K162704 · Micro Therapeutics, Inc. d/b/a ev3 Neurovascular · HCG · Jan 3, 2017 · Neurology
Device Facts
Record ID
K162704
Device Name
Axium Prime Detachable Coil System
Applicant
Micro Therapeutics, Inc. d/b/a ev3 Neurovascular
Product Code
HCG · Neurology
Decision Date
Jan 3, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.5950
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Axium Prime Detachable Coil System is indicated for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities, such as arteriovenous malformations and arteriovenous fistulae. The Axium Prime Detachable Coils are also indicated for arterial and venous embolizations in the peripheral vasculature.
Device Story
Axium Prime Detachable Coil System consists of platinum/tungsten embolization coil attached to composite implant delivery pusher; includes radiopaque positioning marker. Used with hand-held Axium I.D. (Instant Detacher) for coil release. Device navigated through vasculature to target site (intracranial aneurysm or peripheral vessel) by physician; coil deployed to induce embolization. System provides mechanical occlusion of vascular abnormalities. Line extension adds 44 new 3D-configuration models (6-loop design) to existing portfolio. Used in clinical settings by neurovascular specialists/interventionalists. Benefits include improved stability and conformability for aneurysm treatment.
Clinical Evidence
No clinical or animal testing performed. Substantial equivalence supported by non-clinical bench testing (visual/dimensional inspection, deformation force, friction/deliverability, tensile strength, fatigue/knotting, and physician usability testing in tortuous benchtop models) and adoption of existing biocompatibility, sterilization, and shelf-life data from the predicate device.
Indicated for endovascular embolization of intracranial aneurysms, arteriovenous malformations, and arteriovenous fistulae, as well as arterial and venous embolizations in the peripheral vasculature.
Regulatory Classification
Identification
A neurovascular embolization device is an intravascular implant intended to permanently occlude blood flow to cerebral aneurysms and cerebral ateriovenous malformations. This does not include cyanoacrylates and other embolic agents, which act by polymerization or precipitation. Embolization devices used in other vascular applications are also not included in this classification, see § 870.3300.
Special Controls
*Classification.* Class II (special controls.) The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Vascular and Neurovascular Embolization Devices.” For availability of this guidance document, see § 882.1(e).
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 3, 2016
Micro Therapeutics, Inc. d/b/a ev3 Neurovascular Joyce Zhong, PhD, RAC Regulatory Affairs Specialist 9775 Toledo Way Irvine, California 92618
Re: K162704
Trade/Device Name: Axium™ Prime Detachable Coil System Regulation Number: 21 CFR 882.5950 Regulation Name: Neurovascular Embolization Device Regulatory Class: Class II Product Code: HCG, KRD Dated: November 18, 2016 Received: November 21, 2016
Dear Dr. Zhong:
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 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,
William J.
Heetderks -A
Digitally signed by William J. Heetderks
-A
DN: c=US, o=U.S. Government, ou=HHS,
ou=NIH, ou=People,
0.9.2342.19200300.100.1.1=0010149848
, cn=William J. Heetderks -A
Date: 2017.01.03 16:31:53 -05'00'
for Carlos L. Peña, Ph.D., M.S. Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K162704
Device Name Axium Prime Detachable Coil System
#### Indications for Use (Describe)
The Axium Prime Detachable Coil System is indicated for the endovascular embolization of intracranial anewrysms and other neurovascular abnormalities, such as arteriovenous malformations and arteriovenous fistulae. The Axium Prime Detachable Coils are also indicated for arterial and venous embolizations in the peripheral vasculature.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| <div> <span> <span style="font-size: 20px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> <span style="font-size: 20px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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# 510(k) Summary for K162704
| 510(k) Owner: | Micro Therapeutics, Inc. d/b/a ev3 Neurovascular<br>9775 Toledo Way<br>Irvine, CA 92618<br>Establishment Registration No. 2029214 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Joyce Zhong<br>Regulatory Affairs Specialist<br>Telephone: (949) 680-1307<br>E-mail: joyce.zhong@medtronic.com |
| Date Summary<br>Prepared: | December 19, 2016 |
| Trade Name of<br>Device: | Axium™ Prime Detachable Coil System |
| Common Name of<br>Device: | Neurovascular Embolization Device |
| Classification of<br>Device: | 21 CFR 882.5950 – Class II |
| Product Code | HCG and KRD |
| Predicate Device: | Axium™ Detachable Coil System:<br>K151447, cleared July 28, 2015 K133310, cleared January 10, 2014 K081465, cleared August 19, 2008 K060747, cleared April 24, 2007 |
| Performance Data: | The following bench tests were performed to support the addition of<br>new models to the Axium coil portfolio and to establish substantial<br>equivalence to predicate Axium™ Detachable Coil System :<br>Visual and Dimensional Inspection First loop OD post-sterilization Dimensional Inspection Deformation Force Friction in Sheath Friction in Catheter Force Transfer Stretch Resistant Polypropylene Tensile Test Coil Shell Tensile Test Fatigue and Knotting Labeling verification Physician use testing<br>The following testing was adopted from existing test data for currently<br>cleared Axium™ coil sizes: |
- Porque Responsions .
