MICROCUTTER XCHANGE 30, MICROCUTTER XCHANGE 30, BLUE STAPLE CARTRIDGE, BLUE STAPLE CARTRIDGE
K132581 · Cardica, Inc. · GDW · Jan 7, 2014 · General, Plastic Surgery
Device Facts
Record ID
K132581
Device Name
MICROCUTTER XCHANGE 30, MICROCUTTER XCHANGE 30, BLUE STAPLE CARTRIDGE, BLUE STAPLE CARTRIDGE
Applicant
Cardica, Inc.
Product Code
GDW · General, Plastic Surgery
Decision Date
Jan 7, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4750
Device Class
Class 2
Attributes
Therapeutic, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K132581 · Jan 7, 2014
MICROCUTTER XCHANGE 30, MICROCUTTER XCHANGE 30, BLUE STAPLE CARTRIDGE, BLUE STAPLE CARTRIDGE
Cardica, Inc.
Comprehensive analysis of medical literature (historical control data)
The sponsor used a composite historical control rate derived from medical literature to demonstrate non-inferiority of the device's severe adverse event rate compared to standard open and laparoscopic procedures.
Historical control; Literature review; Non-inferiority; Clinical performance
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
MicroCutter European Trial I (METI); Prospective, open label, multi-center study; Follow-up/Duration: At least 30 days postoperatively
Subjects requiring surgical stapling of the stomach and/or intestine; Sample Size: 160 subjects; Number of Sites: Multi-center
Composite historical control derived from medical literature
Statistical non-inferiority of composite related severe adverse event rate (infection, leakage, bleeding, and strictures)
Indications for Use
The MicroCutter XCHANGE™30 is intended for use in multiple open or minimally invasive surgical procedures for the transection, resection, and/or creation of anastomoses in small and large intestine as well as the transection of the appendix.
Device Story
MicroCutter XCHANGE 30 is a single-patient-use, cartridge-based surgical stapler. It delivers two double-staggered rows (4 rows total) of 316L stainless steel D-shaped staples while simultaneously transecting tissue. Features a 5mm diameter shaft with 360° rotation and 160° articulation. Operated by surgeons in open or minimally invasive procedures. Device uses a guided, rotating staple formation mechanism, mimicking curved needle motion. Output is a 30mm staple line. Benefits include high-strength stainless steel staples and enhanced articulation for surgical access. Device is MR-Conditional.
Clinical Evidence
Prospective, open-label, multi-center study (n=160) with 423 deployments. Primary endpoint: non-inferiority of composite severe adverse event rate (infection, leakage, bleeding, strictures) vs. historical literature control. One related severe adverse event reported (0.65%; 95% CI upper limit 3.59%). Primary endpoint met. Bench testing confirmed staple line integrity, burst pressure, and mechanical reliability.
Technological Characteristics
Cartridge-based stapler; 5mm shaft; 360° rotation; 160° articulation. Staples: 316L stainless steel, D-shaped, 30mm line length. Biocompatibility per ISO 10993-1. Sterilization: Gamma radiation (10^-6 SAL). Packaging: PTFE tray with Tyvek lid. Shelf life: 24 months. MR-Conditional.
Indications for Use
Indicated for patients undergoing open or minimally invasive surgical procedures requiring transection, resection, or creation of anastomoses in the small and large intestine, or transection of the appendix.
Regulatory Classification
Identification
An implantable staple is a staple-like device intended to connect internal tissues to aid healing. It is not absorbable.
Ethicon Proximate™ and Endopath™ Linear Staplers (K020779)
Submission Summary (Full Text)
{0}------------------------------------------------
Image /page/0/Picture/1 description: The image shows the logo for "Cardica". The logo consists of a stylized, curved shape resembling an open bracket or a stylized letter "C" on the left side. To the right of this shape is the word "cardica" in a simple, sans-serif font, with a registered trademark symbol (®) next to it.
