K180146 · Karl Storz Endoscopy America, Inc. · GWG · Apr 17, 2018 · Neurology
Device Facts
Record ID
K180146
Device Name
KARL STORZ ICG Imaging System
Applicant
Karl Storz Endoscopy America, Inc.
Product Code
GWG · Neurology
Decision Date
Apr 17, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1480
Device Class
Class 2
Attributes
Real-World Evidence, Pediatric
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K180146 · Apr 17, 2018
KARL STORZ ICG Imaging System
Karl Storz Endoscopy America, Inc.
Published clinical literature (case series and clinical cohorts)
The sponsor utilized peer-reviewed clinical literature to support the effectiveness of NIR imaging in neuro- and endonasal skull base surgeries and the use of the device in pediatric populations.
Literature review; Clinical case series; Pediatric use; Neuroendoscopy
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Literature review of NIR imaging in neuro/endonasal surgery and pediatric use; Retrospective case series and clinical cohort studies; Study Period: Various (referenced publications 2014-2017)
Adult and pediatric patients undergoing neuro- and endonasal skull base surgery
Not applicable for this study
Evaluation of flap perfusion, differentiation of intracranial tumors, and clinical application in pediatric surgery
Indications for Use
The KARL STORZ ICG Imaging System is intended to provide real-time visible and near-infrared fluorescence imaging.
Device Story
System provides real-time high-definition visible (VIS) and near-infrared (NIR) fluorescence imaging during surgery. Input consists of optical signals captured via HOPKINS ICG/NIR endoscopes or VITOM II ICG/NIR telescope, illuminated by a light source. Signals are processed by the Image1 S Camera Control Unit (CCU) and displayed on a medical-grade HD monitor. Used in OR settings by surgeons to assess blood flow, tissue perfusion, and anatomical structures (e.g., biliary ducts, neuro-structures). NIR imaging is selected by the surgeon to confirm perfusion or visualize specific structures after initial VIS navigation. Output provides visual feedback to surgeons, aiding intraoperative decision-making regarding tissue viability and surgical navigation. Benefits include enhanced visualization of perfusion and critical structures during minimally invasive procedures.
Clinical Evidence
No clinical trials conducted. Evidence consists of published clinical literature supporting the effectiveness of NIR imaging for neuro- and endonasal skull base surgeries and pediatric applications. Bench testing verified design specifications, including color performance, detection linearity, distortion, dynamic range, illumination, resolution, SNR, sensitivity, and depth of field.
Technological Characteristics
Rigid rod-lens endoscopes (4mm, 5mm, 10mm) and VITOM II telescope. Components: camera head (H3Z-FI), fiber-optic light cables, light source, Image1 S CCU. Connectivity: DVI-D or 3G-SDI output to HD monitor. Sterilization: Steam sterilization. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-18, ISO 8600 series, ISO 10993.
Indications for Use
Indicated for minimally invasive surgery in adults and pediatrics, including cranial neurosurgery and endonasal skull base surgery (adults and pediatrics > 6 years), and plastic, micro- and reconstructive surgical procedures. Enables visualization of anatomy using white light and assessment of vessels, blood flow, and tissue perfusion using near-infrared (NIR) imaging with ICG dye. Also indicated for visualization of major extra-hepatic bile ducts (cystic, common bile, common hepatic) as an adjunct to white light and intraoperative cholangiography; not for standalone biliary visualization.
Regulatory Classification
Identification
A neurological endoscope is an instrument with a light source used to view the inside of the ventricles of the brain.
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April 17, 2018
KARL STORZ Endoscopy America, Inc. Winkie Wong Senior Regulatory Affairs Specialist 2151 E. Grand Avenue El Segundo, California 90245
Re: K180146
Trade/Device Name: KARL STORZ ICG Imaging System Regulation Number: 21 CFR 882.1480 Regulation Name: Neurological Endoscope Regulatory Class: Class II Product Code: GWG, OWN Dated: January 16, 2018 Received: January 18, 2018
Dear Ms. Wong:
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.
