K213658 · El.En Electronic Engineering Spa · NVK · Mar 11, 2022 · General, Plastic Surgery
Device Facts
Record ID
K213658
Device Name
DEKA SMARTPERIO
Applicant
El.En Electronic Engineering Spa
Product Code
NVK · General, Plastic Surgery
Decision Date
Mar 11, 2022
Decision
SESE
Submission Type
Special
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The DEKA SmartPerio system is intended to perform intraoral soft tissue dental, general, oral maxillofacial, and cosmetic surgery. The DEKA SmartPerio is intended for ablating, incising, vaporization and coagulation of soft tissues using a contact fiber-optic delivery system. The device is intended to be used in dentistry. The following are the oropharyngeal indications for use: Abscess Incision and Drainage Apthous Ulcers Treatment Biopsies Excision and Incision Crown lengthening Hemostatic assistance Fibroma Removal Frenectomy Frenotomy Gingival Incision and Excision Gingivectomy Gingivoplasty Operculectomy Oral Papillectomy Tissue retraction for Impression Vestibuloplasty. Selective ablation of enamel (first degree) caries Exposure of unerupted / partially erupted teeth Implant recovery Lesion (tumor) removal Leukoplakia Pulpotomy Pulpotomy as adjunct to root canal therapy Removal of filling material such as gutta percha or resin as adjunct treatment during root canal retreatment Sulcular debridement (removal of diseased or inflamed soft tissue in the periodontal pocket) to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment level and tooth mobility. Laser assisted new attachment procedure (cementum-mediated periodontal ligament new-attachment to the root surface in the absence of long junctional epithelium.)
Device Story
Nd:YAG laser device for intraoral soft-tissue dental, oral maxillofacial, and cosmetic surgery. System delivers 1064 nm laser energy via optical fiber, handpiece, and tip to target tissue. Used in dental clinics by trained professionals. Laser energy enables ablation, incision, vaporization, and coagulation of soft tissues. Clinician guides fiber-optic delivery system to target site; output provides precise tissue interaction for surgical procedures. Benefits include improved clinical indices in periodontal pockets and efficient soft tissue management. Modification from predicate involves increasing average output power from 6W to 10W.
Clinical Evidence
Bench testing only. No clinical data provided. Compliance with ANSI AAMI ES60601-1, IEC 60601-1-2, IEC 60601-2-22, and IEC 60825-1 standards demonstrated.
Technological Characteristics
Nd:YAG laser; 1064 nm wavelength; 0.2-10W average power; 20-300 mJ energy per pulse; 10-100 Hz pulse frequency; 100-650 µs pulse duration. Contact fiber-optic delivery system. 635 nm aiming beam (5 mW). Complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-22, and IEC 60825-1.
Indications for Use
Indicated for patients requiring intraoral soft tissue dental, general, oral maxillofacial, or cosmetic surgery. Procedures include abscess drainage, ulcer treatment, biopsies, crown lengthening, hemostasis, fibroma removal, frenectomy/frenotomy, gingival procedures, operculectomy, papillectomy, tissue retraction, vestibuloplasty, caries ablation, tooth exposure, implant recovery, lesion removal, leukoplakia treatment, pulpotomy, root canal adjuncts, sulcular debridement, and laser-assisted new attachment.
Regulatory Classification
Identification
(1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
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March 11, 2022
El.En Electronic Engineering Spa Paolo Peruzzi Regulatory Affairs Manager Via Baldanzese 17 Calenzano. Florida 50041
# Re: K213658
Trade/Device Name: DEKA Smartperio Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: NVK, GEX Dated: February 7, 2022 Received: February 10, 2022
# Dear Paolo Peruzzi:
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,
For Michael E. Adjodha, M.ChE. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental 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)
K213658
Device Name DEKA SMARTPERIO
Indications for Use (Describe)
### surgery. The DEKA SmartPerio is intended for ablating, incising, vaporization and coagulation of soft tissues using a contact fiber-optic delivery system. The device is intended to be used in dentistry. The following are the oropharyngeal indications for use: Abscess Incision and Drainage Apthous Ulcers Treatment Biopsies Excision and Incision Crown lengthening
Hemostatic assistance
Fibroma Removal
Frenectomy
-
Frenotomy
Gingival Incision and Excision
Gingivectomy
Gingivoplasty
Operculectomy
Oral Papillectomy
Tissue retraction for Impression
Vestibuloplasty.
