K983572 · Healthdyne Technologies, Inc. · MNR · Mar 19, 1999 · Anesthesiology
Device Facts
Record ID
K983572
Device Name
SIMON MULTICHANNEL RECORDING SYSTEM, MODEL 5500
Applicant
Healthdyne Technologies, Inc.
Product Code
MNR · Anesthesiology
Decision Date
Mar 19, 1999
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.2375
Device Class
Class 2
Attributes
Pediatric
Indications for Use
Simon™ is a multichannel recording system designed to record and store physiological signals acquired from adult and pediatric patients during sleep. The portable design of the device facilitates its use in any clinical setting or in the home environment. Physiological signals are acquired via transducers attached to the patient and directly connected to the recorder. Additionally, a modem may be used to connect to the Host PC during acquisition, to interface with a Respironics CPAP or BiPAP device for titration or to download the data post acquisition. Once downloaded, the recorded data can be scored for physiological events using the associated Simon™ HOST Software. The clinician can review, validate, edit and print scored data. The software allows the user to configure / customize all reports to best meet individual needs.
Device Story
Simon™ is a portable, 8-channel multichannel recording system for sleep studies. It collects physiological signals via patient-attached sensors, including nasal flow/pressure, body position, snoring sounds, oximetry, respiration (chest/abdominal effort), actigraphy, and auxiliary CPAP/BiPAP data. The device is worn by the patient during sleep in clinical or home environments. Data is downloaded to a PC running Simon™ Host Software via modem or direct connection. The software automatically scores physiological events based on user-defined parameters; clinicians review, validate, and edit these events. The system supports remote titration of CPAP/BiPAP settings via modem. The output allows clinicians to generate customized reports to assist in sleep disorder diagnosis and therapy management, potentially improving patient outcomes through optimized titration and monitoring.
Clinical Evidence
Bench testing only. No clinical data was performed. Testing included operational, performance, environmental, and EMC testing, alongside system and module-level hardware and software verification using simulated data.
Technological Characteristics
8-channel recording system; portable form factor; powered by wall supply or rechargeable battery. Software-based analysis using the same engine as the Alice 4 predicate. Connectivity via modem or direct PC link. No specific materials or sterilization standards cited.
Indications for Use
Indicated for adult and pediatric patients requiring recording and storage of physiological signals during sleep in clinical or home settings.
Regulatory Classification
Identification
A breathing (ventilatory) frequency monitor is a device intended to measure or monitor a patient's respiratory rate. The device may provide an audible or visible alarm when the respiratory rate, averaged over time, is outside operator settable alarm limits. This device does not include the apnea monitor classified in § 868.2377.
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| 3/19/99 | K983572 |
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| 1. | 510(k) SUMMARY<br>(As required by 21 CFR 807.93) |
| | |
| Establishment<br>Registration Number: | 1040777 |
| Submitter: | Betsy Cortelloni<br>Respironics, Inc.<br>1255 Kennestone Circle<br>Marietta, GA 30066<br>Phone: 770-429-2894<br>Fax: 770-499-1139 |
| Name of Contact: | Betsy Cortelloni, Regulatory Affairs Process Leader |
| Device Name: | Simon™ Multichannel Recording System |
| Device Model Number: | 5500 |
| Classification Name: | Programmable Diagnostic Computer, 21 CFR 870.1425 |
| Device Classification: | DQK |
| Predicate Devices: | Healthdyne Technologies' Alice 4 System. Originally<br>cleared under K971867 (8/13/97). |
| Device Description: | Simon™ is a multichannel recording system, which may<br>be used for adult or pediatric patients in a variety of<br>settings. The system is comprised of the Simon<br>Recorder, Host Software, auxiliary CPAP / BiPAP<br>devices (as applicable), computer equipment (CPU and<br>monitor) and various accessories (modem, etc.). The<br>recorder is small, lightweight and may be worn while the<br>patient sleeps. The recorder collects physiologic<br>signals from sensors attached to the patient. This eight-<br>channel system records Nasal Flow or Pressure, Body<br>Position, Snoring Sounds, Oximetry, Respiration via<br>Chest Effort, Respiration via Abdominal Effort,<br>Actigraphy, Pressure and Flow from auxiliary<br>Respironics CPAP / BiPAP devices.<br><br>The Simon™ Host Software is a Windows-based<br>application, which facilitates remote titration of CPAP /<br>BiPAP settings via modem, as well as download of<br>recorded data onto a personal computer. Once<br>downloaded, the Host software scores the recorded data<br>for physiological events per user-defined parameters.<br><br>- continued - |
| | FILENAME: HORISEC2.DOC |
