K180356 · Scanadu, Inc. · JIL · May 25, 2018 · Clinical Chemistry
Device Facts
Record ID
K180356
Device Name
inui In-Home Urine Analysis Test System
Applicant
Scanadu, Inc.
Product Code
JIL · Clinical Chemistry
Decision Date
May 25, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1340
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
The inui In-Home Urine Analysis Test System consists of the inui In-Home Urine Analysis Device and the inui Urine Analysis Mobile Application. The inui In-Home Urine Analysis Test System is intended for detecting the following parameters in urine: protein, glucose, leukocytes, nitrites, and ketones. The test results provide information regarding the status of urinary tract infections (UTI), proteinuria, glucosuria, and ketonuria. These results can be used as an aid for monitoring kidney functions, metabolic disorders (e.g. diabetes mellitus), and can be used in the screening for urinary tract infections (UTI). The inui In-Home Urine Analysis Device is intended for use as a Prescription Home use device.
Device Story
System comprises disposable test paddle with chemistry test pads (CTPs), urine collection cup, gray background sheet, and mobile application. User collects urine, applies to paddle; mobile device camera captures image of color reaction on CTPs. App performs electronic color analysis to determine semi-quantitative or qualitative results. Used in home setting by lay users under prescription. Results aid monitoring of kidney function, metabolic disorders, and UTI screening. QR code on paddle ensures quality control (lot/expiration). System provides invalid error messages for interfering substances or colors outside expected ranges.
Clinical Evidence
Clinical accuracy established via two-method comparison (n=190, n=91) between lay-user inui device results and professional-user predicate device results. Usability study (n=45) confirmed lay-user ability to follow procedural steps (86.7%-91.1% success). Reproducibility study (n=10) showed 100% reproducibility. Agreement metrics provided for all analytes; exact match agreement ranged from 67% to 100%, with 100% agreement within one color block for semi-quantitative analytes.
Technological Characteristics
Disposable plastic paddle with chemistry test pads (CTPs) and QR barcode. Colorimetric detection via mobile device camera and app. Storage: 15-30°C. Connectivity: Mobile application-based analysis. Software-based image processing for color analysis.
Indications for Use
Indicated for prescription home use by individuals to detect protein, glucose, leukocytes, nitrites, and ketones in urine as an aid in monitoring kidney function, metabolic disorders (e.g., diabetes), and screening for urinary tract infections (UTI).
Regulatory Classification
Identification
A urinary glucose (nonquantitative) test system is a device intended to measure glucosuria (glucose in urine). Urinary glucose (nonquantitative) measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, hypoglycemia, and hyperglycemia.
Predicate Devices
Siemens Multistix 10 SG Test Strips (k992257)
Submission Summary (Full Text)
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k180356
B. Purpose for Submission:
New Device
C. Measurand:
Glucose, protein, leukocyte, nitrite and ketones in urine
D. Type of Test:
Qualitative and semi-quantitative urinalysis
E. Applicant:
Scanadu, Inc.
F. Proprietary and Established Names:
inui In-Home Urine Analysis Test System
G. Regulatory Information:
| Name | Regulation | Product code | Device class |
| --- | --- | --- | --- |
| Urinary glucose (non-quantitative) test system | 21 CFR 862.1340 | JIL | II |
| Urinary protein or albumin (non-quantitative) test system | 21 CFR 862.1645 | JIR | I |
| Leukocyte peroxidase test | 21 CFR 864.7675 | LJX | I |
| Nitrite (non-quantitative) test system | 21 CFR 862.1510 | JMT | I |
| Ketones (non-quantitative) test system | 21 CFR 862.1435 | JIN | I |
2. Panel:
Chemistry (75), Hematology (81)
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H. Intended Use:
1. Intended use(s):
See indications for use statement below.
2. Indication(s) for use:
The inui In-Home Urine Analysis Test System consists of the inui In-Home Urine Analysis Device and the inui Urine Analysis Mobile Application. The inui In-Home Urine Analysis Test System is intended for detecting the following parameters in urine: protein, glucose, leukocytes, nitrites, and ketones. The test results provide information regarding the status of urinary tract infections (UTI), proteinuria, glucosuria, and ketonuria. These results can be used as an aid for monitoring kidney functions, metabolic disorders (e.g. diabetes mellitus), and can be used in the screening for urinary tract infections (UTI).
