The sponsor uses a retrospective open-label study to demonstrate that there are no statistically significant differences in antidepressant efficacy between the Magstim and NeuroStar TMS devices, supporting the equivalence of the stimulating coils.
Retrospective study; Comparative efficacy; Clinical literature
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Comparative Efficacy of Repetitive Transcranial Magnetic Stimulation for Treatment of Depression Using 2 Different Stimulation Devices: A Retrospective Open-Label Study; Retrospective open-label study
Patients with depression treated with TMS
NeuroStar TMS device
Antidepressant efficacy
Indications for Use
The Horizon 3.0 TMS Therapy System is intended to produce and deliver non-invasive, magnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. Horizon 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
Device Story
Computerized, electromechanical TMS system; delivers non-invasive, pulsed magnetic fields to induce electrical currents in cerebral cortex. Used in inpatient/outpatient settings (clinics, hospitals) by physicians. System comprises hardware, software, and accessories. StimGuide+ configuration utilizes stereotactic navigation for coil positioning and MT determination; standard configuration uses manual measurement. Output parameters (frequency, intensity, duration) are physician-controlled. Benefits include non-invasive cortical stimulation for MDD and OCD. Clinical decision-making supported by established stimulation protocols.
Clinical Evidence
Bench testing only. Includes software V&V (IEC 62304), performance verification of OCD protocols, and human factors testing (HE 75, IEC 62366). FEM modeling demonstrated E-field profile equivalence (±5% difference) to primary predicate. No new clinical trials conducted; relies on previously established safety/effectiveness data and literature (Oliveira-Maia et al., 2016) supporting equivalent antidepressant efficacy.
Technological Characteristics
Electromechanical TMS system; air-cooled figure-of-eight stimulating coils. Biphasic waveform. Operates via pulsed magnetic fields. Connectivity includes stereotactic navigation (StimGuide+). Software-controlled stimulation parameters. Complies with IEC 62304, IEC 62366, and HE 75 standards. No changes to electrical/mechanical safety or biocompatibility from K211389.
Indications for Use
Indicated for treatment of Major Depressive Disorder in adults failing prior antidepressant medication and as an adjunct for treatment of adults with Obsessive-Compulsive Disorder (OCD).
Regulatory Classification
Identification
A repetitive transcranial magnetic stimulation system is an external device that delivers transcranial repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex to treat the symptoms of major depressive disorder without inducing seizure in patients who have failed at least one antidepressant medication and are currently not on any antidepressant therapy.
Special Controls
*Classification.* Class II (special controls). The special control is FDA's “Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation System.” See § 882.1(e) for the availability of this guidance document.
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January 13, 2023
Magstim Company Ltd Tom Campbell Corporate Director Regulatory Affairs Spring Gardens Whitland, Carmarthenshire SA340HR United Kingdom
# Re: K222171
Trade/Device Name: Magstim Horizon 3.0 TMS Therapy System, Horizon 3.0 System, Horizon 3.0. H3.0, Horizon 3.0 with StimGuide+ Regulation Number: 21 CFR 882.5805, 21 CFR 882.5802 Regulation Name: Repetitive Transcranial Magnetic Stimulation System Regulatory Class: Class II Product Code: OBP, QCI Dated: December 13, 2022 Received: December 14, 2022
Dear Tom Campbell:
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
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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 (OS) 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,
Pamela D. Scott -S
Digitally signed by Pamela D. Scott -S Date: 2023.01.13 22:31:45 -05'00'
Pamela D. Scott Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine 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) K222171
Device Name Horizon 3.0 TMS Therapy System
#### Indications for Use (Describe)
Horizon 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------------------------|-----------------------------------------------|
| <span style="font-family: Arial, sans-serif;">☑</span> 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 word "magstim" in a bold, sans-serif font. The letters are a dark blue color, except for a light blue circle above the "i". There is a small registered trademark symbol to the right of the word.
