K241395 · Caerus Corporation · ILX · Dec 18, 2024 · Physical Medicine
Device Facts
Record ID
K241395
Device Name
Active System; Avenue8
Applicant
Caerus Corporation
Product Code
ILX · Physical Medicine
Decision Date
Dec 18, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5290
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Active System is intended to be worn for one two-hour treatment of 2 30-minute non-thermal shortwave diathermy treatments per day by adult users. For prescription use (Rx) only. The Avenue8 is intended to be worn for two 30-minute treatments per day by adult users. For prescription use (Rx) only.
Device Story
Active System and Avenue8 are portable, non-invasive devices delivering transcutaneous pulsed electromagnetic field (non-thermal shortwave diathermy) and thermal exchange/electronic heat therapy. Active System uses single-use OrthoPods; Avenue8 uses electronic heat. Devices are worn by adult patients for pain relief associated with over-exertion, strains, sprains, and arthritis. Operation involves induction coil energy delivery at 27.12 MHz, 2 Hz burst frequency, and 2 ms burst width. Healthcare providers prescribe the device; patients self-administer treatment. Output is non-thermal electromagnetic energy and localized heat, intended to reduce pain. Clinical benefit demonstrated via 36% pain reduction (Mankowski scale) compared to 10% in standard of care group.
Clinical Evidence
Prospective clinical study of 120 patients (Active System + SOC vs SOC alone) with superficial soft tissue pain. Primary endpoint: change in pain assessment (Mankowski scale) over 2 weeks. Results: 36% pain reduction in Active System + SOC group vs 10% in SOC group. Adverse events were mild (3.3% incidence), including shoulder pain, sleepiness, and tingling; no serious adverse events reported.
Technological Characteristics
Portable, non-invasive shortwave diathermy system. Energy source: 27.12 MHz pulsed electromagnetic field via induction coil. Thermal delivery: chemical (Active System) or electrical (Avenue8). Compliance: IEC 60601-1 (electrical safety), IEC 60601-1-2 (EMC). Output: 50 Ohm impedance, 2 Hz burst frequency, 2 ms burst width, 1.35 W peak power. Software: Basic Level of Documentation.
Indications for Use
Indicated for adjunctive use in the temporary relief of pain, such as pain associated with over-exertion, strains, sprains, and arthritis in adult patients.
Regulatory Classification
Identification
A nonthermal shortwave therapy is a prescription device that applies to the body pulsed electromagnetic energy in the RF bands of 13.56 MHz or 27.12 MHz and that is intended for adjunctive use in the palliative treatment of postoperative pain and edema of soft tissue by means other than the generation of deep heat within body tissues as described in paragraph (a) of this section.
Special Controls
*Classification: Class II (special controls).* The device is classified as class II. The special controls for this device are:(i) Components of the device that come into human contact must be demonstrated to be biocompatible.
(ii) Appropriate analysis/testing must demonstrate that the device is electrically safe and electromagnetically compatible in its intended use environment.
(iii) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use. Non-clinical performance testing must characterize the output waveform of the device and demonstrate that the device meets appropriate output performance specifications. The output characteristics and the methods used to determine these characteristics, including the following, must be determined:
(A) Peak output power;
(B) Pulse width;
(C) Pulse frequency;
(D) Duty cycle;
(E) Characteristics of other types of modulation that may be used;
(F) Average measured output powered into the RF antenna/applicator;
(G) Specific absorption rates in saline gel test load or other appropriate model;
(H) Characterization of the electrical and magnetic fields in saline gel test load or other appropriate model for each RF antenna and prescribed RF antenna orientation/position; and
(I) Characterization of the deposited energy density in saline gel test load or other appropriate model.
(iv) A detailed summary of the clinical testing pertinent to use of the device to demonstrate the effectiveness of the device in its intended use.
(v) Labeling must include the following:
(A) Output characteristics of the device;
(B) Recommended treatment regimes, including duration of use; and
(C) A detailed summary of the clinical testing pertinent to the use of the device and a summary of the adverse events and complications.
(vi) Nonthermal shortwave therapy devices marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with these special controls.
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December 18, 2024
Caerus Corporation % Jean-Marie Toher Regulatory Consultant MEDIcept Inc 200 Homer Avenue Ashland, Massachusetts 01721
Re: K241395
Trade/Device Name: Active System; Avenue8 Regulation Number: 21 CFR 890.5290 Regulation Name: Shortwave Diathermy Regulatory Class: Class II Product Code: ILX, IRT, IMD Dated: December 2, 2024 Received: December 2, 2024
Dear Jean-Marie Toher:
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 (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"
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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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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. 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).
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Sincerely,
# Vivek J. Pinto -S
Vivek Pinto, PhD, MBA 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) K241395
Device Name Active System: Avenue8
Indications for Use (Describe)
The Active System and Avenue8 are indicated for adjunctive use in the temporary relief of pain, such as pain associated with over-exertion, strains, sprains, and arthritis.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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## K241395
# CAERUS CORP
CAERUSCORP.COM 8611 W 35W SERVICE DRIVE NE, SUITE 180 BLAINE, MN 55449
## 510(k) SUMMARY
### I. SUBMITTER
| 510(k) Holder: | Caerus Corporation<br>8611 W 35W Service Dr NE Ste 180<br>Blaine MN 55449 |
|----------------|---------------------------------------------------------------------------|
|----------------|---------------------------------------------------------------------------|
- Contact Person: Jean-Marie Toher Regulatory Consultant MEDIcept, Inc. jtoher(@medicept.com
Date Prepared: December 18, 2024
#### II. DEVICES
| Trade Name: | Active System |
|----------------------|-------------------------------------------------------------------------------------------------------------------|
| Classification Name: | Shortwave Diathermy, For Use Other Than Applying Therapeutic Deep Heat |
| Regulatory Class: | Class II |
| Product Codes: | ILX - Shortwave Diathermy, For Use Other Than Applying Therapeutic Deep Heat<br>IMD - Hot Or Cold Disposable Pack |
| Trade Name: | Avenue8 |
| Classification Name: | Shortwave Diathermy, For Use Other Than Applying Therapeutic Deep Heat |
| Regulatory Class: | Class II |
| Product Codes: | ILX - Shortwave Diathermy, For Use Other Than Applying Therapeutic Deep Heat<br>IRT – Powered Heating Pad |
#### PREDICATE DEVICES III.
Primary Predicate: K121702 - OrthoCor Active Device Secondary Predicate (Active System): K092044 - OrthoCor Knee Active System Secondary Predicate (Avenue8): K202337 - HiDow Pulsed electromagnetic field wrap
#### IV. DEVICE DESCRIPTION
The Caerus Active System is a portable, compact, lightweight, non-invasive system designed to deliver transcutaneous pulsed electromagnetic field (non-thermal shortwave diathermy) and thermal exchange
Image /page/4/Picture/14 description: The image shows the logo for CAERUS. The logo features the word "CAERUS" in a sans-serif font. To the left of the word is a stylized graphic that resembles a bird's wing or a stylized leaf. The logo is presented in a monochromatic color scheme, with the text and graphic in a dark color against a light background.
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therapy. The Active System includes general use wraps and therapy is delivered with single-use OrthoPods, sold separately.
The Caerus Avenue8 device is a portable, compact, lightweight, non-invasive system designed to deliver transcutaneous pulsed electromagnetic field (non-thermal shortwave diathermy) therapy and electronic heat.
### INDICATIONS FOR USE V.
The Active System and Avenue8 are indicated for adjunctive use in the temporary relief of pain, such as pain associated with over-exertion, strains, sprains, and arthritis.
### VI. INTENDED USE
The Active System is intended to be worn for one two-hour treatment of 2 30-minute non-thermal shortwave diathermy treatments per day by adult users. For prescription use (Rx) only.
The Avenue8 is intended to be worn for two 30-minute treatments per day by adult users. For prescription use (Rx) only.
### COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE VII. DEVICE
In accordance with the 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)] issued July 28, 2014, the comparison between the predicate devices and the subject devices is shown to be substantially equivalent by comparing the indications for use, principles of operation, technological characteristics, and performance testing similarities and differences (Table 2). The technological characteristic differences do not raise different questions of safety and effectiveness than the predicate device.
