K201678 · Ice Neurosystems, Inc. · GZL · Mar 8, 2021 · Neurology
Device Facts
Record ID
K201678
Device Name
iCE-SG Subcutaneous Electrode Arrays
Applicant
Ice Neurosystems, Inc.
Product Code
GZL · Neurology
Decision Date
Mar 8, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1330
Device Class
Class 2
Indications for Use
iCE-SG Subcutaneous Electrode Arrays are intended for temporary (<14 days) use with recording and monitoring equipment for the recording and monitoring of electrical signals at the subsurface level of the brain.
Device Story
iCE-SG Subcutaneous Electrode Arrays are sterile, single-patient-use depth electrodes designed for continuous EEG monitoring in the subcutaneous space. The system includes a preparation kit, insertion kit (trocar sheath, passage/exit assist tools, stoppers), and electrode arrays. Operated by healthcare professionals in hospital settings (including ICU), the device is tunneled subcutaneously to record electrical signals, which are then transmitted to external electrophysiology recording/monitoring equipment. The output allows clinicians to visualize EEG data for diagnostic or monitoring purposes. The device benefits patients by providing a minimally invasive method for subsurface brain signal acquisition without requiring intracranial penetration. The electrode is withdrawn at the bedside after the monitoring period.
Clinical Evidence
No clinical data. Evidence consists of biocompatibility testing (ISO 10993-3, 5, 6, 10, 11) and bench performance testing (dimensions, bending force, adhesion, stopper endurance) and an animal study confirming durability for 14 days of continuous subcutaneous implantation.
Technological Characteristics
Platinum/iridium electrode array; 1.12 mm diameter; subcutaneous placement; ethylene oxide sterilization; single-patient use; disposable. Connectivity via standard electrophysiology systems. No active stimulation capability.
Indications for Use
Indicated for temporary (<14 days) recording and monitoring of electrical signals at the subsurface level of the brain in patients requiring EEG monitoring.
Regulatory Classification
Identification
A depth electrode is an electrode used for temporary stimulation of, or recording electrical signals at, subsurface levels of the brain.
Epidural Peg Electrode (EP), Sphenoidal Electrode (EDS) and Foramen Ovale Depth Electrode (ED-FO) for Epilepsy Monitoring (K961942)
Submission Summary (Full Text)
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March 8, 2021
iCE Neurosystems, Inc. % Allison Komiyama Principal Consultant AcKnowledge Regulatory Strategies, LLC 2251 San Diego Avenue Suite B-257 San Diego, California 92110
Re: K201678
Trade/Device Name: iCE-SG Subcutaneous Electrode Arrays Regulation Number: 21 CFR 882.1330 Regulation Name: Depth Electrode Regulatory Class: Class II Product Code: GZL Dated: March 3, 2021 Received: March 4, 2021
Dear Allison Komiyama:
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
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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,
Jay Gupta Assistant 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
Enclosure
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# Indications for Use
510(k) Number (if known) K201678
### Device Name
iCE-SG Subcutaneous Electrode Arrays
#### Indications for Use (Describe)
iCE-SG Subcutaneous Electrode Arrays are intended for temporary (<14 days) use with recording and monitoring equipment for the recording and monitoring of electrical signals at the subsurface level of the brain.
Type of Use (Select one or both, as applicable)
| <input checked="true" type="checkbox"/> | Prescription Use (Part 21 CFR 201 Subpart D) |
|-----------------------------------------|----------------------------------------------|
| <input type="checkbox"/> | Over-The-Counter Use (21 CFR 201 Subpart C) |
> Prescription Use (Part 21 CFR 801 Subpart D)
| | 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 iCE Neurosystems. The logo features a stylized brain graphic on the left, with a red line extending from it to a red dot above the letter 'i' in 'iCE'. The letters 'iCE' are in a bold, blue font. Below 'iCE', the word 'NEUROSYSTEMS' is written in a smaller, gray font.
