K152280 · Biophotas, Inc. · ILY · Mar 2, 2016 · Physical Medicine
Device Facts
Record ID
K152280
Device Name
BioPhotas Celluma3
Applicant
Biophotas, Inc.
Product Code
ILY · Physical Medicine
Decision Date
Mar 2, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The BioPhotas Celluma3 is intended to deliver heat in the IR spectrum to provide topical heating for the purpose of elevating tissue temperature; for the temporary relief of minor muscle and joint pain, arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation. The blue spectrum light is intended to reduce mild to moderate inflammatory acne vulgaris. The Celluma3 is intended to emit energy in the red and infrared spectrum for use in dermatology for the treatment of periorbital wrinkles.
Device Story
Celluma3 is a shapeable, portable LED panel; conforms to anatomical contours; uses biocompatible materials. Emits blue (464nm) light for mild/moderate inflammatory acne; red (640nm) and infrared (880nm) light for periorbital wrinkle reduction and topical heating for pain relief. Used in esthetician clinics or home settings; operated by patient or provider. Device delivers light energy to target tissue; heat elevation increases local circulation. Healthcare providers/users assess wrinkle reduction via visual inspection or Fitzpatrick Classification. Benefits include non-invasive pain management and aesthetic improvement of periorbital wrinkles.
Clinical Evidence
Prospective clinical study; 50 subjects enrolled, 42 completed; ages 30-75. Treatment: 30-min sessions, 3x/week for 4 weeks; 12-week post-treatment follow-up. Primary endpoint: reduction in periorbital wrinkle severity per Fitzpatrick Classification. Results: 2/3 dermatologists agreed majority of subjects achieved >=1 point reduction in wrinkle severity 12 weeks post-treatment. No adverse events reported.
Indicated for patients aged 30-75 with periorbital wrinkles, or those seeking temporary relief of minor muscle/joint pain, arthritis, muscle spasm, stiffness, or requiring increased local blood circulation, and those with mild to moderate inflammatory acne vulgaris.
Regulatory Classification
Identification
An infrared lamp is a device intended for medical purposes that emits energy at infrared frequencies (approximately 700 nanometers to 50,000 nanometers) to provide topical heating.
Special Controls
*Classification.* Class II (special controls). The device, when it is an infrared therapeutic heating lamp, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 2, 2016
Biophotas, Inc % Mr. Robert Seiple QPM Consulting, LLC 3817 Seville Rd Denton, Texas 76205
Re: K152280
Trade/Device Name: Biophotas Celluma3 Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared lamp Regulatory Class: Class II Product Code: ILY, OHS, OLP Dated: December 30, 2015 Received: January 27, 2016
Dear Mr. Seiple:
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 of medical devicerelated 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/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,
## Jennifer R. Stevenson -A
For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### Indications for Use
510(k) Number (if known) K152280
Device Name BioPhotas Celluma3
#### Indications for Use (Describe)
The BioPhotas Celluma3 is intended to deliver heat in the IR spectrum to provide topical heating for the purpose of elevating tissue temperature; for the temporary relief of minor muscle and joint pain, arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation. The blue spectrum light is intended to reduce mild to moderate inflammatory acne vulgaris. The Celluma3 is intended to emit energy in the red and infrared spectrum for use in dermatology for the treatment of periorbital wrinkles.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a stylized butterfly-like design on the left, made up of many small blue circles arranged in a radial pattern. To the right of the butterfly is the word "biophotas" in a sans-serif font. The "bio" part of the word is in a teal color, while the "photas" part is in a light green color.
### 510(k) Summary
Traditional 510(k) Summary
As required in 21CFR 807.92, we hereby submit this 510(k) Summary:
#### 510(k) owners name, address, phone, fax, contact person:
The 510(k) owner is BioPhotas, Inc., 250 El Camino Real, #110, Tustin, CA 92780
Phone: (714) 838-1956 Fax:
The contact person: Mr. Patrick Johnson
Date Prepared: March 200 2016
#### Name of the device, trade name, proprietary name, and classification name:
Trade name: Celluma³
Common name: Infrared Lamp
Classification name: Lamp Infrared, Therapeutic Heating (ILY), Over-The-Counter Powered Light Based Laser For Acne (OLP) and Light Based Over-The Counter Wrinkle Reduction (OHS). Note that the product does not employ laser light, but these product codes has been used for these devices.