## Table 1. Substantial Equivalence Subject Device Active System (K241395) Compared to the Predicate Devices OrthoCor Active Device (K121702) and OrthoCor Knee Active System (K092044)
| Characteristic | OrthoCor Active<br>System (K241395) | OrthoCor General<br>Use Device<br>(Primary Predicate)<br>K121702 | OrthoCor Active Knee<br>System (Secondary<br>Predicate)<br>K092044 | Equivalence<br>Comparison |
|--------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------|
| Regulatory<br>Class | Class II | Class II | Class II | Same |
| Regulatory<br>Number | 21 CFR 890.5290(b)<br>21 CFR 890.5710 | 21 CFR 890.5290(b)<br>21 CFR 890.5710 | 21 CFR 890.5290(b)<br>21 CFR 890.5710 | Same |
| Characteristic | OrthoCor Active<br>System (K241395) | OrthoCor General<br>Use Device<br>(Primary Predicate)<br>K121702 | OrthoCor Active Knee<br>System (Secondary<br>Predicate)<br>K092044 | Equivalence<br>Comparison |
| Regulation<br>Name | Shortwave<br>Diathermy, For Use<br>Other Than Applying<br>Therapeutic Deep<br>Heat | Shortwave<br>Diathermy, For Use<br>Other Than Applying<br>Therapeutic Deep<br>Heat | Shortwave Diathermy, For Use<br>Other Than Applying<br>Therapeutic Deep Heat | Same |
| Product Code | ILX, IMD | ILX | ILX, IMD | Similar |
| Indication for<br>use | Adjunctive use in the<br>temporary relief of<br>pain, such as pain<br>associated with over-<br>exertion, strains,<br>sprains, and arthritis. | Adjunctive use in the<br>palliative treatment<br>of postoperative<br>edema and pain in<br>superficial soft tissue | Adjunctive use in the palliative<br>treatment of postoperative<br>edema and pain in superficial<br>soft tissue. Temporary relief of<br>minor aches and pains<br>associated with overexertion,<br>strains, sprains, and arthritis. | Performance<br>testing justified<br>substantial<br>equivalence |
| Anatomical site | General Use | General Use | Knee | Similar |
| Frequency -<br>short wave | 27.12 MHz | 27.12 MHz | 27.12 MHz | Same |
| Output<br>Impedance | 50 Ohm | 50 Ohm | 50 Ohm | Same |
| Burst Frequency | 2 Hz | 2 Hz | 2 Hz | Same |
| Therapy Control<br>Burst Width | 2 ms | 2 ms/PPR 2Hz | 2 ms/PPR 2Hz | Same |
| Exposure | 1 hour | 30 minutes | 30 minutes | Performance<br>testing justified<br>substantial<br>equivalence |
| Energy<br>Deposited Via | Induction Coil | Induction Coil | Induction Coil | Same |
| Peak Generator<br>Power | 1.35 W | .5 W | .5 W | Performance<br>testing justified<br>substantial<br>equivalence |
| Heating Method | Chemical | NA | Chemical | Same |
Image /page/5/Picture/13 description: The image shows the logo for CAERUS. The logo features the word "CAERUS" in a simple, sans-serif font. To the left of the word, there is a stylized graphic that resembles a crescent shape with a pointed element extending upwards, possibly representing a sail or a stylized leaf. The overall design is clean and modern.
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Image /page/6/Picture/3 description: The image shows the word "CAERUS" in a sans-serif font. To the left of the word is a stylized graphic that resembles a bird's wing or a stylized leaf. The image is in black and white, and the background is a light gray color.
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## Table 2. Substantial Equivalence Subject Device Avenue8 (K241395) Compared to the Predicate Devices OrthoCor Active Device (K121702) and HiDow Pulsed electromagnetic field wrap (K202337)
| Characteristic | Avenue8 (K241395) | OrthoCor General<br>Use Device<br>(Primary<br>Predicate)<br>K121702 | HiDow Pulsed Electromagnetic<br>Field Wrap<br>(Secondary Predicate)<br>K202337 | Equivalence<br>Comparison |
|-----------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------|
| Regulatory<br>Class | Class II | Class II | Class II | Same |
| Regulatory<br>Number | 21 CFR 890.5290(b)<br>21 CFR 890.5740 | 21 CFR<br>890.5290(b) | 21 CFR 890.5290<br>21 CFR 890.5740 | Similar |
| Regulation<br>Name | Shortwave<br>Diathermy, For Use<br>Other Than<br>Applying<br>Therapeutic Deep<br>Heat | Shortwave<br>Diathermy, For Use<br>Other Than<br>Applying<br>Therapeutic Deep<br>Heat | Shortwave Diathermy | Similar |
| Product Code | ILX, IRT | ILX | ILX, IRT | Similar |
| Indication for<br>use | Adjunctive use in<br>the temporary relief<br>of pain, such as pain<br>associated with<br>over-exertion,<br>strains, sprains, and<br>arthritis. | Adjunctive use in<br>the palliative<br>treatment of<br>postoperative<br>edema and pain in<br>superficial soft<br>tissue | Adjunctive use in the palliative<br>treatment of postoperative edema<br>and pain in superficial soft tissue.<br>It is also indicated for the<br>temporary relief of minor aches<br>and pains associated with<br>overexertion, strains, sprains, and<br>arthritis. | Performance<br>testing justified<br>substantial<br>equivalence |
| Anatomical site | General Use | General Use | General Use | Same |
| Frequency -<br>short wave | 27.12 MHz | 27.12 MHz | 27.12 MHz | Same |
| Output<br>Impedance | 50 Ohm | 50 Ohm | Not Publicly Available | Same |
| Burst<br>Frequency | 2 Hz | 2 Hz | Not Publicly Available | Same |
| Therapy<br>Control Burst<br>Width | 2 ms | 2 ms/PPR 2Hz | Not Publicly Available | Same |
| Exposure | 1 hour | 30 minutes | Not Publicly Available | Performance<br>testing justified<br>substantial<br>equivalence |
| Characteristic | Avenue8 (K241395) | OrthoCor General<br>Use Device<br>(Primary<br>Predicate)<br>K121702 | HiDow Pulsed Electromagnetic<br>Field Wrap<br>(Secondary Predicate)<br>K202337 | Equivalence<br>Comparison |
| Energy<br>Deposited Via | Induction Coil | Induction Coil | Not Publicly Available | Same |
| Peak Generator<br>Power | 1.35 W | .5 W | Not Publicly Available | Performance<br>testing justified<br>substantial<br>equivalence |
| Heating Method | Electrical | NA | Electrical | Same |
Image /page/7/Picture/4 description: The image shows the logo for CAERUS. The logo features the company name in a simple, sans-serif font, with the letters "CAERUS" clearly visible. To the left of the name is a stylized graphic element that resembles a bird's wing or a stylized leaf, adding a touch of visual interest to the overall design.
