K150766 · Carestream Health, Inc. · MQB · Jun 24, 2015 · Radiology
Device Facts
Record ID
K150766
Device Name
Carestream DRX-1 System
Applicant
Carestream Health, Inc.
Product Code
MQB · Radiology
Decision Date
Jun 24, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1680
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The device is intended to capture for display radiographic images of human anatomy including both pediatric and adult patients. The device is intended for use in general projection radiographic applications wherever conventional screen-film systems or CR systems may be used. Excluded from the indications for use are mammography, fluoroscopy, and angiography applications.
Device Story
Carestream DRX-1 System is a digital radiography (DR) imaging system; captures x-ray projections using flat panel detectors (GOS or CsI scintillators). System components include operator console, detector, and optional tether. Detectors communicate via tethered or wireless connection to console. Beam Detect Mode allows integration with OEM x-ray generators without direct signal interception; detector senses exposure arrival. Used in clinical settings by healthcare professionals to generate digital images for diagnostic viewing and printing. Provides improved image quality, IPX7 liquid resistance, and extended battery life compared to predicate. Output enables clinicians to perform diagnostic procedures; benefits include high-quality digital imaging, workflow efficiency, and compatibility with existing x-ray infrastructure.
Clinical Evidence
Clinical evidence includes a reader study comparing clinical image pairs from the subject device and the predicate. Results indicated diagnostic capability is statistically equivalent or better than the predicate. Bench testing performed per FDA guidance for solid-state imaging devices confirmed conformance to specifications for image quality (MTF, DQE, sensitivity, ghosting), workflow, and reliability. No clinical data was required to establish substantial equivalence, but the reader study provided supplemental evidence.
Technological Characteristics
Flat panel digital imager; GOS or CsI scintillator; powder-coated aluminum housing with plastic bumpers and carbon fiber panel. Connectivity: tethered or wireless. Standards: ISO 14971:2012, DICOM, IEC 60601-1 (3rd Ed), IEC 60601-1-2:2007, CFR 47 part 15, ANSI C95.1. Features IPX7 liquid resistance. Software-based image processing resident on system console.
Indications for Use
Indicated for pediatric and adult patients requiring general projection radiographic imaging. Excludes mammography, fluoroscopy, and angiography.
Regulatory Classification
Identification
A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
Predicate Devices
Carestream DRX-1 System (with DRX 2530C Detector) (K130464)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 24, 2015
Carestream Health, Inc. % Ms. Carolyn Wagner Sr. Regulatory Affairs Manager, US&C 150 Verona Street ROCHESTER NY 14608
Re: K150766
Trade/Device Name: Carestream DRX-1 System Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: MOB Dated: March 25, 2015 Received: March 26, 2015
Dear Ms. Wagner:
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 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.
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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/Resourcesfor You/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,
Robert A Ochs
Robert Ochs. Ph.D. Acting Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K150766
Device Name Carestream DRX-1 System
#### Indications for Use (Describe)
The device is intended to capture for display radiographic images of human anatomy including both pediatric and adult patients. The device is intended for use in general projections wherever conventional screen-film systems or CR systems may be used. Excluded from the indications for use are mammography, fluoroscopy, and angiography applications.
Type of Use (*Select one or both, as applicable*)
| <span></span> | Prescription Use (Part 21 CFR 801 Subpart D) | <span></span> | Over-The-Counter Use (21 CFR 801 Subpart C) |
|---------------|----------------------------------------------|---------------|---------------------------------------------|
|---------------|----------------------------------------------|---------------|---------------------------------------------|
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# Carestream
# "510(k) Summary"
| 510(k) Owner Name: | Carestream Health, Inc. |
|------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) Owner Address: | 150 Verona Street<br>Rochester, New York 14608 |
| 510(k) Owner Phone: | 585 627-6977 |
| 510(k) Owner Fax: | 585 454-1894 |
| Contact Person & Info: | Carolyn Wagner<br>Sr. Regulatory Affairs Manager, X-ray Solutions<br>carolyn.wagner@carestream.com<br>585-627-6588 |
| Date Summary Prepared: | May 22, 2015 |
| Device Trade Name: | Carestream DRX-1 System w/ DRX Plus Detectors |
| Device Common Name: | Flat Panel Digital Imager |
| Classification Name: | Stationary x-ray system |
| Device Class: | Class II |
| Device Code: | MQB |
| Regulation Number: | 21 CFR 892.1680 |
| Predicate Device: | Carestream DRX-1 System (with DRX 2530C<br>Detector) |
| | Manufactured by: Carestream Health, Inc.<br>510(k) No.: K130464 (June 7, 2013)<br>Classification Regulation: 21 CFR 892.1680<br>Classification Name: Stationary x-ray system<br>Primary Product Code: MQB |
#### Device Description:
The Carestream DRX-1 System is a diagnostic imaging system utilizing digital radiography (DR) technology that is used with diagnostic x-ray systems. The system consists of the Carestream DRX-1 System Console (operator console), flat panel digital imager (detector), and optional tether interface box. The system can operate with either the Carestream DRX-1 System Detector (GOS), the DRX-2530C Detector (CsI), the DRX Plus 3543 (GOS) Detector, or the DRX Plus 3543C (CsI) Detector and can be configured to register and use any of the detectors. Images captured with a flat panel digital detector can be communicated to the operator console via tethered or wireless connection.
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### Indications for Use / Intended Use:
The Indications for Use for the device, as described in its labeling, are:
"The device is intended to capture for display radiographic images of human anatomy including both pediatric and adult patients. The device is intended for use in general projection radiographic applications wherever conventional screen-film systems or CR systems may be used. Excluded from the indications for use are mammography, fluoroscopy, and angiography applications."
The intended use for this device, as determined by descriptions and the proposed labeling contained in this submission, is similar to the Indications for Use statement provided above. The Carestream DRX-1 System with DRX Plus Detectors is a diagnostic imaging system utilizing digital radiography (DR) technology that is used to capture x-rays for diagnostic procedures. We believe that the Carestream DRX-1 System with DRX Plus 3543 and DRX Plus 3543C Detectors and the predicate device have the same intended use.
The Indications for Use for the subject device is the same as for the predicate device and the intended use remains unchanged. Any variation in features or technical specifications have been identified and addressed through testing (described below) to support a substantial equivalence determination.
#### Comparison of Technological Characteristics:
Based upon information provided within this submission. we believe that the Carestream DRX-1 System with DRX Plus 3543 and DRX Plus 3543C Detectors is substantially equivalent to the legally marketed Carestream DRX-1 System with DRX-1 System Detector and DRX 2530C Detector (predicate device). Both the currently marketed DRX-1 and DRX 2530C Detectors and the new DRX Plus Detectors are used in combination with the image processing software and user interface resident on the DRX-1 System Console component of the Carestream DRX-1 System. The system is used to directly capture conventional projected x-rays to generate digital images, regardless of which detector is being used. An image can be displayed on a preview monitor for viewing with any of the detectors. The system can transmit diagnostic images through a digital network for diagnostic viewing and printing regardless of which detector is used.
The predicate (DRX-1/DRX-1C) and replacement (DRX Plus 3543/3543C) detectors share almost identical design specifications. However, the new DRX Plus Detectors also conform to requirements for additional features such as IPX7 liquid resistance, support for future software features, extended battery life, lighter weight, and improved image quality. The physical size of the new detectors is identical to the DRX-1 and DRX-1C Detectors except for the thickness. The new detectors are 1.47cm thick while the DRX-1/DRX-1C detectors are 1.55cm thick. The materials used to fabricate the DRX-1/DRX-1C and DRX Plus detectors are similar. All have powder coated (painted) aluminum housings with plastic bumpers and a carbon fiber panel, and all use the same DRX-1 system battery or tether for power.
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Internally, the four detectors are also similar, containing various printed circuit boards, a core plate upon which the detector glass is adhered, and either a GOS or CsI scintillator to convert x-rays to light. The DRX Plus GOS scintillator is exactly the same as the DRX-1 (predicate) except that it is laminated to the glass. The CsI scintillator on the new DRX Plus detector is deposited to the same specifications as the DRX-1C detector. The glass used on both DRX Plus detectors is identical in active pixel area and pixel pitch to the detectors used with the predicate device. However, the glass used for the DRX Plus 3543/3543C Detectors has increased sensitivity over the DRX-1 glass. The increased sensitivity of the glass and associated electronics allows the DRX Plus Detectors to exceed the imaging performance characteristics of the DRX-1 and DRX-1C detectors.
#### Discussion of Testing:
The performance characteristics and operation / usability of the Carestream DRX-1 System with DRX Plus 3543 and DRX Plus 3543C Detectors were evaluated in non-clinical (bench) testing in accordance with FDA guidance document "Guidance for the Submission of 510(k)'s for Solid State Imaging Devices".
Non-clinical test results have demonstrated that the device conforms to its specifications. Acceptance criteria were determined based on desired performance with respect to image quality, intended use, workflow related performance, shipping performance, and general functionality and reliability, including both hardware and software requirements. Predefined acceptance criteria were met and demonstrated that the device is as safe, as effective, and performs as well as or better than the predicate device: therefore supporting a substantial equivalence determination. Acceptance criteria were identified for weight, pixel size, resolution, pixel pitch, total pixel area, usable pixel area. MTF (at various spatial resolutions), DQE (at various spatial resolutions), sensitivity, ghosting, boot-up time, operating temperature, exposure latitude, signal uniformity, and dark noise (ADC).
