The Esophageal Manometry System is intended to record, store, view and analyze data on line in the gastrointestinal tract to assist in the diagnoses of gastrointestinal disorders.
Device Story
Stationary manometry system for gastrointestinal tract function evaluation. System captures pressure, respiration, and swallow data via patient-connected sensors. Data processed online, recorded for review, analysis, and reporting. Operated by trained technicians or physicians in clinical settings. System utilizes Polygram 98 software on Windows 98 to transform raw sensor inputs into visual tracings and calculated parameters (LES location, resting/residual pressure, motility amplitude/duration/velocity). Healthcare providers review signal tracings and automated reports to assist in clinical diagnosis. Benefits include standardized data collection and analysis for GI disorder assessment.
Clinical Evidence
No clinical trials performed. Substantial equivalence established via bench testing and verification of system performance against predicate device specifications.
Technological Characteristics
Stationary manometry system; 4-16 channels; 22-bit resolution; 105-1674 Hz sampling rate; USB connectivity. Power supply 24V DC. Insulation via HCPL-0710 and NMV 2405S. Software: Polygram 98 (C++, Visual Basic) running on Windows 98. Complies with EN 60601-1, UL 2601-1, and CAN/CSA C22.2 No.610.1-M90.
Indications for Use
Indicated for infants, pediatric, and adult patients requiring gastrointestinal tract pressure and function evaluation to assist in diagnosing gastrointestinal disorders.
Regulatory Classification
Identification
A gastrointestinal motility monitoring system is a device used to measure peristalic activity or pressure in the stomach or esophagus by means of a probe with transducers that is introduced through the mouth into the gastrointestinal tract. The device may include signal conditioning, amplifying, and recording equipment. This generic type of device includes the esophageal motility monitor and tube, the gastrointestinal motility (electrical) system, and certain accessories, such as a pressure transducer, amplifier, and external recorder.
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# 510(k) SUMMARY
as required per 807.92(c)
### 1. Submitters Name, Address:
Medtronic Functional Diagnostics A/S Tonsbakken 16-18 DK-2740 SKOVLUNDE Tel: (+ 45 ) 44 57 90 00 Fax: (+ 45 ) 44 57 90 10 Contact person for this submission: Ann-Christine Jönsson Date submission was prepared: 6d August, 1999
### 2. Trade Name, Common Name and Classification Name:
A. Trade Name: Esophageal Manometry System
B. Common Name, Classification Name, Class and Regulation Number:
| Common Name | Classification<br>Number | Class | Regulation Number |
|--------------------------------------------------|--------------------------|-------|-------------------|
| Polygraf ID | 78 FFX | II | 21 CFR 876.1725 |
| Polygram 98, Esophageal Manometry<br>Application | 78 KLA,<br>FFX | II | 21 CFR 876.1725 |
# 3. Predicate Device Identification:
The functionality and intended use of the Esophageal Manometry System is equivalent to Medtronic Synectics Polygraf HR (K872712) with Polygram for Windows, Base Module (K946322) and Esophageal Manometry Analysis Module (K961070).
# 4. Device Description:
The system is a stationary manometry system for use in evaluating the function of the gastrointestinal tract. The system measures pressure and other parameters online using sensors on and in the patient. The parameters are presented during the capture and are also recorded for later display, analysis and reporting.
In its daily use, a trained technician and/or a physician are the main users of the system.
# 1 (4) COMPANY CONFIDENTIAL
Medtronic Functional Diagnostics A/S
Tonsbakken 16-18 DK-2740 SKOVLUNDE
Tel: + 45 44 57 90 00 Fax: + 45 44 57 90 10
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The main tasks when performing a manometry procedure with a stationary manometry system are:
- . Prepare equipment including calibration
- . Enter patient/study demographic information
- Perform procedure and obtain relevant data .
- Review, analysis and post procedure activities .
- . Create and print a report
The Polygram 98 Esophageal Manometry Application software runs on Microsoft Windows® 98
#### 5. Intended Use:
The Esophageal Manometry System is intended to record, store, view and analyze data on line in the gastrointestinal tract to assist in the diagnoses of gastrointestinal disorders.
### 6. Table of Device Similarities and differences to predicate device
| Manufacturer | Medtronic Synectics AB | Medtronic Functional<br>Diagnostics A/S | - |
|-------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------|
| 510(k) number | Predicate devices<br>• