K200713 · Philips Medical Systems Nederland B.V. · LLZ · Apr 9, 2020 · Radiology
Device Facts
Record ID
K200713
Device Name
EchoNavigator
Applicant
Philips Medical Systems Nederland B.V.
Product Code
LLZ · Radiology
Decision Date
Apr 9, 2020
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.2050
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
EchoNavigator supports the interventionalist and surgeon in treatments where both live X-ray and live Echo guidance are used. The targeted patient population consists of patients with cardiovascular diseases requiring such a treatment.
Device Story
EchoNavigator R3.0.3 assists interventionalists and surgeons during cardiovascular procedures requiring concurrent live X-ray and live Echo guidance. The device integrates inputs from compatible Echo-probes, Echo units, and Philips interventional X-ray systems. It transforms these inputs by synchronizing image orientation, providing multiple viewing modes (including a new 'Model View'), and enabling C-arm tracking. The system is operated in the interventional suite via a touch screen module (TSM) or wireless mouse on a tray table. Outputs are displayed to the clinician to facilitate anatomical structure identification and manual annotation. By providing fused or synchronized visualization of X-ray and ultrasound data, the device aids in procedural guidance, potentially improving clinical decision-making and patient outcomes during complex cardiovascular interventions.
Clinical Evidence
No clinical data. Substantial equivalence is supported by non-clinical performance data, including software verification testing and in-house simulated use design validation. All verification and validation protocols passed, confirming the device meets intended use, claims, and user needs.
Technological Characteristics
Class II PACS (21 CFR 892.2050). Features include synchronized image orientation, multiple views (X-ray, Free, Echo, C-arm, Model), C-arm tracking, and manual annotation. Connectivity includes integration with Philips interventional X-ray systems and compatible Echo units. Software developed per IEC 62304; cybersecurity per UL 2900-1. Usability per IEC 62366-1. Risk management per ISO 14971.
Indications for Use
Indicated for patients with cardiovascular diseases requiring treatment using both live X-ray and live Echo guidance.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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Philips Medical Systems Nederland B.V. % Ioana Ulea Regulatory Affairs Specialist Veenpluis 6 5684 PC Best THE NETHERLANDS
Re: K200713
Trade/Device Name: EchoNavigator R.3.0.3 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: Class II Product Code: LLZ Dated: March 16, 2020 Received: March 18, 2020
Dear Ioana Ulea:
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 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for
April 9, 2020
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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,
For
Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
## Indications for Use
510(k) Number (if known) K200713
Device Name EchoNavigator R3.0.3
Indications for Use (Describe)
EchoNavigator supports the interventionalist and surgeon in treatments where both live Echo guidance are used. The targeted patient population consists of patients with cardiovascular diseases requiring such a treatment.
Type of Use (Select one or both, as applicable)
|X Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
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# PHILIPS
## 510(k) Summary
This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR §807.92.