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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.
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,
# 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) K180146
Device Name KARL STORZ ICG Imaging System
#### Indications for Use (Describe)
The KARL STORZ ICG Imaging System is intended to provide real-time visible (VIS) and near-infrared (NIR) fluorescence imaging.
The KARL STORZ Endoscopic ICG System enables surgeons to perform minimally invasive surgery using standard endoscopic visible light as well as visual assessment of vessels, blood flow and related tissue perfusion, or at least one of the major extra-hepatic bile duct, common bile duct and common hepatic duct), using near infrared imaging. Fluorescence imaging of biliary ducts with the KARL STORZ Endoscopic ICG System is intended for use with standard of care white light and, when indicated, intraoperative cholangiography. The device is not intended for standalone use for biliary duct visualization.
Additionally, the KARL STORZ Endoscopic ICG System enables surgeon to perform minimally invasive cranial neurosurgery in adults and pediatrics and endonasal skull base surgery in adults and pediatrics > 6 years of age using standard endoscopic visible light as well as visual assessment of vessels, blood flow and related tissue perfusion using near infrared imaging.
The KARL STORZ VITOM II ICG System is intended for capturing fluorescent mages for the visual assessment of blood flow, as an adjunctive method for the evaluation of tissue perfusion, and related tissue-transfer circulation in tissue and free flaps used in plastic, micro- and reconstructive surgical procedures. The VITOM II ICG System is intended to provide a magnified view of the surgical field in standard white light.
| Type of Use (Select one or both, as applicable) |
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| <div> <span> <span style="font-size:16px">✘</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> <span style="font-size:16px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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Image /page/3/Picture/0 description: The image contains the logo for Karl Storz Endoskope. The word "STORZ" is in large, bold, blue letters. Below that, the words "KARL STORZ - ENDOSKOPE" are written in smaller, blue letters.
## 510(k) SUMMARY
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of the Safe Medical Devices Act (SMDA) of 1990 and 21 CFR 807.92. All data included in this document is accurate and complete to the best of KSEA's knowledge.
| Applicant: | KARL STORZ Endoscopy-America, Inc<br>2151 E. Grand Avenue<br>EI Segundo, CA 90245 |
|-----------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Winkie Wong<br>Senior Regulatory Affairs Specialist<br>424-218-8379<br>424-218-8519 |
| Date of Preparation: | January 15, 2018 |
| Type of 510(k)<br>Submission: | Traditional |
| Device Identification: | Trade Name: KARL STORZ ICG Imaging System<br>Classification Name: Neurological Endoscope |
| Product Code: | GWG, OWN |
| Regulation: | 21 CFR 876.1480 (Neurological Endoscope) |
| Predicate Device(s): | KARL STORZ ICG Imaging System (K171238) – Primary<br>KSEA Neuroendoscopes and Accessories (K021050) – Secondary<br>**The above predicate has not been subject to any recall** |
| Device Description: | The KARL STORZ ICG Imaging System is used to provide real-<br>time high-definition (HD) endoscopic or telescopic images of<br>visible (VIS) and near-infrared (NIR) indocyanine green (ICG) dye<br>fluorescence during minimally invasive, neuro- and endonasal<br>skull base surgery as well as plastic, micro- and reconstructive<br>surgical procedures in general and pediatric populations. |