Selective ablation of enamel (first degree) caries
Exposure of unerupted / partially erupted teeth
Implant recovery
Lesion (tumor) removal
Leukoplakia
Pulpotomy
Pulpotomy as adjunct to root canal therapy
Removal of filling material such as gutta percha or resin as adjunct treatment during root canal retreatment Sulcular debridement (removal of diseased or inflamed soft tissue in the periodontal pocket) to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment level and tooth mobility. Laser assisted new attachment procedure (cementum-mediated periodontal ligament new-attachment to the root surface in the absence of long junctional epithelium.)
The DEKA SmartPerio system is intended to perform intraoral soft tissue dental, general, oral maxillofacial, and cosmetic
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)
# CONTINUE ON A SEPARATE PAGE IF NEEDED.
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### K213658
### 510(K) Summary
#### DEKA SMARTPERIO – Special 510(k)
#### Submitter:
El.En. S.p.A. Via Baldanzese, 17 50041 Calenzano (FI), Italy
#### Contact:
Paolo Peruzzi Regulatory Affairs Manager & Official Correspondent Phone: +39.055.8826807 E-mail: p.peruzzi@elen.it
#### Date Summary Prepared:
January 3, 2022
#### Device Trade Name:
DEKA SMARTPERIO
#### Common Name:
Laser, dental, soft tissue
#### Classification Name:
Laser Surgical Instrument for use in General and Plastic Surgery and in Dermatology
#### Product Code:
NVK, GEX
#### Regulatory Class:
Class II
#### Classification Number:
21 CFR 878.4810
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### Predicate Device:
DEKA SMARTPERIO (K203396)
### Device Description:
The DEKA SmartPerio is a Nd:YAG laser device for soft-tissues intraoral treatments. The DEKA SmartPerio system delivers laser through an optical fiber that is guided to the target tissue with the aid of an handpiece and a tip.
The modification to the device consists in the increasing of the average output power from 6W to 10W.
The intended use of the modified device, as described in the labelling, has not changed as a result of the modifications.
### Indications for Use:
The DEKA SmartPerio system is intended to perform intraoral soft tissue dental, gral maxillofacial, and cosmetic surgery. The DEKA SmartPerio is intended for ablating, incising, excising, vaporization and coagulation of soft tissues using a contact fiber-optic delivery system.
The device is intended to be used in dentistry.
The following are the oropharyngeal indications for use:
Abscess Incision and Drainage
Apthous Ulcers Treatment
Biopsies Excision and Incision
Crown lengthening
Hemostatic assistance
Fibroma Removal
Frenectomy
Frenotomy
Gingival Incision and Excision
Gingivectomy
Gingivoplasty
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Operculectomy Oral Papillectomy Tissue retraction for Impression Vestibuloplasty. Selective ablation of enamel (first degree) caries Exposure of unerupted / partially erupted teeth Implant recovery Lesion (tumor) removal Leukoplakia Pulpotomy Pulpotomy as adjunct to root canal therapy
Removal of filling material such as gutta percha or resin as adjunct treatment during root canal retreatment Sulcular debridement (removal of diseased or inflamed soft tissue in the periodontal pocket) to improve clinical indices including gingival bleeding index, probe depth, attachment level and tooth mobility tooth mobility.
Laser assisted new attachment procedure (cementum-mediated periodontal ligament newattachment to the root surface in the absence of long junctional epithelium.)
