K190456 · BTL Industries, Inc. · NGX · Jul 5, 2019 · Physical Medicine
Device Facts
Record ID
K190456
Device Name
BTL 799-2L
Applicant
BTL Industries, Inc.
Product Code
NGX · Physical Medicine
Decision Date
Jul 5, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5850
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
BTL 799-2L is indicated to be used for: - Improvement of abdominal tone, strengthening of the abdominal muscles, development of firmer abdomen. - Strengthening, Toning and Firming of buttocks, thighs and calves. - Improvement of muscle tone and firmness, for strengthening muscles in arms.
Device Story
Non-invasive therapeutic device; produces electromagnetic field to interact with human body tissues; initiates nerve action potentials to induce muscle contraction. System console includes electromagnetic field generators, computer, and touch-screen control panel; supports two simultaneous applicators. User interface guides therapy procedure; displays therapy type, remaining time, and parameters. Used in clinical settings by professionals; parameters set via touch screen. Benefits include muscle strengthening, toning, and firming. Applicators BTL 299-6 and BTL 299-7 vary in size and magnetic field intensity to accommodate different muscle groups (larger groups vs. arms/calves).
Clinical Evidence
Bench testing only. Device evaluated for electrical safety and performance per IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60601-2-10, and ISO 14971. Biocompatibility testing performed per ISO 10993-1, ISO 10993-5, and ISO 10993-10.
Technological Characteristics
System console with electromagnetic field generators, computer, and touch-screen interface. Energy source: 100-240V AC, 50-60Hz. Magnetic field intensity: 0.5-2.0 T. Pulse repetition rate: 1-150 Hz. Pulse duration: 190-280 μs. Class II, BF electrical protection. Indoor use only. Firmware-controlled.
Indications for Use
Indicated for improvement of abdominal tone, strengthening abdominal muscles, development of firmer abdomen; strengthening, toning, and firming of buttocks, thighs, and calves; and improvement of muscle tone and firmness for strengthening arm muscles.
Regulatory Classification
Identification
A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.
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July 5, 2019
BTL Industries, Inc. David Chmel VP of Operations 362 Elm Street Marlborough, Massachusetts 01752
Re: K190456
Trade/Device Name: BTL 799-2L Regulation Number: 21 CFR 890.5850 Regulation Name: Powered Muscle Stimulator Regulatory Class: Class II Product Code: NGX Dated: April 4, 2019 Received: April 9, 2019
Dear David Chmel:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Vivek Pinto, PhD Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K190456
Device Name BTL 799-2L
Indications for Use (Describe)
BTL 799-2L is indicated to be used for:
- · Improvement of abdominal tone, strengthening of the abdominal muscles, development of firmer abdomen.
- · Strengthening, Toning and Firming of buttocks, thighs and calves.
- · Improvement of muscle tone and firmness, for strengthening muscles in arms.
Type of Use (Select one or both, as applicable)
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) |
|----------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# 510(k) Summary
# K190456
# General Information
| Sponsor: | BTL Industries, Inc.<br>362 Elm Street<br>Marlborough, MA 01752<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Applicant: | BTL Industries, Inc.<br>362 Elm Street<br>Marlborough, MA 01752<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
| Contact Person: | David Chmel<br>BTL Industries, Inc.<br>chmel@btlnet.com |
| Summary Preparation<br>Date: | June 28, 2019 |
### Device Name
| Trade/Proprietary Name: | BTL 799-2L |
|------------------------------|-----------------------------|
| Primary Classification Name: | Stimulator, Muscle, Powered |
| Classification Regulation: | 21 CFR 890.5850, Class II |
| Classification Product Code: | NGX |
## Legally Marketed Predicate Device
The BTL 799-2L is a state-of-the-art electromagnetic device with accessories, and is substantially equivalent to the current products that are already cleared for distribution in the USA under the following 510(k) Premarket Notification number:
- . primary predicate 799-2T (K182106)
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- secondary predicate HPM-6000 (K160992) ●
#### Product Description
The BTL 799-2L is a non-invasive therapeutic device. The device produces electromagnetic field that interacts with the tissues of the human body. The device has two outputs that enable simultaneous treatment by two applicators.
The BTL 799-2L is equipped with a large color touch screen with wide view angle that significantly facilitates the use of the device. The on-screen information guides the user stepby-step through the entire therapy procedure. The therapeutic parameters are easily set using the touch screen of the device. During the therapy the device keeps information about the applied therapy type, remaining therapy time and main therapy parameters on the screen.
#### Intended Use
BTL 799-2L is indicated to be used for:
- . Improvement of abdominal tone, strengthening of the abdominal muscles, development of firmer abdomen.