## 510(k) Summary K201678
#### DATE PREPARED
March 8, 2021
#### MANUFACTURER AND 510(k) OWNER
iCE Neurosystems, Inc. 1050 30th St NW Washington, DC 20007, USA Telephone: Official Contact: Allen Waziri, M.D., CEO
#### REPRESENTATIVE/CONSULTANT
Allison C. Komiyama, Ph.D., R.A.C. Michelle Rubin-Onur, Ph.D. AcKnowledge Regulatory Strategies, LLC Telephone: (619) 458-9547 Email: akomiyama@acknowledge-rs.com; mrubin@acknowledge-rs.com Website: https://www.acknowledge-rs.com/
#### DEVICE INFORMATION
| Proprietary Name/Trade Name: | iCE-SG Subcutaneous Electrode Arrays |
|------------------------------|---------------------------------------------------------------------------|
| Common Name: | Depth electrode |
| Regulation Number: | 21 CFR 882.1330 |
| Class: | Class II |
| Product Code: | GZL |
| Review Panel: | Neurology |
| Premarket Review: | Neurosurgical, Neurointerventional<br>and Neurodiagnostic Devices (DHT5A) |
#### PREDICATE DEVICE IDENTIFICATION
The iCE-SG Subcutaneous Electrode Arrays is substantially equivalent to the following predicate and reference devices:
| 510(k) Number | Predicate Device Name / Manufacturer | Primary Predicate |
|---------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|
| K163355 | Depth Electrodes (Depth Electrode, Foramen Ovale Depth<br>Electrodes, Macro Micro Depth Electrode, Spencer Probe<br>Depth Electrodes, Wyler Sphenoidal Depth Electrode) / Ad-<br>tech Medical Instrument Corporation | ✓ |
| K961942 | Epidural Peg Electrode (EP), Sphenoidal Electrode (EDS)<br>and Foramen Ovale Depth Electrode (ED-FO) for Epilepsy<br>Monitoring / Radionics Inc. | |
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Image /page/4/Picture/0 description: The image shows the logo for iCE Neurosystems. The logo features a stylized brain graphic with red lines emanating from it, followed by the text "iCE" in blue, with a red dot above the "i". Below the text "iCE" is the word "NEUROSYSTEMS" in a smaller font size.
#### DEVICE DESCRIPTION
The iCE-SG Subcutaneous Electrode Arrays are intended for use with recording and monitoring equipment for the purpose of recording electroencephalograph (EEG) signals. The subject device allows for continuous EEG monitoring in the subcutaneous space. The iCE-SG Subcutaneous Electrode Arrays can connect to commonly used electrophysiology systems. The subject device is provided sterile and for single patient use in hospitals by healthcare professionals (HCPs).
A kit includes the following components:
- 1. Preparation box
- 2. Insertion kit box
- 3. Two iCE-SG electrode boxes
#### INDICATIONS FOR USE
iCE-SG Subcutaneous Electrode Arrays are intended for temporary (<14 days) use with recording and monitoring equipment for the recording and monitoring of electrical signals at the subsurface level of the brain.
#### COMPARISON OF TECHNOLOGICAL CHARACTERISTICS
iCE Neurosystems believes that the iCE-SG Subcutaneous Electrode Arrays are substantially equivalent to the predicate device based on the information summarized here:
The subject device has the same intended use and similar technological characteristics as the devices cleared in K163355 and K961642. The electrode array used in the subject device is the same as the electrode array cleared in K163355. The insertion methodology is the same or similar to K163355 and K961942. Overall, the iCE-SG Subcutaneous Electrode Arrays have undergone testing to ensure that any difference in technological characteristics (i.e., inclusion of a preparation and insertion kit) do not affect safety and effectiveness when compared to the predicate device. A SE chart is included at the end of this summary.
#### SUMMARY OF NON-CLINICAL TESTING
No FDA performance standards have been established for the iCE SG-Subcutaneous Electrode Arrays. The following tests were performed to demonstrate safety based on current industry standards:
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Image /page/5/Picture/0 description: The image shows the logo for iCE Neurosystems. The logo features a stylized brain graphic in red, with a red dot connecting it to the letters "iCE" in blue. Below the letters is the word "NEUROSYSTEMS" in a smaller, gray font.
