AMBULO 2400 AMBULATORY BLOOD PRESSURE MONITORING SYSTEM
K133989 · Mortara Instrument, Inc. · DXN · Nov 25, 2014 · Cardiovascular
Device Facts
Record ID
K133989
Device Name
AMBULO 2400 AMBULATORY BLOOD PRESSURE MONITORING SYSTEM
Applicant
Mortara Instrument, Inc.
Product Code
DXN · Cardiovascular
Decision Date
Nov 25, 2014
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 870.1130
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Ambulo 2400 is intended to be a compact, non-invasive Ambulatory Blood Pressure Monitoring (ABPM) system. ABPM technology involves the use of an automatic, non-invasive device to measure blood pressure over an extended period of time – typically 24 hours. The ABPM procedure is an essential tool for physicians, clinical researchers, and other healthcare professionals to analyze a patient's blood pressure as it relates to his/her circadian rhythm. This process offers insight into diagnostic factors as they relate to the spectrum of activity within everyday life.
Device Story
Compact, non-invasive ambulatory blood pressure monitor; measures systolic/diastolic blood pressure and pulse rate via oscillometric method using cuffed arm. Device configured/fitted by physician/healthcare professional; automatically captures measurements over 24-hour period without supervision. Data downloaded to computer for physician analysis/interpretation. Used to evaluate circadian rhythm, daily activity fluctuations, and treatment effectiveness. Benefits include improved diagnosis and treatment planning compared to single-point measurements.
Clinical Evidence
Clinical performance evaluation conducted to demonstrate safety and effectiveness. No specific metrics (e.g., sensitivity, specificity) provided in the summary; device performance verified against predetermined requirements and consensus standards.
Technological Characteristics
Non-invasive oscillometric sphygmomanometer; compact, lightweight form factor. Connectivity via data download to computer. Complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-30, AAMI/ANSI SP10. Software developed per IEC/EN 62304. Risk management per ISO 14971. Usability per IEC 62366.
Indications for Use
Indicated for adult and pediatric patient populations; not indicated for neonates. Designed to measure systolic and diastolic blood pressure and pulse rate using the oscillometric method on a cuffed arm.
Regulatory Classification
Identification
A noninvasive blood pressure measurement system is a device that provides a signal from which systolic, diastolic, mean, or any combination of the three pressures can be derived through the use of tranducers placed on the surface of the body.
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Public Health Service
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 25, 2014
Mortara Instrument, Inc. Amy Yang Sr. Regulatory Affairs Engineer 7865 North 86th St. Milwaukee, Wisconsin 53224
Re: K133989
Trade/Device Name: Ambulo 2400 Ambulatory Blood Pressure Monitoring System Regulation Number: 21 CFR 870.1130 Regulation Name: Noninvasive Blood Pressure Measurement System Regulatory Class: Class II Product Code: DXN Dated: October 13, 2014 Received: October 15, 2014
Dear Amy 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, 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 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
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Part 807); labeling (21 CFR Part 801); medical device reporting of medical devicerelated 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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,
# Melissa A. Torres -S
For
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
510(k) Number (if known) K133989
Device Name
Ambulo 2400 Ambulatory Blood Pressure Monitor
Indications for Use (Describe)
The Ambulo 2400 Ambulatory Blood Pressure Monitor is indicated for use in adult & pediatric patient populations; it is not indicated for use with neonates.
The Ambulo 2400 Ambulatory Blood Pressure Monitor is designed to measure systolic and diastolic blood pressure and pulse rate of adults and pediatric patients, using the oscillometric method on a cuffed arm.
Type of Use (Select one or both, as applicable)
| <span> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> |
|--------------------------------------------------------------------------------------------------------|
| <span> <span style="font-size: 16px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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## 510(k): Ambulo 2400 Device Summary
## Submitter:
## Date: November 25, 2014
| Amy Yang, Sr. Regulatory Affairs Engineer<br>Mortara Instrument, Inc.<br>7865 N. 86th Street | | |
|----------------------------------------------------------------------------------------------|-------------------------------------------------------|--------------------------------|
| Milwaukee, WI 53224 | | |
| FAX: | (414) 354-4760 | |
| Phone: | (414) 354-1600 | |
| Contact: | Amy Yang (see above) | |
| Trade Name: | Mortara Ambulo 2400 Ambulatory Blood Pressure Monitor | |
| Common Name: | Ambulatory Blood Pressure Monitoring System | |
| Classification Name: | System, Measurement, Blood-Pressure, Non-Invasive | |
| Classification Description: | Noninvasive blood pressure measurement system | |
| Classification Regulation: | 21 CFR §870.1130 | |
| Product Code: | DXN | |
| Legally marketed devices to which S.E. is claimed: | | |
| Mortara Ambulo 2400 | Predicate 510(k) Number | Predicate Manufacturer / Model |
| | | |
| System, Measurement, Blood-<br>Pressure, Non-Invasive | K080274 | Tiba Medical / Ambulo 2400 |
## Description:
The Ambulo 2400 is a compact, lightweight, non-invasive ambulatory blood monitoring system. The Ambulo 2400 can measure systolic and diastolic blood pressure and pulse rate over and pulse rate over a 24 hour period. It is easily configured and individually-fitted for each patient by a physician or health care professional. Measurements are automatically captured, without medical supervision, by the Ambulo 2400 and later downloaded to a computer for analysis and interpretation by a physician.