MicroCutter XCHANGE 30
JAN - 7 2014
510(k) Summary - Cardica MicroCutter XCHANGE™ 30
- A. Date Prepared January 2, 2014
## B. Applicant Information
Cardica, Inc. 900 Saginaw Drive Redwood City, California 94063 Main: 650-364-9975 Fax: 650-364-3134
### C. Contact Person
Vee Arya Senior QA/RA Manager
(650) 331-7152 direct (650) 644-7339 mobile (650) 331-7195 fax arya@cardica.com
Alternate Contact: Frederick Bauer Vice President of Operations
(650) 331-7163 direct (650) 331-7195 fax bauer@cardica.com
# D. Establishment Registration Number 3004114958
### E. Device Information
Common, Usual or Classification Name: Staple, Implantable Regulation Number: 21 CFR §878.4750 Product Code: GDW
- F. Trade Name MicroCutter XCHANGE™ 30
# G. Legally Marketed Predicate Device(s)
Autosuture™ ENDO GIA™ Universal Stapler (K111825) Ethicon Proximate™ and Endopath™ Linear Staplers (K020779)
{1}------------------------------------------------
MicroCutter XCHANGE 30
# cardıca
### H. Device Description
The MicroCutter XCHANGE™ 30 is a single patient use stapler that delivers two, double staggered rows of 316L stainless steel staples while simultaneously transecting tissue between staple rows. The staple (blue; 3.5mm) is compatible with tissue that can be compressed to 1.5mm. The staple line is approximately 30mm long with a transection length of approximately 27mm.
### I. Indications for Use
The MicroCutter XCHANGE™30 is intended for use in multiple open or minimally invasive surgical procedures for the transection, and/or creation of anastomoses in small and large intestine as well as the transection of the appendix.
### J. Comparison to Predicate Device
The Cardica MicroCutter XCHANGE™ 30 is substantially equivalent in its Indications for Use to the Covidien Autosuture™ ENDO™ GIA Stapler (K111825) and Ethicon Proximate™ Linear Staplers (K020779) in regards to the predicates' use for the transection, resection, and/or creation of anastomoses in surgical procedures involving gastrointestinal tissue.
The Cardica MicroCutter XCHANGE™ 30 is substantially equivalent in design and performance specifications to the Covidien Autosuture™ ENDO™ GIA Universal Stapler trigger handle, shaft and end-effecter function (K111825) and the Ethicon Proximate™ Linear Cutters' and Staplers' staple cartridge (K020779).
### K. Technological Characteristics
The Cardica MicroCutter XCHANGE™ 30 is a cartridge based stapling device with a 5mm diameter shaft, capable of unlimited rotation and articulation up to 160° (80° degrees in each direction) in 20° increments. Predicate devices are also cartridge based, offer varying amounts of shaft rotation (90° to unlimited rotation) and less articulation range (80° - 90° total compared to 160°).
The MicroCutter XCHANGE™ 30 Blue Cartridge delivers a 30mm staple line consisting of two double-staggered rows (4 rows total) of D-shaped staples constructed of medical grade 316L stainless steel. The outermost rows contain 12 staples each, while the inner rows contain 13 staples each, for a total of 50 staples. Predicate devices can be used with various cartridges to deliver titanium staples ranging from 30 - 90mm, consisting of either two, double-staggered rows (4 rows total) or two, triple staggered rows (6 rows total).
One of the primary differentiating factors in the design of the MicroCutter XCHANGE™ 30 staple is that the staples are medical grade 316L stainless steel, which is a higher strength material than titanium alloy used in other stapling products. Current B-shaped staples are formed by buckling the tines. The forces required to accomplish the buckling typically represent the peak forces during staple formation. The MicroCutter XCHANGE™ 30 uses a guided, rotating form. The motion through the tissue is similar to that of a curved needle.
{2}------------------------------------------------
Image /page/2/Picture/1 description: The image shows the word "cardica" in a stylized font. The word is in black and has a registered trademark symbol after it. There is a curved line above and below the word, which gives the impression of a logo.
MicroCutter XCHANGE 30
The Cardica MicroCutter XCHANGE™ 30 has similar features as compared to the predicate devices as shown in table below:
| Feature | MicroCutter<br>XCHANGE 30 | ENDO GIA<br>Universal<br>(K111825) | PROXIMATE<br>Linear Cutters and<br>Staplers (K020779) |
|--------------------------------|-----------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|
| Deployment Device | | | |
| Deployment | Cartridge based<br>deployment (up to 6<br>deployments per<br>tool) for single<br>patient use | Cartridge based<br>deployment (up<br>to 25<br>deployments per<br>tool) for single<br>patient use | Cartridge based<br>deployment (up to 4-<br>8 deployments per<br>tool) for single<br>patient use<br>(excepting Access<br>55) |
| Shaft Length | 340mm | 325mm | Not available |
| Transection Line<br>Length | 27mm | 30mm | Up to 100mm<br>(depending on<br>Cutter);<br>Staplers do not cut<br>(Staplers and Access<br>55) |
| End-Effector Opening | 5.3mm at tissue stop<br>(proximal);<br>16.7mm at distal<br>opening | 5.25mm at tissue<br>stop (proximal);<br>16.45mm at<br>distal opening | Adjustable parallel<br>jaws (excepting<br>Access 55) |
| Shaft Rotation | 360° | Same as subject<br>device | 90°; 30° shaft flex<br>(Access 55 only) |
| Articulation | 160° (80° each<br>direction) | 90° on the<br>roticulator model<br>(45° each<br>direction) | 80° (Access 55 only) |
| Staple | | | |
| Staple Material | Stainless steel<br>(316L) | Titanium | Titanium |
| Blue Unformed Staple<br>height | 3.22mm | 3.50mm | 3.50-3.85mm |
| Blue Formed Staple<br>Height | 0.75mm (compatible<br>with tissue thickness<br>that can be<br>compressed easily to<br>1.50mm) | 1.00mm<br>(compatible with<br>tissue thickness<br>that can be<br>compressed<br>easily to<br>1.50mm) | 1.00-1.50mm<br>(compatible with<br>tissue thickness that<br>can be compressed<br>easily to 1.00-<br>2.50mm) |
| Formed Staple<br>Configuration | D shaped | B shaped | B shaped |
| Staple Line | Two (2), double | Two (2), triple | Same as subject |
Page 3 – K132581 Cardica Response
{3}------------------------------------------------
Image /page/3/Picture/1 description: The image shows the text "510(k) Summary for K132581". The text is in a simple, sans-serif font and is left-aligned. The text is likely a title or heading for a document or section of a document related to a 510(k) summary for the product with the identifier K132581.
# MicroCutter XCHANGE 30
.
.
| Feature | MicroCutter<br>XCHANGE 30 | ENDO GIA<br>Universal<br>(K111825) | PROXIMATE<br>Linear Cutters and<br>Staplers (K020779) |
|----------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|-----------------------------------------------------------------------------------------------|
| Configuration | staggered rows | staggered rows | device |
| Staple Line Length | 30mm | 30mm, 45mm,<br>60mm | 10 (Cutters only),<br>30, 55 (Cutters and<br>Access 55), 60, 75<br>(Cutters only) and<br>90mm |
| Number of Staples Per<br>Deployment | 50 (One row of 13<br>and one row of 12<br>on either side of<br>transaction line) | 48 (for the 30mm<br>staple line length) | 58 and 74 (for the 30<br>and 55mm staple<br>line) |
| MRI Compatibility | MR-Conditional | MR-Safe | Same as subject<br>device |
| Biocompatibility | | | |
| Material<br>Biocompatibility<br>(Delivery Device and<br>Staple) | All components of<br>the Cardica<br>MicroCutter<br>XCHANGE 30 are<br>comprised of<br>materials that were<br>deemed acceptable<br>in accordance with<br>ISO Standard<br>10993-1. | Same as subject<br>device | Same as subject<br>device |
| Packaging, Sterilization and Shelf Life | | | |
| Packaging | PTFE tray with<br>Tyvek lid | Thermoformed<br>tray with Tyvek<br>lid | Thermoformed tray<br>with Tyvek lid |
| Sterilization<br>Sterility Assurance<br>Level | Gamma radiation<br>$10^{-6}$ | Ethylene Oxide<br>Not Available | Gamma radiation<br>Not Available |
| Shelf Life | 24 months | Not Available | Not Available |
| Performance | | | |
| Tissue Leak Pressure<br>(Bench) | No statistical difference p>0.05 | | Not Tested |
| Tissue Leak Pressure<br>(Animal) | No statistical difference p>0.05 | | Not Tested |
| Clinical Performance<br>(MicroCutter European<br>Trial I (METI): The<br>Cardica MicroCutter in<br>Surgical Stapling) | Non-inferior to<br>composite historical<br>control | Not Applicable | Not Applicable |
.
.