Biocompatibility: Patient contacting material was subjected to biocompatibility testing in compliance to ISO 10993-1 Biological Evaluation Of Medical Devices - Part 1: Evaluation And Testing Within A Risk Management Process.
| Standard | Study Description | Results |
|-----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|
| Insertion kit | | |
| ISO 10993-5 | Cytotoxicity study using L-929 cells; EMEM extract;<br>Evaluated using percent viability. | Non-cytotoxic |
| ISO 10993-10 | Intradermal injection and topical application in guinea pigs; sesame oil or 0.9%<br>normal saline extracts. | Non-sensitizing |
| ISO 10993-10 | Intracutaneous injection in New Zealand white rabbits; cottonseed oil or sodium<br>chloride extracts. | Non-irritating |
| ISO 10993-11 | Intraperitoneal injection of albino swiss mice with cottonseed oil or sodium chloride<br>extracts. | Non-toxic |
| ISO 10993-11 | Marginal ear vein injection of New Zealand white rabbits; 0.9% sodium chloride<br>extract. | Non-pyrogenic |
| iCE-SG Electrode Arrays | | |
| ISO 10993-5 | Cytotoxicity study using L-929 cells; EMEM extract;<br>Evaluated using morphological grading. | Non-cytotoxic |
| ISO 10993-10 | Intradermal injection and topical application in guinea pigs; cottonseed oil or 0.9%<br>sodium chloride extracts | Non-sensitizing |
| Standard | Study Description | Results |
| ISO 10993-10 | Intracutaneous injections in New Zealand white strain albino rabbits; cottonseed oil<br>or 0.9% sodium chloride extracts. | Non-irritating |
| ISO 10993-11 | Intraperitoneal injection in albino swiss mice with cottonseed oil extract<br>Intravenous injection in albino swiss mice with 0.9% sodium chloride extract | Non-toxic |
| ISO 10993-11 | Marginal ear vein injection of New Zealand white albino rabbits; 0.9% sodium<br>chloride extract. | Non-pyrogenic |
| ISO 10993-6<br>ISO 10993-11 | Implantation of two articles maintained for 28 and 29-days (males or females,<br>respectively). | Non-toxic |
| ISO 10993-6 | Implantation for four weeks into the left hemisphere in New Zealand White rabbits. | Non-bioreactive |
| ISO 10993-3 | Genotoxicity study with L5178Y cells; RPMIi and polyethylene glycol 400 (PEG)<br>extracts; Visual assessment of colonies. | Non-mutagenic |
| ISO 10993-3 | Top agar plating metabolically activated and incubated for 48 – 72 hours;<br>physiological saline and polyethylene glycol 400 (PEG) extracts | Non-mutagenic |
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Image /page/6/Picture/0 description: The image shows the logo for iCE Neurosystems. The logo features a stylized brain graphic with red lines emanating from it, leading to the letters "iCE" in blue. Below the letters, the word "NEUROSYSTEMS" is written in a smaller, sans-serif font.
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Image /page/7/Picture/0 description: The image shows the logo for iCE Neurosystems. The logo features a stylized brain graphic with red lines emanating from it, followed by the text "iCE" in blue, with a red dot above the "i". Below the "iCE" text is the word "NEUROSYSTEMS" in a smaller, gray font. The logo is clean and modern, suggesting a focus on neuroscience and technology.
The following tests were performed to demonstrate equivalence to the predicate device:
- Performance Testing (Bench) ●
- Examination of kit component dimensions O
- Examination of the packaging opening orientation O
- Examination of kit components colors, markings, and graphics O
- Examination for sharp edges o
- Examination of the opacity of the packaging O
- Examination of the trocar sheath tool's penetration tip bending force endurance O
- Examination of the bending force endurance of the exit assist device O
- Examination of the holding endurance of the posterior stopper O
- O Examination of the trocar sheath tool adhesion endurance
- Examination of the adhesion of the passage assist device O
- O Examination of the passage assist device bending resistance
- Examination of the anterior stopper endurance O
- о Cadaver study
- . Performance Testing (Animal)
- Durability of the subject device to record EEG after 14 days continuous implantation in o the subcutaneous space
The results of these tests indicate that the iCE-SG Subcutaneous Electrode Arrays are substantially equivalent to the predicate device.
#### CONCLUSION
Based on the testing performed, biocompatibility and performance testing (bench and animal), it can be concluded that the subject device does not raise new issues of safety or effectiveness compared to the predicate devices. The similar indications for use, technological characteristics, and performance characteristics for the proposed iCE-SG Subcutaneous Electrode Arrays are assessed to be substantially equivalent to the predicate device.