| Intended Use: | The software allows user validation/editing of all events, and provides reporting capabilities that are fully user-configurable.<br>Simon™ is a multichannel recording system designed to record and store physiological signals acquired from adult and pediatric patients during sleep. The portable design of the device facilitates its use in any clinical setting or in the home environment.<br>Physiological signals are acquired via transducers attached to the patient and directly connected to the recorder. Additionally, a modem may be used to connect to the Host PC during acquisition, to interface with a Respironics CPAP or BiPAP device for titration or to download the data post acquisition. Once downloaded, the recorded data can be scored for physiological events using the associated Simon™ HOST Software.<br>The clinician can review, validate, edit and print scored data. The software allows the user to configure / customize all reports to best meet individual needs. |
| Comparison of<br>Technological<br>Characteristics: | Simon™ is essentially a line extension of the Healthdyne Technologies Alice 4 System and utilizes the same software "engine" to control device functions. Simon records eight input channels and will display ten, as compared to 20 channels on Alice 4. Signals are recorded in a similar manner.<br>Simon™ is designed to facilitate home use although it may also be used in clinical settings. It is small and lightweight enough to be worn by the patient as s/he sleeps. It is operated using a wall mounted power supply or a rechargeable battery back.<br>The Simon™ Host Software facilitates download of recorded data to a PC via external modem or direct connection to the device. |
| - continued - | |
1
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## 510(K) SUMMARY – SIMON™ MULTICHANNEL RECORDING SYSTEM Device Description, continued:
Image /page/1/Picture/2 description: The image shows the logo for Respironics. The logo consists of a stylized human figure inside of a triangle shape, which is positioned above the word "RESPIRONICS". The logo is black and white. The human figure appears to be abstract, with a circular head and geometric shapes forming the body and limbs.
MARIETTA, GA. 30066
FILENAME: HORISEC2.DOC
PAGE 3 of 4
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## 510(K) SUMMARY - SIMON™ MULTICHANNEL RECORDING SYSTEM
| Testing: | The System Qualification Test Plan for Simon™ included<br>Operational and Performance testing, Environmental testing<br>and EMC testing. The Hardware Test Plan and Software Test<br>Plan consisted of system level and module / integration level<br>testing to verify all the defined hardware and software<br>requirements, respectively. Bench testing utilized simulated<br>data. No Clinical testing was performed. |
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- The cumulative test results demonstrated the functionality, Conclusion: safety and effectiveness of the Simon™ Multichannel Recording System, as well as its substantial equivalence to the predicate device.
Image /page/2/Picture/3 description: The image shows the logo for Respironics. The logo features a stylized triangle with a human-like figure inside. The word "RESPIRONICS" is written in bold, sans-serif font below the triangle. There is a trademark symbol to the right of the word.
MARIETTA, GA. 30066
FILENAME: HORISEC2.DOC
PAGE 4 of 4
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAR 1 9 1999
Ms. Betsy Cortelloni Healthdyne Technologies 1255 Kennestone Circle Marietta, GA 30066-6029
Re: K983572 Simon Multichannel Recording System Requlatory Class: II (two) Product Code: 73 MNR Dated: February 8, 1999 February 9, 1999 Received:
Dear Ms. Cortelloni:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in requlatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
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Page 2 - Ms. Betsy Cortelloni
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4648. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification"(21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597, or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
sincerely yours,
Thomas J. Callahan
Thomas J. Callahan, Ph.D. Director Division of Cardiovascular, Respiratory, and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Center for Devices and Radiological Health
Page l of
| 510(k) Number (if known): | 12983572 |
|---------------------------|-------------------------------------|
| Device Name: | SIMON MULTICHANNEL RECORDING SYSTEM |
Indications for Use:Simon™ is a multichannel recording system designed to record and store physiological signals acquired from adult and pediatric patients during sleep. The portable design of the device facilitates its use in any clinical setting or in the home environment.
Physiological signals are acquired via transducers attached to the patient and directly connected to the recorder. Additionally, a modem may be used to connect to the Host PC during acquisition, to interface with a Respironics CPAP or BiPAP device for titration or to download the data post acquisition. Once downloaded, the recorded data can be scored for physiological events using the associated Simon™ HOST Software.
The clinician can review, validate, edit and print scored data. The software allows the user to configure / customize all reports to best meet individual needs.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurence of CDRH, Office of Device Evaulation (ODE)
Ath A. Ciarkush.
(Division Sign-Off) Division of Cardiovascular, Respiratory, and Neurological Devices
510(k) Number
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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.