K170903 · Djo, LLC · NGX · Jun 19, 2017 · Physical Medicine
Device Facts
Record ID
K170903
Device Name
Compex Wireless USA
Applicant
Djo, LLC
Product Code
NGX · Physical Medicine
Decision Date
Jun 19, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5850
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Compex Wireless USA is an Over-The-Counter device intended to stimulate healthy muscles in order to improve or facilitate muscle performance. It is to be used by adults only. The Compex Wireless USA is not intended for adjunctive therapy in the treatment of medical diseases and conditions of any kind. None of the Compex Wireless USA stimulation programs are designed for injured or disease afflicted muscles. Its use on such muscles is contraindicated. The work imposed on the Compex Wireless USA programs is definitely not suitable for rehabilitation and physiotherapy. The Compex Wireless USA electrical impulses allow the triggering of action potentials on motor nerves (excitations). These excitations of motoneurones are transmitted to the muscle fibers via the motor endplate where they generate mechanical muscle fiber responses that correspond to muscle work. Depending on the parameters of the electrical impulses (pulse frequency, duration of contraction, duration of rest, total session duration), different types of muscle work can be imposed on the stimulated muscles. The Compex Wireless USA may therefore be considered a technique of muscle training. The Compex Wireless USA TENS is used for: • temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities. · the symptomatic relief and management of chronic, intractable pain associated with arthritis.
Device Story
Compex Wireless USA is an OTC neuromuscular electrical stimulator (NMES) and transcutaneous electrical nerve stimulator (TENS). System includes a remote control, 4 wireless stimulation modules, and electrodes. Remote communicates with modules via 2.4 GHz proprietary RF protocol. Device delivers electrical impulses to motor nerves to induce muscle contractions (NMES) or sensory nerves to block pain signals (TENS). User selects programs (e.g., Endurance, Strength, Recovery, TENS) via remote interface. Modules are powered by rechargeable LiPo batteries. Used by adults to improve muscle performance or manage pain. Output intensity controlled by user. Benefits include muscle conditioning and pain relief without clinical intervention.
Clinical Evidence
No clinical data. Evidence consists of bench testing, electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), wireless coexistence, and usability/human factors testing.
Technological Characteristics
Battery-powered (LiPo 3.7V) handheld stimulator. 4 wireless modules (2.4 GHz ISM band). Symmetrical biphasic (NMES) and balanced asymmetrical biphasic (TENS) waveforms. Regulated current output. Materials: proprietary snap gel electrodes. Standards: AAMI/ANSI ES60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60601-1-11, IEC 60601-2-10, ISO 14971, IEC 62304.
Indications for Use
Indicated for healthy adults to improve or facilitate muscle performance via NMES. Also indicated for TENS use for temporary relief of pain associated with sore/aching muscles from exercise or daily activities, and symptomatic relief/management of chronic, intractable pain associated with arthritis. Contraindicated for injured or disease-afflicted muscles; not for rehabilitation or physiotherapy.
Regulatory Classification
Identification
A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 12, 2017
DJO, LLC Neeta Sharma Sr. Director, Regulatory Affairs 1430 Decision Street Vista, California 92081
Re: K170903
Trade/Device Name: Compex Wireless USA Regulation Number: 21 CFR 890.5850 Regulation Name: Powered Muscle Stimulator Regulatory Class: Class II Product Code: NGX, NUH, NYN Dated: March 27, 2017 Received: March 28, 2017
Dear Neeta Sharma:
This letter corrects our substantially equivalent letter of June 19, 2017.
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
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CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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" (21CFR 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,
# Michael J. Hoffmann -S
Carlos L. Peña. PhD. MS for 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) K170903
Device Name Compex Wireless USA
#### Indications for Use (Describe)
The Compex Wireless USA is an Over-The-Counter device intended to stimulate healthy muscles in order to improve or facilitate muscle performance. It is to be used by adults only.
The Compex Wireless USA is not intended for adjunctive therapy in the treatment of medical diseases and conditions of any kind. None of the Compex Wireless USA stimulation programs are designed for injured or disease afflicted muscles. Its use on such muscles is contraindicated. The work imposed on the Compex Wireless USA programs is definitely not suitable for rehabilitation and physiotherapy. The Compex Wireless USA electrical impulses allow the triggering of action potentials on motor nerves (excitations). These excitations of motoneurones are transmitted to the muscle fibers via the motor endplate where they generate mechanical muscle fiber responses that correspond to muscle work. Depending on the parameters of the electrical impulses (pulse frequency, duration of contraction, duration of rest, total session duration), different types of muscle work can be imposed on the stimulated muscles. The Compex Wireless USA may therefore be considered a technique of muscle training.