The inui In-Home Urine Analysis Device is intended for use as a Prescription Home use device.
3. Special conditions for use statement(s):
In vitro diagnostic use only.
The inui In-Home Urine Analysis Test System is intended for prescription home use only. Not for visual read.
4. Special instrument requirements:
iPhone 6 (iOS 8.X or higher)
I. Device Description:
The inui In-Home Urine Analysis Test System (inui Device) is comprised of a disposable test paddle, a urine collection cup, a gray background sheet, and the inui Urine Analysis Mobile Application. The plastic paddle contains multiple chemistry test pads (CTPs) and 1 quick response (QR) barcode. CTPs contain pre-dried chemicals that react to specific substances in a urine sample. A color reaction occurs on the CTP based on the amount of substance in the urine sample. The inui In-Home Urine Analysis Test System mobile app guides the user through the main steps of collecting urine, dipping the paddle into the urine, capturing an image of the reacted paddle, and displaying, saving, and sharing results. The inui In-Home Urine Analysis Device uses the mobile device's camera and the inui Urine Analysis Mobile Application to capture an image of the dipped CTPs, analyze the color changes and interpret the results. The results, are stored in Scanadu's secure encrypted cloud server for future reference. The inui In-Home Urine Analysis Test System must be used with a compatible mobile device (iPhone 6 with iOS version 8.X or higher). The inui Urine Analysis Mobile
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Application installed on the mobile device serves as the only display for the inui Device. The list of compatible mobile devices is provided in the product labeling.
The inui In-Home Urine Analysis Device reports semiquantitative or qualitative values for each test parameter. The reportable ranges for each analyte are summarized below:
| Analyte | Color block | Reportable range |
| --- | --- | --- |
| Protein | 1 | Negative |
| | 2 | Trace (15 mg/dL) |
| | 3 | Moderate (30(+) mg/dL) |
| | 4 | Large (100(++)-2000(++++) mg/dL) |
| Glucose | 1 | Negative |
| | 2 | Low (100 mg/dL) |
| | 3 | Moderate-Large (250(+) - 2000(++++) mg/dL) |
| Leukocyte | 1 | Negative-Trace |
| | 2 | Small-Large |
| Nitrite | 1 | Negative |
| | 2 | Positive |
| Ketone | 1 | Negative (0-5 mg/dL) |
| | 2 | Small (15 mg/dL) |
| | 3 | Moderate-Large (40-160 mg/dL) |
# J. Substantial Equivalence Information:
1. Predicate device name(s):
Siemens Multistix 10 SG Test Strips
2. Predicate $510(\mathbf{k})$ number(s):
k992257
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Candidate Device Inui In-Home Analysis Device K180356 | Predicate Device Mutistix 10 SG Test strips K992257 |
| Intended Use | For the detection of protein, glucose, leukocytes, nitrites, and ketones | Same |
| Specimen | Urine | Same |
| Urine analyte detection methodology | Based on color change result from the reaction of urine analytes on test pads | Same |
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| Differences | | |
| --- | --- | --- |
| Item | Candidate Device
Inui In-Home Analysis Device
K180356 | Predicate Device
Mutistix 10 SG Test strips
K992257 |
| Testing parameters | protein, glucose, leukocytes, nitrites, and ketones | leukocytes, protein, nitrites, blood, ketones, glucose, specific gravity, pH, bilirubin and urobilinogen |
| Special instrument requirements | Image capture by mobile phone’s digital camera | Visual read by trained professionals or read on a Clinitek urinalysis instrument |
| Device Intended Users | Prescription home use by lay users | In near patient (point-of-care) and centralized laboratory locations. |
K. Standard/Guidance Document Referenced (if applicable):
- CLSI EP5-A3: Evaluation of Precision Performance of Quantitative Measurement Methods
- CLSI EP6-A: Evaluation of the Linearity of Quantitative Measurement Procedures
- CLSI EP7-A2: Interference Testing in Clinical Chemistry
- CLSI EP12-A2: User Protocol for Evaluation of Qualitative Test Performance
- CLSI EP17-A2: Evaluation of Detection Capability of Clinical Laboratory Measurement Procedures
- CLSI EP25-A: Evaluation of Stability of In Vitro Diagnostic Reagents
L. Test Principle:
The inui In-Home Urine Analysis Test System detects urine analytes based on colorimetry. A color reaction occurs on the chemical test pads, based on the concentration of chemicals present in the urine sample. The color reaction is captured as an image using the mobile device camera and read using the mobile application on the display screen of the mobile device. The results are reported as specified by the measurement range for each test.
