K200456 · Medtronic, Inc. · GWM · Mar 26, 2020 · Neurology
Device Facts
Record ID
K200456
Device Name
Becker External Drainage and Monitoring System
Applicant
Medtronic, Inc.
Product Code
GWM · Neurology
Decision Date
Mar 26, 2020
Decision
SESE
Submission Type
Special
Regulation
21 CFR 882.1620
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Draining and monitoring of CSF flow from the lateral ventricles or lumbar subarachnoid space is indicated in selected patients to: 1. Reduce intracranial pressure (ICP), e.g., pre-, intra- or postoperative; 2. Monitor CSF chemistry, cytology, and physiology; 3. Provide temporary CSF drainage in patients with infected cerebrospinal fluid shunts. Monitoring of intracranial pressure (ICP) is indicated in selected patients with: 1. Severe head injury 2. Subarachnoid hemorrhage graded III, IV. or V preoperatively 3. Reyes syndrome or similar encephalopathies 4. Hydrocephalus 5. Intracranial hemorrhage 6. Miscellaneous problems when drainage is to be used as a therapeutic maneuver. Monitoring can also be used to evaluate the status pre- and postoperatively for space-occupying lesions.
Device Story
Closed system for draining/monitoring cerebrospinal fluid (CSF) from lateral ventricles or lumbar subarachnoid space; gravity-fed drainage based on system height relative to patient anatomy. Components include patient connection line, stopcocks, mounting panel, and removable 600ml drainage bag with microbial barrier vent. Used in clinical settings (e.g., ICU/neurosurgical units) by physicians/nurses. Output consists of visual CSF volume measurements and pressure monitoring via optional transducer. Facilitates therapeutic pressure reduction and diagnostic monitoring of CSF chemistry/physiology. Benefits include temporary management of intracranial pressure and drainage for infected shunts.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing including visual/dimensional inspection, leakage testing, flow initiation pressure, seal weld integrity, and tensile strength of the inlet port.
Technological Characteristics
Sterile, single-use, non-pyrogenic system. Components: nondistensible patient line, stopcocks, mounting panel, 600ml drainage bag with hydrophobic/anti-microbial vent. Gravity-based drainage. Sterilization via Ethylene Oxide. No direct patient contact materials. Shelf life: 2 years.
Indications for Use
Indicated for patients requiring CSF drainage or ICP monitoring due to severe head injury, subarachnoid hemorrhage (grade III-V), Reyes syndrome/encephalopathies, hydrocephalus, intracranial hemorrhage, or space-occupying lesions.
Regulatory Classification
Identification
An intracranial pressure monitoring device is a device used for short-term monitoring and recording of intracranial pressures and pressure trends. The device includes the transducer, monitor, and interconnecting hardware.
Predicate Devices
Medtronic PS Medical Becker External Drainage and Monitoring System (K984053)
Submission Summary (Full Text)
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March 26, 2020
Medtronic, Inc. Nancy Hampton, Ph.D. Principal Regulatory Affairs Specialist 125 Cremona Drive Goleta, California 93117
Re: K200456
Trade/Device Name: Becker External Drainage and Monitoring System Regulation Number: 21 CFR 882.1620 Regulation Name: Intracranial Pressure Monitoring Device Regulatory Class: Class II Product Code: GWM, HCA Dated: February 20, 2020 Received: February 25, 2020
# Dear Dr. Nancy Hampton:
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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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 mediation-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,
Xiaolin Zheng, Ph.D., M.S. Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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# Indications for Use
### 510(k) Number (if known) K200456
Device Name
Becker External Drainage and Monitoring System
Indications for Use (Describe)
Draining and monitoring of CSF flow from the lateral ventricles or lumbar subarachnoid space is indicated in selected patients to:
- 1. Reduce intracranial pressure (ICP), e.g., pre-, intra- or postoperative;
- 2. Monitor CSF chemistry, cytology, and physiology;
- 3. Provide temporary CSF drainage in patients with infected cerebrospinal fluid shunts.
Monitoring of intracranial pressure (ICP) is indicated in selected patients with:
- 1. Severe head injury
- 2. Subarachnoid hemorrhage graded III, IV. or V preoperatively
- 3. Reyes syndrome or similar encephalopathies
- 4. Hydrocephalus
- 5. Intracranial hemorrhage
- 6. Miscellaneous problems when drainage is to be used as a therapeutic maneuver.
Monitoring can also be used to evaluate the status pre- and postoperatively for space-occupying lesions.