#### Predicate Devices:
The legally marketed predicates for the BioPhotas Celluma³ are:
- K131113, BioPhotas Celluma
- . K083183, Aklarus Phototherapy System, Hill Laboratories, Frazer, PA.
#### Device Description:
The Celluma3 is a highly shapeable LED panel designed to fit the contours of the target areas of the anatomy, covered with biocompatible material, which uses specific wavelengths of light to manage aesthetic and musculoskeletal conditions. Celluma3 produces light in the near infrared region of the spectrum (880nm) intended to provide topical heating to tissue for pain relief. Blue light (464nm) is intended to help reduce the appearance of mild to moderate inflammatory acne. Red light (640nm) in combination with infrared light is intended to improve the appearance of wrinkles. Note that the Cellumad and the Celluma predicate device are technologically identical; only the indications for use have been revised to add treatment of periorbital wrinkles.
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Image /page/4/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a blue, stylized image of a butterfly or starburst made up of small circles on the left. To the right of the image is the word "biophotas" in a sans-serif font. The "bio" part of the word is in blue, while the "photas" part is in green.
#### Indication for Use/Intended Use:
The BioPhotas Cellumad is intended to deliver heat in the IR spectrum to provide topical heating for the purpose of elevating tissue temperature; for the temporary relief of minor muscle and joint pain, arthritis and muscle spasm; relieving stiffness; promoting relaxation of muscle tissue; and to temporarily increase local blood circulation. The blue spectrum is intended to reduce mild to moderate inflammatory acne vulgaris. The Celluma3 is intended to emit energy in the red and infrared region of the spectrum for use in dermatology for the treatment of periorbital wrinkles.
The Intended Use information from the predicate products is equivalent and is reproduced below:
#### K131113 BioPhotas Celluma
The BioPhotas Celluma device is intended to deliver heat in the IR spectrum to provide topical heating for the purpose of elevating tissue temperature; for the temporary relief of minor muscle and joint pain, arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation. The blue spectrum is intended to reduce mild to moderate inflammatory acne vulgaris. Note that the Celluma' is technologically identical to the Celluma device, only the indication has been revised to include treatment for periorbital wrinkles.
#### K083183 – Aklarus Phototherapy System
The Aklarus Phototherapy system utilizes blue light (420 nm) and the combination of red (628 nm) and blue (420 nm) to treat dermatology conditions – specifically indicated to treat moderate inflammatory acne.
The Aklarus anti-aging Red (628nm and Anti-Aging Infrared (880nm) combination is intended for use in dermatology for the treatment of periorbital wrinkles.
The Aklarus Infrared (880 nm) is intended to provide topical heating for the purpose of elevating tissue temperature; for the temporary relief of minor muscle and joint pain, arthritis and muscle spasm,; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation where applied.
#### Technological characteristics:
The BioPhotas Celluma³ is a lightweight, portable light-emitting diode (LED) device which emits light energy. A blue LED array (464 nm) is used in treatment for mild to moderate inflammatory acne. A red LED array (640 nm) and an infrared LED array (880 nm) are used in combination for reduction of periorbital wrinkles. The near infrared LED array also provides mild topical heating for the purpose of elevating tissue temperature for a temporary relief of minor muscle pain.
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Image /page/5/Picture/0 description: The image shows the logo for biophotas. The logo consists of a blue abstract symbol on the left, followed by the word "bio" in blue and "photas" in green. The abstract symbol appears to be a cluster of blue dots arranged in a pattern.