Protein: This test is based on the protein error-of-indicator principle that produces a color change.
Glucose: This test is based on a double sequential enzyme reaction.
Leukocytes: This test is based on the action of esterase present in leukocytes, which catalyzes the hydrolysis of an indoxyl ester derivative. The indoxyl ester liberated reacts with a diazonium salt to produce a color change.
Nitrites: This test depends on the conversion of nitrate to nitrite by the action of Gram-negative bacteria in the urine.
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Ketones: This test is based on the reaction of acetoacetic acid with sodium nitroprusside in a strongly basic medium to produce a color change.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Precision was evaluated with two studies; each study used three spiked urine solutions made from a pool of negative urine samples.
The first study determined the agreement between measurements using 3 phones and 3 paddle lot combinations with a single operator under one lighting condition with testing performed in one day. The study used 40 replicates resulting in N=120 per test level for the three controls solutions (P1 negative, P2 low positive and P3 high positive). Results for each control level for each analyte are summarized in the table below.
| Analyte / Unit | Control solution | Target concentration | Expected results range | Exact agreement (%) | Agreement within ±1 block (%) |
| --- | --- | --- | --- | --- | --- |
| Glucose (mg/dL) | P1 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P2 | 95 | Low (100 mg/dL) | 100% (120/120) | 100% (120/120) |
| | P3 | 1375 | Moderate-Large (250-2000 mg/dL) | 100% (120/120) | 100% (120/120) |
| Ketone (mg/dL) | P1 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P2 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P3 | 75 | Moderate-Large (40-160 mg/dL) | 100% (120/120) | 100% (120/120) |
| Protein (mg/dL) | P1 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P2 | 23 | Trace (15 mg/dL) | 100% (120/120) | 100% (120/120) |
| | P3 | 250 | Large (100 - 2000 mg/dL) | 100% (120/120) | 100% (120/120) |
| Nitrite (mg/dL) | P1 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P2 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P3 | 0.5 | Positive | 100% (120/120) | 100% (120/120) |
| Leukocyte (U/mL) | P1 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P2 | 0 | Negative | 100% (120/120) | 100% (120/120) |
| | P3 | 20 | Small-Large | 100% (120/120) | 100% (120/120) |
A second study was conducted across 3 phones, 3 paddle lots, under 2 lighting conditions (incandescent (INC) and compact fluorescent (CFL) which the sponsor stated were the most common lighting conditions), using 2 replicates, 3 solutions and 3 users for 5 non-consecutive days resulting in N=180 tests per sample. Results for each control level for each analyte are summarized in the table below.
