K203406 · Philips Ultrasound, Inc. · IYN · Feb 23, 2021 · Radiology
Device Facts
Record ID
K203406
Device Name
Lumify Diagnostic Ultrasound System
Applicant
Philips Ultrasound, Inc.
Product Code
IYN · Radiology
Decision Date
Feb 23, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1550
Device Class
Class 2
Attributes
Pediatric
Indications for Use
Philips Lumify Diagnostic Ultrasound System is intended for diagnostic ultrasound imaging in B (2D), Color Doppler, Combined (B+Color), and M modes. It is indicated for diagnostic ultrasound imaging and fluid flow analysis in the following applications: Fetal/Obstetric, Abdominal, Pediatric, Cephalic, Urology, Gynecological, Cardiac Fetal Echo, Small Organ, Musculoskeletal, Peripheral Vessel, Carotid, Cardiac, Lung. Lumify is a transportable ultrasound system intended for use in environments where healthcare is provided by healthcare professionals.
Device Story
Lumify Diagnostic Ultrasound System is a mobile, software-controlled ultrasound device. It acquires high-resolution ultrasound data via USB transducers (C5-2, L12-4, S4-1) connected to a COTS mobile device (iOS/Android). The system displays images in B, Color Doppler, Combined, and M modes. A new 'B-lines Feature' provides automated detection and counting of B-lines in lung ultrasound images to assist in assessing pulmonary conditions like pneumonia, pulmonary edema, and ARDS. Users can review and manually edit the automated B-line counts. The system is used by healthcare professionals in point-of-care settings. The Lumify Power Module enables connectivity and power for iOS devices. The output aids clinicians in diagnostic decision-making by quantifying lung artifacts.
Clinical Evidence
Bench testing only. Performance data provided to support the software algorithm for the B-lines Feature, including requirements review, risk analysis, and product performance testing. All pre-determined acceptance criteria were met.
Technological Characteristics
Mobile ultrasound system comprising COTS mobile device, Philips ultrasound app, and USB-based transducers (Curved, Linear, Sector arrays). Includes Lumify Power Module for iOS interface/power. Software-based image processing for B-mode, Color Doppler, and M-mode. Automated B-line detection algorithm added to existing software platform.
Indications for Use
Indicated for diagnostic ultrasound imaging and fluid flow analysis in fetal/obstetric, abdominal, pediatric, cephalic, urological, gynecological, cardiac fetal echo, small organ, musculoskeletal, peripheral vessel, carotid, cardiac, and lung applications. Intended for use by healthcare professionals in clinical environments.
Regulatory Classification
Identification
An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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February 23, 2021
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Philips Ultrasound, Inc. % Mr. Colin Jacob Senior Regulatory Affairs Specialist 22100 Bothell Everett Highway BOTHELL WA 98021
Re: K203406
Trade/Device Name: Lumify Diagnostic Ultrasound System Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic pulsed doppler imaging system Regulatory Class: Class II Product Code: IYN, IYO, ITX Dated: January 15, 2021 Received: January 19, 2021
Dear Mr. Jacob:
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 and Part 809); 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)
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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<br>Food and Drug Administration | Form Approved: OMB No. 0910-0120<br>Expiration Date: 06/30/2023<br>See PRA Statement below. | |
|--------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|-----------------------------------------------|
| 510(k) Number (if known) | K203406 | | |
| Device Name | Lumify Diagnostic Ultrasound System | | |
| Indications for Use (Describe) | Philips Lumify Diagnostic Ultrasound System is intended for diagnostic ultrasound imaging in B (2D), Color Doppler, Combined (B+Color), and M modes. | | |
| | It is indicated for diagnostic ultrasound imaging and fluid flow analysis in the following applications: Fetal/Obstetric, Abdominal, Pediatric, Cephalic, Urology, Gynecological, Cardiac Fetal Echo, Small Organ, Musculoskeletal, Peripheral Vessel, Carotid, Cardiac, Lung. | | |
| | Lumify is a transportable ultrasound system intended for use in environments where healthcare is provided by healthcare professionals. | | |