- Strengthening, Toning and Firming of buttocks, thighs and calves.
- . Improvement of muscle tone and firmness, for strengthening muscles in arms.
## Non-clinical Testing
The BTL 799-2L device has been thoroughly evaluated for electrical safety. The device has been found to comply with the following applicable medical device safety standards:
| IEC 60601-1 | Medical electrical equipment – Part 1: General requirements for basic<br>safety and essential performance |
|----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-1-2 | Medical electrical equipment – Part 1-2: General requirements for<br>basic safety and essential performance - Collateral standard:<br>Electromagnetic disturbances - Requirements and tests |
| IEC 60601-1-6 | Medical electrical equipment – Part 1-6: General requirements for<br>basic safety and essential performance - Collateral standard: Usability |
| IEC 60601-2-10 | Medical Electrical Equipment – Part 2-10: Particular Requirements for<br>the Basic Safety and Essential Performance of Nerve and Muscle<br>Stimulators |
| IEC 62304 | Medical device software - Software life cycle processes |
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| ISO 14971 | Medical devices – Application of risk management to medical devices |
|--------------|---------------------------------------------------------------------------------------------------------------|
| ISO 10993-1 | Biological evaluation of medical devices – Part 1: Evaluation and<br>testing within a risk management process |
| ISO 10993-5 | Biological evaluation of medical devices – Part 5: Tests for in vitro<br>cytotoxicity |
| ISO 10993-10 | Biological evaluation of medical devices – Part 10: Tests for irritation<br>and skin sensitization |
### Technological Characteristics
The BTL 799-2L device has similar indications for use, technological characteristics and principles of operation to its predicate devices. The BTL 799-2L device and its predicates are comprised of a system console and applicator(s). The system console consists of the electromagnetic field generators, computer, and the touch-screen control panel.
Generated electromagnetic field is intended to interact with the tissues of the human body to achieve muscle stimulation.
The technological similarities and differences between the BTL 799-2L device and predicate devices are described below in the comparison table. The differences do not raise any new types of safety or effectiveness questions.
| 510(k) number | K190456 | K182106 | K160992 |
|--------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device name | BTL 799-2L | BTL 799-2T | HPM-6000 |
| Company name | BTL Industries, Inc. | BTL Industries, Inc. | BTL Industries, Inc. |
| Product Code<br>and Regulation | Physical Medicine<br>21 CFR 890.5850<br>NGX - Stimulator, Muscle,<br>Powered, Muscle Conditioning | Physical Medicine<br>21 CFR 890.5850<br>NGX - Stimulator, Muscle,<br>Powered, Muscle Conditioning | Physical Medicine<br>21 CFR 890.5850<br>IPF - Stimulator, Muscle,<br>Powered |
| Intended Use | BTL 799-2L is indicated to be<br>used for:<br>• Improvement of abdominal<br>tone, strengthening of the<br>abdominal muscles,<br>development of firmer<br>abdomen.<br>• Strengthening, Toning and | BTL 799-2T is indicated to be<br>used for:<br>• Improvement of abdominal<br>tone, strengthening of the<br>abdominal muscles,<br>development of firmer<br>abdomen.<br>• Strengthening, Toning and | Indications for Use for Muscle<br>Stimulators:<br>• Relaxation of muscle spasms<br>• Prevention or retardation of<br>disuse atrophy<br>• Increasing local blood<br>circulation<br>• Muscle re-education |
| 510(k) number | K190456 | K182106 | K160992 |
| Device name | BTL 799-2L | BTL 799-2T | HPM-6000 |
| Company name | BTL Industries, Inc. | BTL Industries, Inc. | BTL Industries, Inc. |
| | Firming of buttocks, thighs<br>and calves.<br>• Improvement of muscle tone<br>and firmness, for<br>strengthening muscles in<br>arms. | Firming of buttocks and<br>thighs.<br>• Improvement of muscle tone<br>and firmness, for<br>strengthening muscles in<br>arms. | • Immediate post-surgical<br>stimulation of calf muscles to<br>prevent venous thrombosis<br>• Maintaining or increasing<br>range of motion |
| Principle of Action | Initiating action potential of<br>nerves results in muscle<br>contraction | Initiating action potential of<br>nerves results in muscle<br>contraction | Initiating action potential of<br>nerves results in muscle<br>contraction |
| Clinical Use | Prescription use | Prescription use | Prescription use |