The Compex Wireless USA TENS is used for:
• temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities.
· the symptomatic relief and management of chronic, intractable pain associated with arthritis.
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------|-----------------------------------------------------------|
| <span></span> Prescription Use (Part 21 CER 801 Subpart D) | <span></span> Over-The-Counter Use (21 CER 801 Subpart C) |
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## 510(k) Summary
This 510(k) summary of safety and effectiveness is being submitted in accordance with the requirements of 21 CFR 807.92.
The assigned 510(k) number is K170903.
| Submitted by: | DJO, LLC<br>1430 Decision Street<br>Vista, CA 92081 |
|------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Neeta Sharma<br>Sr. Director, Regulatory Affairs<br>760-734-3551 |
| Date Summary Prepared: | March 27, 2017 |
| Trade Name: | Compex® Wireless USA |
| Classification Name: | Powered muscle stimulator (21 CFR 890.5850)<br>Stimulator, Nerve, Transcutaneous (21 CFR 882.5890) |
| Product Code: | Powered Muscle Stimulator, For Muscle Conditioning – 21 CFR 890.5850<br>Product Code NGX; Review Panel: Physical Medicine<br>Stimulator, Nerve, Transcutaneous, Over-The-Counter- 21 CFR 882.5890;<br>Product Code NUH; Review Panel: Neurology<br>Stimulator, Electrical, Transcutaneous, For Arthritis 21 CFR 890.5850;<br>Product Code NYN (subsequent code); Review Panel: Neurology |
| Regulatory Class: | Class II |
| Predicate Device: | Compex Wireless USA (K143551)<br>Strive (K153704) |
#### Device Description:
The Compex Wireless USA employs programs for neuromuscular electrical stimulation (NMES) and transcutaneous electrical stimulation (TENS).
TENS (Transcutaneous Electrical Nerve Stimulation) and NMES (NeuroMuscular Electrical Stimulation) target different nerve groups of the body. TENS is specifically targets the sensory nerves, which are responsible for sending pain signals to the brain. NMES targets the muscle itself, specifically through the motor nerves. This allows the NMES machine to create a muscle contraction to recruit more muscle fibers when training; warming up or recovering.
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The Compex Wireless USA device stimulates nerve fibers by means of electrical impulses transmitted by electrodes. The electrical pulses generated by the Compex Wireless USA stimulate motor nerves to stimulate a muscular response. Depending on the parameters of the electrical impulses (pulse frequency, duration of contraction, duration of rest, and total session duration), different types of muscle work can be imposed on the stimulated muscles. The Compex Wireless USA may therefore be considered a technique of muscle training.
The device system is made up of a remote control. 4 stimulation modules, and electrodes, which are stored and shipped within the docking station which is used to recharge the remote and the modules. The docking station is powered by an AC-DC adapter.
The remote control is the interface between the stimulation modules and the user. It sends and receives information to and from the modules via a wireless network. The remote control allows the user to navigate through the user interface (UI), select stimulation program or objectives, set desired options and control the four (4) module intensities independently. The remote control is powered by a rechargeable battery.
The Compex Wireless USA stimulation module set is composed of 4 independent stimulation modules that are controlled via the remote control by a wireless connection. Each module is composed of two "pods" (1 battery "pod" and one stimulation "pod") linked by an electrical connection (cable). Two proprietary Compex standard snap gel electrodes are also needed to connect each "pod" to the body. The modules are powered by a Lithium Polymer (LiPo) rechargeable 3.7[V] /> 450 [mAh] battery.
The wireless protocol of the Compex Wireless USA Device is a proprietary design of a Radio-Frequency protocol operating the 2.4 GHz ISM band.
It is used to 1) Send particular information from remote control to stimulation modules (stimulation settings)
2) Send particular information from stimulation modules to remote control. like current stimulation level and stimulation module subsystem status,
3) Transfer binary data to stimulation modules, and
4) Allow synchronization from stimulation modules to remote control clocks.
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## Indications for Use:
The Compex Wireless USA is an Over-The-Counter device intended to stimulate healthy muscles in order to improve or facilitate muscle performance. It is to be used by adults only.
The Compex Wireless USA is not intended for adjunctive therapy in the treatment of medical diseases and conditions of any kind. None of the Compex Wireless USA stimulation programs are designed for injured or disease afflicted muscles. Its use on such muscles is contraindicated. The work imposed on the muscles by the Compex Wireless USA programs is definitely not suitable for rehabilitation and physiotherapy.
The Compex Wireless USA electrical impulses allow the triggering of action potentials on motoneurones of motor nerves (excitations). These excitations of motoneurones are transmitted to the muscle fibers via the motor endplate where they generate mechanical muscle fiber responses that correspond to muscle work. Depending on the parameters of the electrical impulses (pulse frequency, duration of contraction. duration of rest, total session duration), different types of muscle work can be imposed on the stimulated muscles. The Compex Wireless USA may therefore be considered a technique of muscle training.
Compex Wireless USA as a TENS device is used for:
- temporary relief of pain associated with sore and aching muscles due to strain from exercise or . normal household and work activities.
- the symptomatic relief and management of chronic, intractable pain and relief of pain associated ● with arthritis.
#### Programs:
Muscle Stimulation Training Programs: The Compex Wireless USA provides four muscle stimulation training programs: Endurance, Strength, and Explosive Strength. They correspond to the type of muscle performance the athlete wishes to improve or maintain. Each of the four training programs offers five different working levels that enable the amount of work to be gradually increased.
Specialized Muscle Training Programs: The Compex Wireless USA also offers five special muscle training programs: Potentiation, Training Recovery, Competition Recovery, Muscle Relaxation, and Pre-Warmup. Their objective is to prepare muscles for explosive motions or to facilitate recovery after active muscle training and competition.
TENS Program: Pain Relief TENS program is to alleviate all types of localized pain. Please note that Pain relief TENS was called "Frequency Modulation (FM)" in the predicate device-Strive.
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# Programs Specification
| Program name | Frequency [Hz] | Contraction duration [s] |
|-------------------------|---------------------------|--------------------------|
| Training recovery | From 1 to 9 Hz continuous | |
| Potentiation | From 1 to 2 Hz continuous | |
| Competition<br>Recovery | From 1 to 5 Hz continuous | |
| Pre Warmup | 8 Hz continuous | |
| Endurance | 10 | 9 |
| Explosive strength | 104 | 4.25 |
| Resistance | 50 | 9.25 |
| Strength | 75 | 6.25 |
| Muscle Relaxation | 1Hz continuous | |
| Pain Relief TENS | From 90 to 120 Hz | |
## Comparison to the Predicate Device:
The similarities and differences between the technology and specifications of the subject device and its predicate devices are reflected below:
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## Basic Device Characteristics – Comparison with Predicate Devices Device Comparison Tables
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
|-----------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------|
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| 510(k) Number | Pending | K143551 | K153704 | |
| Device Name, Model | Compex® Wireless USA | Compex® Wireless USA | Strive | |
| Manufacturer | DJO LLC | DJO LLC | DJO LLC | Similar |
| Prescription/OTC | OTC | OTC | OTC | Similar |
| Type of device | A non-implantable, battery powered, hand held, electrical stimulator, used for medical purposes through applying an electrical current to electrodes on a patient's skin | A non-implantable, battery powered, hand held, electrical stimulator, used for medical purposes through applying an electrical current to electrodes on a patient's skin | A non-implantable, battery powered, hand held, electrical stimulator, used for medical purposes through applying an electrical current to electrodes on a patient's skin | Similar |