# Substantial equivalence discussion:
The modified DEKA SMARTPERIO is substantially equivalent to the DEKA SMARTPERIO device, cleared by FDA with K203396:
| | Proposed 510(k) Device | Predicate Device | Comparison |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| | DEKA SMARTPERIO | DEKA SMARTPERIO | |
| Device Trade Name | | K203396 | |
| Indications for use | The DEKA SmartPerio system is intended to perform intraoral soft tissue dental, general, oral maxillofacial, and cosmetic surgery. The DEKA SmartPerio is intended for ablating, incising, excising, | The DEKA SmartPerio system is intended to perform intraoral soft tissue dental, general, oral maxillofacial, and cosmetic surgery. The DEKA SmartPerio is intended for ablating, incising, excising, | Identical |
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| vaporization and coagulation of soft | vaporization and coagulation of soft |
|--------------------------------------|--------------------------------------|
| tissues using a contact fiber-optic | tissues using a contact fiber-optic |
| delivery system. | delivery system. |
| The device is intended to be used in | The device is intended to be used in |
| dentistry. | dentistry. |
| The following are the oropharyngeal | The following are the oropharyngeal |
| indications for use: | indications for use: |
| Abscess Incision and Drainage | Abscess Incision and Drainage |
| Apthous Ulcers Treatment | Apthous Ulcers Treatment |
| Biopsies Excision and Incision | Biopsies Excision and Incision |
| Crown lengthening | Crown lengthening |
| Hemostatic assistance | Hemostatic assistance |
| Fibroma Removal | Fibroma Removal |
| Frenectomy | Frenectomy |
| Frenotomy | Frenotomy |
| Gingival Incision and Excision | Gingival Incision and Excision |
| Gingivectomy | Gingivectomy |
| Gingivoplasty | Gingivoplasty |
| Operculectomy | Operculectomy |
| Oral Papillectomy | Oral Papillectomy |
| Tissue retraction for Impression | Tissue retraction for Impression |
| Vestibuloplasty. | Vestibuloplasty. |
| Selective ablation of enamel (first | Selective ablation of enamel (first |
| degree) caries | degree) caries |
| Exposure of unerupted / partially | Exposure of unerupted / partially |
| erupted teeth | erupted teeth |
| Implant recovery | Implant recovery |
| Lesion (tumor) removal | Lesion (tumor) removal |
| Leukoplakia | Leukoplakia |
| Pulpotomy | Pulpotomy |
| Pulpotomy as adjunct to root canal | Pulpotomy as adjunct to root canal |
| therapy | therapy |
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| | Removal of filling material such as<br>gutta percha or resin as adjunct<br>treatment during root canal<br>retreatment Sulcular debridement<br>(removal of diseased or inflamed soft<br>tissue in the periodontal pocket) to<br>improve clinical indices including<br>gingival index, gingival bleeding index,<br>probe depth, attachment level and<br>tooth mobility tooth mobility.<br><br>Laser assisted new attachment<br>procedure (cementum-mediated<br>periodontal ligament new-attachment<br>to the root surface in the absence of<br>long junctional epithelium.) | Removal of filling material such as<br>gutta percha or resin as adjunct<br>treatment during root canal<br>retreatment Sulcular debridement<br>(removal of diseased or inflamed soft<br>tissue in the periodontal pocket) to<br>improve clinical indices including<br>gingival index, gingival bleeding index,<br>probe depth, attachment level and<br>tooth mobility tooth mobility.<br><br>Laser assisted new attachment<br>procedure (cementum-mediated<br>periodontal ligament new-attachment<br>to the root surface in the absence of<br>long junctional epithelium.) | |
|---------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------|
| Product code | NVK, GEX | GEX | Identical |
| Laser Wavelength | 1064 nm | 1064 nm | Identical |
| Energy per Pulse | 20-300 mJ | 20-300 mJ | Identical |
| Pulses per Second | 10-100 Hz | 10-100 Hz | Identical |
| Pulse duration | 100-650 µs | 100-650 µs | Identical |
| Average Power | 0.2-10W | 0.2-6W | The<br>modification<br>does not<br>adversely<br>affect safety<br>and<br>effectiveness |
| Aiming Beam<br>wavelength | 635 nm | 635 nm | Identical |
| Power of Aiming<br>beam | 5 mW | 5mW | Identical |
# Performance data:
# Electrical safety and electromagnetic compatibility (EMC)
Electrical safety and EMC testing were conducted on the modified DEKA SMARTPERIO device, according to the following standards:
- ANSI AAMI ES60601-1Medical electrical equipment Part 1: General requirements for basic safety and essential performance.
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- . IEC 60601-1-2 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances -Requirements and tests.
### Additional non-clinical testing conducted
Additional tests were conducted on the modified DEKA SMARTPERIO, according to the following standards:
- IEC 60601-2-22: Medical electrical equipment Part 2-22: Particular requirements for basic safety and essential performance of surgical, cosmetic, therapeutic and diagnostic laser equipment
- IEC 60825-1: Safety of laser products Part 1: Equipment classification and requirements.
### Conclusion:
Based on the comparison of indications for use and the technological characteristics, we can conclude that the modified DEKA SMARTPERIO is as safe, as effective, and performs as well as the unmodified legally marketed predicate device (K203396).
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.