| Type of Use (Select one or both, as applicable) | <table style="display: inline-table;"><tr><td><span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D)</td><td>☐ Over-The-Counter Use (21 CFR 801 Subpart C)</td></tr></table> | <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
| <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | ☐ Over-The-Counter Use (21 CFR 801 Subpart C) | | |
| | CONTINUE ON A SEPARATE PAGE IF NEEDED. | | |
| | This section applies only to requirements of the Paperwork Reduction Act of 1995. | | |
| | *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* | | |
| | The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: | | |
| | Department of Health and Human Services<br>Food and Drug Administration<br>Office of Chief Information Officer<br>Paperwork Reduction Act (PRA) Staff<br>PRAStaff@fda.hhs.gov | | |
| | "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." | | |
| FORM FDA 3881 (6/20) | Page 1 of 1 | PSC Publishing Services (301) 443-6740 | |
| | COMPANY CONFIDENTIAL<br>May Not Be Reproduced Without Written Permission | | |
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## 510(k) Summary
This summary of safety and effectiveness information is submitted in accordance with 21 CFR § 807.92. Date Prepared: February 16, 2021
EMAIL: benny.lam@philips.com
### I. Submitter
| Manufacturer Name<br>and Address | Philips Ultrasound, Inc.<br>22100 Bothell Everett Hwy<br>Bothell, WA 98021-8431 |
|----------------------------------|--------------------------------------------------------------------------------------------------------------------|
| Contact<br>Information | Colin S. Jacob<br>Senior Regulatory Affairs Specialist<br>TEL: +1 (425)-908-1209<br>EMAIL: colin.jacob@philips.com |
| Secondary Contact<br>Information | Benny Lam<br>Principal Regulatory Affairs Specialist<br>TEL: +1 (425)-215-3496 |
### II. Device
| Trade Name | Lumify Diagnostic Ultrasound System |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------|
| Common Name | Diagnostic ultrasound system and transducers |
| Regulation Description | Ultrasonic pulsed doppler imaging system<br>Ultrasonic pulsed echo imaging system<br>Diagnostic ultrasonic transducer |
| Regulation Number | 892.1550<br>892.1560<br>892.1570 |
| Primary Product Code | IYN |
| Secondary Product Codes | IYO<br>ITX |
| Device Class | Class II |
| Classification Panel | Radiology |
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PHILIPS
### III. Predicate Device
K192226 - Philips Ultrasound - Lumify Diagnostic Ultrasound System
### IV. Device Description
Lumify Diagnostic Ultrasound System is a mobile, general, software-control medical device, which is intended to acquire high-resolution ultrasound data and to display the data in various modes of operation. It is intended to be used by trained professionals at various clinical settings including point-of-care.
The Lumify Diagnostic Ultrasound System provides various imaging features including guided scan protocol for comprehensive lung exam. The introduction of the subject B-lines Feature enables the automated detection and counting of B-lines during a lung exam; the subject feature also provides the users the capabilities of reviewing the detected B-lines and editing the number of B-lines for each scanned lung zone.
Clinically, B-line is a lung ultrasound artifact that can aid users in the assessment of patients with a variety of pulmonary conditions and diseases such as pneumonia, pulmonary edema, lung contusion, and acute respiratory distress syndrome (ARDS).
The Lumify Diagnostic Ultrasound System includes:
- A commercial off-the-shelf (COTS) mobile device l
- I Philips Ultrasound software running as an app on the COTS device
- I The C5-2 Curved array USB transducer
- I The L12-4 Linear array USB transducer
- I The S4-1 Sector array USB transducer
- I The Lumify Power Module (LPM) to convert the USB interface used on the family of Lumify transducers to Apple's iAP2 Lightning interface standard used on iPhones and iPads, and to provide battery power to the transducers when using an iOS mobile device.
#### V. Indications for Use
Philips Lumify Diagnostic Ultrasound System is intended for diagnostic ultrasound imaging in B (2D), Color Doppler, Combined (B+Color), and M modes. It is indicated for diagnostic ultrasound imaging and fluid flow analysis in the following applications:
Fetal/Obstetric, Abdominal, Pediatric, Cephalic, Urology, Gynecological, Cardiac Fetal Echo, Small Organ, Musculoskeletal, Peripheral Vessel, Carotid, Cardiac, Lung.
