K223867 · Immunodiagnostic Systems Limited · CKG · Aug 18, 2023 · Clinical Chemistry
Device Facts
Record ID
K223867
Device Name
IDS ACTH II
Applicant
Immunodiagnostic Systems Limited
Product Code
CKG · Clinical Chemistry
Decision Date
Aug 18, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1025
Device Class
Class 2
Indications for Use
IDS ACTH II assay is an automated in vitro diagnostic device intended for the quantitative, determination of ACTH in human K2 and K3 EDTA plasma on the IDS system. Results are to be used in conjunction with other clinical and laboratory data as an aid in the assessment of pituitary and adrenal gland function and the differential diagnosis of hyper- and hypo-cortisolism.
Device Story
IDS ACTH II is an automated in vitro diagnostic assay for quantitative measurement of ACTH in human K2 and K3 EDTA plasma. The device uses a sandwich chemiluminescence immunoassay protocol on the IDS-iSYS Multi-Discipline Automated System. The reagent cartridge includes magnetic particles coated with mouse monoclonal anti-ACTH antibody, an acridinium ester-labeled mouse monoclonal anti-ACTH antibody, and buffer. The system processes the sample, performs the immunoassay, and provides a quantitative result in pg/mL. It is intended for use in clinical laboratories by trained personnel. Healthcare providers use the ACTH concentration results, alongside other clinical and laboratory data, to assess pituitary and adrenal gland function and diagnose hyper- or hypo-cortisolism. The device provides a standardized, automated method for ACTH testing, facilitating clinical decision-making regarding adrenal and pituitary disorders.
Clinical Evidence
Bench testing only. Performance evaluated per CLSI guidelines: LoB (0 pg/mL), LoD (1 pg/mL), LoQ (3 pg/mL). Linearity confirmed 4–1000 pg/mL. Precision (repeatability/reproducibility) evaluated across 5 samples; CVs generally <10% at higher concentrations. Interference testing showed no significant bias (≤±10%) for common substances (bilirubin, biotin, hemoglobin, HAMA, RF, etc.) up to specified thresholds. Cross-reactivity with related peptides (POMC, endorphins, MSH, ACTH fragments) was negligible. Method comparison (N=170) against a commercial automated assay showed high correlation (r=1.0, slope 1.0). Matrix comparison (N=55) confirmed equivalence between K2 and K3 EDTA plasma.
Indicated for quantitative determination of ACTH in human K2 and K3 EDTA plasma to aid in assessment of pituitary and adrenal gland function and differential diagnosis of hyper- and hypo-cortisolism. No specific age or gender restrictions provided.
Regulatory Classification
Identification
An adrenocorticotropic hormone (ACTH) test system is a device intended to measure adrenocorticotropic hormone in plasma and serum. ACTH measurements are used in the differential diagnosis and treatment of certain disorders of the adrenal glands such as Cushing's syndrome, adrenocortical insufficiency, and the ectopic ACTH syndrome.
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FDA
U.S. FOOD & DRUG
ADMINISTRATION
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
ASSAY ONLY
## I Background Information:
A 510(k) Number
K223867
B Applicant
Immunodiagnostic Systems Limited
C Proprietary and Established Names
IDS ACTH II
D Regulatory Information
| Product Code(s) | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| CKG | Class II | 21 CFR 862.1025 - Adrenocorticotropic Hormone (ACTH) Test System | CH - Clinical Chemistry |
## II Submission/Device Overview:
A Purpose for Submission:
New Device
B Measurand:
Adrenocorticotropic hormone (ACTH)
C Type of Test:
Quantitative electrochemiluminescence immunoassay
Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
www.fda.gov
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K223867 - Page 2 of 8
## III Intended Use/Indications for Use:
### A Intended Use(s):
See Indications for Use below.
### B Indication(s) for Use:
IDS ACTH II assay is an automated in vitro diagnostic device intended for the quantitative, determination of ACTH in human K2 and K3 EDTA plasma on the IDS system. Results are to be used in conjunction with other clinical and laboratory data as an aid in the assessment of pituitary and adrenal gland function and the differential diagnosis of hyper- and hypo-cortisolism.