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## VIII. PERFORMANCE DATA
Non-clinical performance testing was conducted to verify the subject device performance. The following performance data was provided in support of the substantial equivalence determination.
## Electrical safety and electromagnetic compatibility (EMC):
The systems comply with the IEC 60601-1 standard for electrical safety and the IEC 60601-1-2 standard for EMC.
## Software Verification and Validation Testing:
The software is classified as a Basic Level of Documentation. Testing and documentation for a Basic Level of Documentation are provided in the submission in compliance with "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (June 2023)
## Non-Clinical Testing Summary:
The following testing was conducted to satisfy the under the Special Controls under regulation 890.5290(0):
- Peak output power: .
- Pulse width; ●
- Pulse frequency; .
- Duty cycle; ●
- Characteristics of other types of modulation that may be used; .
- Average measured output powered into the RF antenna/applicator;
Image /page/8/Picture/17 description: The image shows the logo for CAERUS. The logo features the company name in a simple, sans-serif font, with the letters "CAERUS" clearly visible. To the left of the name is a stylized graphic element that resembles a wing or a stylized leaf, adding a unique visual element to the logo.
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- Specific absorption rates in saline gel test load or other appropriate model;
- Characterization of the electrical and magnetic fields in saline gel test load or other appropriate model for each RF antenna and prescribed RF antenna orientation/position; and
- Characterization of the deposited energy density in saline gel test load or other appropriate model.
- Temperature testing was completed on participants of varying skin types to demonstrate that the devices were capable of maintaining a skin temperature of 40 - 45 degrees Celsius for 20 minutes.
## Clinical Study:
In compliance with the special controls for regulation 890.5290(b), a clinical study was performed. 120 patients were enrolled, 48 in the Active System (Shortwave Diathermy + Heating Therapy) group and 43 in the SOC group, both males, over 18 years of age, with a history of pain in superficial soft tissue, such as in the ankle, back, knee, wrist, elbow, shoulder, foot, or neck. The incidence of adverse events in this study was notably low, with only 3.3% of participants (4 out of 120) experiencing minor complications. These events were distributed equally across both the Active System + Standard of Care (SOC) and Standard of Care (SOC) groups. The nature of these events were mild, consisting of shoulder pain, sleepiness. discomfort associated with the device wrap, and a tingling or numb sensation in the cervicothoracic region. Critically, there were no reports of serious adverse events or unanticipated adverse device effects. The lack of significant complications and the minimal
occurrence of adverse events reinforces the safety profile of the Active System treatment, affirming its suitability for clinical use in pain management.
This study was conducted in compliance with the Special Controls under regulation 21 CFR 890.5290(b)(2)(iv). The study examined the change from baseline in pain assessment scores at the end of 2 weeks of study treatment using the Mankowski scale. The SOC group experienced a 10% reduction in pain while the Active System + SOC group had 36% reduction in pain.
The findings from this clinical study report establish the Active System as an adjunctive therapy is a significantly more effective intervention for pain management in soft tissue injuries, than Standard of Care (SOC) alone as outlined in the study protocol. Specifically, the study primarily enrolled participants in the foot, knee and shoulder groups. The clinical data was clinically meaningful in the foot, knee and shoulder.
### CONCLUSIONS IX.
The substantial equivalence tables and performance testing results demonstrate that the Caerus Corporation Active System and Avenue8 devices are substantially equivalent to the OrthoCor Active Device.
Image /page/9/Picture/13 description: The image shows the logo for CAERUS. The logo features the word "CAERUS" in a sans-serif font. To the left of the word is a stylized graphic that resembles a leaf or a flame. The logo is presented in black against a light gray background.
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CAERUSCORP.COM 8611 W 35W SERVICE DRIVE NE, SUITE 180 BLAINE, MN 55449
Image /page/10/Picture/2 description: The image shows the word "CAERUS" in all capital letters. To the left of the word is a stylized graphic that resembles a leaf or a wing. The text and graphic are in a dark color, set against a light background. The overall impression is clean and modern.
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.
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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.
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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.
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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.