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- Shield Coil Weld ●
- Coil Tensile - Assembly
- Marker Radiopacity ●
- Tip Buckling
- . Detachment Zone Stiffness
- Detachment Reliability
- Kink Resistance
- Hypotube and Weld Tensile Strength ●
- Pusher Elongation
- Pusher Tensile
- Positive Load Indicator Dimension
- Break Indicator Dimension
- Sheath wave-lock .
- Thrombogenicity ●
- MRI Compatibility ●
Sterilization, biocompatibility, packaging and aging data were also adopted from the predicate device as there is no change to the materials or packaging for the addition of these new models.
No clinical or animal testing was performed, as the subject device has a similar safety profile and a similar effectiveness profile when compared to the predicate device. In addition, there is no change in the indications for use or the fundamental scientific technology of the device that would require any additional testing.
Conclusion: The forty-four (44) new Axium™ Prime Detachable Coil System models are substantially equivalent to the currently cleared AxiumTM Detachable Coil System based on the successful completion of nonclinical testing; a thorough assessment of existing test data; as well as identical materials of coil implant construction, principles of operation, packaging and indications for use. The subject device has a similar safety profile and a similar effectiveness profile when compared to the predicate device.
#### Device Description:
The Axium™ Prime Detachable Coil System consists of a platinum/tungsten embolization coil attached to a composite implant delivery pusher with a radiopaque positioning marker and a hand-held Axium™ I.D. (Instant Detacher) which, when activated, detaches the coil from the delivery pusher tip. The Axium™ I.D. (Instant Detacher) is sold separately.
This submission expands Axium™ Detachable Coil (subject device) family by adding forty-four (44) new model numbers to the currently cleared Axium product portfolio (predicate device). These new model numbers come in the 3D configuration only and are a line extension of the currently sold predicate device, ranging in size from 3mm diameter x 6cm length to 25mm diameter x 50cm length. All forty-four (44) new SKUs fall within the currently cleared Axium size range of 1mm diameter x 1cm length to 25mm diameter x 50cm length.
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The subject device was modified to change the 3D loop configuration from a 4-loop configuration to a 6-loop configuration and to slightly increase the primary wire diameter size for the 7 - 10mm and the 12 - 25mm size coils.
All other aspects of the subject device design (materials of construction of the implant coil, principles of operation, packaging, labeling and indications for use) are identical to the predicate device.
### Indications for Use:
The Axium Prime Detachable Coil System is indicated for the endovascular embolization of intracranial aneurysms and other neurovascular abnormalities, such as arteriovenous malformations and arteriovenous fistulae. The Axium Prime Detachable Coils are also indicated for arterial and venous embolizations in the peripheral vasculature.
### Device Comparison:
The table below provides a comparison of the technological characteristics of the subject device and the currently cleared predicate Axium device line.