### C Special Conditions for Use Statement(s):
Rx - For Prescription Use Only
### D Special Instrument Requirements:
IDS-iSYS Multi-Discipline Automated Analyzer
## IV Device/System Characteristics:
### A Device Description:
Components of the candidate device include:
- Magnetic particles coated with mouse monoclonal anti-ACTH antibody and buffer containing phosphate with blocking proteins and ProClin 300 as preservative (<0.1%), 1 bottle, 2.5 mL
- Mouse monoclonal anti-ACTH antibody labeled with an acridinium ester derivative, in buffer containing phosphate with BSA and ProClin 300 as preservative (<0.1%), 1 bottle, 6.5 mL
- Buffer containing phosphate with blocking proteins and ProClin 300 as preservative (<0.1%), 1 bottle, 3.5 mL
- A mini-CD containing documentation
### B Principle of Operation:
The assay is based on chemiluminescence technology. 150 µL of patient sample or calibrators are incubated with monoclonal anti-ACTH antibody-coated magnetic particles. Following the first incubation step, an acridinium-labeled ACTH antibody conjugate is added, followed by a subsequent incubation step. The magnetic particles are captured using a magnet, and a wash step is performed to remove any unbound analyte. Trigger reagents are added; the resulting light emitted by the acridinium label is proportional to the concentration of analyte in the original sample.
### V Substantial Equivalence Information:
#### A Predicate Device Name(s):
Roche Elecsys- ACTH
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B Predicate 510(k) Number(s):
K060585
C Comparison with Predicate(s):
| Device & Predicate Device(s): | K223867 | K060585 |
| --- | --- | --- |
| Device Trade Name | IDS ACTH II | Roche Elecsys - ACTH |
| General Device Characteristic Similarities | | |
| Intended Use/ | Quantitative determination of ACTH in human EDTA plasma | Same |
| Test Method | Electrochemiluminescence | Same |
| General Device Characteristic Differences | | |
| Sample Type | K2- and K3-EDTA plasma | K3-EDTA plasma |
| Measuring Range | 4-1000 pg/mL | 1-2000 pg/mL |
| Sample Volume | 150 μL | 50 μL |
VI Standards/Guidance Documents Referenced:
CLSI EP05-A3: Evaluation of Precision of Quantitative Measurement Procedures
CLSI EP07, 3rd Ed.: Interference Testing in Clinical Chemistry
CLSI EP09c, 3rd Ed.: Measurement Procedure Comparison and Bias Estimation Using Patient Samples
CLSI EP17-A2: Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures
CLSI EP28-A3c: Defining, Establishing, and Verifying Reference Intervals in the Clinical Laboratory
CLSI EP35, 1st Ed.: Assessment of Equivalence or Suitability of Specimen Types for Medical Laboratory Measurement Procedures
CLSI EP37, 1st Ed.: Supplemental Tables for Interference Testing in Clinical Chemistry
VII Performance Characteristics (if/when applicable):
A Analytical Performance:
1. Precision/Reproducibility:
Precision studies were conducted using five K3-EDTA plasma samples. Within-run precision was established by testing one reagent lot on one analyzer by two operators, over 20 days, with two runs per day and two replicates per run, for a total of 80 replicates per sample.
K223867 - Page 3 of 8
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Reproducibility was established by testing one reagent lot by three operators, one operator per each of three analyzers, over five days, with five replicates per run, for a total of 75 replicates per sample. Lot-to-lot precision was established by testing three reagent lots on one analyzer by one operator, over five days, with five replicates per run, for a total of 75 replicates per sample.
The results of the 20-day precision study are shown in the table below.
| Sample ID | N | Mean Conc. (pg/mL) | Repeatability | | Within Laboratory | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | SD | CV% | SD | CV% |
| 1 | 80 | 6 | 0.8 | - | 1.5 | - |
| 2 | 80 | 13 | 0.7 | 5.3% | 1.6 | 12.8% |
| 3 | 80 | 81 | 0.9 | 1.2% | 2.5 | 3.1% |
| 4 | 80 | 215 | 3.1 | 1.4% | 5.3 | 2.5% |
| 5 | 80 | 616 | 5.5 | 0.9% | 10.5 | 1.7% |
The results of the 5-day reproducibility studies are shown in the table below.