# K222171 Traditional 510(k) SUMMARY Magstim's Horizon® 3.0 TMS Therapv System
Prepared according to the requirements outlined in 21 CFR 807.92
## Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Magstim® Company Limited Spring Gardens, Whitland, Carmarthenshire SA34 OHR, United Kingdom Phone: +44 (0) 1994 240798 Facsimile: +44 (0) 1994 240061 Contact Person: Tom Campbell, Corporate Director Regulatory Affairs
Date Prepared: August 31, 2022
#### Trade Name of Device
Horizon® 3.0 TMS Therapy System
#### Common or Usual Name
Transcranial Magnetic Stimulation System for Neurological and Psychiatric Disorders and Conditions
#### Classification
21 C.F.R. § 882.5805, Class II, product code OBP 21 C.F.R. § 882.5802, Class II, product code QCI
#### Predicate Devices
K212289 NeuroStar Advanced Therapy, Neuronetics Inc. (Primary Predicate Device), 21 C.F.R § 882.5802, QCI K211389 Horizon® 3.0 TMS Therapy System, The Magstim® Company Limited (Secondary Predicate Device ), 21 C.F.R § 882.5805, OBP
K193006 MagVenture TMS Therapy, Tonica Elektronik A/S (Reference Predicate), 21 C.F.R ട്ട 882.5802, QCI
#### Device Description
The Horizon® 3.0 TMS Therapy System is a computerized, electromechanical medical device that produces and delivers non-invasive, maqnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation. ("TMS").
The Horizon® 3.0 TMS Therapy System is a non-invasive tool for the stimulation of cortical neurons for the treatment of Major Depressive Disorder (MDD) in adult patients who have failed to achieve satisfactory improvement from antidepressant medication in the current
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episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
The Horizon® 3.0 TMS Therapy System is used for patient treatment by prescription only under the supervision of a licensed physician. It can be used in both inpatient and outpatient settings, including physicians' offices, clinics, and hospitals.
Horizon® 3.0 TMS Therapy System is an integrated system consisting of a combination of hardware, software, and accessories. Its technological characteristics are described in further detail below.
#### Intended Use & Indications for Use
The Horizon® 3.0 TMS Therapy System is intended to produce and deliver non-invasive, magnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex.
Horizon® 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
#### Technological Characteristics
Horizon® 3.0 TMS Therapy System and its technological characteristics remain almost identical to that cleared within K211389.
The proposed changes to Horizon 3.0, for adjunctive treatment of OCD, are limited to updates to the IFU and software for user interface and treatment stimulation parameters. Both these changes are made to facilitate safe and effective treatment of patients with OCD and do not raise new or different questions of safety and effectiveness.
The coil positioning mechanism of action with Horizon 3.0 also remains unchanged with two options available dependent on Horizon 3.0 configuration. Horizon 3.0 with StimGuide+ offers the ability to locate and determine MT and the location of the treatment location with the use of stereotactic navigation, where standard Horizon 3.0 uses the conventional manual measurement approach.
All other aspects of the device compared to the currently marketed Horizon 3.0 device remain unchanged and are identical.
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## Non-clinical Testing
Due to the minor nature of changes to the current Horizon 3.0 device, only a limited amount of non-clinical testing was necessary:
- 1. Software verification & validation of the Horizon 3.0 software updates. The software modification was performed in accordance with IEC 62304 and the company's quality procedure, which is considered a well-established method via the utilization of a recognized international standard (FR Recognition Number 13-79) and the utilization of the development strategy used in the software development of the most recently cleared Horizon 3.0 device (K211389).
- 2. Performance verification of the system therapeutic delivery. Testing was performed to verify that Horizon 3.0 could reliably and safely deliver the OCD protocol, at maximum output whilst remaining within recognized safety temperature limits. The verification protocol and test limits are well-established methods via utilization of a recognized international standard (FR Recognition Number 19-46) for the safety limits and K182853 for the verification protocol.
- a. In addition to OCD protocol performance testing, the subject device (Horizon 3.0) and the primary predicate device (NeuroStar) applicating coils were modeled in COMSOL and according to Finite Element Method (FEM) and statistical analysis, the induced E-field profiles are equivalent and have an average difference of ±5% at distances of 1 to 4 cm from the coil surface. The data provided is consistent with the FDA's quidance "Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation (rTMS)."
- 3. Human Factors testing of user interface and coil positioning mechanism was performed in accordance with HE 75 and IEC 62366 and the company's quality procedure, which is considered a well-established method via the utilization of a recognized international standard (FR Recognition Number 5-57 and 5-114) and the utilization of the validation strategies used in the development of the most recently cleared Horizon 3.0 device (K211389).
The testing performed is both described in the software section (Section XVIII) and performance testing section (Section XX).
No further testing for Electrical Safety, Mechanical Safety, Electromagnetic Compatibility, Alarm Systems and Biocompatibility was necessary as previous data submitted as part of K211389 premarket notification remains valid to demonstrate safety and effectiveness and support a determination of substantial equivalence. This is re-iterated in Sections XII, XIV, XVII and XIX.
# Substantial Equivalence
Horizon 3.0 device changes are limited to updates to the IFU and software for user interface and treatment stimulation parameters. Both these changes are made to facilitate safe and effective treatment of patients with OCD and do not raise new or different questions of safety and effectiveness. Information on these changes can be found in the software section, Section XVIII.
Where the labelling has been updated, this has been performed appropriately to identify various contraindications and instructions relevant to the usage of the device for treatment of
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OCD as per special controls. Confirmed to be equivalent to that of the reference predicate (K193006), the well-established method used to update the labeling to extend the indication to include OCD does not raise new or different questions regarding safety and effectiveness. Labelling can be found in Section XV.
The focus component of both the subject device and the primary predicate device when considering the extension to the indication to include OCD is the stimulating coil.
Whilst the coil construction characteristics of the Ez Cool Coil and the NeuroStar Advanced Therapy are different, the magnetic field characteristics of the coils are equivalent which is pertinent to treatment delivery effectiveness. Earlier in K143531, the FDA determined that Magstim figure of eight stimulating coils are substantially equivalent to the NeuroStar Advanced Therapy System coil for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from medication in the current episode. This decision was later further substantiated in a retrospective open-label study titled "Comparative Efficacy of Repetitive Transcranial Magnetic Stimulation for Treatment of Depression Using 2 Different Stimulation Devices: A Retrospective Open-Label Study" where the authors Oliveira-Maia, Garcia-Guarniz, et al, conclude in that there was no statistically significant differences between outcomes in Magstim and NeuroStar treated patients which is suggestive of equivalent antidepressant efficacy between devices.1
To further substantiate this argument, the Horizon 3.0 Ez Cool Coil and the NeuroStar Advanced Therapy Coil were modeled in COMSOL and according to the finite element modelling (FEM) and statistical analysis, the induced E-field profiles by the Horizon 3.0 Ez Cool Coil and NeuroStar Advanced Therapy Coil are equivalent and have an average difference of ±5% at distances of 1 to 4 cm from the coil surface. The modeling method is based on well-established scientific methods, equivalent to those used to demonstrate equivalence for the reference predicate (K193006). For further information on the modelling, please refer to Section XX.
Coil positioning mechanism is identical to that of the Primary Predicate (K211389) where non-clinical testing according to international standard JEC 62366-1 (5-114) and HE 75 (5-57) has demonstrated that representative TMS users, after a brief training session, were able to appropriately position the coil for treatment, and follow the recommended treatment definition protocol with low variability between position. Human factors testing information can be found in Section XX.
Thus, in summary, as an adjunct for the treatment of OCD, the Horizon 3.0 figure of eight stimulating coil is considered equivalent to the NeuroStar Advanced Therapy System coil cleared by the FDA in K212289 and does not raise new or different questions of safety and effectiveness.
All other aspects of the device compared to the currently marketed Horizon 3.0 device remain unchanged and are identical.
