The SOZO Pro has the following uses: For adult human patients at risk of lymphedema: A bioimpedance spectroscopy device for use on adult human patients, utilizing impedance ratios that are displayed as an L-Dex ratio that supports the measurement of extracellular volume differences between the limbs and is presented to the clinician on an L-Dex scale as an aid to their clinical assessment of lymphedema. The use of the device to obtain an L-Dex score is only indicated for patients who will have or who have had lymph nodes, from the axillary and/or pelvic regions, either removed, damaged or irradiated. The SOZO Pro is intended for adult patients living with heart failure. This device is intended for use, under the direction of a physician, for the nonitoring of patients with fluid management problems suffering from heart failure. Data from the device should be considered in conjunction with other clinical data. The SOZO Pro may be used as an adjunct to existing methods by aiding clinicians who are using Subjective Global Assessment (SGA) tools to assess patients at risk of protein-calorie malnutrition (PCM). The SOZO Pro may be further used to estimate the following body composition parameters in humans to track clinically relevant body composition parameters over time: - Fat mass - Fat-free mass - Total body water - Intracellular fluid - Extracellular fluid - Skeletal muscle mass - The following outputs are also presented: - Body Mass Index (BMI) - Basal metabolic rate (BMR; based on Mifflin St. Jeor's algorithm) displayed in calories per day - Protein and mineral (also known as 'dry lean mass') represents the content of a body that is not fat or fluid; calculated by subtracting total body water weight from fat-free mass weight. The SOZO Pro device measures current (I), voltage (V) and phase angle (Phi), and from these values calculates resistance (R), reactance (Xc), and impedance (Z), which are used to estimate the above body composition parameters. The device' software will also display the Cole plot, subject height, weight, age and sex.
Device Story
Bioimpedance spectroscopy device; measures body composition and fluid status. Inputs: patient weight (via integrated scale or manual entry), current (200µA RMS), voltage, and phase angle across 256 frequencies (3kHz-1000kHz) via stainless-steel hand/foot electrodes. Operation: device applies electrical energy; measures impedance, resistance, and reactance; calculates body composition parameters and L-Dex ratio. Used in clinical settings under physician direction. Output: L-Dex score, Cole plot, and body composition metrics displayed on Android tablet via Bluetooth-connected app. Data synced to cloud-based 'MySOZO' database. Clinicians use outputs as adjunct to clinical assessment for lymphedema, heart failure fluid management, and malnutrition risk. Benefits: non-invasive tracking of fluid and body composition changes over time.
Clinical Evidence
Bench testing only. Performance verified via electrical safety/EMC (IEC 60601), biocompatibility (ISO 10993), and scale verification (NIST Handbook 44/EU Directive 2014/31/EU). Functional performance testing compared modified SOZO Pro to predicate SOZO using fixed loads to ensure consistent accuracy/precision. Compatibility with pacemakers/ICDs verified per ISO 14117.
Indicated for adult patients at risk of lymphedema (post-axillary/pelvic lymph node removal, damage, or irradiation) to aid clinical assessment via L-Dex ratio; adult patients with heart failure for monitoring fluid management; and adult patients at risk of protein-calorie malnutrition as an adjunct to SGA tools. Also used to track body composition parameters (fat mass, fat-free mass, total body water, intracellular/extracellular fluid, skeletal muscle mass, BMI, BMR, and dry lean mass) over time.
Regulatory Classification
Identification
An impedance plethysmograph is a device used to estimate peripheral blood flow by measuring electrical impedance changes in a region of the body such as the arms and legs.
Special Controls
*Classification.* Class II (special controls). The device, when it is a body composition analyzer which is not intended to diagnose or treat any medical condition, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the FDA logo is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
October 17, 2023
ImpediMed Limited Richard Hines Senior Manager of Regulatory Affairs 5900 Pasteur Court, Unit 125 Carlsbad, California 92008
Re: K232089 Trade/Device Name: SOZO Pro Regulation Number: 21 CFR 870.2770 Regulation Name: Impedance Plethysmograph Regulatory Class: II Product Code: DSB Dated: June 5, 2023 Received: July 19, 2023
Dear Richard Hines:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov
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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
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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,
# Gema Gonzalez -S
Maura Rooney Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of Gastrorenal, ObGyn, General Hospital, and Urology 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) K232089
Device Name SOZO Pro
Indications for Use (Describe) The SOZO Pro has the following us es:
For adult human patients at risk of lymphedema:
A bioimpedance spectroscopy device for use on adult human patients, utilizing impedance ratios that are displayed as an L-Dex ratio that supports the measurement of extracel lular volume differences between the limbs and is presented to the clinician on an L-Dex scale as an aid to their clinical as sessment of lym phedema.