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Image /page/8/Picture/0 description: The image shows the logo for iCE Neurosystems. The logo features a stylized brain graphic with red lines emanating from it, leading to the letters "iCE" in blue. Below the graphic and letters, the word "NEUROSYSTEMS" is written in a smaller, gray font.
| | Subject Device | Primary Predicate Device | Secondary Predicate Device | Statement of Equivalence |
|---------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | iCE Neurosystems, Inc. /<br>iCE-SG Subcutaneous Electrode<br>Arrays | Ad-Tech Medical Instrument<br>Corporation /<br>Depth Electrodes (Depth Electrode,<br>Foramen Ovale Depth Eletrodes,<br>Macro Micro Depth Electrode,<br>Spencer Probe Depth Electrodes,<br>Wyler Sphenoidal Depth Electrode) | Radionics, Inc. /<br>Epidural Peg Electrode (EP), Sphenoidal<br>Electrode (EDS) and Foramen Ovale<br>Depth Electrode (ED-FO) for Epilepsy<br>Monitoring | |
| | K201678 | K163355 | K961942 | |
| Indications for Use | iCE-SG Subcutaneous Electrode<br>Arrays are intended for temporary<br>(<14 days) use with recording and<br>monitoring equipment for the<br>recording and monitoring of<br>electrical signals at the subsurface<br>level of the brain. | The Ad-Tech Depth Electrodes<br>(Depth Electrodes, Foramen Ovale<br>Depth Electrodes, Macro Micro<br>Depth Electrodes, Spencer Probe<br>Depth Electrodes, Wyler Sphenoidal<br>Depth Electrodes) are intended for<br>temporary (< 30 days) use with<br>recording, monitoring and<br>stimulation equipment for the<br>recording, monitoring and<br>stimulation of electrical signals at<br>the subsurface level of the brain. The<br>recording of electrical activity<br>supports definition of the location of<br>epileptogenic foci and brain<br>mapping. | Radionics Epidural Peg, Sphenoidal and<br>Foramen Ovale Depth Electrodes are<br>indicated for intraoperative recording<br>of electrical signals for epilepsy<br>monitoring at the surface and<br>subsurface levels of the brain. | Substantially equivalent to the<br>primary predicate device. The<br>subject device is intended for<br>use up to 14 days, is only for<br>recording/monitoring, and the<br>indications do not mention<br>epileptogenic foci and brain<br>mapping. This does not raise<br>new questions of safety and<br>effectiveness. |
| Product Codes /<br>Regulation Number | GZL / 21 CFR 882.1330 | GZL / 21 CFR 882.1330 | GZL / 21 CFR 882.1330<br>GYC / 21 CFR 882.1310 | Identical to the primary and<br>secondary predicate devices. |
| Regulation<br>Description | Depth electrode | Depth electrode | Depth electrode<br>Cortical electrode | Identical to the primary and<br>secondary predicate devices. |
| | Subject Device | Primary Predicate Device | Secondary Predicate Device | Statement of Equivalence |
| | iCE Neurosystems, Inc. / | Ad-Tech Medical Instrument | Radionics, Inc. / | |
| | iCE-SG Subcutaneous Electrode | Corporation / | Epidural Peg Electrode (EP), Sphenoidal | |
| | Arrays | Depth Electrodes (Depth Electrode, | Electrode (EDS) and Foramen Ovale | |
| | | Foramen Ovale Depth Eletrodes, | Depth Electrode (ED-FO) for Epilepsy | |
| | | Macro Micro Depth Electrode, | Monitoring | |
| | | Spencer Probe Depth Electrodes, | | |
| | | Wyler Sphenoidal Depth Electrode) | | |
| | K201678 | K163355 | K961942 | |
| Use Environment | Hospitals including ICU | Intraoperative and neurological<br>monitoring locations within a<br>hospital setting | Unknown | Substantially equivalent to the<br>predicate device. The subject<br>device can be used in the same<br>and similar environments as<br>well as by the bedside due to<br>the convenience kits included in<br>the subject device. This does not<br>raise new questions of safety<br>and effectiveness. |
| Device Components | Surgical Ruler Marker pen Sterile drape Gauze pad Head drape Trocar sheath tool Passage assist tool Exist assist device Stoppers Body adhesive iCE-SG Electrode Array | Depth electrode array | Depth electrode arrays | Substantially equivalent to the<br>primary and secondary<br>predicate devices. The subject<br>device is provided with two<br>convenience kits (Preparation<br>Kit and Insertion Kit) to make<br>subject use easier for the user.<br>The nonclinical testing has<br>demonstrated that these kits do<br>not raise new questions of<br>safety and effectiveness. |