#### Conclusion
<sup>1 (</sup>Garcia-Guarniz AL, Sinanis A, Pascual-Leone A, Press D. Comparative efficacy of repettive transcranial magnetic stimulation for treatment of depression using 2 different stimulation devices: A refrospective open-label study. J Clin Psychiatry 2016;77:e743.)
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In summary, the intended use and indications for use for Horizon 3.0 and it predicate devices are identical.
The minor modifications to Horizon 3.0 to extend the indications for use do not raise new or different questions regarding safety and effectiveness. Where non-clinical testing was performed, this was performed according to well established methods recognized either as an FDA recognized standard, FDA guidance document, scientific literature or via an approach previously accepted by the FDA.
Although the indications have been modified, the overall operating principles of TMS devices for stimulating the cerebral cortex remains the same. Regardless of indication, the same type of energy output is used and the same principles apply to determining a MT hotspot and positioning of the coil for delivery of brief duration, rapidly alternating, or pulsed, magnetic fields to induce electrical currents that are directed at spatially discrete regions of the cerebral cortex. The Physical State, Technical Method and Target Area for both OBP and QCI devices are equivalent in themselves.
Non-clinical test data collected via well-established methods demonstrates that Horizon 3.0 is as safe and effective as its predicate devices (K211389 and K212289).
Thus, the information and data provided in this 510(k) premarket notification submission support a finding of substantial equivalence for the Horizon 3.0 for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
A tabular comparison of device characteristics can be found on the following page.
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| Criteria | Horizon 3.0 TMS Therapy System<br>(Subject of this submission) | HORIZON 3.0 TMS Therapy System<br>(K211389)<br>(Secondary Predicate) | NeuroStar Advanced Therapy System<br>(K212289)<br>(Primary Predicate) | Magventure TMS Therapy System<br>(K193006)<br>(Reference Predicate) |
|--------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Magstim Company Limited | Magstim Company Limited | Neuronetics, Inc. | Tonica Elektronik A/S |
| Device Name | Horizon 3.0 TMS Therapy System | Horizon 3.0 TMS Therapy System | NeuroStar TMS Therapy System | Magventure TMS Therapy System |
| Clearance date | | 09/14/2021 | 05/06/2022 | 08/09/2020 |
| 510(k) number | K222171 | K211389 | K212289 | K193006 |
| Device code | OBP, QCI | OBP | QCI | QCI |
| Intended Indications Use/<br>Use for | The Horizon 3.0 TMS Therapy System is<br>indicated for the treatment of Major<br>Depressive Disorder in adult patients who<br>have failed to receive satisfactory<br>improvement from prior antidepressant<br>medication in the current episode, as wellas an adjunct for the treatment of adult<br>patients suffering from Obsessive-<br>Compulsive Disorder (OCD). | The Horizon 3.0 TMS Therapy<br>System is indicated for the treatment<br>of Major Depressive Disorder in adult<br>patients who have failed to receive<br>satisfactory improvement from prior<br>antidepressant medication in the<br>current episode. | The NeuroStar Advanced<br>Therapy System is intended to<br>be used as an adjunct for the<br>treatment of adult patients<br>suffering from Obsessive-<br>Compulsive Disorder (OCD). | The MagVenture TMS Therapy<br>System is intended to be used<br>as an adjunct for the treatment<br>of adult patients suffering from<br>Obsessive-Compulsive Disorder<br>(OCD). |
| | | OCD Treatment Protocol | | |
