K162050 · Zeltiq Aesthetics, Inc. · OOK · Nov 21, 2016 · General, Plastic Surgery
Device Facts
Record ID
K162050
Device Name
ZELTIQ CoolSculpting System
Applicant
Zeltiq Aesthetics, Inc.
Product Code
OOK · General, Plastic Surgery
Decision Date
Nov 21, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4340
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The CoolSculpting System is a skin cooling or heating device is indicated for cold-assisted lipolysis (breakdown of fat) of the upper arm, bra fat, banana roll, submental area, thigh, abdomen, and flank, or "love handles" in individuals with a Body Mass Index (BMI) of 30 or less. The device is intended to affect the appearance of visible fat bulges in the upper arm, bra fat, banana roll, submental area, thigh, abdomen and flank. Cooling with the device may also be used to minimize pain and thermal injury during laser and dermatological treatments and act as a local anesthetic for procedures that induce minor local discomfort. The CoolSculpting System is also indicated for use to provide localized thermal therapy (hot or cold) to minimize pain post-trauma and post-surgery, and for temporary relief of minor aches, pains, and muscle spassms. The optional massage function can also be used for the temporary relief of minor muscle aches, pain, and spasm and for temporary improvement in local circulation and temporary reduction in the appearance of cellulite. The ZELTIQ Pretreatment Skin Wipe and Gel/Gelpad facilitate thermal contact of the device with a patient's skin by mitigating minor variances in device-to-skin contact.
Device Story
Portable thermoelectric cooling/heating device; applies controlled thermal energy to treatment sites. Comprised of control unit, vacuum/surface applicators, and accessories (liners, gel/gelpads, cycle cards). Vacuum applicators (including new CoolAdvantage) use suction to draw tissue into cup; surface applicators treat flat areas. Clinician-operated in clinical setting. Output: controlled thermal application. Effect: induces cold-assisted lipolysis (fat breakdown) or provides thermal therapy. Benefits: non-invasive fat reduction, pain relief, improved circulation. Healthcare provider uses device to target specific fat bulges; clinical decision-making based on patient BMI and aesthetic goals.
Clinical Evidence
Prospective, multicenter, non-randomized, interventional cohort study (n=30). Subjects treated on both upper arms at -11°C for 35 minutes. Primary efficacy: independent panel review of pre- and 12-week post-treatment photos; 85.2% correct identification rate [72.9%, 93.4%]. Ultrasound measurements showed significant fat layer reduction (0.32 cm). Secondary efficacy: 72.41% subject satisfaction. Safety: no unanticipated adverse device effects; 4 patients experienced prolonged numbness (>12 weeks), which resolved spontaneously.
Technological Characteristics
Thermoelectric cooling/heating system. Components: control unit, vacuum/surface applicators, disposable gaskets, gel/gelpads. Vacuum applicators feature interchangeable contours. Treatment parameters: -11°C for 35 minutes. Connectivity: standalone. Sterilization: not specified (disposable components).
Indications for Use
Indicated for cold-assisted lipolysis of upper arm, bra fat, back fat, banana roll, submental area, thigh, abdomen, and flank in individuals with BMI ≤ 30. Also indicated for localized thermal therapy to minimize pain post-trauma/surgery, relief of minor aches/pains/muscle spasms, and use as local anesthetic for minor discomfort during laser/dermatological procedures. Optional massage for circulation improvement and cellulite appearance reduction.
Regulatory Classification
Identification
A contact cooling system for aesthetic use is a device that is a combination of a cooling pad associated with a vacuum or mechanical massager intended for the disruption of adipocyte cells intended for non-invasive aesthetic use.
Special Controls
*Classification.* Class II (special controls). The special controls for this device is FDA's “Guidance for Industry and FDA Staff; Class II Special Controls Guidance Document: Contact Cooling System for Aesthetic Use.” See § 878.1(e) for the availability of this guidance document.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 21, 2016
Zeltiq Aesthetics, Inc Ms.Shruti Jayakumar Senior Regulatory Affairs Manager 4698 Willow Road Pleasanton, California 94588
Re: K162050
Trade/Device Name: Zeltiq Coolsculpting System Regulation Number: 21 CFR 878.4340 Regulation Name: Contact Cooling System For Aesthetic Use Regulatory Class: Class II Product Code: OOK Dated: October 20, 2016 Received: October 21, 2016
Dear Ms. Jayakumar:
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,
# 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) K162050
Device Name CoolSculpting System
#### Indications for Use (Describe)
The CoolSculpting System is a skin cooling or heating device is indicated for cold-assisted lipolysis (breakdown of fat) of the upper arm, bra fat, banana roll, submental area, thigh, abdomen, and flank, or "love handles" in individuals with a Body Mass Index (BMI) of 30 or less. The device is intended to affect the appearance of visible fat bulges in the upper arm, bra fat, banana roll, submental area, thigh, abdomen and flank.
