Diamondback 360 Peripheral Orbital Atherectomy System, Stealth 360 Peripheral Orbital Atherectomy System
Applicant
Cardiovascular Systems, Inc.
Product Code
MCW · Cardiovascular
Decision Date
Jul 2, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.4875
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Diamondback 360® Peripheral Orbital Atherectomy System is a percutaneous orbital atherectomy system indicated for use as therapy in patients with occlusive atherosclerotic disease in peripheral arteries and who are acceptable candidates for percutaneous transluminal atherectomy. The OAS supports removal of stenotic material from artificial arteriovenous dialysis fistulae (AV shunt). The system is a percutaneous orbital atherectomy system indicated as a therapy in patients with occluded hemodialysis grafts who are acceptable candidates for percutaneous transluminal angioplasty. The Stealth 360® Peripheral Orbital Atherectomy System is a percutaneous orbital atherectomy system indicated for use as therapy in patients with occlusive atherosclerotic disease in peripheral arteries and who are acceptable candidates for percutaneous transluminal atherectomy. The OAS supports removal of stenotic material from artificial arteriovenous dialysis fistulae (AV shunt). The system is a percutaneous orbital atherectomy system indicated as a therapy in patients with occluded hemodialysis grafts who are acceptable candidates for percutaneous transluminal angioplasty.
Device Story
Percutaneous orbital atherectomy system; removes/reduces occlusive material in peripheral arteries and AV dialysis fistulae. Components: reusable saline pump, single-use orbital atherectomy device (OAD), lubricant, guide wire. Operation: rapidly rotating eccentric diamond-coated crown creates centrifugal force; presses crown against calcified plaque; differential/bi-directional sanding reduces plaque; orbit diameter increases with each pass. Used in clinical settings by physicians. Output: restored luminal patency. Benefits: plaque reduction; improved blood flow in peripheral arteries and dialysis access sites.
Clinical Evidence
Bench testing only. Conducted in accordance with standards/guidance: track verification, stall/life and tight stenosis verification, pre-conditioning, tensile, temperature/saline flow, glide start-up, software verification, electromagnetic compatibility, and electrical safety. No clinical data presented.
Indicated for patients with occlusive atherosclerotic disease in peripheral arteries or occluded hemodialysis grafts who are candidates for percutaneous transluminal atherectomy or angioplasty.
Regulatory Classification
Identification
An intraluminal artery stripper is a device used to perform an endarterectomy (removal of plaque deposits from arterisclerotic arteries.)
Predicate Devices
Diamondback 360® Peripheral Orbital Atherectomy System (K152694)
Submission Summary (Full Text)
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July 2, 2019
Cardiovascular Systems Inc. Kris Miller Sr. Regulatory Specialist 1225 Old Highway 8 NW St. Paul, MN 55112
Re: K190634
Trade/Device Name: Diamondback 360 Peripheral Orbital Atherectomy System, Stealth 360 Peripheral Orbital Atherectomy System Regulation Number: 21 CFR 840.4875 Regulation Name: Intramural Artery Stripper Regulatory Class: Class II Product Code: MCW
Received: May 29, 2019
Dated: May 28, 2019
Dear Ms. Miller:
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.
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
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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 (OS) 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,
For
Gregory O'Connell Assistant Director DHT2C: Division of Coronary and Peripheral Intervention Devices OHT2: Office of Cardiovascular 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)
#### K190634
Device Name
Diamondback 360® Peripheral Orbital Atherectomy System Stealth 360® Peripheral Orbital Atherectomy System
#### Indications for Use (Describe)
The Diamondback 360® Peripheral Orbital Atherectomy System is a percutaneous orbital atherectomy system indicated for use as therapy in patients with occlusive atherosclerotic disease in peripheral arteries and who are acceptable candidates for percutaneous transluminal atherectomy.
The OAS supports removal of stenotic material from artificial arteriovenous dialysis fistulae (AV shunt). The system is a percutaneous orbital atherectorny system indicated as a therapy in patients with occluded hemodialysis grafts who are acceptable candidates for percutaneous transluminal angioplasty.
The Stealth 360® Peripheral Orbital Atherectomy System is a percutaneous orbital atherectomy system indicated for use as therapy in patients with occlusive atherosclerotic disease in peripheral arteries and who are acceptable candidates for percutaneous transluminal atherectomy.
The OAS supports removal of stenotic material from artificial arteriovenous dialysis fistulae (AV shunt). The system is a percutaneous orbital atherectomy system indicated as a therapy in patients with occluded hemodialysis grafts who are acceptable candidates for percutaneous transluminal angioplasty.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <input checked="" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) |
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| <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the logo for CSI. The logo is in gray and green. The letters "CSI" are in gray, and there is a green arc below the letters.