| Connection of device to electrodes | Lead wires<br>Stimulation Module is directly connected to the custom Compex female SNAP assembled in the electrode. User Interface (LCD and buttons) is physically separated (Remote Control) and communicates wirelessly with up to four (4) Stimulation Modules | Lead wires<br>Stimulation Module is directly connected to the custom Compex female SNAP assembled in the electrode. User Interface (LCD and buttons) is physically separated (Remote Control) and communicates wirelessly with up to four (4) Stimulation | Lead wires | Similar |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| | Stimulation safety remains<br>fully managed by<br>Stimulation Module<br>electronic circuit itself. | Modules. Stimulation<br>safety remains fully<br>managed by Stimulation<br>Module electronic<br>circuit itself. | | |
| Power Sources | Remote: : Lithium<br>Polymer (LiPo)<br>rechargeable 3.7[V] / ≥<br>1500[mAh]<br>Stimulation Modules:<br>Lithium Polymer (LiPo)<br>rechargeable 3.7[V] / ≥<br>450[mAh] | Remote: : Lithium<br>Polymer (LiPo)<br>rechargeable 3.7[V] / ≥<br>1500[mAh]<br>Stimulation Modules:<br>Lithium Polymer<br>(LiPo) rechargeable<br>3.7[V] / ≥ 450[mAh] | LiPo 250 [mAh] (3.7[V]),<br>not removable | Same as Compex<br>Wireless USA<br>Different from<br>Strive |
| Method of line current<br>isolation | N/A (battery operated<br>device) | N/A (battery operated<br>device) | N/A (battery operated<br>device) | Similar |
| Patient Leakage Current | N/A (battery operated<br>device) | N/A (battery<br>operated device) | N/A (battery<br>operated device) | Similar |
| • Normal condition | N/A (battery operated<br>device) | N/A (battery<br>operated device) | N/A (battery<br>operated device) | Similar |
| • Single fault<br>condition | N/A (battery operated<br>device) | N/A (battery<br>operated device) | N/A (battery<br>operated device) | Similar |
| Number of Output Modes | Two (NMES/TENS) | One (NMES) | Two (2 x TENS) | Different |
| Number of Output Channels | Four | Four | 1, split | Same as Compex<br>Wireless USA<br>Different from<br>Strive |
| Synchronous or | Synchronous, but | Synchronous, but | N/A | Same as Compex |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| Alternating? | never 2 channels<br>activated at the same<br>time | never 2 channels<br>activated at the<br>same time | | Wireless USA |
| - Method of Channel<br>Isolation | Each channel is the<br>middle of a H- Bridge.<br>Except when it is<br>activated, each channel is<br>always in high<br>impedance state. | Each channel is the<br>middle of a H-<br>Bridge. Except when<br>it is activated, each<br>channel is always in<br>high impedance state. | N/A | Same as Compex<br>Wireless USA |
| Regulated Current or<br>Regulated Voltage? | Regulated current (all<br>channels) | Regulated current (all<br>channels) | Regulated Current | Similar |
| Software/Firmware/Micropro<br>cessor Control? | Yes | Yes | Yes | Similar |
| Automatic Overload Trip? | Yes | Yes | No | Same as Compex<br>Wireless USA |
| Automatic No-Load Trip? | Yes | Yes | Yes | Similar |
| Automatic Shut Off? | "On/Off" switch | "On/Off" switch | "On/Off" switch | Similar |
| Patient Override Control? | Yes, push on On/Off button<br>directly pause the program | Yes, push on On/Off button<br>directly pause the program | Yes, push on On/Off button<br>directly pause the program | Similar |
| Indicator Display<br>- On/Off Status? | Yes | Yes | Yes | Similar |
| - Low Battery? | Yes | Yes | No | Same as Compex<br>Wireless USA |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/Different |
| Voltage/Current Level? | Yes, unit = [Energy] | Yes, unit = [Energy] | Active/inactive output | Different from Strive<br>Same as Compex Wireless USA |
| Compliance with 21 CFR 898? | Yes | Yes | Yes | Different from Strive<br>Similar |
| Weight | Remote: 110 [g]<br>Stimulation Module:2x60 [g]<br>Docking Station 800 [g] | Remote: 110 [g]<br>Stimulation Module:2x60 [g]<br>Docking Station 800 [g] | 0.99 oz | Same as Compex Wireless USA<br>Different from Strive |
| Waveform (program per program) | -Endurance:<br>Symmetrical Biphasic<br>-Resistance:<br>Symmetrical Biphasic<br>-Strength :<br>Symmetrical Biphasic<br>-Explosive Strength:<br>Symmetrical Biphasic<br>-Potentiation:<br>Symmetrical Biphasic<br>-Training Recovery (same as Active Recovery):<br>Symmetrical Biphasic<br>-Competition | -Endurance:<br>Symmetrical Biphasic<br>-Resistance:<br>Symmetrical Biphasic<br>-Strength : Symmetrical Biphasic<br>-Explosive Strength:<br>Symmetrical Biphasic<br>-Potentiation:<br>Symmetrical Biphasic<br>-Active Recovery:<br>Symmetrical Biphasic<br>-Recovery Plus: | | Same as Compex Wireless USA<br>Different from Strive |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| | Recovery (same as<br>Recovery Plus):<br>Symmetrical Biphasic | Symmetrical<br>Biphasic | | |