| | The overall system includes a 4mm HOPKINS ICG/NIR Endoscope<br>(0°, 30° or 45°) for use in neuro- and endonasal skull base<br>surgery, a 5mm & 10mm HOPKINS ICG/NIR Endoscope (0° or<br>30°) for use in minimally invasive procedures and a VITOM II<br>ICG/NIR Telescope for use in plastic, micro- and reconstructive<br>surgical procedures for VIS and NIR illumination and imaging, a<br>light source with foot switch for emission of VIS and NIR<br>illumination, a color video camera head capable of capturing both<br>VIS and NIR imaging, and a KARL STORZ ICG Kit. Additional<br>accessories used with the KARL STORZ ICG Imaging System<br>include two standards fiber-optic light cables for transmission of<br>VIS and NIR light and the Image1 S Camera Control Unit (CCU).<br>The KARL STORZ ICG Imaging System can be used with any<br>medical grade HD monitor with a DVI-D or 3G-SDI input. |
| | |
| Intended Use; | The KARL STORZ ICG Imaging System is intended to provide real-<br>time visible and near-infrared fluorescence imaging. |
| Indications For Use: | The KARL STORZ Endoscopic ICG System enables surgeons to<br>perform minimally invasive surgery using standard endoscopic<br>visible light as well as visual assessment of vessels, blood flow<br>and related tissue perfusion, or at least one of the major extra-<br>hepatic bile ducts (cystic duct, common bile duct and common<br>hepatic duct), using near infrared imaging. Fluorescence imaging<br>of biliary ducts with the KARL STORZ Endoscopic ICG System is<br>intended for use with standard of care white light and, when<br>indicated, intraoperative cholangiography. The device is not<br>intended for standalone use for biliary duct visualization.<br>Additionally, the KARL STORZ Endoscopic ICG System enables<br>surgeon to perform minimally invasive cranial neurosurgery in<br>adults and pediatrics and endonasal skull base surgery in adults<br>and pediatrics > 6 years of age using standard endoscopic visible<br>light as well as visual assessment of vessels, blood flow and<br>related tissue perfusion using near infrared imaging.<br>The KARL STORZ VITOM II ICG System is intended for capturing<br>and viewing fluorescent images for the visual assessment of<br>blood flow, as an adjunctive method for the evaluation of tissue<br>perfusion, and related tissue-transfer circulation in tissue and |
| Technological<br>Characteristics: | free flaps used in plastic, micro- and reconstructive surgical<br>procedures. The VITOM II ICG System is intended to provide a<br>magnified view of the surgical field in standard white light.<br>The KARL STORZ ICG Imaging System includes the following<br>components and accessories:<br>4mm, 5mm & 10mm HOPKINS ICG/NIR Endoscopes VITOM II ICG Telescope Camera Head (H3Z-FI) Fiber optic Light Cables Light Source Image1 S CCU The endoscopes/telescope are intended to be connected to the<br>optical coupler of the camera head, which connects to the CCU for<br>image processing, as well as to the light source via compatible<br>light cable as the source of illumination to allow visualization of<br>internal anatomy. Visualization and navigation is performed<br>initially using VIS imaging. NIR imaging is selected when visual<br>assessment and/or confirmation of vessels, blood flow or tissue<br>perfusion is desired. |
| Non-Clinical<br>Performance Data: | There are no performance standards or special controls<br>developed under Section 514 of the FD&C Act for endoscopes.<br>However, the KARL STORZ ICG Imaging System follows the FDA<br>recognized consensus standards and is tested according to the<br>following standards and FDA Guidance:<br>Electrical Safety and EMC IEC 60601-1 IEC 60601-1-2 IEC 60601-2-18 ISO Endoscopic Standards ISO 8600-1 ISO 8600-3 ISO 8600-4 ISO 8600-5 ISO 8600-6 Biocompatibility (ISO 10993) |