Cooling with the device may also be used to minimize pain and thermal injury during laser and dermatological treatments and act as a local anesthetic for procedures that induce minor local discomfort.
The CoolSculpting System is also indicated for use to provide localized thermal therapy (hot or cold) to minimize pain post-trauma and post-surgery, and for temporary relief of minor aches, pains, and muscle spassms. The optional massage function can also be used for the temporary relief of minor muscle aches, pain, and spasm and for temporary improvement in local circulation and temporary reduction in the appearance of cellulite.
The ZELTIQ Pretreatment Skin Wipe and Gel/Gelpad facilitate thermal contact of the device with a patient's skin by mitigating minor variances in device-to-skin contact.
Type of Use (Select one or both, as applicable)
| <span style="text-decoration: underline;"></span> | <span style="text-decoration: underline;"></span> X Prescription Use (Part 21 CFR 801 Subpart D) | <span style="text-decoration: underline;"></span> | <span style="text-decoration: underline;"></span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# 510(K) SUMMARY
# COOLSCULPTING SYSTEM
| Submitted by: | ZELTIQ™ Aesthetics, Inc.<br>4410 Rosewood Drive<br>Pleasanton, CA 94588 |
|------------------------|------------------------------------------------------------------------------------------------------------------------------|
| CONTACT: | Shruti Jayakumar<br>Senior Regulatory Affairs Manager<br>ZELTIQ Aesthetics, Inc.<br>Phone: 925-474-2516<br>Fax: 925-474-8028 |
| DATE PREPARED: | November 21, 2016 |
| TRADE NAME: | ZELTIQ CoolSculpting System |
| COMMON NAME: | Skin Cooling Device |
| CLASSIFICATION NAME: | Contact Cooling System for Aesthetic Use |
| DEVICE CLASSIFICATION: | Class II, 21 CFR §878.4340 |
| PRODUCT CODE: | OOK |
| PREDICATE DEVICES: | The ZELTIQ CoolSculpting System (K160259) |
#### INDICATION FOR USE:
The CoolSculpting System is a skin cooling or heating device is indicated for cold-assisted lipolysis (breakdown of fat) of the upper arm, bra fat, back fat, banana roll, submental area, thigh, abdomen, and flank, or "love handles" in individuals with a Body Mass Index (BMI) of 30 or less. The device is intended to affect the appearance of visible fat bulges in the upper arm, bra fat, back fat, banana roll, submental area, thigh, abdomen and flank.
Cooling with the device may also be used to minimize pain and thermal injury during laser and dermatological treatments and act as a local anesthetic for procedures that induce minor local discomfort.
The CoolSculpting System is also indicated for use to provide localized thermal therapy (hot or cold) to minimize pain post-trauma and post-surgery, and for temporary relief of minor aches, pains, and muscle spasms. The optional massage function can also be used for the temporary relief of minor muscle aches,
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pain, and spasm and for temporary improvement in local circulation and temporary reduction in the appearance of cellulite.
The ZELTIQ Pretreatment Skin Wipe and Gel/Gelpad facilitate thermal contact of the device with a patient's skin by mitigating minor variances in device-to-skin contact.
### DEVICE DESCRIPTION:
The CoolSculpting System is a portable thermoelectric cooling and heating device that applies controlled cooling or heating to a treatment site. The CoolSculpting System is comprised of a control unit, detachable vacuum and surface applicators and supplies such as liners, gel/gelpads, cycle cards, geltraps, foam borders and securement system.
# TECHNOLOGICAL CHARACTERISTICS:
The CoolSculpting System is a thermoelectric cooling and heating device that applies controlled cooling or heating to a treatment site. This submission expands the CoolSculpting System's indications for use to include treatment of the upper arm and also introduces a new vacuum applicator known as CoolAdvantage.
This CoolSculpting features vacuum applicators of various sizes and non-vacuum surface applicators that are intended to provide clinicians with an additional option when treating a flat area of the body. As part of its suite of vacuum applicators, ZELTIQ has also developed a new applicator known as CoolAdvantage. CoolAdvantage has the same cup design as CoolMini and features interchangeable contours to accommodate body areas of different curvature. The contours are in the shapes of previously cleared vacuum applicators (CoolCurve+, CoolFit, and CoolCore cleared in DEN090002 and K133212). The treatment parameters for CoolAdvantage are within the previously cleared parameters for vacuum applicators (K142491). Treatment of the upper arm is cleared for -11°C for 35 minutes.
## SUMMARY OF SUBSTANTIAL EQUIVALENCE:
The ZELTIQ CoolSculpting System is substantially equivalent to the device cleared in K160259. Clinical data demonstrates that cold-assisted lipolysis of the upper arms is substantially equivalent to coldassisted lipolysis of the abdomen, flanks, thighs, submental area, back fat, bra fat, and banana roll which were cleared under K160259.