Since blood pressure naturally fluctuates throughout a full day according to various factors, such as sleep patterns, medication, diet, exercise and stress, a single measurement is not sufficient to make a sound diagnosis. Analyzing a person's blood pressure over an extended period of time can improve the diagnosis and ultimately the treatment. The Ambulo 2400 can collect blood pressure data under a variety of daily activities over a 24 hour period and then downloaded to a computer for analysis and treatment. The Ambulo 2400 may also be use on an ongoing basis to evaluate the effectiveness of a prescribed treatment.
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## Abbreviated 510(k) Notification
## Technology Comparison:
The Mortara Ambulo 2400 utilizes the same or similar technology for each parameter as utilized by the predicate device.
## Intended Use:
The Ambulo 2400 is intended to be a compact, non-invasive Ambulatory Blood Pressure Monitoring (ABPM) system. ABPM technology involves the use of an automatic, non-invasive device to measure blood pressure over an extended period of time – typically 24 hours. The ABPM procedure is an essential tool for physicians, clinical researchers, and other healthcare professionals to analyze a patient's blood pressure as it relates to his/her circadian rhythm. This process offers insight into diagnostic factors as they relate to the spectrum of activity within everyday life.
## Indications for Use:
The Ambulo 2400 Ambulatory Blood Pressure Monitor is indicated for use in adult & pediatric patient populations; it is not indicated for use with neonates.
The Ambulo 2400 Ambulatory Blood Pressure Monitor is designed to measure systolic and diastolic blood pressure and pulse rate of adults and pediatic patients, using the oscillometric method on a cuffed arm.
## Standards and Testing:
Performance testing has been completed on the Mortara S4 Mobile Monitor and demonstrates compliance with International and FDA-recognized consensus standards:
IEC 60601-1-1:2000 - Medical electrical equipment Part 1: General requirements for basic safety and essential performance. Collateral Standard: Safety Requirements for Medical Electrical Systems.
IEC 60601-1-2:2007 – Medical Electrical Equipment – Part 1-2: General requirements for safety – Collateral Standard: Electromagnetic Compatibility.
IEC 60601-1-4 Consol. Ed. 1.1:2000 – Medical Electrical Equipment – Part 1-4: General requirements for Collateral Standard: Programmable Electrical Medical Systems.
IEC 60601-1-6:2004 – Medical Electrical Equipment – Part 1-6: General Requirements for Safety and Essential Performance - Collateral Standard: Usability.
IEC 60601-1-6:2010 - Medical Electrical Equipment - Part 1-6: General Requirements for Safety and Essential Performance - Collateral Standard: Usability.
IEC 60601-2-30:1999 - Medical Electrical Equipment. Part 2-30: Particular requirements for the basic safety and essential performance of automated non-invasive sphygmomanometers.
IEC 80601-2-30:2009+A1:2013 – Medical Electrical Equipment. Part 2-30: Particular requirements for the basic safety and essential performance of automated non-invasive sphygmomanometers.
IEC/EN 62304:2006+AC:2008 - Medical device software - Software life-cycle processes.
IEC 62366:2007 - Medical devices - Application of usability engineering to medical devices.
ISO 14971:2007 – Medical devices – Application of Risk Management to Medical Devices
AAMI/ANSI SP10:2002/ 2008 & AAMI SP10:2002/A1:2003 - Manual, electronic or automated sphygmomanometers.
Additionally, verfication, validation, performance and environmental tests have been performed to address the intended use, requirement specifications, usability and risk management requirements.
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## Abbreviated 510(k) Notification
## Performance Testing:
## Sterilization Validation:
The Mortara Ambulo 2400 is not sterilizable, and therefore this section does not apply to the device itself.
## Shelf Life Testing:
The Mortara Ambulo 2400 is not sterilizable, and therefore this section does not apply to the device itself.
## Biocompatibility Testing:
The cuffs used are parts of the system that come in contact with the patient. These component devices have been previously tested in their own right for other submissions and found to be acceptable. However, the Ambulo 2400 itself does not involve direct / indirect patient contact.
## Software Testing:
Software for the Mortara Ambulo 2400 was designed and developed according to a robust software development process, and was rigorously verified and validated. Test results indicated that the Mortara Ambulo 2400 complies with its predetermined specification.
## Electrical Safety:
The Mortara Ambulo 2400 was evaluated for patient safety in accordance with applicable Standards.
## Electromagnetic Compatibility Testing:
The Mortara Ambulo 2400 was tested for EMC in accordance with applicable Standards. Test results indicated that the Mortara Ambulo 2400 complies with its predetermined specification.
## Performance Testing - Bench:
The Mortara Ambulo 2400 was tested in accordance with internal requirements and test results indicated that the device complies with the predetermined requirements. This testing includes performance and functional.
## Performance Testing - Animal:
Animal performance testing was not performed and is not necessary to demonstrate safety and effectiveness of the Mortara Ambulo 2400.
## Performance Testing - Clinical:
The Ambulo 2400 was evaluated for clinical performance to demonstrate safety and effectiveness.
#### Conclusion:
The results of these activities demonstrate that the Mortara Ambulo 2400 is as safe, as effective and performs as well as or better than the predicate device.
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.