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| Analyte / Unit | Control solution | Target concentration | Expected test results | Exact agreement (%) | Agreement within ±1 block (%) |
| --- | --- | --- | --- | --- | --- |
| Glucose (mg/dL) | P1 | 0 | Negative | 100% (180/180) | 100% (180/180) |
| | P2 | 95 | Low (100 mg/dL) | 100% (180/120) | 100% (180/180) |
| | P3 | 1375 | Moderate-Large (250-2000 mg/dL) | 100% (180/180) | 100% (180/180) |
| Ketone (mg/dL) | P1 | 0 | Negative-Trace | 100% (180/180) | 100% (180/180) |
| | P2 | 0 | Small (15 mg/dL) | 100% (180/180) | 100% (180/180) |
| | P3 | 75 | Moderate-Large (40-160 mg/dL) | 100% (180/180) | 100% (180/180) |
| Protein (mg/dL) | P1 | 0 | Negative | 100% (180/180) | 100% (180/180) |
| | P2 | 23 | Trace (15 mg/dL) | 100% (180/180) | 100% (180/180) |
| | P3 | 250 | Moderate-Large (100-2000 mg/dL) | 100% (180/180) | 100% (180/180) |
| Nitrite (mg/dL) | P1 | 0 | Negative | 100% (180/180) | 100% (180/180) |
| | P2 | 0 | Negative | 100% (180/180) | 100% (180/180) |
| | P3 | 0.5 | Positive | 100% (180/180) | 100% (180/180) |
| Leukocyte (U/mL) | P1 | 0 | Negative-Trace | 100% (180/180) | 100% (180/180) |
| | P2 | 0 | Negative-Trace | 100% (180/180) | 100% (180/180) |
| | P3 | 20 | Small-Large | 100% (180/180) | 100% (180/180) |
# b. Linearity/assay reportable range:
Five different lighting conditions representing incandescent (INC), compact fluorescent (CFL), LED, daylight (D65) and halogen (HAL) were used to determine the linearity and limit of detection for each analyte. Measurements were made using three phones, three paddle lots, three operators, and three replicates $= \mathrm{N}$ of 45 for each solution. Some solutions had less than 45 replicates because no test result was generated or the samples were depleted. Contrived samples were generated using a negative fresh urine sample spiked with commercially available reagents to obtain the target range of concentrations. For each analyte, the cutoff levels were defined as concentrations where at least $50\%$ of results belonged to the next corresponding level. The results are provided in the tables below:
| Analyte | Conc. (U/mL) | Negative-Trace | Small-Large |
| --- | --- | --- | --- |
| Leukocyte | 0 | 100% (45/45) | |
| | 0.0014 | 97.8% (44/45) | 2.2% (1/45) |
| | 0.0016 | 95.6% (43/45) | 4.4% (2/45) |
| | 0.0018 | 77.8% (35/45) | 22.2% (10/45) |
| | 0.0019 | 80% 36/45) | 20% (9/45) |
| | 0.002 | 68.9% (31/45) | 31.1% (14/45) |
| | 0.0023 | 31.1% (14/45) | 68.9% (31/45) |
| | 0.0038 | 4.40% (2/45) | 95.6% (43/45) |
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| Analyte | Conc. (mg/dL) | Negative-Trace | Small-Large |
| --- | --- | --- | --- |
| Nitrite | 0 | 100% (45/45) | |
| | 0.0025 | 100% (45/45) | |
| | 0.025 | 14% (6/44) | 86% (38/44) |
| | 0.05 | | 100% (45/45) |
| | 0.1 | | 100% (43/43) |
| | 0.125 | | 100% (43/43) |
| | 0.2 | | 100% (41/41) |
| | 0.25 | | 100% (46/46) |
| | 0.3 | 2 (1/45) | 98% (44/45) |
| Analyte | Conc. (mg/dL) | Negative | Trace (15 mg/dL) | Moderate (30 mg/dL) | Large (100 – 2000 mg/dL) |
| --- | --- | --- | --- | --- | --- |
| Protein | 0 | 100% (45/45) | | | |
| | 5 | 100% (45/45) | | | |
| | 9 | 80% (36/45) | 20% (9/45) | | |
| | 10 | 46.7% (21/45) | 53.3% (24/45) | | |
| | 11 | 20% (9/45) | 80% (36/45) | | |
| | 13 | 2.2% (1/45) | 97.8% (44/45) | | |
| | 21 | | 73.3% (33/45) | 26.7% (12/45) | |
| | 23 | | 33.3% (15/45) | 66.7% (30/45) | |
| | 26 | | 6.7% (3/45) | 93.3% (42/45) | |
| | 30 | | 2.2% (1/45) | 97.8% (44/45) | |
| | 50 | | | 91.1% (41/45) | 8.9% (4/45) |
| | 60 | | | 44.4% (20/45) | 55.6% (25/45) |
| | 77 | | | 8.9% (4/45) | 91.1% (41/45) |
| | 86 | | | 4.4% (2/45) | 95.6% (43/45) |
| | 100 | | | | 100% (45/45/45) |
| | 300 | | | | 100% (45/45/45) |
| | 750 | | | | 100% (45/45/45) |
| | 1500 | | | | 100% (45/45/45) |
| | 2000 | | | | 100% (45/45/45/45) |
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Based on these results, the sponsor defined the following cutoffs for each analyte level (color block).