A concurrence study of clinical image pairs was performed in accordance with FDA guidance document "Guidance for the Submission of 510(k)'s for Solid State Imaging Devices" to demonstrate the diagnostic capability of the Carestream DRX-1 System with the new DRX Plus 3543 and DRX Plus 3543C Detectors. Results of the Reader Study indicated that the diagnostic capability of the Carestream DRX-1 System with DRX Plus Detectors is statistically equivalent to or better than that of the predicate device. Clinical images were not necessary to establish substantial equivalence based on the nature of modifications to the device and adequacy of the non-clinical data, but they provide further evidence in addition to the laboratory performance data to show that the device works as intended.
#### Consensus Standards:
The device conforms to ISO 14971:2012, Digital Imaging and Communications in Medicine (DICOM) Set, IEC 60601-1+Amd 1 - 3td Edition 2005, CFR 47 part 15, ANSI C95.1, and IEC 60601-1-2:2007.
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## Compatibility:
Carestream has a documented validation and verification process for integrating the Carestream DRX-1 System and DRX 3543 Plus detectors with OEM x-ray consoles that were originally installed by other manufacturers as analog or computed radiography x-ray systems. The modifications made to the existing x-ray system are limited to integration between the hand-switch and its connector to the x-ray system console. Sales and service personnel are qualified to determine whether the Carestream DRX-1 System can be integrated with a particular x-ray system. Once installed, proper operation is verified before the system is turned over for use on patients.
As of March 21, 2013, the systems listed in the Compatibility List (Table 1) have been found compatible with the Carestream DRX-1 System. This list may be updated in the future to include additional compatible systems.
| Bennett Model HFQ-12050P | Philips Diagnost 94 | DEL ATC 525 |
|---------------------------|-----------------------------|------------------------------|
| CPI CMP | Philips Easy Diagnost Eleva | DEL ATC 725 |
| CPI Indico 100 | Odyssey | Dyna RAD |
| CPI Indico 100 RAD | Quantum (Odyssey HF Series) | GE AMX4 |
| DEL AXR | Quantum Q-Vision | GE MPG 50 |
| Fischer RMS Digital 425HF | Rontgenwerk Editor Mp | GE MPG 65 |
| GE 500D | Sedecal Shf-330 | GE MPS 64 |
| GE Advantx | Shimadzu Gsc | GE MVP 80 |
| GE MPG | Siemens Axiom Dr | GE Silhouette VR |
| GE MPH | Siemens Fluorospot Compact | Gendex Reliance ATC525 |
| GE MVP | Philips Optimus | Gendex Reliance ATC725 |
| GE Precision RXi | Philips Super Cp | Medira 2000 |
| GE Prestige II | Picker Mtx | Philips Medio CP |
| GE Prestilix 1600X | Picker Rad 65 | Picker Clinx-R |
| GE Proteus | Primax Go | Quantum Quest |
| GENDEX APG500 | Primax/Mecal Challenger | Reliance ATC725 |
| GMM Opera | Siemens Polydoros | Sedecal Global |
| KODAK DIRECTVIEW DR 5100 | Siemens Polydoros 80s | Sedecal Ideal |
| KODAK DIRECTVIEW DR 7100 | Siemens Polydoros Gen It55 | Sedecal SHF |
| KODAK DIRECTVIEW DR 3500 | Siemens Polydoros Lx | Sedecal Touchscreen |
| KODAK DIRECTVIEW DR 7500 | Siemens Polydoros Sx | Shimadzu Evolution |
| KODAK DIRECTVIEW DR 9000 | Stephanix Trophy N500 | Siemens Mobile XP Hybrid |
| KODAK DIRECTVIEW DR 9500 | Suinsa Hercules | Siemens Mobilette |
| Quantum | Toshiba Kalare | Stadler Electonik AG SE 4500 |
| Philips Diagnost 93 | Toshiba Kxo | |
#### CARESTREAM DRX-1 System Compatibility List
#### Table 1
The new Beam Detect Mode allows integration with OEM systems where there is no access to intercept the Prep/Expose signal. The user commands the detector to get prepared for an
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exposure on the Carestream DRX-1 System Console and separately asserts the "expose" command to the x-ray generator when the Console indicates the detector is ready. The detector determines when an exposure has arrived and captures the image.
### Conclusion:
In conclusion, the new detectors are equivalent or superior to the DRX-1/DRX-1C detectors in all applicable parameters recommended by the Guidance for the Submission of 510(k)'s for Solid State Imaging Devices. Image quality parameters such as DQE, sensitivity, and MTF of the DRX Plus detectors demonstrate this. The tests used to determine these parameters were performed using industry standards. Liquid resistance of the DRX Plus detectors as compared to the DRX-1 Detectors is improved from IPX1 liquid resistance to IPX7 liquid resistance as tested and confirmed by a certified independent laboratory.
In addition to meeting specifications for the new features included in the DRX Plus detectors, the new detectors have been tested to conform to applicable existing specifications of the predicate DRX-1 detectors. Quality Assurance tests with traceable links to design inputs were performed to verify conformance to specifications. In addition, tests were included to confirm mitigation of risks identified in an extensive product hazard risk analysis based on results of a Failure Mode Effects Analysis.
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.