LifeSignals WiPoint Biosensor_iOS Receiver_App System (LifeSignals WiPatch & WiApp System)
K172011 · Hmicro, Inc. · DRG · Jun 14, 2018 · Cardiovascular
Device Facts
Record ID
K172011
Device Name
LifeSignals WiPoint Biosensor_iOS Receiver_App System (LifeSignals WiPatch & WiApp System)
Applicant
Hmicro, Inc.
Product Code
DRG · Cardiovascular
Decision Date
Jun 14, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2910
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
The LifeSignals WiPatch & WiApp system is intended for spot check and short-term monitoring of ECG & heart rate of patients at rest or patients who can be transported within the range of the antenna network. The WiPatch & WiApp system has visual and audio alarms to alert clinical personnel when heart rate falls outside the set limits. The device is intended for use on general care patients of 18 years or older. The device is not intended for use on critical care patients. The LifeSignals WiPatch & WiApp System is contraindicated for use on patients with active implantable medical devices such as pacemakers, implanted cardioverter defibrillators (ICD) and left ventricular assist devices (LVAD); for use in a magnetic resonance (MR) environment; for use during surgical procedures when electro-surgical equipment is operational.
Device Story
System comprises disposable wireless ECG patch (WiPatch), iOS-based receiver app (WiApp), and standard wireless access point. WiPatch attaches to upper left chest; acquires two-channel ECG signals; performs initial pre-processing; transmits data via 802.11b (2.4 GHz) to WiApp. WiApp runs on commercial iOS tablets (iPad/iPad Air); displays real-time ECG waveforms and heart rate; provides visual/audio alarms for heart rate limits, lead-off, low battery, or connection loss. Used in healthcare facilities by clinical personnel for general care monitoring. Benefits include continuous, wireless patient monitoring without tethering, facilitating patient mobility within facility range.
Clinical Evidence
Non-randomized, self-control comparative clinical study validated heart rate accuracy and on-body adhesion for wear duration. Heart rate accuracy on simulator study was +/- 3 BPM or better for 100% of data; on-body performance study was +/- 3 BPM or better for 97% of data.
Technological Characteristics
Wireless ECG patch with 4 integrated adhesive electrodes. Powered by two zinc-air coin cell batteries (up to 72-hour life). Connectivity via 802.11b (2.4 GHz) to standard wireless access point. Receiver platform: commercial iOS tablet. Standards: ISO 10993-1/5/10 (biocompatibility), IEC 60601-1, IEC 60601-2-27, IEC 60601-1-8, ANSI/AAMI/EC12, IEC 60086-5 (battery), IEC 62304 (software), IEC 62366 (usability).
Indications for Use
Indicated for spot check and short-term ECG and heart rate monitoring of general care patients aged 18 years or older at rest or during transport within antenna network range. Contraindicated for patients with active implantable devices (pacemakers, ICDs, LVADs), use in MR environments, or during use of electro-surgical equipment.
Regulatory Classification
Identification
A radiofrequency physiological signal transmitter and receiver is a device used to condition a physiological signal so that it can be transmitted via radiofrequency from one location to another, e.g., a central monitoring station. The received signal is reconditioned by the device into its original format so that it can be displayed.
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June 14, 2018
LifeSignals, Inc. for HMicro, Inc. % Saravanan Balasubramanian Principal Consultant LifeSignals, Inc. 39355 California St., Ste. 305 Fremont, CA 94538
Re: K172011
LifeSignals WiPoint Biosensor iOS Receiver App System (LifeSignals WiPatch & Trade/Device Name: WiApp System) Regulation Number: 21 CFR 870.2910 Regulation Name: Radiofrequency physiological signal transmitter and receiver Regulatory Class: Class II Product Codes: DRG, DRX, DRT Dated: June 1, 2018 Received: June 4, 2018
Dear Saravanan Balasubramanian:
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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
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For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice
(https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn
(http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website
(http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
M.A. Willemsen
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
### 510(k) Number (if known) K172011
### Device Name
LifeSignals WiPoint Biosensor iOS Receiver App System (LifeSignals WiPatch & WiApp System)
Indications for Use (Describe)
The LifeSignals WiPatch & WiApp system is intended for spot check and short-term monitoring of ECG & heart rate of patients at rest or patients who can be transported within the range of the antenna network. The WiPatch & WiApp system has visual and audio alarms to alert clinical personnel when trate falls outside the set limits. The device is intended for use on general care patients of 18 years or older. The device is not intended for use on critical care patients.
The LifeSignals WiPatch & WiApp System is contraindicated for use on patients with active implantable medical devices such as pacemakers, implanted cardioverter defibrillator (ICD) & left ventricular assist devices (LVAD); for use in a magnetic resonance (MR) environment; for use during surgical procedures when electro-surgical equipment is operational.
| Type of Use (Select one or both, as applicable) |
|------------------------------------------------------------------------------------------------|
| <span style="text-decoration: overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) |
| □ Over-The-Counter Use (21 CFR 801 Subpart C) |
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K172011
Image /page/3/Picture/1 description: The image shows the logo for LifeSignals. The logo consists of a blue square with a white waveform inside, followed by the word "LifeSignals" in a blue, sans-serif font. The waveform is a stylized representation of a signal, possibly indicating the company's focus on monitoring or analyzing life signals. The font used for "LifeSignals" is modern and clean, contributing to the overall professional and technological feel of the logo.