| Analyte | Conc. mg/dL | Negative-Trace 0-5 mg/dL) | Small (15 mg/dL) | Moderate-Large (40-160 mg/dL) |
| --- | --- | --- | --- | --- |
| Ketone | 0 | 100% (45/45) | | |
| | 2 | 100% (45/45) | | |
| | 8 | 73% (32/45) | 27% (12/44) | |
| | 10 | 9% (4/45) | 91% (40/44) | |
| | 13 | | 100% (45/45) | |
| | 15 | | 100% (45/45) | |
| | 21 | | 89% (32/36) | 11% (4/36) |
| | 28 | | 17% (6/35) | 83% (29/35) |
| | 34 | | 3% (1/35) | 97% (34/35) |
| | 40 | | | 100% (35/35) |
| Analyte | Level 1 | Level 2 | Level 3 | Level 4 |
| --- | --- | --- | --- | --- |
| Protein | < 10 mg/dL | >10 mg/dL and <23 mg/dL | >23 mg/dL and <60 mg/dL | >60 mg/dL |
| Glucose | < 50 mg/dL | 50 mg/dL and 175 mg/dL | above 175 mg/dL | NA |
| Leukocyte | < 0.0023 U/mL | > 0.0023 U/mL and above | NA | NA |
| Nitrite | < 0.025 mg/dL | 0.025 mg/dL and above | NA | NA |
| Ketone | < 10 mg/dL | 10 mg/dL and <28 mg/dL | 28 mg/dL and above | NA |
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c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The device is not traceable to a standard or method.
d. Detection limit:
See Section M.1.b. for evaluation of the detection limit.
e. Analytical specificity:
Three solutions were used for interference study prepared from a natural pool of negative urine samples obtained from urine donors. The solution "Neg Ctrl" is a pooled human negative urine for all analytes. The solution "Pos 1" is low positive urine for Leukocyte (2 U/mL), Nitrite (0.1 mg/L), and Glucose (260 mg/dL) concentrations. The solution "Pos 2" is a low to moderate positive urine solution for Protein (100 mg/dL) and Ketone (40 mg/dL) concentrations.
To determine whether a substance is potentially interfering, high concentration of the substance was spiked in the positive (Pos 1 and Pos 2) and negative controls (Neg Ctl). A substance is considered an interferent if there was a result $\pm 1$ level from the expected result/control. Concentrations of the potentially interfering substances that did not produce a change in both the negative and positive pools are shown in the table below:
| Interfering Substance | Concentration Tested (mg/dL) |
| --- | --- |
| Creatine | 10 |
| Fructose | 18 |
| Ammonium Chloride | 200 |
| Ascorbic Acid | 2.2 |
| Amoxicillin | 7.5 |
| Citric Acid | 6 |
| Creatinine | 500 |
| Galactose | 15.13 |
| Glycine | 450 |
| Oxalic Acid | 0.73 |
| Sodium Acetate | 1200 |
| Cephalexin | 11.7 |
| Calcium Chloride | 300 |
| Ciprofloxacin | 1 |
| Sodium Chloride | 648 |
| Potassium Chloride | 37 |
| Sodium Nitrate | 0.3 |
| Sodium Phosphate | 25.2 |
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| Interfering Substance | Concentration Tested (mg/dL) |
| --- | --- |
| Urea | 120 |
| Acetaminophen | 20 |
| Phenolphthalein | 986 |
| Theophylline | 10 |
| Lactose | 226 |
The following interferences were observed and are described in the instructions for use labeling:
| Urine Analyte | Positive Bias / Increase in results | Negative bias / Decrease in results |
| --- | --- | --- |