| Electrical<br>Protection | Class II, BF | Class II, BF | Class II, BF |
| User Interface | Touch screen | Touch screen | Touch screen |
| Firmware<br>Controlled | Yes | Yes | Yes |
| Type of Energy | Magnetic field | Magnetic field | Magnetic field |
| Number of outputs | 2 | 2 | 1 |
| Number of<br>Magnetic Coils<br>in the Applicator | 1 | 1 | 1 |
| Magnetic Field<br>Intensity | BTL 299-6 applicator: 0.5 - 1.8 T<br>±20% | BTL 299-6 applicator: 0.5 - 1.8 T<br>±20% | BTL 299-1 applicator: 0.5 - 1.8 T<br>±20% |
| | BTL 299-7 applicator: 0.7 - 2.0 T<br>±20% | N/A | BTL 299-2 applicator: 0.7 - 2.5 T<br>±20% |
| Maximum<br>Magnetic Field | BTL 299-6 applicator: 1.154 T<br>±20% | BTL 299-6 applicator: 1.154 T<br>±20% | BTL 299-1 applicator: 1.220 T<br>±20% |
| Intensity at<br>Applicator Center<br>Surface | BTL 299-7 applicator: 1.173 T<br>±20% | N/A | BTL 299-2 applicator: 1.412 T<br>±20% |
| Pulse Repetition<br>Rate | 1 – 150 Hz | 1 – 150 Hz | 1 – 150 Hz |
| 510(k) number | K190456 | K182106 | K160992 |
| Device name | BTL 799-2L | BTL 799-2T | HPM-6000 |
| Company name | BTL Industries, Inc. | BTL Industries, Inc. | BTL Industries, Inc. |
| Pulse Duration | BTL 299-6 applicator: 280 ±<br>20% μs | BTL 299-6 applicator: 280 ±<br>20% μs | BTL 299-1 applicator: 280 ±<br>20% μs |
| | BTL 299-7 applicator: 190 ±<br>20% μs | N/A | BTL 299-2 applicator: 280 ±<br>20% μs |
| Selection of<br>parameters<br>(Intensity, Time) | Yes | Yes | Yes |
| Therapy Time | Up to 60 min | Up to 60 min | Up to 60 min |
| Energy Source | 100 - 240 V AC, 50-60 Hz | 100 - 240 V AC, 50-60 Hz | 100 - 240 V AC, 50-60 Hz |
| System<br>Dimensions<br>(W×H×D) | 580×1380×580 mm<br>(23×55×23 in) | 580×1380×580 mm<br>(23×55×23 in) | 500×970×580 mm<br>(20×38×23 in) |
| Ambient<br>Temperature | -10°C to +55°C | -10°C to +55°C | -10°C to +55°C |
| Relative Humidity | 10% to 85% | 10% to 85% | 10% to 85% |
| Environmental<br>Specifications | For indoor use only | For indoor use only | For indoor use only |
# Comparison with the Predicate Device
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# Substantial Equivalence
The BTL 799-2L device is intended for improvement of abdominal tone, strengthening of the abdominal muscles, development of firmer abdomen; strengthening, toning and firming of buttocks and thighs; improvement of muscle tone and firmness, for strengthening muscles in arms, identically compared to the primary predicate device. Additionally, the BTL 799-2L device is intended for calves strengthening, toning and firming, which is supported by the secondary predicate device HPM-6000.
The BTL 799-2L, when compared to the primary predicate device, may be used with two types of applicators. Applicator BTL 299-6 is identical to the applicator of the primary predicate device. The new applicator BTL 299-7 is of smaller size on the ground that it is intended to be used for smaller treatment areas, such as calves.
The BTL 299-7 applicator has slightly higher magnetic field intensity and shorter pulse width when compared to the applicator of the primary predicate device. However, magnetic field
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intensity is within the range of the BTL 299-2 applicator of the second predicate device. Pulse duration is shorter due to the smaller coil surface intended for smaller muscle parts.
The applicator of the primary predicate device (BTL 299-6) has wider field exposure compared to the currently submitted BTL 299-7 applicator. This is because the BTL 299-7 coil is smaller than the one in the BTL 299-6 applicator, due to the fact that the BTL 299-6 applicator is intended for larger groups of muscles, while the new BTL 299-7 applicator is intended for smaller muscle parts, particularly arms and calves.
All named applicators are based on identical principle, mechanism of action, as well as manufacturing material. The system console, consisting of the electromagnetic field generators, computer, and the touch-screen control panel is also identical to the predicate devices.
Any differences between the predicate devices and BTL 799-2L device have no significant influence on safety or effectiveness of the BTL 799-2L device. Therefore, the BTL 799-2L device is substantially equivalent to the predicate devices.
### Conclusion
Based upon the intended use and known technical information provided in this pre-market notification, the BTL 799-2L device has been shown to be substantially equivalent to currently marketed predicate 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.