The use of the device to obtain an L-Dex score is only indicated for patients who will have or who have had lymph nodes, from the axillary and/or pelvic regions, either removed, damaged or irradiated.
The SOZO Pro is intended for adult patients living with heart failure.
This device is intended for use, under the direction of a physician, for the nonitoring of patients with fluid management problems suffering from heart frilure. Data from the device should be considered in conjunction with other clinical data.
The SOZO Pro may be used as an adjunct to existing methods by aiding clinicians who are using Subjective Global Assessment (SGA) tools to assess patients at risk of protein-calorie malnutrition (PCM).
The SOZO Pro may be further used to estimate the following body composition parameters in humans to track clinically relevant body composition parameters over time:
- · Fat mass
- · Fat-free mass
- · Total body water
- · Intracellular fluid
- · Extracellular fluid
- · Skeletal muscle mass
- The following outputs are also presented:
- · Body Mass Index (BMI)
- · Basal metabolic rate (BMR; based on Mifflin St. Jeor's algorithm) dis played in calories per day
· Protein and mineral (also known as 'dry lean mass') represents the content of a body that is not fat or fluid; calculated by subtracting total body water weight from fat-free mass weight.
The SOZO Pro device measures current (I), voltage (V) and phase angle (Phi), and from these values calculates resistance (R), reactance (Xc), and impedance (Z), which are used to estimate the above body composition parameters. The device' software will also display the Cole plot, subject height, weight, age and sex.
Type of Use (Select one or both, as applicable)
× 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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# impedimed®
K232089 Page 1 of 4
### Traditional 510(k) SUMMARY
#### ImpediMed SOZO Pro
#### Submitter
| ImpediMed Limited<br>Unit 1<br>50 Parker Court<br>Pinkenba, Qld 4008<br>Australia | |
|-------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------|
| Phone: | 760 585 2104 |
| Facsimile: | 760 804 9425 |
| Contact Person:<br>Contact Email: | Richard Hines<br>rhines@impedimed.com |
| Date Prepared: | August 30, 2023 |
| Name of Device: | SOZO Pro® |
| Common or Usual Name | Body Fluid Analyzer |
| Regulation Number | 21 CFR §870.2770 |
| Regulation Name | Impedance Plethysmograph |
| Regulatory Class | II |
| Product Code: | DSB (Cardiac Electrophysiology, Diagnostics and Monitoring) |
| Predicate Device:<br>Reference Device #1:<br>Reference Device #2:<br>Reference Device #3: | SOZO® (K203473)<br>SOZO Pro (K230530)<br>SOZO Pro (K230531)<br>Bodyport Cardiac Scale (K211585) |
#### Purpose of the Special 510(k) Notice
The purpose of the 510(k) is to clear the SOZO Pro device which is a modification of the predicate K203473 SOZO device to include a weight scale to allow for patient weights to be measured directly with the device, along with updates to the stand hardware and electrodes. Software updates were included to integrate the scale and weight measurement capabilities.
## impedimed
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#### Indications for Use
The SOZO Pro has the following uses:
The SOZO Pro is intended for adult patients living with heart failure.
This device is intended for use, under the direction of a physician, for the nonitoring of patients with fluid management problems suffering from heart failure. Data from the device should be considered in conjunction with other clinical data.
For adult human patients at risk of Ivmphedema:
A bioimpedance spectroscopy device for use on adult human patients, utilizing impedance ratios that are displayed as an L-Dex ratio that supports the measurement of extracellular volume differences between the limbs and is presented to the clinician on an L-Dex scale as an aid to their clinical assessment of lymphedema.
The use of the device to obtain an L-Dex score is only indicated for patients who will have or who have had lymph nodes, from the axillary and/or pelvic regions, either removed, damaged or irradiated.
The SOZO Pro may be used as an adjunct to existing methods by aiding clinicians who are using Subjective Global Assessment (SGA) tools to assess patients at risk of protein-calorie malnutrition (PCM).