| | |
| | Systemic toxicity Intracutaneous irritation Maximization sensitization Mucosal Irritation Software Verification and Validation Testing Guidance for the Content of Premarket Submissions for Software Contained in Medical Device Level of concern: Moderate Performance Testing Color Performance Detection Linearity Distortion Dynamic Range Illumination Resolution SNR & Sensitivity Depth of Field UV Exposure Irradiance Color Reproduction Reprocessing (Cleaning and Steam Sterilization) AAMI TIR30:2011 AAMI TIR 12:2010 ANSI/AAMI/ISO 14937:2009 ANSI/AAMI ST9:2010/A4:2013 ISO TS 15883:2005 Processing/Reprocessing Medical Device in Health Care Settings: Validation Methods and Labeling Additional bench testing was performed to ensure the device met its design specifications.<br><br>The bench testing performed verified and validated that the KARL STORZ ICG Imaging System has met all its design specification and is substantially equivalent to its predicate devices. |
| Clinical Performance Data: | Clinical published literatures were provided to support the effectiveness of NIR imaging in the neuro- and endonasal skull |
| | base surgeries as well as the use of the KARL STORZ ICG Imaging<br>System in pediatrics. |
| Substantial<br>Equivalence: | The KARL STORZ ICG Imaging System is a modification of and<br>substantially equivalent to the primary predicate, KARL STORZ<br>Imaging System (K171238), in regards to its intended use, design,<br>technology, and performance specifications. |
| | The main difference between the subject and primary predicate<br>device is the addition of the 4mm HOPKINS ICG/NIR Endoscopes<br>to the KARL STORZ Endoscopic ICG System to be used in neuro-<br>and endonasal skull base surgery in adults and pediatrics. |
| | The KARL STORZ ICG Imaging System is also substantial<br>equivalent to the secondary predicate, KSEA Neuroendoscope &<br>Accessories, in regards to its intended use (VIS imaging), design,<br>technology, and performance specifications. |
| | The main difference between the subject and secondary<br>predicate device is the addition of filter located at the eyepiece of<br>the endoscope for the purpose of NIR imaging. |
| | Bench and comparative testing were used to demonstrate<br>substantial equivalence to the predicate devices. Clinical<br>published literatures were used to support the expanded<br>indications for NIR imaging in neuro- and endonasal skull base<br>surgeries as well as the use of the KARL STORZ ICG Imaging<br>system in pediatrics. Therefore, the differences between the<br>subject device and the predicate device do not raise any new<br>issues of safety and effectiveness. |
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| Standard Performance Parameters Comparison: | | | |
|---------------------------------------------|-----------------------------------------|------------------------------------------|-----------------------------------------------|
| | KARL STORZ<br>ICG Imaging<br>System | KARL STORZ<br>ICG System | KS Neuro-<br>endoscopes<br>and<br>Accessories |
| | Subject<br>Device | Primary<br>Predicate<br>Device | Secondary<br>Predicate<br>Device |
| | | K162882 | K021050 |
| (D1)<br>Endoscope<br>Type | Rigid, rod lens | Rigid, rod lens | Rigid, rod lens |
| (D2)<br>Endoscope<br>Diameters | 4mm, 5mm & 10mm | 5mm & 10mm | 2.7mm, 4mm & 4.8mm |
| (D3)<br>Direction of<br>View | 0°, 30°, 45° | 0°, 30° | 0°, 30°, 45° |
| (D4)<br>Working<br>Length | 18cm (4mm)<br>29cm (5mm)<br>31cm (10mm) | 29cm (5mm)<br>31cm (10mm) | 18 or 20 cm |
| Depth of<br>Field | 8mm – 38mm | 30mm - 80mm (5mm)<br>30mm – 110mm (10mm) | 8mm – 38mm |
| Field of View | 80° | 74° | 80° |
| Imaging Type | Visible and near-infrared imaging | Visible and near-infrared imaging | Visible Imaging |
| Imaging<br>Agent | ICG | ICG | N/A |
