------------------------------------------------------------------------|--------------------------------------|
| Electrode Mounts | Polyethylene | Polyethylene | PVC | Silicone | Rubber Material | Same as/equivalent<br>the predicates |
| Location of<br>Wiring | Inside Cap | Inside Cap | Inside Cap | Inside Cap | Outside Cap | Same as predicates |
| Cable Length | Various - 3 to 5 feet | 3 feet | 1 Foot | Not Available | 5 Feet | Same as/equivalent<br>the predicates |
| Type of Cables | Standard Ribbon<br>Cable and Lead<br>Wires | Standard Ribbon Cable<br>and Lead Wires | Shielded Lead Wires | Shielded Lead Wires | Standard Ribbon Cable<br>and Lead Wires | Same as/equivalent<br>the predicates |
| Type of Electrode<br>Drop | Detachable and Non<br>Detachable | Detachable and Non<br>Detachable | Non Detachable | Non Detachable | Non Detachable | Same as predicates |
| Electrode Metal | Pure Tin, Silver,<br>Silver/Silver<br>Chloride, Gold<br>Plated | Pure Tin | Silver/Silver/Chloride | Silver/Silver/Chloride | Tin, Silver,<br>Silver/Silver Chloride,<br>Gold and AgCL | Same as/equivalent<br>the predicates |
| Type of<br>Connectors | D-Sub Connectors,<br>Touch Proof Din<br>Sockets and<br>Special Connectors<br>to Match EEG<br>Equipment and<br>Computers | D-Sub Connectors,<br>Touch Proof Din<br>Sockets and<br>Special Connectors to<br>Match EEG Equipment<br>and Computers | Alden Pulse Lok<br>Connectors, Touch<br>proof Din Sockets and<br>D-Sub Connectors and<br>Track-it connectors. | D-Sub Connectors 25<br>and 35 pins. | D-Sub Connectors,<br>Touch Proof Din<br>Sockets and<br>Special Connectors to<br>Match EEG Equipment<br>and Computers | Same as/equivalent<br>the predicates |
| Biocompatibility<br>Testing | None was conducted | None was conducted | None was conducted | Nonclinical test | None was conducted | Same as most<br>Predicates |
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### 4.0 SPECIFICATIONS/COMPARISONS TO PREDICATE DEVICES
| Performance<br>Requirements | Needs to transmit<br>electrophysiological<br>signals from an<br>individual to data<br>collection devices<br>with a maximum<br>impedance of<br>5K/Ohms. Does not<br>transmit electrical<br>current, nor are they<br>intended to be used<br>for stimulation. | Needs to transmit<br>electrophysiological<br>signals from an<br>individual to data<br>collection devices with<br>a maximum impedance<br>of 5K/Ohms. Does not<br>transmit electrical<br>current, nor are they<br>intended to be used for<br>stimulation. | Needs to transmit<br>electrophysiological<br>signals from an<br>individual to data<br>collection devices with<br>a maximum<br>impedance of<br>5K/Ohms. Does not<br>transmit electrical<br>current, nor are they<br>intended to be used for<br>stimulation. | Needs to transmit<br>electrophysiological<br>signals from an<br>individual to data<br>collection devices with a<br>maximum impedance of<br>5K/Ohms. Does not<br>transmit electrical<br>current, nor are they<br>intended to be used for<br>stimulation. | Needs to transmit<br>electrophysiological<br>signals from an<br>individual to data<br>collection devices with<br>a maximum impedance<br>of 5K/Ohms. Does not<br>transmit electrical<br>current, nor are they<br>intended to be used for<br>stimulation. | Same as predicates |
|-------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|
| Manufacturing<br>Methods | Caps sewn and<br>assembled internally.<br>Lead wires<br>purchased from FDA<br>approved<br>manufacturer. | Caps sewn and<br>assembled internally.<br>Lead wires purchased<br>from FDA approved<br>manufacturer. | Caps sewn by third<br>party vendor.<br>Lead wires purchased<br>from FDA approved<br>manufacturer. | Not Available | Not Available | Same as/equivalent<br>the predicates |
| Type of<br>Additional<br>Electrodes | Various metal Disk<br>Electrodes for<br>Reference.<br>Electrodes made<br>from Tin, Gold<br>Plated, Silver and<br>Silver/Silver<br>Chloride. | Disk Electrodes (Pure<br>Tin Cups) for<br>Reference. May be<br>attached with ear clips<br>or Adhesive Electrode<br>Pads. | Not Available | Not Available | Various metal Disk<br>Electrodes for<br>Reference. Electrodes<br>made from Tin, Gold<br>Plated, Silver and<br>Silver/Silver Chloride. | Same as/equivalent<br>the predicates |
### 4.0 Comparison Summary
As shown above in Table 4.0, the proposed device is identical/equivalent in all aspects to the inclusion of the variant parameters demonstrates that the device itself is manufactured for the same patient population with equivalent manufacturing methods and technologies.
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### 4.0 Conclusions
י
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A comparison of the technological characteristics demonstrates that the device is substantially equivalent to the legally marketed predicated devices.
4
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Image /page/7/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 stripes forming its wing. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Electro-Cap International, Inc. c/o Ms. Amy Swallows Director of Marketing 1011 West Lexington Road PO Box 87 Eaton, OH 45320
SEP 1 4 2012
Re: K112319
Trade/Device Name: Electro-Cap System Regulation Number: 21 CFR 882.1320 Regulation Name: Cutaneous Electrode Regulatory Class: Class II Product Code: GXY Dated: December 20, 2011 Received: December 21, 201
Dear Ms. Swallows:
This letter corrects our substantially equivalent letter of January 27, 2012.
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.
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
{8}------------------------------------------------
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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## Indications for Use
510(k) Number (if known): K112319
Device Name: Electro-Cap System
Indications for Use:
The Electro-Cap System is intended for use in routine clinical and research settings where rapid placement of a number of EEG electrodes is desired.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Luynh Hoang
(Division: Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
KIL2319 510(k) Number __
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.