| | Subject Device | Primary Predicate Device | Secondary Predicate Device | Statement of Equivalence |
| | iCE Neurosystems, Inc. /<br>iCE-SG Subcutaneous Electrode<br>Arrays | Ad-Tech Medical Instrument<br>Corporation /<br>Depth Electrodes (Depth Electrode,<br>Foramen Ovale Depth Eletrodes,<br>Macro Micro Depth Electrode,<br>Spencer Probe Depth Electrodes,<br>Wyler Sphenoidal Depth Electrode) | Radionics, Inc. /<br>Epidural Peg Electrode (EP), Sphenoidal<br>Electrode (EDS) and Foramen Ovale<br>Depth Electrode (ED-FO) for Epilepsy<br>Monitoring | |
| | K201678 | K163355 | K961942 | |
| Insertion Kit<br>Components | ● Gauze pad<br>● Head drape<br>● Trocar sheath tool<br>● Passage assist tool<br>● Exist assist device<br>● Stoppers<br>● Body adhesive | (n/a) | (n/a) | The primary and secondary<br>predicate devices are tunneled<br>through the subcutaneous space<br>and out of the skin using a<br>trocar that is not included with<br>the cleared devices. The trocars<br>are sold separately by the<br>manufacturers. These<br>differences raise no new<br>questions of safety or<br>effectiveness. |
| Location of<br>Placement | Extracranially | Extracranially | Extracranially | Identical to the primary and<br>secondary predicate. |
| Duration of Use | <14 days | <30 | Unknown | Substantially equivalent to the<br>primary predicate device. The<br>subject device is intended to be<br>used for a shorter period of time<br>compared to the primary<br>predicate. Based on the results<br>of the nonclinical data, the<br>shorter time period does not<br>raise new questions of safety<br>and effectiveness. |
| | Subject Device | Primary Predicate Device | Secondary Predicate Device | Statement of Equivalence |
| | iCE Neurosystems, Inc. /<br>iCE-SG Subcutaneous Electrode<br>Arrays | Ad-Tech Medical Instrument<br>Corporation /<br>Depth Electrodes (Depth Electrode,<br>Foramen Ovale Depth Electrodes,<br>Macro Micro Depth Electrode,<br>Spencer Probe Depth Electrodes,<br>Wyler Sphenoidal Depth Electrode) | Radionics, Inc. /<br>Epidural Peg Electrode (EP), Sphenoidal<br>Electrode (EDS) and Foramen Ovale<br>Depth Electrode (ED-FO) for Epilepsy<br>Monitoring | |
| | K201678 | K163355 | K961942 | |
| Contraindications | These depth electrodes should not<br>be used on any patient who the<br>physician considers at risk for<br>infection or for whom the<br>insertion procedure cannot be<br>performed safely and effectively. | These depth electrodes should not<br>be used on any patient who the<br>physician/surgeon considers at risk<br>for infection or for whom the<br>surgical recording and stimulation<br>procedure cannot be performed<br>safely and effectively. | Unknown | Substantially equivalent to the<br>primary predicate. The subject<br>device does not stimulate.<br>Based on the results of the<br>nonclinical data, there are no<br>new questions of safety and<br>effectiveness. |
| Technological Characteristics | | | | |
| Electrode<br>configuration | Array | Array | Array | Identical to the primary and<br>secondary predicate devices.<br>There are no new questions of<br>safety and effectiveness. |
| Single Patient Use | Yes | Yes | Yes | Identical to the primary<br>predicate device. There are no<br>new questions of safety and<br>effectiveness. |
| Disposable | Yes | Yes | Yes | Identical to the primary<br>predicate device. There are no<br>new questions of safety and<br>effectiveness. |
| Electrode Material | Platinum<br>Iridium | Platinum<br>Iridium | Unknown | Identical to the primary<br>predicate device. There are no<br>new questions of safety and<br>effectiveness…
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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.
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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.
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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.
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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.
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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.