| Magnetic Field Intensity | 100% of the MT | N/A | 100% of the MT | 100% of the MT |
| Stimulus Frequency | 20 Hz | N/A | 20 Hz | 20 Hz |
| Stimulus duration | 2 sec | N/A | 2 sec | 2 sec |
| Inter-train interval | 20 sec | N/A | 20 sec | 20 sec |
| Number of trains | 50 | N/A | 50 | 50 |
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| Magnetic Pulses<br>per Session | 2000 | N/A | 2000 | 2000 | | | | | | | | | |
|-----------------------------------|---------------------------------------------------------------|----------------------------------------|---------------------------------------------------------------|---------------------------------------------------------------|---------------------------------------------------|-------------------------------------|-------------------------------------|----------------------------------|-------------------------|----------------------------|----------------------------------|----------------------------|--------------------|
| Treatment<br>Session Duration | 18.3 min | N/A | 18.3 min | 18.0 min | Train Duration | 2 sec | 2 sec | N/A | N/A | N/A | N/A | N/A | N/A |
| Sessions/week | 5 | N/A | 5 | 5 | Inter-train Interval | 8 sec | 8 sec | N/A | N/A | N/A | N/A | N/A | N/A |
| Treatment<br>Schedule | 5 daily sessions for 5 weeks, 4 daily<br>sessions for 1 week. | N/A | 5 daily sessions for 5 weeks,<br>4 daily sessions for 1 week. | 5 daily sessions for 5 weeks,<br>4 daily sessions for 1 week. | Burst Pulses | 3 | 3 | N/A | N/A | N/A | N/A | N/A | N/A |
| Area of brain to be<br>stimulated | Dorsomedial Prefrontal Cortex | N/A | Dorsomedial Prefrontal<br>Cortex | Dorsomedial Prefrontal<br>Cortex | Bursts | 200 | 200 | N/A | N/A | N/A | N/A | N/A | N/A |
| Standard Treatment Protocol | | | | | Pulse Inter interval | 20 msec | 20 msec | N/A | N/A | N/A | N/A | N/A | N/A |
| Magnetic<br>Intensity | 120% of the MT | 120% of the MT | N/A | N/A | Number of trains | 20 | 20 | N/A | N/A | N/A | N/A | N/A | N/A |
| Stimulus<br>Frequency | 10 Hz | 10 Hz | N/A | N/A | Number of Pulses per Session | 600 | 600 | N/A | N/A | N/A | N/A | N/A | N/A |
| Stimulus<br>duration | 4 sec | 4 sec | N/A | N/A | Treatment Session Duration | 3.09 min | 3.09 min | N/A | N/A | N/A | N/A | N/A | N/A |
| Inter-train interval | 11-26 sec | 11-26 sec | N/A | N/A | Sessions/week | 5 | 5 | N/A | N/A | N/A | N/A | N/A | N/A |
| Number of trains | 75 | 75 | N/A | N/A | Treatment Schedule | 5 daily sessions for 6 weeks | 5 daily sessions for 6 weeks | N/A | N/A | N/A | N/A | N/A | N/A |
| Magnetic Pulses<br>per Session | 3000 | 3000 | N/A | N/A | Area of brain to be stimulated | Left Dorsolateral Prefrontal Cortex | Left Dorsolateral Prefrontal Cortex | N/A | N/A | N/A | N/A | N/A | N/A |
| Treatment<br>Session Duration | 18.8 min-37.5 min | 18.8 min-37.5 min | N/A | N/A | | Horizon® MT Remote Coil | Horizon® 3.0 E-z Cool Coil | Horizon® 3.0 E-z Cool Coil (Nav) | Horizon® MT Remote Coil | Horizon® 3.0 E-z Cool Coil | Horizon® 3.0 E-z Cool Coil (Nav) | NeuroStar Stimulating Coil | Cool D-B80 |
| Sessions/week | 5 | 5 | N/A | N/A | Waveform | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic |
| Treatment<br>Schedule | 5 daily sessions for 6 weeks | 5 daily sessions for 6 weeks | N/A | N/A | Core Material | Air | Air | Air | Air | Air | Air | Ferromagnetic Core | Air, Liquid Cooled |
| Area of brain to be<br>stimulated | Left Dorsolateral Prefrontal Cortex | Left Dorsolateral Prefrontal<br>Cortex | N/A | N/A | Pulse Width | 330μς | 340μς | 340μς | 330μς | 340μς | 340μς | 180μς | 290μς |
| iTBS Treatment Protocol | | | | | Amplitude in SMT units (Standard Motor Threshold) | 0.28 - 1.9 | 0.28 - 1.9 | N/A | N/A | N/A | N/A | 0.22 - 2.08 | 0 - 1.9 |