| Protein | Albumin (Expected Interferent) | Acetoacetic Acid (invalid results at all conc)* |
| | Bilirubin (>10 mg/dL) | |
| | Hemoglobin (>100 mg/dL) | Hypochlorite (>375 mg/dL) |
| | Chlorhexidine (>40 mg/dL) | Specific Gravity (>1.025) |
| | Riboflavin (>5 mg/dL) | |
| Leukocyte | Leukocyte (Expected Interferent) | Acetoacetic Acid (invalid results at all conc)* |
| | | Albumin (>3000 mg/dL) |
| | | Bilirubin (>10 mg/dL) |
| | Hemoglobin (>150 mg/dL) | Sodium Chloride (>324 mg/dL) |
| | | Hemoglobin (>100 mg/dL) |
| | | Hypochlorite >(375 mg/dL) |
| | | Chlorhexidine (>60 mg/dL) |
| | | Microbial Peroxidase (>0.65%) |
| | | Riboflavin (>5 mg/dL) |
| | | Sodium Acetate (>600 mg/dL) |
| | | Sodium Bicarbonate (>630 mg/dL) |
| | | Specific gravity (>1.020) |
| Urobilinogen (>4 mg/dL) | | |
| Nitrite | Sodium Nitrite (Expected Interferent) | Hypochlorite (>375 mg/dL) |
| | Hemoglobin (>100 mg/dL) | |
| | Hypochlorite (>375 mg/dL) | |
| | Leukocyte (>0.0375 U/mL) | Sodium Bicarbonate (>945mg/dl) |
| | Urobilinogen (>4 mg/dl) | Sodium Acetate (>900 mg/dL) |
| Ketone | Litihium Acetoacetate (Expected Interferent) | Hypochlorite (>375 mg/dL) |
| | | Sodium Nitrite (>7.5 mg/dL) |
| Glucose | D-(+)-Glucose (Expected Interferent) | Acetoacetic Acid (invalid results at all conc)* |
| | Hypochlorite (>375 mg/dL) | Lithium Acetoacetate (>80 mg/dL) |
| | Bilirubin (Invalid results at all conc)* | Sodium Chloride (>486 mg/dL) |
* These interferents produce results that are outside the expected color trajectory. The inui App detects these interferents and reports the result as invalid.
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f. Assay cut-off:
Not Applicable.
## 2. Comparison studies:
a. Method comparison with predicate device:
Two method comparison studies were performed. Method comparison study 1 was performed to evaluate glucose, nitrite and ketones and method comparison study 2 was performed to evaluate protein and leukocytes. Both studies were conducted using subjects at two clinical sites. The agreement with the predicate device was evaluated with results obtained by lay users testing the inui Device (proposed device) with urine samples compared with results generated using the Siemens Multistix 10SG (predicate device) test strips tested and visually read by professional users. De-identified urine samples were collected from various geographic locations in the US. 338 samples were tested for method comparison study-1 and 177 samples were tested for method comparison study-2 (<3.0% of the total samples were contrived). Subjects were asked to test two clinical samples, their own urine sample and one provided to them from the collected pool of de-identified urine samples. The urine samples were randomized and blinded to both the lay users and professionals testing the samples. To adequately cover the positive ranges across all analyte levels, contrived specimens were included in the study. The data from each site was combined and are presented in the tables below showing the percent exact agreement and the percent agreement within ±1 color block.