| | Predicate Device | Subject Device | Rationale for<br>Difference (if<br>applicable) |
|----------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------|------------------------------------------------------------------------------------------------------|
| Characteristics | Axium™ Detachable Coil<br>System (K133310, K081465,<br>K060747, K151447) | Axium™ Prime Detachable<br>Coil System (K162704) | |
| Indication for<br>Use | The Axium Detachable Coil<br>System is indicated for the<br>endovascular embolization of<br>intracranial aneurysms and other<br>neurovascular abnormalities, such<br>as arteriovenous malformations<br>and arteriovenous fistulae. The<br>Axium Detachable Coils are also<br>indicated for arterial and venous<br>embolizations in the peripheral<br>vasculature. | Same* | N/A |
| Method of<br>Supply | Stored within dispenser coil,<br>Tyvek pouch, & shipping carton | Same | N/A |
| Sterilization<br>Method | Ethylene Oxide | Same | N/A |
| Device Size<br>Range<br>(Coil Diameter x<br>Coil Length) | 1mm x 1cm - 25mm x 50cm | 3mm x 6cm - 25mm x 50cm | Subject device size<br>range falls within<br>the currently<br>cleared predicate<br>device size range |
| 3D Loop<br>Configuration | 4 loops | 6 loops | Additional loops<br>provide improved<br>stability |
| Primary wire<br>diameter | 0.0015" for 3-3.5 mm size coils<br>0.0020" for 4-6 mm size coils<br>0.00225" for 7-10mm size coils | same<br>same<br>0.0025" for 7-10mm size coils | Larger wire<br>diameter provide<br>improved stability |
| | 0.00275" for 12-25mm size coils | 0.0030" for 12-25mm size coils | |
| Materials<br>(Implant Coil) | | | |
| Characteristics | Predicate Device | Subject Device | Rationale for Difference (if applicable) |
| | Axium™ Detachable Coil System<br>(K133310, K081465, K060747,<br>K151447) | Axium™ Prime<br>Detachable Coil<br>System (K162704) | |
| Implant Coil<br>Wire | Pt (92%)/ W (8%) | Same | N/A |
| Stretch<br>Resistant<br>Member | Polypropylene | Same | N/A |
| Coil Shell | Pt (92%)/ W (8%) | Same | N/A |
| Detach<br>Subassembly | SS 316LVM | Same | N/A |
| Materials<br>(Implant Delivery Pusher) | | | |
| Characteristics | Predicate Device | Subject Device | Rationale for Difference (if applicable) |
| | Axium™ Detachable Coil System<br>(K133310, K081465, K060747,<br>K151447) | Axium™ Prime<br>Detachable Coil<br>System (K162704) | |
| Unibody | SS 304 | Same | N/A |
| Outer Jacket | PTFE | Same | N/A |
| Marker Coil | Pt (92%)/ W (8%) | Same | N/A |
| Lumen Stop | SS 304 | Same | N/A |
| Inner Liner | PTFE | Same | N/A |
| Coupler Tube | SS 304 | Same | N/A |
| Actuator<br>Interface | SS 304 | Same | N/A |
| Release Wire | SS 304 | Same | N/A |
| Retainer Ring | SS 304 | Same | N/A |
| Break Indicator | PET shrink tubing or Laser mark | PET shrink tubing | N/A |
| Positive Load<br>Indicator | PET shrink tubing or Laser mark | PET shrink tubing | N/A |
| Materials<br>(Introducer sheath) | | | |
| Introducer<br>sheath | Polypropylene/HDPE | Same | N/A |
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*product name has been rebranded to Axium™ Prime, otherwise identical.
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### Sterilization and Shelf Life
The subject device was adopted into the EO sterilization cycle originally cleared under K060747 for the predicate device. The materials of construction of the subject device, packaging and overall manufacturing process are the same to the predicate device. EO residual, bioburden and pyrogen testing were adopted as well for these reasons.
Aging and packaging studies for the predicate device have established the product and packaging remain functional and maintain sterility for 3 years. Aging studies for packaging integrity (per ASTM F2096-11) and conditioning (ASTM-4169, ISTA-2A) and device functionality were adopted from the predicate device and met all acceptance criteria. The materials of implant coil construction, manufacturing process, and packaging of the new line extension models of the subject device are identical to the predicate device.
### Biocompatibility
Biocompatibility data for the subject device has been adopted from the predicate device. A summary of adopted biocompatibility tests is provided in the table below.