The SOZO Pro may be further used to estimate the following body composition parameters in humans to track clinically relevant body composition parameters over time:
- Fat mass
- Fat-free mass
- Total body water
- Intracellular fluid
- Extracellular fluid
- Skeletal muscle mass
- The following outputs are also presented:
- Body Mass Index (BMI)
- · Basal metabolic rate (BMR: based on Mifflin St. Jeor's algorithm) displayed in calories per dav
• Protein and mineral (also known as 'dry lean mass') represents the content of a body that is not fat or fluid; calculated by subtracting total body water weight from fat-free mass weight.
The SOZO Pro device measures current (1), voltage (V) and phase angle (Phi), and from these values calculates resistance (R), reactance (Xc), and impedance (Z), which are used to estimate the above body composition parameters. The device/ software will also display the Cole plot, subject height, age and sex.
#### Device Description
The SOZO Pro system consists of a connected hand and footplate with built-in stainless-steel electrodes, paired with an Android tablet over Bluetooth connection. An app ("SOZOapp"), supplied with the tablet, controls the functionality of the hardware, and supplies the bioimpedance measurement data to a database ("MySOZO") managed on an external cloud- hosted database. Patient weight is measured with load cells located in the SOZO Pro foot unit or can be hand entered.
Bioimpedance measurements require the patient's weight to be measured by a scale embedded in the base of the system or for the weight of the patient to be entered manually. Following the collection of the patient weight, the patient contacts the SOZO Pro with their bare hands and feet on stainless steel electrodes. The impedance measurement takes about 30 seconds, during which the SOZO Pro® system applies small levels of electrical energy (200μA RMS) to the body across 256 frequencies spaced from 3kHz to 1000kHz and measures the resulting voltage levels.
# impedimed
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### Technological Characteristics
Bioimpedance spectroscopy is the technological principle for both the subject and predicate devices. The subject and predicate devices are based on the following same fundamental technological elements:
ം Use of electrodes to take measurements; two channels are used to measure each side of the body.
o Delivery of very low levels of current (200µA RMS) across 256 frequencies logarithmically spaced from 3kHz to 1000kHz.
ം Measure patient weight, current (l), voltage (V) and phase angle (Ph) and calculates three bioimpedance parameters: impedance (Z), resistance (R) and reactance (Xc) to estimate extracellular fluid, intracellular fluid, and total body water.
ം Data is stored in and accessed from a cloud-based database (MySOZO) using a web browser interface. SOZO Pro is controlled through an Android app ("SOZOapp") on a supplied tablet, which is paired to the SOZO Pro hardware over Bluetooth connection and connects with the MySOZO database over Wi-Fi.
impedimed
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#### Performance Data
The SOZO Pro system has gone through appropriate testing per design controls to confirm functionality and performance of the indications.
Electrical safety/EMC: testing was performed according to the requirements set forth in IEC 60601 (subparts -1, -1-2, and -1-6). It was determined that the SOZO Pro device meets electrical safety and EMC requirements, and CB certificate was granted for the system.
Software V&V: the SOZO Pro same level of concern software documentation as the predicate device was created and testing performed in accordance with ISO 62304. The software was verified and validated to meet acceptance criteria and perform as intended.
Biocompatibility: testing was performed by an accredited third party according to the requirements set forth in ISO 10993 for a low risk, limited contact device. It was determined that the patient contact areas of SOZO Pro system passed biocompatibility testing with no failures reported as they are unchanged from the predicate.
Functional performance: performance testing was undertaken using fixed loads and comparing modified SOZO Pro to predicate SOZO measurements to demonstrate that outputs remained consistently accurate and precise.
Weight Scale Verification: Scale verification testing for SOZO Pro was performed in accordance with the NIST Handbook 44 (2022 Edition) and EU Directive 2014/31/EU for non-automatic weighing instruments. Scale verification testing experienced no failures.
Active implantable pacemakers and ICD compatibility: SOZO Pro illustrated compatibility to a variety of pacemakers and implantable cardioverter defibrillators per the test methods described in ISO 14117.
#### Substantial Equivalence
The modified SOZO Pro has the same intended use and similar indications, principles of operation, and technological characteristics as its predicate device. The differences in the SOZO Pro device's technological characteristics to the predicate SOZO device do not raise any new questions of safety or effectiveness:
#### Conclusions
Testing discussed above demonstrates that the modified SOZO Pro device is as safe and effective and performs as well as or better than the predicate device.
# impedimed
510(k) Summary 4 of 4
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.