Image /page/3/Picture/5 description: The image shows the word "cardica" with a registered trademark symbol. The word is in a sans-serif font and is slightly italicized. To the left of the word is a stylized symbol that looks like a curved bracket or parenthesis.
{4}------------------------------------------------
Image /page/4/Picture/1 description: The image shows the word "carpica" in a stylized font. The word is accompanied by two curved lines, one above and one below the word, that converge to the left of the word. The font is sans-serif and appears to be bolded. There is a registered trademark symbol to the right of the word.
MicroCutter XCHANGE 30
### L. Non-Clinical Performance Data
Bench and animal testing were conducted and the results demonstrated substantial equivalence to the predicate devices, and that the Cardica MicroCutter XCHANGE 30 met design specifications. A summary of the type of testing conducted is as follows:
- Integrity of the staple line was confirmed via dimensional analysis of the staples, � visual inspection of the staple line, and through burst pressure testing of the staple line.
- . Dimensional tests were conducted to confirm attributes for shaft diameter, jaw aperture, clamp gap, articulation angle, and staple line length.
- . Ergonomics testing was conducted to confirm device ergonomics and usability for cartridge load/unload force, force to articulate, force to deploy, force reset . device, and torque require to rotate device.
- Safety testing was completed to confirm the strength of the deploy lockout safety . mechanism to prevent advancement of the knife when a cartridge is not properly loaded into the device.
- . Functionality testing was completed to confirm device features for the clamp system, deployment system, and articulation.
- . Reliability testing was completed and demonstrated that device performance does not degrade when deploying within the indicated number of clinical deployments.
- . Packaging Validation testing was completed and passed in accordance with ASTM D4169.
- . Sterilization testing was completed and passed in accordance with ISO11137-2.
- Bioburden testing was conducted and passed in accordance with . ANSI/AAMI/ISO 11737-1:1995 Sterilization of Medical Devices-Microbiological Methods Part I: Estimation of Population of Microorganisms on Products.
- . Shelf life testing was completed and passed in accordance with ASTM F1980.
- 0 Biocompatibility testing was completed in accordance with ISO 10993-1 requirements. The following tests were completed and passed:
- Cytotoxicity 해
- ISO Intracutaneous Reactivity
- Hemolysis (in vitro)
- 트 Sensitization
- l Acute Systemic Toxicity
- I Material Mediated Pyrogen (as required)
- 트 Coagulation (as required)
- Thromboresistance (as required)
{5}------------------------------------------------
Image /page/5/Picture/1 description: The image shows the word "cardica" in a stylized font. The word is accompanied by a design element that resembles a stylized, elongated bracket or parenthesis on the left side. A horizontal line extends from the top of the bracket over the word and a similar line extends from the bottom of the bracket under the word.
MicroCutter XCHANGE 30
### M. Clinical Study Information
The MicroCutter XCHANGE™ 30 System was evaluated in a prospective, open label, multi-center study with an All-Comers enrollment of subjects requiring surgical stapling of the stomach and/or intestine. 160 subjects were enrolled and followed postoperatively for at least 30 days. 423 deployments were performed. The primary endpoint was statistical non-inferiority of composite related severe adverse event rate (composite of infection, leakage, bleeding, and strictures) in study subjects when compared to composite severe adverse event rate (composite of infection, leakage, bleeding, and strictures) as derived from a comprehensive analysis of the medical literature with regards to the comparable open and laparoscopic procedure. One (1) composite severe adverse event (composite of infection (non-dermal), leakage, bleeding, and strictures) related to the MicroCutter XCHANGE 10 30 System was reported in a total of one hundred fifty three (153) patients (0.65%). The exact upper 95% confidence limit for this rate is 3.59%. Based on these results, the primary endpoint was met.