| Test | Test method | Results | Conclusion |
|----------------------------|---------------------------------------------------------|---------|----------------------------------------------------------|
| Cytotoxicity | MEM Elution Using L-929 Mouse<br>Fibroblast Cells | Pass | Non-cytotoxic |
| Sensitization | Guinea Pig Maximization<br>Sensitization | Pass | A Grade I sensitization<br>rate is not significant |
| Irritation | Intracutaneous Irritation Test | Pass | Negligible irritant |
| Acute Systemic<br>Toxicity | Acute Systemic Injection Test | Pass | No significant<br>difference comparing<br>to the control |
| Genotoxicity | Materials Mediated Rabbit Pyrogen | Pass | Non-pyrogenic |
| | Bacterial Mutagenicity Test (Ames<br>Assay) | Pass | Not mutagenic |
| | In Vitro Mouse Lymphoma Assay | Pass | Not mutagenic |
| | Chromosomal Aberration Assay | Pass | Non-clastogenic |
| Hemo-<br>compatibility | Thrombosis (In Vivo) - Dog (4hr) | Pass | Insignificant<br>thrombosis |
| | Lee & White Clotting<br>Time/Coagulation | Pass | Not significant<br>different comparing to<br>controls |
| | Unactivated Partial Thromboplastin<br>Time (UPTT) | Pass | No significant<br>difference comparing<br>to controls |
| | In Vitro Hemocompatibility<br>(includes Platelet count) | Pass | No adverse effects |
| | Hemolysis (Direct Contact) | Pass | Non-hemolytic |
| | Hemolysis (Extract) | Pass | Non-hemolytic |
| | Complement Activation C3a and | Pass | No difference from |
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| | SC5b-9 Assay | | controls |
|-------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|------|----------------------------------------------------------|
| In Vivo Animal<br>Study (systemic<br>effects – SubAcute<br>/SubChronic) | SubChronic (14-day) Intravenous<br>Toxicity Study in Rats or Mice,<br>with Histopathology | Pass | Non-toxic |
| In Vivo Animal<br>Study (localized<br>effects)<br>Implantation | Intramuscular Implantation Test<br>(Rabbits) with Histopathology - 1<br>wk | Pass | No significant<br>difference comparing<br>to the control |
| | Intramuscular Implantation Test<br>(Rabbits) with Histopathology -<br>4wk | Pass | No significant<br>difference comparing<br>to the control |
| | Intramuscular Implantation Test<br>(Rabbits) with Histopathology -<br>13wk | Pass | No significant<br>difference comparing<br>to the control |
# Performance Data – Bench
A summary of the non-clinical bench testing performed for the subject device is presented in the table below:
| Test | Test Method | Conclusion |
|-----------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|
| Visual and Dimensional<br>Inspection of Coil:<br>• Length<br>• First Loop OD | Dimensions were measured and key<br>characteristics of the implant coil were<br>inspected. | All devices met acceptance<br>criteria. |
| Coil Deformation Force | The first loop is compressed to a<br>deformation distance of 20% of the<br>coil's loop OD. The peak force is<br>recorded. | All devices met acceptance<br>criteria. |
| Ease of Deliverability<br>• Friction Testing<br>• Force Transfer<br>• Fatigue and<br>Knotting | • Peak delivery force was measured<br>through a representative tortuous<br>anatomical model.<br>• The proximal end of the device is<br>advanced until the distal force<br>exceeds a specified value. The force<br>transfer is calculated.<br>• The device is placed inside the<br>microcatheter and advanced until<br>the coil is deployed completely<br>inside the aneurysm model. The<br>device is retracted and the cycle is<br>repeated. After the required<br>number of cycles the device is<br>inspected. | All devices met acceptance<br>criteria. |
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| Test | Test Method | Conclusion |
|-----------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------|
| Detachment<br>Stretch Resistant Polypropylene Tensile test Coil-Coil Shell Tensile Test | The coil is stretched until the stretch resistant member breaks. The peak force result was recorded The primary wire of the coil is stretched until the coil-coil shell weld breaks. The peak force result was recorded | All devices met acceptance criteria. |
| Labeling Verification | Text and format of drawings were visually compared to labeling and packaging product specifications. | All devices met acceptance criteria. |
| Physician Usability Testing | The device was navigated through a tortuous benchtop model and deployed into a simulated silicone aneurysm in order to assess stability, neck coverage, conformability, softness and smoothness of delivery. | All test results met the acceptance criteria. |
### Performance Data – Animal
No animal study was performed as there is no change to the indications for use or the fundamental scientific technology for the new model numbers. Substantial equivalence of the subject device has been established to the predicate device through the results of the bench testing that was performed as well as the testing that was adopted from the predicate device.
#### Performance Testing - Clinical
No clinical study was performed as there is no change to the indications for use or the fundamental scientific technology for the new model numbers. Substantial equivalence of the subject device has been established to the predicate device through the results of the bench testing that was performed as well as the testing that was adopted from 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.