## 510(k) Summary for LifeSignals WiPoint Biosensor_iOS Receiver_App System
| 1. Company name: | LifeSignals, Inc. |
|------------------|-----------------------------------------------------------------------------------------------------------------|
| Contact: | Saravanan Balasubramanian, Principal Consultant<br>Email: saravanan@lifesignals.com<br>Tel: 510.770.6412 Ext. 4 |
- 2. Date prepared: June 11, 2018
- 3.
ကံ Device
| Trade Name: | LifeSignals WiPoint Biosensor_iOS Receiver_App System |
|--------------|-----------------------------------------------------------|
| Model Name: | LifeSignals WiPatch & WiApp System |
| Common Name: | Monitor, cardiac (incl. cardio-tachometer and rate alarm) |
## 4. Classification
| Device Panel | Regulation<br>Classification | Product<br>Code | Description |
|----------------|------------------------------|-----------------|-------------------------------------------------------------|
| Cardiovascular | 21 CFR 870.2910<br>Class II | DRG | RF physiological signal<br>transmitter and receiver |
| Cardiovascular | 21 CFR 870.2360<br>Class II | DRX | Electrocardiograph electrode |
| Cardiovascular | 21 CFR 870.2300<br>Class II | DRT | Monitor, cardiac (incl. cardio-<br>tachometer & rate alarm) |
#### 5. Predicate Device
Vios Monitoring System (K150992)
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#### 6. Intended Use
The LifeSignals WiPatch & WiApp system is intended for spot check and short-term monitoring of ECG & heart rate of patients at rest or patients who can be transported within the range of the antenna network. The WiPatch & WiApp system has visual and audio alarms to alert clinical personnel when heart rate falls outside the set limits. The device is intended for use on general care patients of 18 years or older. The device is not intended for use on critical care patients
The LifeSignals WiPatch & WiApp System is contraindicated for use on patients with active implantable medical devices such as pacemakers, implanted cardioverter defibrillators (ICD) and left ventricular assist devices (LVAD); for use in a magnetic resonance (MR) environment; for use during surgical procedures when electro-surgical equipment is operational.
#### Device description 7.
Image /page/4/Picture/7 description: The image shows a WiPatch device, a Wi-Fi access point, and an iPad installed with WiApp software. The WiPatch device is a small, white, flower-shaped device with several sensors on its surface. The Wi-Fi access point is a blue tower with a circular antenna on top. The iPad is showing a graph of data collected by the WiPatch device. The image suggests that the WiPatch device is used to collect data, which is then transmitted wirelessly to the iPad for analysis.
WiPatch
Image /page/4/Figure/9 description: This image is a title for a figure. The title says "Figure -1 Illustration of WiPatch and WiApp System". The title is written in a bold, sans-serif font. The title is centered on the image.
The LifeSignals WiPatch & WiApp System consists of the 1) LifeSignals WiPatch 2) LifeSignals WiApp System and 3) Access Point as described below.
### The LifeSignals WiPatch:
- . is a wireless ECG patch that--when attached to the upper left chest of a patient -continuously acquires physiological signals and transmits these signals wirelessly to any compatible receiver.
- is disposable and integrated with four adhesive electrodes for body interface.
- acquires two channels of electrocardiograph (ECG-A and ECG-B) signals
- transmits acquired signals after initial pre-processing to a compatible receiver wirelessly using the 802.11b communication protocol (2.4 GHz).
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Image /page/5/Picture/1 description: The image shows the logo for LifeSignals. The logo consists of a blue square with a stylized waveform inside, followed by the word "LifeSignals" in a sans-serif font, also in blue. The waveform graphic is composed of several vertical lines of varying heights, resembling a signal or sound wave.
- is powered by two-coin cell batteries (zinc air) with an operating life up to 72 hours.
- . has an integrated switch to power it on, and has bi-color LED indicators to indicate the communication status with the receiver.
### The LifeSignals WiApp System:
- . consists of a LifeSignals WiApp Software App (WiApp SW), and a compatible commercial iOS device (iPad, iPad 2, iPad Air or iPad Air 2)
- . software, when installed on a compatible hardware, establishes a connection to any one of the LifeSignals WiPatches connected to the same wireless network/Access Point through a pairing process.
- receives the transmitted signals from the paired WiPatch wirelessly, processes the signals and displays heart rate, ECG (ECG-A and ECG-B) waveforms on its LCD display for monitoring purposes by trained clinical personnel.
- . has audio and visual alarms to alert clinical personnel when heart rate of a patient is outside the set limits, lead off, when the battery is low (either the WiPatch or the WiApp System - iPad), or when there is a loss of communication link between the WiApp System and the WiPatch.
## Access Point:
An access point is a commercially available hardware device (a.k.a wireless router) that allows wireless capable devices connect through a wireless standard (e.g. 802.11b). LifeSignals WiPatch and WiApp system communicate through an access point.