Type of Use (Select one or both, as applicable)
| <span style="text-decoration: underline;"><b>Prescription Use</b></span> (Part 21 CFR 801 Subpart D) | <svg height="16" width="16"> <path d="M2 2 L14 2 L14 14 L2 14 Z M3 3 L13 3 L13 13 L3 13 Z M4 4 L12 4 L12 12 L4 12 Z M5 5 L11 5 L11 11 L5 11 Z M6 6 L10 6 L10 10 L6 10 Z M7 7 L9 7 L9 9 L7 9 Z" fill="black"></path> <path d="M4 4 L12 12 M12 4 L4 12" stroke="black" stroke-width="2"></path> </svg> |
|------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Over-The-Counter Use (21 CFR 801 Subpart C) | <svg height="16" width="16"> <path d="M2 2 L14 2 L14 14 L2 14 Z M3 3 L13 3 L13 13 L3 13 Z M4 4 L12 4 L12 12 L4 12 Z M5 5 L11 5 L11 11 L5 11 Z M6 6 L10 6 L10 10 L6 10 Z M7 7 L9 7 L9 9 L7 9 Z" fill="white"></path> </svg> |
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### Becker® External Drainage and Monitoring System
510(k) Summary
March 26, 2020
- I. Medtronic, Inc. Company: Medtronic Neurosurgery 125 Cremona Drive Goleta, California 93117 USA
- Contact: Nancy Hampton, PhD Principal Regulatory Affairs Specialist nancy.d.hampton@medtronic.com Telephone Number: 949-490-3773
- Establishment Registration Number: 2021898 II.
- III. Proprietary Trade Name: Becker® External Drainage and Monitoring System
- IV. Regulatory Class: II
#### V. Primary Classification:
Name: Intracranial pressure monitoring device. Product Code: GWM Regulation: 21 CFR 882.1620
## Secondary Classification:
Name: Ventricular catheter Product Code: HCA Regulation:21 CFR 882.4100
#### VI. Product Description:
The Becker External Drainage and Monitoring System (Becker EDMS) provides the physician with a complete closed system for:
1. Draining cerebrospinal fluid (CSF) from the lateral ventricles of the brain or the lumbar subarachnoid space.
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2. Monitoring CSF pressure and flow rate from the lateral ventricles of the brain and the lumbar subarachnoid space.
The Becker EDMS consists of a nondistensible blue or green striped (proximal end) patient connection line, patient line stopcock, mounting panel/main system section, two latex-free injection sites and a removable drainage bag with approximate volumetric graduations and microbial barrier air vent.
The main system section located on the mounting panel includes:
- 1. Mounting bracket for height adjustment of system
- Optional self-adjusting cord with lock for adjustment of system height 2.
- 3. Main system stopcock with optional transducer attachment location
- Sliding, graduated, 50 cc drip chamber with drip former and conical bottom, and locking 4. bracket
- 5. Two drainage line slide clamps for flow monitoring and sampling
- Drainage bag connection line 6.
- Needleless Injection Site (Interlink or Smartsite) 7.
- Instructions for Use 8.
The system does not contain any latex components.
#### VII. Indications for Use:
Draining and monitoring of CSF flow from the lateral ventricles or lumbar subarachnoid space is indicated in selected patients to:
- 1. Reduce intracranial pressure (ICP), e.g., pre-, intra- or postoperative;
- 2. Monitor CSF chemistry, cytology, and physiology;
- 3. Provide temporary CSF drainage in patients with infected cerebrospinal fluid shunts.
Monitoring of intracranial pressure (ICP) is indicated in selected patients with:
- 1. Severe head injury
- 2. Subarachnoid hemorrhage graded III, IV, or V preoperatively
- 3. Reyes syndrome or similar encephalopathies
- 4. Hydrocephalus
- 5. Intracranial hemorrhage
- 6. Miscellaneous problems when drainage is to be used as a therapeutic maneuver.
Monitoring can also be used to evaluate the status pre- and postoperatively for space-occupying lesions.
#### VIII. Summary of the Technological Characteristics:
The proposed Becker EDMS modified disposable bag is a sterile nonpyrogenic single use component of the system that is removable from the Becker EDMS mounting panel. The bag has an approximate volume capacity of 600ml with approximate volumetric markings in 50mL increments, an inlet port, an outlet port and a hydrophobic/anti-microbial vent embedded into the body of the bag. The rest of the Becker EDMS system has the same technological characteristics as the predicate device.