# Substantial Equivalence:
| Substantial Equivalence:<br>Table 5A – Device Comparison Chart | | | | |
|----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|
| | BioPhotas Celluma<br>K131113 | BioPhotas Celluma3<br>K number TBD | Aklarus Phototherapy<br>System<br>K083183 | Significant<br>Differences |
| Regulation | 21 CFR 890.5500 | 21 CFR 890.5500 | 21 CFR 890.5500 | Identical |
| Regulation<br>Name | Infrared Lamp | Infrared Lamp | Infrared Lamp | Identical |
| Indicated<br>Use | Acne, Pain | Acne, Pain, Wrinkles | Acne, Pain, Wrinkles | Identical to Aklarus,<br>Identical to Celluma<br>except wrinkles<br>added. |
| Indications<br>For Use | The BioPhotas<br>Celluma is intended<br>to deliver heat in the<br>IR spectrum to<br>provide topical<br>heating for the<br>purpose of elevating<br>tissue temperature;<br>for the temporary<br>relief of minor<br>muscle and joint<br>pain, arthritis and<br>muscle spasm;<br>relieving stiffness;<br>promoting the<br>relaxation of muscle<br>tissue; and to<br>temporarily increase<br>local blood<br>circulation. The blue<br>spectrum light is<br>intended to reduce<br>mild to moderate<br>inflammatory acne<br>vulgaris. | The BioPhotas<br>Celluma3 is intended to<br>deliver heat in the IR<br>spectrum to provide<br>topical heating for the<br>purpose of elevating<br>tissue temperature; for<br>the temporary relief of<br>minor muscle and joint<br>pain, arthritis and<br>muscle spasm;<br>relieving stiffness;<br>promoting the<br>relaxation of muscle<br>tissue; and to<br>temporarily increase<br>local blood circulation.<br>The blue spectrum<br>light is intended to<br>reduce mild to<br>moderate<br>inflammatory acne<br>vulgaris. The Celluma3<br>is intended to emit<br>energy in the red and<br>infrared spectrum for<br>use in dermatology for<br>the treatment of<br>periorbital wrinkles. | The Aklarus Blue (420nm +/-<br>10nm), is generally indicated<br>to treat dermatological<br>conditions and specifically<br>indicated to treat moderate<br>inflammatory acne vulgaris.<br>The Aklarus combination of<br>Red (628nm+/-10nm) and<br>Blue(420nm +/-10nm) is<br>intended to emit in the red,<br>blue regions of the spectrum<br>for use in dermatology<br>treatment of mild to<br>moderate acne vulgaris.<br>The Aklarus Anti-Aging Red<br>(628nm +/-10nm) and Anti-<br>Aging Infrared (880nm +/-<br>10nm) combination is<br>intended to emit energy in<br>the red and infra-red region<br>of the spectrum for use in<br>dermatology for the<br>treatment of periorbital<br>wrinkles.<br>The Aklarus Infrared (880nm<br>+/-10nm) is intended to emit<br>energy in the IR spectrum to<br>provide topical heating for<br>the purpose of elevating<br>tissue temperature; for the<br>temporary relief of minor<br>muscle and joint pain,<br>arthritis and muscle spasm;<br>relieving stiffness; promoting<br>the relaxation of muscle<br>tissue; and to temporarily<br>increase local blood<br>circulation where applied. | Identical to Aklarus,<br>Identical to Celluma<br>except wrinkles<br>added. |
| | BioPhotas Celluma<br>K131113 | BioPhotas Celluma3<br>K number TBD | Aklarus Phototherapy<br>System<br>K083183 | Significant<br>Differences |
| Mechanism<br>of Action | Use of visible blue<br>light in treatment of<br>acne, red light for<br>elevating tissue<br>temperature. | Use of visible blue light<br>in treatment of acne,<br>red light for elevating<br>tissue temperature<br>and IR light in<br>improving appearance<br>of periorbital wrinkles. | Use of visible blue light in<br>treatment of acne, red light<br>for elevating tissue<br>temperature and IR light in<br>improving appearance of<br>periorbital wrinkles. | Identical to Aklarus,<br>Identical to Celluma<br>except wrinkles<br>added. |
| Wavelengths | 465nm, 640nm,<br>880nm | 465nm, 640nm, 880nm | 420nm, 633nm, 830nm | Equivalence of blue<br>light in the 400nm<br>range previously<br>established<br>(K122237). |
| Electrical<br>power | 110 – 120 V | 110 – 120 V | 110 – 120 V | Identical |
| Treatment | 3 times a week for<br>30 min.<br>4 weeks | 3 times a week for 30<br>min.<br>4 weeks | Twice Weekly for 30 min.<br>4 weeks | Identical |
| Electrical<br>Safety | ISO 60601-1 &<br>collateral standards | ISO 60601-1 &<br>collateral standards | ISO 60601-1 & collateral<br>standards | Identical |
| Use | ОТС | OTC | Prescription | Identical to the<br>Celluma predicate,<br>Aklarus is an older<br>device. |
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Image /page/6/Picture/0 description: The image shows the logo for biophotas. The logo consists of a blue, stylized image of a butterfly or starburst made up of small circles on the left. To the right of the image is the word "biophotas" in a sans-serif font, with "bio" in blue and "photas" in green.