#### Summary Table of Substantial Equivalence 8.
Table 12-1: Table of Comparison
| Comparison | WiPatch & WiApp System<br>(Subject) | VIOS Monitoring<br>System<br>(Predicate) |
|-------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) | K172011 | K150992 |
| Sponsor | LifeSignals, Inc.<br>Fremont, CA | Vios Medical, Inc.<br>St. Paul, MN |
| Comparison | WiPatch & WiApp System<br>(Subject) | VIOS Monitoring<br>System<br>(Predicate) |
| Intended use/Indications for use | The LifeSignals WiPatch & WiApp system is intended for spot check and short-term monitoring of ECG & heart rate of patients at rest or patients who can be transported within the range of the antenna network. The WiPatch & WiApp system has visual and audio alarms to alert clinical personnel when heart rate falls outside the set limits. The device is intended for use on general care patients of 18 years or older. The device is not intended for use on critical care patients. | The Vios Monitoring System (VMS) is intended for use by medically qualified personnel for physiological and vital signs monitoring of adult (18+) patients in healthcare facilities. It is indicated for use in monitoring of ECG, heart rate, pulse rate, functional oxygen saturation of arterial hemoglobin, and axillary temperature. |
| Intended Population | Adults ≥ 18 | Adults ≥ 18 |
| Intended Use Environment | Healthcare facility | Healthcare facility or clinical pharmacological unit |
| Heart Rate | Yes | Yes |
| Temperature | No | Yes |
| ECG Display | ECG-A and ECG-B | Channel I and II |
| SpO2 | No | Optional |
| Pulse Rate | No | Optional |
| NIBP | No | Optional |
| Sensor | Wireless patch design—<br>RF/Wi-Fi 2.4 GHz 802.11b | Wireless patch design—<br>RF/Bluetooth 2.4 GHz |
| Wear duration | 72 hours (maximum) | |
| Hardware Platform | Standard commercial iOS tablet (iPad, iPad2, iPad Air, iPad Air2) | Standard commercial IT equipment |
| TECHNICAL SPECIFICATION (HEART RATE) | | |
| Display Range | 30 to 250 BPM | |
| Accuracy | +/- 3 BPM Note 1 | |
| Resolution | 1 BPM | |
| Comparison | WiPatch & WiApp System<br>(Subject) | VIOS Monitoring System<br>(Predicate) |
| ALARMS | | |
| Vital signs parameter | Visual and audio | Visual and audio |
| Technical alarms – System Low<br>Battery, Patch Low Battery, Lead<br>Off, Connection Lost | Visual and audio | Visual and audio |
| Power (sensor module) | Two zinc air coin cell<br>batteries | Lithium battery |
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Image /page/6/Picture/1 description: The image shows the logo for LifeSignals. The logo consists of a blue square with white waveforms inside, followed by the word "LifeSignals" in a stylized blue font. The waveforms in the square represent the "signals" aspect of the company's name, while the text clearly identifies the brand.
# Table 12-1: Table of Comparison
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Image /page/7/Picture/1 description: The image shows the logo for LifeSignals. The logo consists of a blue square with white sound wave-like lines inside, followed by the word "LifeSignals" in a blue, sans-serif font. The logo is clean and modern, and the sound wave graphic suggests a connection to health monitoring or communication.
### Table 12-1: Table of Comparison
Note 1:
Heart Rate accuracy on Simulator study is +/- 3 BPM or better for 100% of data.
Heart Rate accuracy on-body performance study is +/- 3 BPM or better for 97% of data
Minor differences are: 1) the predicate device has an ability to display additional parameters, including SpO2 (optional), pulse rate (optional) and temperature, while the subject device (WiPatch & WiApp System) does not support or display these additional parameters - SpO2, pulse rate and temperature; 2) the subject device is battery powered with two zinc air coin cell batteries while the predicate device is powered with a lithium battery.
### 9. Summary of Performance Testing
The following non-clinical testing has been completed to demonstrate safety and effectiveness of the LifeSignals WiPatch & WiApp System: -
- Bio-compatibility testing per ISO 10993-1, ISO 10993-5 and ISO 10993-10:2003 ●
- . Safety and performance testing per IEC 60601-1:2012, AAMI/ANSI/EC 60601-1-2:2007/(R)2012, IEC 60601-2-27:2011, ANSI/AAMI/EC12:2000/r2015, IEC 60601-1-8:2012, 47 CFR 15 FCC Part 15C, and ANSI C63.27:2017
- Battery safety testing as per IEC 60086-5:2016
- Design verification and validation: Software Unit(s) verification and Software System verification & validation as per IEC 62304:2015 / USFDA Guidance-General Principles of Software validation; Wireless performance (QoS); Product Design verification.
- . Usability engineering as per IEC 62366:2007 +A1:2014
In addition, performance data for heart rate accuracy and on-body adhesion for determination of wear duration was validated using a non-randomized, self-control comparative clinical study.
### 10. Conclusion
The LifeSignals WiPoint Biosensor iOS Receiver App System (WiPatch & WiApp System) is substantially equivalent with respect to safety and effectiveness to the legally marketed predicate device for its intended use.
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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.