| Reproducibility | | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| Sample ID | N | Mean Conc. (pg/mL) | Repeatability | | Reproducibility | |
| | | | SD | CV% | SD | CV% |
| 1 | 75 | 4 | 0.6 | - | 1.0 | - |
| 2 | 75 | 17 | 0.6 | 3.6% | 1.2 | 7.2% |
| 3 | 75 | 59 | 1.5 | 2.5% | 3.5 | 6.0% |
| 4 | 75 | 213 | 2.9 | 1.4% | 9.3 | 4.4% |
| 5 | 75 | 615 | 7.5 | 1.2% | 27.8 | 4.5% |
| Lot-to-lot precision | | | | | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Sample ID | N | Mean Conc. (pg/mL) | Repeatability | | Within Laboratory | | Reproducibility | |
| | | | SD | CV% | SD | CV% | SD | CV% |
| 1 | 75 | 4 | 0.8 | - | 1.4 | - | 2.0 | - |
| 2 | 75 | 17 | 0.7 | 4.1 | 0.9 | 5.5 | 1.8 | 10.9 |
| 3 | 75 | 61 | 0.8 | 1.3 | 1.5 | 2.5 | 1.9 | 3.2 |
| 4 | 75 | 217 | 1.7 | 0.8 | 4.1 | 1.9 | 7.6 | 3.5 |
| 5 | 75 | 645 | 3.8 | 0.6 | 7.3 | 1.1 | 31.8 | 4.9 |
2. Linearity:
The linearity study was performed with reference to the protocols in CLSI EP06-A2 using series dilutions by mixing different proportion of the high and low samples with four replicates per sample. The data was analyzed using a linear regression. The maximum deviation from linearity observed within the claimed measuring range was 11.1%. The results support the claimed measuring range of 4 to 1000 pg/mL.
3. Analytical Specificity/Interference:
K223867 - Page 4 of 8
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The analytical specificity of the IDS ACTH II assay on the IDS-iSYS Multi-Discipline Automated Analyzer was established by conducting interference testing following the recommendations in CLSI EP07 third edition guideline.
Interference from endogenous and exogenous substances was assessed using plasma samples containing ACTH at 15 pg/mL and 200 pg/mL. Each sample was further divided into two aliquots: a test sample (with added interferent) and a control sample (with no added interferent). Each sample was tested in a minimum of 4 replicates. The difference between the mean concentration of the test and control sample were calculated. The following table lists the highest concentration of each substance at which no significant interference was found, defined as a difference of less than or equal to ±10% between the test sample and control.
| Interferent | Highest interferent concentration tested that showed no significant interference |
| --- | --- |
| Triglycerides | 1500 mg/dL |
| Hemoglobin | 62.5 mg/dL |
| Bilirubin, unconjugated | 40 mg/dL |
| Bilirubin, conjugated | 40 mg/dL |
| Protein (total) | 15 g/dL |
| Rheumatoid Factor | 324 IU/mL |
| HAMA | 1000 ng/mL |
| Biotin | 3.5 μg/mL |
| Acetaminophen | 15.6 mg/dL |
| Acetylsalicylic acid | 3 mg/dL |
| Ampicillin | 7.5 mg/dL |
| Ibuprofen | 21.9 mg/dL |
| Dexamethasone | 1.2 mg/dL |
| Metyrapone | 1.8 mg/L |
The following statements are included as limitations in the device labeling:
The lowest Hemoglobin level that does not significantly interfere (≤±10% bias) with the assay is 62.5 mg/dL. Visual hemolysis in the sample is typically already seen in samples with hemoglobin concentration of 50 mg/dL or greater [Hemolysis_Palette_Bookmark-P.pdf (cdc.gov)]. Visibly hemolyzed samples must not be used with IDS ACTH II assay.
As with all tests containing monoclonal mouse antibodies, erroneous findings may be obtained from samples taken from patients who have been treated with monoclonal mouse antibodies or who have received them for diagnostic purposes.
Heterophilic antibodies in human serum can react with reagent immunoglobulins, interfering with in vitro immunoassays. Patients routinely exposed to animals or to animal serum products can be prone to this interference and anomalous values may be observed.
The lowest Rheumatoid Factor (RF) level that does not significantly interfere (≤±10% bias) with IDS ACTH II assay is 324 IU/mL.
K223867 - Page 5 of 8
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Cholesterol interference was assessed by testing plasma samples with ACTH concentrations of 30 and 500 pg/mL. Each sample was further divided into two aliquots: a test sample (with added interferent) and a control sample (with no added interferent). Each sample was tested in 5 replicates. The difference between the mean concentration of the test and control sample was calculated. The highest level tested that demonstrated no significant interference (<10%) was 400 mg/dL.