| Glucose | Predicate Device (Professionals) | | | | | | Total Samples Used | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | NEG | Low (100mg/dL) | 250 mg/dL | 550 mg/dL | 1000 mg/dL | | 2000 mg/dL |
| Proposed Device (Layuser) | NEG | 278 | 2 | 0 | 0 | 0 | 0 | 338 |
| | Low (100) | 0 | 14 | 0 | 0 | 0 | 0 | |
| | 250/500/1000 /2000 | 0 | 3 | 7 | 6 | 9 | 19 | |
| Total | | 278 | 19 | 7 | 6 | 9 | 19 | |
| % exact match | | 100% | 73.68 | 100% | | | | |
| % ±1 color block | | 100% | 100% | 100% | | | | |
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| Nitrite | Predicate Device | | | Total Samples Used | |
| --- | --- | --- | --- | --- | --- |
| | | NEG | Low Positive | | High Positive |
| Proposed Device | NEG | 282 | 0 | 0 | 338 |
| | Positive | 11 | 15 | 30 | |
| Total | | 293 | 15 | 30 | |
| % exact match | | 96.25% | 100% | | |
| % ±1 color block | | 100% | 100% | | |
| Ketone | Predicate Device | | | | | | Total Samples Used | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | NEG | Trace | Small | Moderate | Large | | Large |
| Proposed Device | NEG/Trace | 286 | 14 | 0 | 0 | 0 | 0 | 338 |
| | Small | 0 | 4 | 12 | 0 | 0 | 0 | |
| | Moderate(40)/Large (80)/Large (160) | 0 | 0 | 6 | 9 | 3 | 4 | |
| Total | | 286 | 18 | 18 | 9 | 3 | 4 | |
| % exact match | | 98.68% | | 66.67% | 100% | | | |
| % ±1 color block | | 100% | 100% | 100% | 100% | | | |
| Protein | Predicate Device | | | | | | Total Samples Used | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | NEG | Trace | 30 mg/dL | 100 mg/dL | 300 mg/dL | | 2000 mg/dL |
| Propose Device | NEG | 92 | 5 | 0 | 0 | 0 | 0 | 177 |
| | Trace-Small (30mg/dL) | 19 | 27 | 0 | 0 | 0 | 0 | |
| | Moderate (30 mg/dL) | 0 | 4 | 9 | 0 | 0 | 0 | |
| | Large (100 –2000 mg/dL) | 0 | 0 | 1 | 10 | 5 | 5 | |
| Total | | 111 | 36 | 10 | 10 | 5 | 5 | |
| % exact match | | 83% | 75% | 90% | 100% | | | |
| % ±1 color block | | 100% | 100% | 100% | 100% | | | |
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| Leukocytes | Predicate Device | | | | | Total Samples Used | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | NEG | Trace | Small | Moderate | | Large |
| Propose Device | NEG/Trace | 82 | 26 | 2 | 0 | 0 | 177 |
| | Small/Mod/Large | 0 | 0 | 24 | 25 | 18 | |
| Total | | 82 | 26 | 26 | 25 | 18 | |
| % exact match | | 100% | 100% | 92.3% | 100% | 100% | |
| % ±1 color block | | 100% | 100% | 100% | 100% | 100% | |
b. Matrix comparison:
Not Applicable.
3. Clinical studies:
a. Clinical Sensitivity:
Not Applicable.
b. Clinical specificity:
Not Applicable.
c. Other clinical supportive data (when a. and b. are not applicable):
Usability and human factors testing was performed to evaluate the ability of the lay users to perform urine testing with the inui In-Home Urine Analysis System under the intended use conditions with the package insert. The study evaluated the overall process flow in the hands of the lay users, the impact of critical device components (i.e. packaging, urine collection cup, CTP test paddle and inui App) and user satisfaction. Usability testing resulted in acceptable performance for all critical actions in the testing procedure confirming that the lay users can follow the entire procedural steps (from sign-in and, test set-up to understanding the results) to obtain a successful test result.
4. Clinical cut-off:
Not Applicable.
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5. Expected values/Reference range:
| Analyte | Results | Recommendations (Call to Action) |
| --- | --- | --- |
| Protein | Negative | Your test result is normal. Note: Consult your physician if symptoms of any medical conditions are present. |
| | Trace (15 mg/dL) | Consult your physician if protein is consistently present or increasing in your urine. |
| | Moderate (30(+) mg/dL) | Consult your physician. |
| | Large (100(++) - 2000 (++++) mg/dL) | Consult your physician immediately. |
| Glucose | Negative | Your test result is normal. Note: Consult your physician if symptoms of any medical conditions are present. |
| | Low (100 mg/dL) | Consult your physician if glucose is consistently present or increasing. |
| | Moderate-Large (250(+) - 2000 (++++) mg/dL) | Consult your physician immediately. |
| Leukocyte | Negative-Trace | Your test result is normal. Note: Consult your physician if symptoms of any medical conditions are present. |
| | Small(+) - Large (+++) | Consult your physician. |
| Nitrite | Negative | Your test result is normal. Note: Consult your physician if symptoms of any medical conditions are present. |
| | Positive | Consult your physician immediately |
| Ketone | Negative-Trace | Your test result is normal. Note: Consult your physician if symptoms of any medical conditions are present. |
| | Small (15 mg/dL) | Consult your physician. |
| | Moderate-Large (40-160 mg/dL) | Consult your physician immediately |
# N. Instrument Name:
iPhone 6 (iOS 8.X or higher)
# O. System Descriptions:
# 1. Modes of Operation:
Smartphone image capture and analysis of the chemical test pad (CTP) colors to determine the analyte concentration.