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| | Subject Device | Predicate Device |
|------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | | K984053 |
| Intended use /<br>Indications for<br>Use | Draining and monitoring of CSF flow<br>from the lateral ventricles or lumbar<br>subarachnoid space is indicated in<br>selected patients to:<br>1. Reduce intracranial pressure (ICP), e.g.,<br>pre-, intra- or postoperative;<br>2. Monitor CSF chemistry, cytology, and<br>physiology;<br>3. Provide temporary CSF drainage in<br>patients with infected cerebrospinal fluid<br>shunts.<br>Monitoring of intracranial pressure (ICP)<br>is indicated in selected patients with:<br>1. Severe head injury<br>2. Subarachnoid hemorrhage graded III,<br>IV, or V preoperatively<br>3. Reyes syndrome or similar<br>encephalopathies<br>4. Hydrocephalus<br>5. Intracranial hemorrhage<br>6. Miscellaneous problems when drainage<br>is to be used as a therapeutic maneuver.<br>Monitoring can also be used to evaluate<br>the status pre- and postoperatively for<br>space-occupying lesions. | Draining and monitoring of CSF flow from<br>the lateral ventricles or lumbar<br>subarachnoid space is indicated in selected<br>patients to reduce intracranial pressure<br>(ICP), e.g. pre- intra- or postoperative;<br>monitor CSF chemistry, cytology and<br>physiology;<br>provide temporary CSF drainage in<br>patients with infected cerebrospinal fluid<br>shunts.<br>The monitoring of the intracranial pressure<br>(ICP) is indicated in selected patients with<br>severe head injury;<br>subarachnoid hemorrhage graded III, IV or<br>V preoperatively;<br>Reyes syndrome or similar<br>encephalopathies;<br>hydrocephalus;<br>intracranial hemorrhage or miscellaneous<br>problems when drainage is to be used as a<br>therapeutic maneuver.<br>Monitoring can also be used to evaluate the<br>status pre-and postoperatively for space<br>occupying lesions. |
| Operating<br>Principle | External drainage is temporary drainage<br>of cerebrospinal fluid (CSF) from the<br>lateral ventricles of the brain, or the<br>lumbar space of the spine, into an external<br>collection bag. The Becker EDMS drains<br>CSF by using a combination of gravity<br>and intercerebral pressure. The drainage<br>rate depends on the height at which the<br>system is placed relative to the patient's<br>anatomy. | Same |
| Materials | There are no materials with direct patient<br>contact | Same |
| Anatomical<br>Sites | Drainage and monitoring of CSF flow<br>from the lateral ventricles or lumbar<br>subarachnoid space. | Same |
| Biocompatibility | No direct patient contact.<br>In contact with CSF | Same |
| | Subject Device | Predicate Device<br>K984053 |
| Sterilization<br>Method | Ethylene Oxide | Same |
| Pyrogenicity | Non pyrogenic | Same |
| Shelf life | 2 years | Same |
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- IX. Identification of Legally Marketing Predicate Devices: Medtronic PS Medical Becker External Drainage and Monitoring System, K984053.
#### X. Discussion of the Performance Testing:
In accordance with the risk assessment of the change it was determined that dimensional verification, and design verification testing of the bag was necessary. The successful results of the testing demonstrated that the changes do not raise questions of safety and effectiveness, supporting the substantial equivalence to the predicate device.
| Test | Test Method Summary / Purpose | Results |
|---------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|
| Visual and<br>Dimensional<br>Inspection | Visual and dimensional inspection demonstrates that<br>the printed graduations meet volumetric capacity.<br>Volumetric graduations are approximate. | The Becker EDMS device met<br>the acceptance criteria for visual<br>and dimensional inspection. |
| Leakage of<br>Drainage Bag | The drainage bag must withstand being inverted<br>without leaking. | The Becker EDMS device met<br>the acceptance criteria for<br>drainage bag leakage. |
| Flow Initiation<br>Pressure | Record pressure at which flow initiates, for each<br>drainage bag. | The Becker EDMS device met<br>the acceptance criteria for flow<br>initiation pressure. |
| Drainage Bag<br>Seal Weld | Ensure there are no leaks in the drainage bag. | The Becker EDMS device met<br>the acceptance criteria for<br>drainage bag seal weld. |
| Tensile Strength<br>of Drainage Bag<br>Inlet Port | Evaluate the tensile strength of the drainage bag<br>inlet port to failure. | The Becker EDMS device met<br>the acceptance criteria for tensile<br>strength of drainage bag inlet<br>port. |
## Performance Data - Bench
# Performance Data – Animal
The risk assessment of the proposed modifications to the disposable bag did not require animal testing. Determination of substantial equivalence for the design change is based upon the design verification bench testing.
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## Performance Data – Clinical
The risk assessment of the proposed modifications to the disposable bag did not require clinical testing. Determination of substantial equivalence for the design change is based upon the design verification bench testing.
#### XI. Conclusions:
The information provided in this submission demonstrates that the subject device Becker EDMS has the same intended use/indications for use as the predicate device and the differences in technological characteristics introduced by the proposed changes to the disposable bag do not raise questions of safety and effectiveness. Based on the information provided in this submission the subject Becker EDMS device is considered substantially equivalent to the previously cleared predicate device.
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.