| Date Prepared: | March 16th, 2020 | | | | | | | | | | | | | | | | |
|----------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------|-------------------------|---------------|----------------------------------------|----------------------|---------------------------------------------|----------------------------|---------------------------------------------|----------------------------|-----------------------|-----------------------|-----------|---------------|----------|---------------|-----|
| Manufacturer: | Philips Medical Systems Nederland B.V.<br>Veenpluis 6,<br>5684 PC Best<br>The Netherlands<br>Establishment Registration Number: 3003768277 | | | | | | | | | | | | | | | | |
| Primary Contact Person: | Ioana Ulea<br>Regulatory Affairs Specialist, IGT Systems<br>Phone: +31 618345875<br>E-mail: ioana.ulea@philips.com | | | | | | | | | | | | | | | | |
| Secondary Contact Person: | Michael Konings<br>Director Regulatory Affairs IGT Systems<br>Phone: +31 619864032<br>E-mail: michael.konings@philips.com | | | | | | | | | | | | | | | | |
| Device: | | | | | | | | | | | | | | | | | |
| | <table><tr><td>Trade Name:</td><td>EchoNavigator</td></tr><tr><td>Release Name:</td><td>R3.0.3</td></tr><tr><td>Classification Name:</td><td>Picture archiving and communications system</td></tr><tr><td>Classification Regulation:</td><td>21 CFR, Part 892.2050</td></tr><tr><td>Classification Panel:</td><td>Radiology</td></tr><tr><td>Device Class:</td><td>Class II</td></tr><tr><td>Product Code:</td><td>LLZ</td></tr></table> | Trade Name: | EchoNavigator | Release Name: | R3.0.3 | Classification Name: | Picture archiving and communications system | Classification Regulation: | 21 CFR, Part 892.2050 | Classification Panel: | Radiology | Device Class: | Class II | Product Code: | LLZ | | |
| Trade Name: | EchoNavigator | | | | | | | | | | | | | | | | |
| Release Name: | R3.0.3 | | | | | | | | | | | | | | | | |
| Classification Name: | Picture archiving and communications system | | | | | | | | | | | | | | | | |
| Classification Regulation: | 21 CFR, Part 892.2050 | | | | | | | | | | | | | | | | |
| Classification Panel: | Radiology | | | | | | | | | | | | | | | | |
| Device Class: | Class II | | | | | | | | | | | | | | | | |
| Product Code: | LLZ | | | | | | | | | | | | | | | | |
| Predicate Device: | | | | | | | | | | | | | | | | | |
| | <table><tr><td>Trade Name:</td><td><i>EchoNavigator R1</i></td></tr><tr><td>Manufacturer:</td><td>Philips Medical Systems Nederland B.V.</td></tr><tr><td>510(k) Clearance:</td><td>K121781 (October 26, 2012)</td></tr><tr><td>Classification Name:</td><td>Picture archiving and communications system</td></tr><tr><td>Classification Regulation:</td><td>21 CFR, Part 892.2050</td></tr><tr><td>Classification Panel:</td><td>Radiology</td></tr><tr><td>Device Class:</td><td>Class II</td></tr><tr><td>Product Code:</td><td>LLZ</td></tr></table> | Trade Name: | <i>EchoNavigator R1</i> | Manufacturer: | Philips Medical Systems Nederland B.V. | 510(k) Clearance: | K121781 (October 26, 2012) | Classification Name: | Picture archiving and communications system | Classification Regulation: | 21 CFR, Part 892.2050 | Classification Panel: | Radiology | Device Class: | Class II | Product Code: | LLZ |
| Trade Name: | <i>EchoNavigator R1</i> | | | | | | | | | | | | | | | | |
| Manufacturer: | Philips Medical Systems Nederland B.V. | | | | | | | | | | | | | | | | |
| 510(k) Clearance: | K121781 (October 26, 2012) | | | | | | | | | | | | | | | | |
| Classification Name: | Picture archiving and communications system | | | | | | | | | | | | | | | | |
| Classification Regulation: | 21 CFR, Part 892.2050 | | | | | | | | | | | | | | | | |
| Classification Panel: | Radiology | | | | | | | | | | | | | | | | |
| Device Class: | Class II | | | | | | | | | | | | | | | | |
| Product Code: | LLZ | | | | | | | | | | | | | | | | |
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# PHILIPS
| Reference Device: | Trade Name: | QLAB Advanced Quantification Software |
|--------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------|
| | Manufacturer: | Philips Ultrasound, Inc. |
| | 510(k) Clearance: | K181264 |
| | Classification Name: | Picture archiving and communications system |
| | Classification<br>Regulation: | 21 CFR 892.2050 |
| | Classification Panel: | Radiology |
| | Device Class: | Class II |
| | Product Code: | LLZ |
| Device description: | EchoNavigator is a tool that assists the interventionalist and surgeon with image guidance during treatment of cardiovascular disease for which the procedure uses both live X-ray and live Echo guidance. EchoNavigator can be used with compatible Echo-probes and Echo units in combination with compatible Philips interventional X-ray systems. | |