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Does the applicant’s device contain the ability to transmit data to a computer, webserver, or mobile device?
Yes ☑ or No ☐
Does the applicant’s device transmit data to a computer, webserver, or mobile device using wireless transmission?
Yes ☑ or No ☐
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☑ or No ☐
3. Specimen Identification:
There is no sample identification function with these devices. Samples are applied directly to the urinalysis strips as they are collected.
4. Specimen Sampling and Handling:
The device is intended to be used with a freshly collected urine sample. The App instructs the user to image the test strip (to obtain a test result) no more than two minutes after sample application.
5. Calibration:
The inui In-Home Urine Analysis Device paddle is affixed with a quick response code (QR). The QR code is a unique ID that will contain information including the paddle expiration and lot number. The QR code has a built-in quality control system to reject the paddle if it has been used previously on the same phone.
6. Quality Control:
The reference color bar (RCB) on the label serves as an internal control for color correction of each captured image to account for the different ambient conditions.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
Studies were performed to validate insensitivity of the inui In-Home Analysis Test System to varying environmental and user conditions.
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1. Lighting effect: The performance of the device in different lighting conditions and illuminance was evaluated. The sponsor concluded having the phone flashlight or torch light on allows the app algorithm to remove light variability. The labeling indicates that testing should be conducted under normal household lighting conditions (i.e. incandescent, CFL, LED or halogen). The App warns the user if there is improper lighting conditions or the lighting conditions are not optimal.
2. Height and Angle study: image capture height, angle and alignment was evaluated to determine optimum range to capture the CTP paddle image. The optimal height and angle is incorporated in the app to give real time feedback to the user holding the phone. The App detects the height and angle of the strip or if the strip is misaligned and will warn the user with real time feedback.
3. Battery Life and Torch Light Intensity study: The sponsor evaluated whether the flashlight or torch light intensity correlates with the battery life and the phones ability to capture the CTP test paddle image. The study concluded that torch light intensity is not dependent on battery life.
4. Paddle Air Exposure study: The effect of air exposure on the chemical test pads on the paddle was evaluated. The study concluded the prolonged exposure (>15 minutes) to air can reduce activity of the CTP. The package insert states under “Precautions”: Conducting the test is very time sensitive. Please read all directions and follow all steps as instructed. Do NOT open pouch until instructed to by the app.
5. Paddle Dip time study: The paddle dip time was evaluated at 1, 3, 7 and 10 seconds using 3 contrived urine solutions. There were 10 replicates for each of the 5 dip times. No differences were observed between dip times and the analyte concentrations reported. The package insert recommends under “Precautions”: Do not dip paddle in urine for more than 1 second.
6. Single or Double Dip study: This study evaluated the effect of double dipping a paddle into a urine sample. A double dip consisted of submerging the test paddles into contrived urine solutions for one second, removing the paddles from the solution for another second and finally submerging the paddles into the solution for a second time for an additional second. The timer on the app was then initiated after the second submersion was completed. No changes were observed between single dipping and double dipping of paddles in regards to app results however the recommendation in the package insert states: Do not use test paddle more than once.
7. Urine Temperature Variation study: The effect of urine temperature variation on analytes was evaluated. Samples were tested at both $25^{\circ}\mathrm{C}$ and $35^{\circ}\mathrm{C}$. Under both temperature conditions ( $25^{\circ}\mathrm{C}$ and $35^{\circ}\mathrm{C}$ ) all 5 analytes tested $100\%$ concordance with the expected results.
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Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Parts 801 and 809, as applicable.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.