Lumify is a transportable ultrasound system intended for use in environments where healthcare is provided by healthcare professionals.
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# PHILIPS
| | Lumify Diagnostic<br>Ultrasound System<br>K# Pending<br>(Subject Device) | Lumify Diagnostic<br>Ultrasound System<br>K192226<br>(Predicate Device) | Comparison |
|-------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|
| Regulation<br>Number | 892.1550 | 892.1550 | Remains<br>unchanged |
| Device<br>Classification<br>Name | System, Imaging, Pulsed<br>Doppler, Ultrasonic | System, Imaging, Pulsed<br>Doppler, Ultrasonic | Remains<br>unchanged |
| Product Code | IYN | IYN | Remains<br>unchanged |
| Secondary<br>Product Code | IYO, ITX | IYO, ITX | Remains<br>unchanged |
| Indications<br>for Use | Philips Lumify Diagnostic<br>Ultrasound System is<br>intended for diagnostic<br>ultrasound imaging in B<br>(2D), Color Doppler,<br>Combined (B+Color), and<br>M modes. It is indicated for<br>diagnostic ultrasound<br>imaging and fluid flow<br>analysis in the following<br>applications:<br>Fetal/Obstetric, Abdominal,<br>Pediatric, Cephalic, Urology,<br>Gynecological, Cardiac Fetal<br>Echo, Small Organ,<br>Musculoskeletal, Peripheral<br>Vessel, Carotid, Cardiac,<br>Lung.<br>Lumify is a transportable<br>ultrasound system intended<br>for use in environments<br>where healthcare is provided<br>by healthcare professionals. | Philips Lumify Diagnostic<br>Ultrasound System is<br>intended for diagnostic<br>ultrasound imaging in B<br>(2D), Color Doppler,<br>Combined (B+Color), and<br>M modes. It is indicated for<br>diagnostic ultrasound<br>imaging and fluid flow<br>analysis in the following<br>applications:<br>Fetal/Obstetric, Abdominal,<br>Pediatric, Cephalic, Urology,<br>Gynecological, Cardiac Fetal<br>Echo, Small Organ,<br>Musculoskeletal, Peripheral<br>Vessel, Carotid, Cardiac.<br>Lumify is a transportable<br>ultrasound system intended<br>for use in environments<br>where healthcare is provided<br>by healthcare professionals. | Added "lung" to<br>indications for<br>use<br>statement |
| Reusable? | Yes | Yes | Remains<br>unchanged |
| | Lumify Diagnostic<br>Ultrasound System<br>K# Pending<br>(Subject Device) | Lumify Diagnostic<br>Ultrasound System<br>K192226<br>(Predicate Device) | Comparison |
| Duration of<br>Use | Limited (≤ 24 hours) | Limited (≤ 24 hours) | Remains<br>unchanged |
| Imaging<br>Technology | Ultrasound Imaging | Ultrasound Imaging | Remains<br>unchanged |
| Principles of<br>Operation<br>(subject B-<br>lines Feature) | Automatic detection and<br>counting of B-lines from<br>lung ultrasound images | Manual counting of B-lines<br>from lung ultrasound images | B-lines Feature is<br>added to the<br>existing Lumify<br>app |
### VI. Comparison of Technological Characteristics between Proposed Subject Device and Predicate Device
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# HILIPS
### VII. Performance Data
The proposed introduction of the Lumify Diagnostic Ultrasound System was tested in accordance with Philips internal processes. Relevant non-clinical testing was conducted to address the change and performance test data is provided to support the introduction of the subject software algorithm for the B-lines Feature. The activities to assure the safe and effective performance of the software revision include but are not limited to the following:
- Requirements Review
- 트 Risk Analysis and Management
- 트 Product Specifications
- I Design Reviews
- 트 Product Performance testing
### VIII. Conclusion
For testing, all pre-determined acceptance criteria were met. Results of these tests show that the proposed subject device meets its intended use. The relevant performance data and compatibility support a determination that the proposed subject device does not raise new questions of safety or effectiveness and is substantially equivalent to the 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.