| Stimulation<br>Intensity | 120% of the MT | 120% of the MT | N/A | N/A | | | | | | | | | |
| Repetition Rate | 50 Hz (5 pulses per sec) | 50 Hz (5 pulses per sec) | N/A | N/A | | | | | | | | | |
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| Frequency range (Hz) at 100% | Pulse train duration range (sec) | Inter-train interval range (sec) | Maximum # of pulses per session (cumulative exposure) | Maximum output amplitude (V/m) at a depth of 2cm below the coil surface | Maximum magnetic field strength (T) at coil surface | Maximum magnetic field strength (T) at a depth of 2cm | Maximum magnetic field gradient (dB/dt) (kT/s) at coil surface | Maximum magnetic field gradient (dB/dt) (kT/s) at a depth of 2cm |
|------------------------------|----------------------------------|----------------------------------|-------------------------------------------------------|-------------------------------------------------------------------------|-----------------------------------------------------|-------------------------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------|
| 1 - 20 | 0.1 - 600 | 1 - 540 | 60000 | 150 V/m | 1.0T | 0.4T | 18 kT/s | 10 kT/s |
| 1 - 20 | 0.1 - 600 | 1 - 540 | 60000 | 150 V/m | 1.0T | 0.4T | 18 kT/s | 10 kT/s |
| 0.1 - 30 | 1-20 | 10-60 | 5000 | 135 V/m nominal | 0.7T | 0.5T | 27 kT/s | 11 kT/s |
| 0.1 - 30 | Unknown | Unknown | Unknown | Unknown | 1.0T | Unknown | 31 kT/s | 11 kT/s |
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| System<br>Configuration | Coil<br>Principle for OCD | Horizon 3.0 | Horizon 3.0 with<br>StimGuide+ | MT Response<br>Principle for OCD | NeuroStar Advanced<br>Therapy System | MagVenture TMS<br>Therapy System |
|---------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------|---------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Indirect targeting<br>of treatment<br>target through<br>measured<br>distance and<br>direction (4cm<br>anterior) from Leg<br>MT Hotspot.<br>Measure derived<br>from statistical<br>distance of<br>DMPFC/ACC<br>from MT hotspot. | Indirect targeting<br>of treatment<br>target through<br>measured<br>distance and<br>direction (4cm)<br>from Leg MT<br>Hotspot using<br>stereotactic<br>navigation.<br>Measure derived<br>from statistical<br>distance of<br>DMPFC/ACC<br>from MT hotspot. | N/A | Visual qualitative monitoring for APB<br>response | Indirect targeting of<br>treatment target through<br>measured distance and<br>direction (4cm anterior) from<br>Leg MT Hotspot using<br>contact sensing and head<br>support system. Measure<br>derived from statistical<br>distance of DMPFC/ACC<br>from MT hotspot. | Indirect targeting of<br>treatment target through<br>measured distance and<br>direction (4cm anterior) from<br>Leg MT Hotspot using<br>contact sensing and head<br>support system. Measure<br>derived from statistical<br>distance of DMPFC/ACC<br>from MT hotspot. |
| Coil Positioning and MT Determination Principle for MDD | Coil<br>Principle for MDD | Horizon 3.0 | Horizon 3.0 with<br>StimGuide+ | Coil<br>Principle for MDD | NeuroStar Advanced<br>Therapy System | MagVenture TMS<br>Therapy System |
| | Indirect targeting<br>of treatment<br>target through<br>measured<br>distance and<br>direction (5.5cm)<br>from MT Hotspot.<br>Measure derived<br>from statistical<br>distance of<br>DLPFC from MT<br>hotspot. | Indirect targeting<br>of treatment<br>target through<br>measured<br>distance and<br>direction (5.5cm)<br>from MT Hotspot<br>using<br>stereotactic<br>navigation.<br>Measure derived<br>from statistical<br>distance of<br>DLPFC from MT | N/A | | N/A | N/A |
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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.
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.