# 510(k) Summary
| Submitter: | Cardiovascular Systems Inc. (CSI)<br>1225 Old Highway 8 NW<br>St. Paul, MN 55112 |
|----------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Kris Miller<br>Sr. Regulatory Affairs Specialist<br>Cardiovascular Systems Inc.<br>1225 Old Highway 8 NW<br>St. Paul, MN 55112<br>Phone: 651-259-1656<br>Fax: 651-259-2094<br>kmiller@csi360.com |
| Date Prepared: | March 8, 2019 |
| 510(k) Number: | K190634 |
| Trade Name: | Diamondback 360® Peripheral Orbital Atherectomy System<br>Stealth 360® Peripheral Orbital Atherectomy System |
| Common Name: | Intraluminal Artery Stripper |
| Classification: | Class II, 21 CFR 870.4875 |
| Product Code: | MCW |
| Predicate Device: | K152694 - Diamondback 360® Peripheral Orbital Atherectomy<br>System (Cardiovascular Systems, Inc.) |
| Device Description: | The Diamondback 360 and Stealth 360 Peripheral Orbital<br>Atherectomy Systems (OAS) are designed to remove or reduce<br>occlusive material and restore luminal patency by using an<br>orbiting, diamond-coated, eccentrically mounted crown.<br><br>The OAS consists of the following main components:<br>1. Reusable Saline Pump (provided non-sterile)<br>2. Single-use Orbital Atherectomy Device (OAD) (provided sterile)<br>3. Single-use Atherectomy lubricant (provided sterile)<br>4. Single-use Atherectomy guide wire (provided sterile) |
| | Mechanism of Action |
| | Traditional 510(k) Pre-market Notification<br>Diamondback 360 and Stealth 360 OAS |
| | The Diamondback and Stealth OAS mechanism of action is<br>identical to the predicate device and is defined by:<br>• Centrifugal force<br>• Orbital rotation<br>• Differential sanding<br>• Bi-directional sanding<br><br>The rapidly rotating eccentric crown creates a centrifugal force that<br>presses the diamond-coated crown against the calcified plaque.<br>With each pass of the crown, plaque is reduced, and the diameter<br>of the orbit increases. |
| Indications for Use: | The Diamondback 360® [Stealth 360®] Peripheral Orbital<br>Atherectomy System is a percutaneous orbital atherectomy system<br>indicated for use as therapy in patients with occlusive<br>atherosclerotic disease in peripheral arteries and who are<br>acceptable candidates for percutaneous transluminal atherectomy. |
| | The OAS supports removal of stenotic material from artificial<br>arteriovenous dialysis fistulae (AV shunt). The system is a<br>percutaneous orbital atherectomy system indicated as a therapy in<br>patients with occluded hemodialysis grafts who are acceptable<br>candidates for percutaneous transluminal angioplasty. |
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# Technologic Characteristic Comparison:
| | DiamondBack<br>(Predicate Device)<br>K152694 | Proposed Device<br>DiamondBack OAS | Proposed Device<br>Stealth OAS | Impact of<br>Difference on<br>Safety and<br>Effectiveness | |
|-----------------------------------|--------------------------------------------------------------------------------------------------|------------------------------------|-----------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------|--|
| Crown Styles | Micro<br>Solid<br>Classic | Same as predicate | 1.25 Micro crown is<br>new to Stealth.<br>Solid and Classic<br>are same as<br>predicate | No Impact to<br>Safety and<br>Effectiveness as<br>this crown style<br>is identical to<br>the predicate<br>device. | |
| Crown Sizes<br>(mm) | 1.25<br>1.50<br>1.75<br>2.00 | Same as predicate | 1.25 Micro crown is<br>new to Stealth. All<br>other sizes are the<br>same as predicate. | No Impact to<br>Safety and<br>Effectiveness as<br>this crown size<br>is identical to<br>the predicate<br>device. | |
| | DiamondBack<br>(Predicate Device)<br>K152694 | Proposed Device<br>DiamondBack OAS | Proposed Device<br>Stealth OAS | Impact of<br>Difference on<br>Safety and<br>Effectiveness | |
| OAD<br>driveshaft<br>lengths (mm) | 145<br>180<br>200 | Same as predicate | Same as predicate | NA - No difference | |
| OAD driveshaft diameter (in.) | .0285 | Same as predicate | New to Stealth<br>(same as predicate) | No Impact to<br>Safety and<br>Effectiveness as<br>this is<br>comparable to<br>the currently<br>marketed<br>1.25MICRO145 | |
| 1.25Solid145 | .029 | Same as predicate | Same as predicate | NA - No difference | |
| 1.50Solid145 | .029 | Same as predicate | Same as predicate | NA - No difference | |
| 2.00Solid145 | .031 | Same as predicate | Same as predicate | NA - No difference | |
| 1.50Classic145 | .0335 | Same as predicate | Same as predicate | NA - No difference | |
| 2.00Classic145 | .0335 | Same as predicate | Same as predicate | NA - No difference | |
| 1.25Solid200 | .029 | Same as predicate | Same as predicate | NA - No difference | |