Additionally, there were 6 events reported for handsewn anastomoses and 6 events for other stapling devices in procedures in which the MicroCutter was used. These events do not factor into the calculation of the primary endpoint event rate for the MicroCutter. There is a procedural success rate of 91.5% (140/153) when the MicroCutter is used with other anastomoses modalities.
| Stapler and Hand-sewn related<br>Severe Adverse Events<br>Categories | Hand-<br>sewn<br>related | Other<br>Stapler<br>related | MicroCutter<br>related | Total N |
|----------------------------------------------------------------------|--------------------------|-----------------------------|------------------------|---------|
| Leakages | 0 | 2 | 0 | 2 |
| Bleedings | 3 | 0 | 1 | 4 |
| Infections | 1 | 2 | 0 | 3 |
| Strictures | 0 | 1 | 0 | 1 |
| Other Complications | 2 | 1 | 0 | 3 |
| Total | 6 | 6 | 1 | 13 |
STAPLER AND HAND-SEWN ANASTOMOSIS RELATED PRIMARY ENDPOINT EVENTS
The following table depicts the tissue and number of deployments where the MicroCutter was used:
| MicroCutter Tissue Use | All Sites<br>N* (%) |
|--------------------------------------------|---------------------|
| Anastomose small intestine to<br>stomach | 1 (0.2) |
| Anastomosis of small intestine | 25 (5.9) |
| Anastomosis of small intestine to<br>colon | 13 (3.1) |
| Closure of enterotomy | 5 (1.2) |
| Transection of appendix | 57 (13.5) |
| Transection of colon | 81 (19.1) |
| Transection of common bile duct | 1 (0.2) |
# Page 6 - K 132581 Cardica Response
{6}------------------------------------------------
Image /page/6/Picture/1 description: The image shows the logo for "cardica". The logo consists of a stylized, curved shape to the left of the word "cardica". The word "cardica" is in a simple, sans-serif font, and there is a registered trademark symbol to the upper right of the word.
MicroCutter XCHANGE 30
... . . . . . . . . . . . . . . . . . . . . . . . . .
| MicroCutter Tissue Use | All Sites<br>N* (%) |
|------------------------------------------|---------------------|
| Transection of duodenum | 19 (4.5) |
| Transection of<br>Mesocolon/Mesoappendix | 6 (1.4) |
| Transection of ovary | 1 (0.2) |
| Transection of small intestine | 213 (50.4) |
| Vascular transection | 1 (0.2) |
| Total | 423 |
*N = number of deployments
The following table depicts procedures by clinical approach:
| | Total<br>N* (%) |
|--------------------------|-----------------|
| Observation | 160 (N/A) |
| Open | 70 (43.8) |
| Laparoscopic | 75 (46.9) |
| Laparoscopic<br>assisted | 15 (9.4) |
| Converted | 0 (0) |
*N = number of observations
### N. Conclusions
The MicroCutter XCHANGE™ 30 Stapler and Blue Cartridge have been carefully compared to legally marketed devices with respect to intended use and technological characteristics. In addition, clinical and non-clinical testing was conducted to validate the performance of the device and ensure the MicroCutter XCHANGE™ 30 Stapler and Blue Cartridge function as intended and meet design specifications. The comparison, clinical and non-clinical results demonstrate that the device is substantially equivalent to the predicate devices for its intended use.
Page 7 - K132581 Cardica Response
{7}------------------------------------------------
Image /page/7/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized eagle-like symbol with three curved lines representing the wings.
# DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 7. 2014
Cardica Incorporated Ms. Vee Arya Senior Manager, Quality Assurance/Regulatory Affairs 900 Saginaw Drive Redwood City, California 94063
Re: K132581
Trade/Device Name: Cardica®MicroCutter XCHANGE™ 30 Regulation Number: 21 CFR 878.4750 Regulation Name: Implantable staple Regulatory Class: Class II Product Code: GDW Dated: November 21, 2013 Received: November 27, 2013
Dear Ms. Arya:
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 r ou may, merelors, manns of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.
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 that I Dri has made a and regulations administered by other Federal agencies. You must of any I cottar statues and regairents, including, but not limited to: registration and listing (21
{8}------------------------------------------------
Page 2 - Ms. Vee Arya
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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 vours.
Binita S. Ashar -S. A 2014.01.07 16:32:32-05'00'
Binita S. Ashar, M.D., M.B.A., F.A.C.S. Acting Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{9}------------------------------------------------
# DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: December 31, 2013 See PRA Statement on last page.
# 510(k) Number (if known) K132581
# Device Name Cardica@MicroCutter XCHANGETM 30
# Indications for Use (Describe)
The MicroCutter XCHANGE™30 is intended for use in multiple open or minimally invasive surgical procedures for the transection, resection, and/or creation of anastomoses in small and large intestine as well as the transection of the appendix.
Type of Use (Select one or both, as applicable)
2017 26 223 2
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
# PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
# FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
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.