Cross-Reactivity: Cross-reactivity was evaluated by spiking structurally similar compounds described below into ACTH-free urine. The results are summarized in the table below. No significant cross-reactivity was observed in the following compounds at the indicated concentration.
| Cross-Reactant | Concentration of cross-reactant [pg/mL] | % Cross-reactivity |
| --- | --- | --- |
| POMC | 500 | -2.1% |
| | 50,000 | 0.0% |
| | 500,000 | 0.0% |
| B-endorphin | 500 | -2.9% |
| | 50,000 | 0.0% |
| | 500,000 | 0.0% |
| a-MSH | 500 | -3.7% |
| | 50,000 | -0.4% |
| | 500,000 | -0.1% |
| b-MSH | 500 | -4.6% |
| | 50,000 | 0.0% |
| | 500,000 | 0.0% |
| ACTH 1-17 | 500 | -1.8% |
| | 50,000 | -0.6% |
| | 500,000 | -0.1% |
| ACTH 1-24 | 500 | -5.8% |
| | 50,000 | -0.5% |
| | 500,000 | -0.1% |
| ACTH 18-39 | 500 | -6.5% |
| | 50,000 | -0.3% |
| | 500,000 | -0.1% |
| ACTH 22-39 | 500 | 4.9% |
| | 50,000 | -0.4% |
| | 500,000 | -0.1% |
| ACTH 1-10 | 500 | -7.5% |
| | 50,000 | -0.1% |
| | 500,000 | 0.0% |
| ACTH 11-24 | 500 | -7.3% |
| | 50,000 | -0.1% |
| | 500,000 | 0.0% |
K223867 - Page 6 of 8
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Studies evaluating high-dose hook effect demonstrated that samples containing ACTH concentrations up to $3 \times 10^{6} \, \mathrm{pg/mL}$ do not give falsely low results with this assay.
4. **Assay Reportable Range:**
The assay measuring interval is 4-1000 pg/mL.
The sponsor provided data to support that the measuring interval can be extended up to 1,500 mg/dL following manual dilution.
5. **Traceability, Stability, Expected Values (Controls, Calibrators, or Methods):**
The IDS ACTH II Calibrators are traceable to a commercially available ACTH assay.
6. **Detection Limit:**
Limit of blank (LoB), limit of detection (LoD), and limit of quantitation (LoQ) were determined using three reagent lots on one analyzer over three days. LoB was established with four blank samples, five replicates, once per day for three days (n = 60 replicates/lot). LoD and LoQ were established with six low level samples tested on five replicates each, once per day for three days (n = 90 replicates/lot). The claimed LoB for the IDS ACTH II is 0 pg/mL and the claimed LoD is 1 pg/mL. LoQ was determined to be 3 pg/mL as the lowest concentration measured with a within-laboratory precision CV ≤ 20%.
7. **Assay Cut-Off:**
Not Applicable
**B Comparison Studies:**
1. **Method Comparison with Predicate Device:**
A method comparison study was conducted comparing the IDS ACTH II assay (y) with the Roche Elecsys ACTH (x). A total of 170 samples were tested in duplicate using one lot of the IDS ACTH II device and tested in single replicate using one lot of the Elecsys ACTH. Only the first replicate of IDS ACTH II was used for data analysis. Data were analyzed using Passing Bablok regression analysis. Results are shown below:
| N | Concentration range (pg/mL) | Intercept | Slope | Correlation Coefficient (R) |
| --- | --- | --- | --- | --- |
| 170 | 4-997 | -0.8587 | 1.013 | 0.98 |
2. **Matrix Comparison:**
K223867 - Page 7 of 8
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Fifty-five (55) matched K2 and K3 EDTA samples were assayed in duplicates with IDS ACTH II assay. The first replicate result for each sample was used for the data analysis. Results were analyzed using Passing-Bablok regression analysis.
| Matrix | n | Range tested(pg/mL) | r | slope | intercept |
| --- | --- | --- | --- | --- | --- |
| K2EDTA Plasma vs. K3EDTA Plasma | 55 | 6 - 1228 | 1.00 | 1.027 | 1.859 |
The results demonstrate equivalency between K2EDTA plasma and K3EDTA plasma.
## C Clinical Studies:
1. Clinical Sensitivity:
Not Applicable
2. Clinical Specificity:
Not Applicable
3. Other Clinical Supportive Data (When 1. and 2. Are Not Applicable):
Not Applicable
## D Clinical Cut-Off:
Not Applicable
## E Expected Values/Reference Range:
A study was performed with IDS ACTH II device using K3 EDTA plasma samples from 140 healthy subjects aged between 21 to 80 years old. The 95% reference interval was calculated by a non-parametric method following guidance from CLSI C28-A3.
The following reference range were determined and are provided in the labeling (2.5th to 97.5th percentile): 6 – 51 pg/mL
## VIII Proposed Labeling:
The labeling supports the finding of substantial equivalence for this device.
## IX Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
K223867 - Page 8 of 8
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.