| | -Pre-Warmup Program:<br>Symmetrical Biphasic<br>-Muscle Relaxation (same<br>as Massage):<br>Symmetrical Biphasic | -Pre-Warmup Program:<br>Symmetrical Biphasic<br>-Massage:<br>Symmetrical Biphasic | | |
| | -Pain relief TENS (same<br>as FM): Balanced,<br>asymetrical Biphasic | | Balanced, Asymmetrical<br>Biphasic | Same as Strive<br>Different from<br>Compex Sport<br>Plus |
| Shape (program per<br>program) | -Endurance:<br>Rectangular<br>-Resistance:<br>Rectangular<br>-Strength :<br>Rectangular<br>-Explosive Strength:<br>Rectangular<br>-Potentiation:<br>Rectangular<br>-Training Recovery:<br>Rectangular | -Endurance:<br>Rectangular<br>-Resistance:<br>Rectangular<br>-Strength:<br>Rectangular<br>-Explosive Strength:<br>Rectangular<br>-Potentiation:<br>Rectangular<br>-Training Recovery:<br>Rectangular | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| | -Competition<br>Recovery:<br>Rectangular<br>-Pre-Warmup:<br>Rectangular<br>-Muscle Relaxation:<br>Rectangular | - Competition<br>Recovery:<br>Rectangular<br>-Pre-Warmup:<br>Rectangular<br>- Muscle Relaxation:<br>Rectangular | | |
| | -Pain relief TENS (same<br>as FM): | | Square positive pulse,<br>current controlled<br>Logarithmic negative<br>pulse,decrease current | Same as Strive<br>Different from<br>Compex<br>Wireless USA |
| Maximum Output Voltage<br>(± 10%) | Endurance:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | Endurance:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Resistance:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | Resistance:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Strength:<br>60 V @ 500 Ω | Strength:<br>60 V @ 500 Ω | | Same as<br>Compex |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| | 165 V @ 2 kΩ<br>165 V @ 10 kΩ | 165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Wireless USA<br>Different from<br>Strive |
| | Explosive Strength:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | Explosive Strength:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Potentiation:<br>60 V @ 500 Ω<br>152 V @ 2 kΩ<br>136 V @ 10 kΩ | Potentiation:<br>60 V @ 500 Ω<br>152 V @ 2 kΩ<br>136 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Training Recovery:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | Training Recovery :<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Competition Recovery:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | CompetitionRecovery:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| Basic Unit Characteristics – Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| | | | | Strive |
| | Pre Warmup<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | Pre Warmup<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Muscle Relaxation:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | Muscle Relaxation:<br>60 V @ 500 Ω<br>165 V @ 2 kΩ<br>165 V @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| Maximum Output Current<br>(± 10%) | Pain Relief TENS:<br>180[V] peak on 10[kΩ]<br>170[V] peak on 2[kΩ]<br>58[V] peak on 500[Ω] | 110[V] peak on 10[kΩ]<br>110[V] peak on 2[kΩ]<br>30[V] peak on 500[Ω] | | Different from<br>Strive and from<br>Compex<br>Wireless USA |
| | Endurance:<br>116 mA @ 500 Ω<br>80 mA @ 2 kΩ<br>15 mA @ 10 kΩ | Endurance:<br>120 mA @ 500 Ω<br>84 mA @ 2 kΩ<br>14 mA @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| Basic Unit Characteristics - Comparison with Predicate Device | | | | |
| Characteristic | New Device | Predicate Device | Predicate Device | Similar/<br>Different |
| | Resistance:<br>116 mA @ 500 Ω<br>80 mA @ 2 kΩ<br>17 mA @ 10 kΩ | Resistance:<br>120 mA @ 500 Ω<br>82 mA @ 2 kΩ<br>17 mA @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Strength:<br>113 mA @ 500 Ω<br>80 mA @ 2 kΩ<br>15 mA @ 10 kΩ | Strength:<br>120 mA @ 500 Ω<br>82 mA @ 2 kΩ<br>18 mA @ 10 kΩ | | Same as<br>Compex<br>Wireless USA<br>Different from<br>Strive |
| | Explosive Strength:<br>81 mA @ 500 Ω<br>81 mA @ 2 kΩ<br>15 mA @ 10 kΩ | Explosive Strength:<br>84 mA @ 500 Ω<br>82 mA @ 2 kΩ<br>18 mA @ 10 kΩ | |…
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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.