| 1.50Solid200 | .029 | Same as predicate | Same as predicate | NA - No difference | |
| 1.75Solid180 | .029 | Same as predicate | Same as predicate | NA - No difference | |
| Sheath Size | 4 Fr | Same as predicate | Same as predicate | No Impact to<br>Safety and<br>Effectiveness as<br>this is<br>comparable to<br>the currently<br>marketed<br>1.25MICRO145 | |
| 1.25Solid145 | 4 Fr | Same as predicate | 6 Fr | The Stealth<br>sheath size is<br>unchanged from | |
| | DiamondBack<br>(Predicate Device)<br>K152694 | Proposed Device<br>DiamondBack OAS | Proposed Device<br>Stealth OAS | Impact of<br>Difference on<br>Safety and<br>Effectiveness | |
| 1.50Solid145 | 5 Fr | Same as predicate | 6 Fr | the currently<br>cleared device.<br>The Stealth<br>sheath size is<br>unchanged from<br>the currently<br>cleared device. | |
| 2.00Solid145 | 5 Fr | Same as predicate | 6 Fr | The Stealth<br>sheath size is<br>unchanged from<br>the currently<br>cleared device. | |
| 1.50Classic145 | 5 Fr | Same as predicate | 6 Fr | The Stealth<br>sheath size is<br>unchanged from<br>the currently<br>cleared device. | |
| 2.00Classic145 | 5 Fr | Same as predicate | 6 Fr | The Stealth<br>sheath size is<br>unchanged from<br>the currently<br>cleared device. | |
| 1.25Solid200 | 5 Fr | Same as predicate | Same as predicate | NA - No<br>difference | |
| 1.50Solid200 | 5 Fr | Same as predicate | Same as predicate | NA – No<br>difference | |
| 1.75Solid180 | 5 Fr | Same as predicate | Same as predicate | NA - No<br>difference | |
| | Filar Count(x) and Wire Diameter | | | | |
| 1.25Micro145 | 3x.0061 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 1.25Solid145 | 3x.0067 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 1.50Solid145 | 3x.0067 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 2.00Solid145 | 6x.0060 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 1.50Classic145 | 3x.0070 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 2.00Classic145 | 3x.0070 | Same as predicate | Same as predicate | NA – No<br>difference | |
| | DiamondBack<br>(Predicate Device)<br>K152694 | Proposed Device<br>DiamondBack OAS | Proposed Device<br>Stealth OAS | Impact of<br>Difference on<br>Safety and<br>Effectiveness | |
| 1.25Solid200 | 7x.0060 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 1.50Solid200 | 7x.0060 | Same as predicate | Same as predicate | NA – No<br>difference | |
| 1.75Solid180 | 7x.0060 | Same as predicate | Same as predicate | NA – No<br>difference | |
| Rotational<br>Speed Range | Low (60 kRPM)<br>Medium (90 kRPM)<br>High (120 kRPM)<br>High (140 kRPM -<br>classic crowns only) | Same as predicate | Same as predicate | NA – No<br>difference | |
| GllideAssist | (cleared in K182397) | Same as predicate | 1.25MICRO145<br>only | No impact. This<br>function was<br>cleared in<br>K182397. | |
| Sterile | Yes | Same as predicate | Same as predicate | NA – No<br>difference | |
| Single Use | Yes | Same as predicate | Same as predicate | NA – No<br>difference | |
| Used in<br>conjunction<br>with | • OAS Saline<br>Pump<br>• CSI Peripheral<br>Guide Wires<br>• ViperSlide<br>Lubricant | Same as predicate | Same as predicate | NA – No<br>difference | |
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Performance Data:
Bench Testing
The following bench tests were conducted in accordance with applicable standards and guidance.
- Track Verification Testing .
- Stall / Life and Tight Stenosis Verification Testing ●
- Device Pre-Conditioning Verification Testing
- Tensile Verification Testing ●
- Temperature and Saline Flow Verification Testing ●
- Glide Start Up Verification Testing
- Software Verification ●
- Electromagnetic Compatibility ●
- Electrical Safety ●
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Image /page/8/Picture/0 description: The image shows the logo for CSI. The logo consists of the letters "CSI" in a rounded, sans-serif font. The letters are gray. Below the letters is a green arc. The arc is curved upwards, suggesting a smile or a rising line.
Performance data and software verification was collected and verified that the design meets all product specifications and address the potential safety hazards that have been identified.
The Diamondback 360 Peripheral Orbital Atherectomy System and Conclusion: the Stealth 360 Peripheral Orbital Atherectomy System have the same indications for use and the same technological characteristics as the predicate device. The testing results demonstrate that the devices perform as intended under the specified use conditions. Based on this and data provided in this pre-market notification, the subject and predicate devices have been shown to be substantially equivalent.
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.