As stated previously, this submission also introduced a new vacuum applicator known as CoolAdvantage. CoolAdvantage has the same cup design as CoolMini and features interchangeable contours to accommodate body areas of different curvature. The contours are in the shapes of previously cleared vacuum applicators (CoolCurve+, CoolFit, and CoolCore cleared in DEN090002 and K133212). The CoolAdvantage applicator is also provided with disposable gaskets which provide a tight seal between the applicator cup and the contour. The treatment parameters for CoolAdvantage are within the previously cleared parameters for vacuum applicators (K142491). Treatment of the upper arm is cleared for -11°C for 35 minutes.
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Clinical data: ZELTIQ conducted a clinical investigation to evaluate the safety and efficacy of cryolipolysis for non-invasive reduction of upper-arm fat. In this study, 30 subjects were enrolled at two clinical sites. Sixty initial treatments were performed with a prototype CoolAdvantage applicator (CoolFit applicator with aluminum Insert). The average age of the 30 subjects enrolled in the study was 45.7 years with an average Body Mass Index (BMI) of 28.2. All subjects were female. Each subject was treated once on each upper arm, at -11°C for 35 minutes. Follow-up data is available through 12 weeks post-treatment. Subject safety was assessed throughout the study. Follow-ups were required at 1 week, and 12 weeks post-treatment. All 30 subjects completed the 12 week follow-up.
The primary safety endpoint was the incidence of unanticipated adverse device effects. Clinical safety assessment showed anticipated side-effects. There were 4 patients with prolonged numbness lasting greater than 12 weeks. No unanticipated adverse device effects, or serious device or procedure-related adverse effects occurred. All device- and/or procedure-related adverse events have resolved spontaneously.
The primary efficacy endpoint involved independent panel review of pre- and 12-Week post-treatment photographs of the treatment area for discernible fat layer reduction. The per protocol population consisted of all the treated subjects followed for 12 weeks with weight change of no more than 5% of total body weight at the time the 12 week images were taken. For the per protocol population, the correct baseline photograph identification rate by the independent panel reviewers was 85.2% [72.9%, 93.4%].
Further evidence of treatment efficacy is found in the data from ultrasound measurements of fat reduction at the treated areas, with significant reduction in the fat layer (0.32 cm) from baseline to 12 weeks post-treatment.
The secondary efficacy endpoint for subject satisfaction was assessed by an IRB-approved questionnaire administered at 12 weeks post-treatment. 72.41% of the subjects found the procedure to be comfortable to very comfortable, and 63.3% of the subjects reported that they would recommend the procedure to a friend.
| Study Design | Prospective, multicenter, non-randomized, interventional cohort study |
|--------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Sample Size | 30 subjects treated on both upper arms (60 treatments total) across two clinical sites |
| Principal Eligibility Criteria | Clearly visible fat sufficient for treatment on the upper arm No weight change exceeding 5% in the preceding month Male or female subjects between 22 and 65 years of age |
| Follow up Intervals | 1 week, 4 weeks, and 12 weeks |
| Endpoints | Primary endpoints: Safety endpoint – Rate of unanticipated adverse device effects (UADE). |
The study design and results are summarized in the table below:
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| | Efficacy endpoint: Correct identification pf pre-treatment vs 12 Week post-treatment images by at least two out of three blinded, independent reviewers Secondary endpoints: Subject satisfaction as assessed by questionnaire administered at 12 weeks post-treatment Change in ultrasound-measured upper arm fat from pre-treatment to 12 weeks post-treatment |
|-----------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Effectiveness Results | The per protocol population consisted of all the treated subjects followed for 12 weeks with weight change of no more than 5% of total body weight at the time the 12 week images were taken. For the per protocol population, the correct baseline photograph identification rate by the independent panel reviewers was 85.2% [72.9%, 93.4%].<br><br>Data from ultrasound measurements showed significant reduction in the fat layer (0.32 cm) from baseline to 12 weeks post-treatment.<br><br>Subject satisfaction: 72.41% of the subjects found the procedure to be comfortable to very comfortable, and 63.3% of the subjects reported that they would recommend the procedure to a friend. |
| Safety Results | Clinical safety assessment showed anticipated side-effects. There were 4 patients with prolonged numbness lasting greater than 12 weeks. All adverse events have resolved. No unanticipated adverse device effects, or serious device or procedure-related adverse effects occurred. All device- and/or procedure-related adverse events have resolved spontaneously. |
This clinical investigation demonstrates that use of the ZELTIQ CoolSculpting System can safely and effectively induce cold-assisted lipolysis as the predicate device.
## CONCLUSION:
Testing of the CoolSculpting System, which includes the CoolAdvantage applicator, demonstrated that the device performs as intended. As such, the CoolSculpting System with CoolAdvantage applicator is substantially equivalent to 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.