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| | Light Source<br>Compatibility | Xenon | Xenon | Xenon |
|--------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|-------|-------|
| Bibliography | Published literatures were used to support the expanded<br>indications for NIR imaging in neuro- and endonasal skull base<br>surgeries as well as the use of the KARL STORZ ICG Imaging<br>system in pediatrics. | | | |
| | NIR Imaging in Neuro and Endonasal Skull Base Surgery: | | | |
| | Geltzeiler M, Nakassa ACI, Setty P, Zenonos G, Hebert A, Wang E,<br>Fernandez-Miranda J, Snyderman C, Gardner P. (2017). Evaluation of<br>Intranasal Flap Perfusion by Intraoperative ICG Fluorescence Angiography.<br>Journal of Neurological Surgery Part B: Skull Base. 78. S1-S156. 10.1055/s-<br>0037-1600668. | | | |
| | Nakassa ACI, Wang E, Fernandez-Miranda J, Snyderman C, Gardner P.<br>(2017). Usefulness of Indocyanine Green Fluorescence Endoscopy for<br>Intraoperative Differentiation of Intracranial Tumors and Adjacent Structures.<br>Journal of Neurological Surgery Part B: Skull Base. 78. S1-S156. 10.1055/s-<br>0037-1600677. | | | |
| | Hide T, Yano S, Kuratsu J. (2014) Indocyanine Green Fluorescence<br>Endoscopy at Endonasal Transsphenoidal Surgery for an Intracavernous Sinus<br>Dermoid Cyst: Case Report. Neurologia Medico-Chirurgica. .54(12):999-1003.<br>doi:10.2176/nmc.cr.2014-0087. | | | |
| | Hide T, Yano S, Shinojima N, Kuratsu J. (2015) Usefulness of the<br>Indocyanine Green Fluorescence Endoscope in Endonasal Transsphenoidal<br>Surgery. Journal of Neurological Surgery. Published online February 27,<br>2015; DOI: 10.3171/2014.9.JNS14599 | | | |
| | Pediatric Use of subject device: | | | |
| | Patrick C. Walz, Charles A. Elmaraghy and Kris R. Jatana (2015). Endoscopic<br>Skull Base Surgery in the Pediatric Patient, Endoscopy - Innovative Uses and<br>Emerging Technologies, Associate Prof. Somchai Amornyotin (Ed.), InTech,<br>DOI: 10.5772/60555. Available from:<br>https://www.intechopen.com/books/endoscopy-innovative-uses-and-emerging-technologies/endoscopic-skull-base-surgery-in-the-pediatric-patient | | | |
| | Alessandro Fiorindi, Alessandro Boaro, Giulia Del Moro, Pierluigi Longatti;<br>Fluorescein-Guided Neuroendoscopy for Intraventricular Lesions: A Case<br>Series, Operative Neurosurgery, Volume 13, Issue 2, 1 April 2017, Pages 173–<br>181, https://doi.org/10.1093/ons/opw008. | | | |
| | Yamamichi T, Oue T, Yonekura T, Owari M, Nakahata K, Umeda S, Nara K,<br>Ueno T, Uehara S, Usui N. Clinical application of indocyanine green (ICG)<br>fluorescent imaging of hepatoblastoma. J Pediatr Surg. 2015 May;50(5):833-6.<br>doi: 10.1016/j.jpedsurg.2015.01.014. Epub 2015 Feb 3,<br>https://www.ncbi.nlm.nih.gov/pubmed/25783395 | | | |
| | Kitagawa N. (2016) Application of Indocyanine Green Fluorescence<br>Imaging to Pediatric Hepatoblastoma Surgery. In: Kusano M., Kokudo N., | | | |
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| | Toi M., Kaibori M. (eds) (2016) ICG Fluorescence Imaging and<br>Navigation Surgery. Springer, Tokyo, ICG Fluorescence Imaging and<br>Navigation Surgery pp343-350., https://doi.org/10.1007/978-4-431-55528-<br>5_31 |
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| Clinical Performance<br>Data: | Clinical performance is not required to demonstrate substantial<br>equivalence to the predicate devices. Non-clinical bench testing<br>was sufficient to establish substantial equivalence. |
| Conclusion: | The KARL STORZ ICG Imaging System is substantially equivalent<br>to its predicate devices. The non-clinical testing and supporting<br>clinical literatures demonstrate that the device is as safe and<br>effective as the legally marketed devices. |
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.