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Image /page/7/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a stylized, teal-colored, abstract butterfly or starburst shape made up of many small circles on the left. To the right of the shape is the word "biophotas" in a sans-serif font, with "bio" in teal and "photas" in a light green color.
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Image /page/8/Picture/0 description: The image shows the logo for biophotas. The logo consists of a blue, star-like symbol on the left, followed by the word "biophotas" in blue and green. The "bio" part of the word is in blue, while the "photas" part is in green. The logo is simple and modern, and the colors are bright and eye-catching.
#### K152280 Nonclinical Performance Data:
To demonstrate safety and effectiveness of the BioPhotas Celluma³ and to demonstrate substantial equivalence to the predicate devices, BioPhotas has completed a number of non-clinical performance tests. The Celluma meets established requirements for overall design, biocompatibility, electrical safety and software validation confirming that the design outputs meet design input requirements and established specifications.
The BioPhotas Celluma successfully passed testing per internal verification/validation requirements and national/international standards illustrated below:
- . Biocompatibility per 10993-1 (specifically 10993-5 & 10993-10)
- Electrical safety per IEC 60601-1
- EMC testing per IEC 60601-1-2
- . Software validation per IEC 62304 and the FDA Guidance document
#### Clinical Performance Data:
A human clinical study was conducted to confirm device efficacy for the additional indication (treatment of periorbital wrinkles).
Test subjects visited a study center for thirty minute treatments, three times per week, for a period of four weeks, and a twelve week post-treatment follow up after the final treatment. Test subjects had photos taken at the start, at the end of the four week treatment, and at the final twelve week post-treatment follow up visit.
Upon completion of the clinical study, all photos were sent to the Clinical Investigators for determination of periorbital wrinkle reduction results, applying the Fitzpatrick Classification of Facial Wrinkling (Perioral and Periorbital).
One of the three Clinical Investigators (Board Certified Dermatologists), acted as the Principal Investigator and all three Clinical Investigators independently evaluated the test subjects' photos for inclusion and final results.
The eligible study population is comprised of test subjects within the Fitzpatrick Classification of Facial Wrinkling (Perioral and Periorbital) and ages between 30 to 75 years, who meet all inclusion criteria for enrollment. Fifty test subjects were recruited across seven esthetician locations, with seven or eight patients per study center. The final test subject count was forty-two with one site and seven test subjects dropping out of the study prior to completion. There were no adverse events observed or reported during the study.
The periorbital wrinkle levels were measured, and professional visual evaluation performed by the Clinical Investigators to evaluate the efficacy of the Celluma on the improvements in periorbital wrinkles.
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Image /page/9/Picture/0 description: The image shows the logo for biophotas. The logo consists of a stylized, abstract symbol on the left, resembling a cluster of dots arranged in a radiating pattern, colored in teal. To the right of the symbol is the word "biophotas" in a sans-serif font, with "bio" in teal and "photas" in a light green color. The overall design is clean and modern.
At least two out of three Clinical Investigators agreed that a majority of test subjects have experienced a one point or greater reduction of wrinkle severity on the Fitzpatrick Classification of Facial Wrinkling (Perioral and Periorbital) 12 weeks following the completion of treatment.
Clinical Study results confirmed at least a full point reduction in the appearance of periorbital wrinkles, along with high positivity rates from test subjects; therefore, has deemed the Celluma efficacious, and demonstrating effectiveness.
#### Statement of Substantial Equivalence:
As defined by FDA, a device is substantially equivalent to a predicate device has the same intended use and the same technological characteristics as the previously cleared device(s). Alternatively the device may have the same intended use and different technological characteristics that have been demonstrated to show that the these differences do not raise any new or additional questions regarding its safety and effectiveness relative to the predicate device.
BioPhotas has demonstrated that the Celluma device has the same intended use as the predicate device, employs very similar technological characteristics, which in addition to the human clinical study results, demonstrated that the device does not pose any additional questions regarding safety and efficacy relative to the predicate.
Therefore, the BioPhotas Celluma as designed and manufactured, has been demonstrated to be substantially equivalent to the referenced predicate devices.
#### End of 510(k) Summary Section
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.