| Indications for Use: | EchoNavigator supports the interventionalist and surgeon in treatments where both live X-ray and live Echo guidance are used. The targeted patient population consists of patients with cardiovascular diseases requiring such a treatment. | |
| Technological characteristics: | The proposed EchoNavigator R3.0.3 has similar technological characteristics compared to the predicate device.<br><br>The subject and predicate devices are based on the following same technological characteristics:<br>The ability of the proposed device to display images from the live X-ray and Ultrasound modalities and the core algorithm for probe (transducer) detection is fundamentally unchanged compared to the predicate device. The following functionalities are available in both predicate and proposed device: Synchronize Image Orientation, Multiple Views, Follow C-arm, Table Side Control, Mannual Annotations and Image Capture Export. The following modifications were implemented in EchoNavigator R3.0.3: The <i>Multiple Views</i> functionality provided by the predicate device is extended in the proposed device with the <i>Model View</i> , which is an additional view compared to the <i>Multiple Views</i> available in the predicate device (X-ray, Free, Echo and C-arm). Although the <i>Table Side Control</i> is available in both devices, the proposed device offers basic control from the Touch Screen Module (TSM) in addition to the wireless mouse control on the tray table, as offered by the predicate device. While both devices are allowing the user to identify anatomical structures in one modality and annotate them by <i>Mannual</i> | |
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## PHILIPS
| Summary of Non-<br>Clinical<br>Performance<br>Data: | No# | Standard<br>Number<br>and Date | Standard Name | Recognition<br>Number |
|-----------------------------------------------------|-----|-------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------|-----------------------|
| | 1. | IEC 62304 Edition<br>1.1 2015-06 | Medical device software –<br>Software life cycle processes | 13-79 |
| | 2. | IEC 62366-1<br>Edition 1.0 2015-<br>02 | Medical devices – Part 1:<br>Application of usability<br>engineering to medical devices | 5-114 |
| | 3. | IEC 82304-1<br>Edition 1.0 2016-<br>10 | Health software – Part 1:<br>General requirements for<br>product safety | 13-97 |
| | 4. | ISO 14971:2007/<br>(R)2010<br>(Corrected 4<br>October 2007) | Medical devices – Application<br>of risk management to medical<br>devices | 5-40 |
| | 5. | ISO 15223-1 Third<br>Edition 2016-11-<br>01 | Medical devices – Symbols to<br>be used with medical device<br>labels, labelling and information<br>to be supplied | 5-117 |
| | 6. | UL 2900-1<br>First Edition 2017 | Software Cybersecurity for<br>Network-Connectable Products,<br>Part 1: General Requirements | 13-96 |
| | 7. | IEC 80001-1<br>Edition 1.0 2010-<br>10 | Application of risk management<br>for IT-networks incorporating | 13-38 |
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| | medical devices – Part 1: Roles,<br>responsibilities and activities | |
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Software verification testing has been performed to verify that all System Requirements Specification including all the Privacy and Security requirements have been implemented. Results demonstrated that all executed verification tests were passed. Software Verification data supports the proposed EchoNavigator R3.0.3 relative to the predicate EchoNavigator R1.
Non-clinical in-house simulated use design validation testing has been performed to validate that EchoNavigator R3.0.3 conforms to intended use, claims and user needs. Results demonstrated that all executed validation protocols were passed.
Summary of The EchoNavigator R3.0.3 introduces no new indications for use or Clinical technological characteristics relative to predicate device (K121781) that would Performance require clinical testing. Data: The EchoNavigator R3.0.3 is substantially equivalent to the predicate device Substantial Equivalence EchoNavigator R1 in terms of indications for use, technological characteristics, Conclusion: safety and effectiveness. Additionally, substantial equivalence was demonstrated by non-clinical performance tests provided in this 510(k) premarket notification. These tests demonstrate that EchoNavigator R3.0.3 complies with the user need requirements as well as the requirements specified in the FDA-recognized consensus standards and guidance documents.
> Therefore EchoNavigator R3.0.3 is as safe and effective as its predicate device and does not raise any new safety and/or effectiveness concerns.
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.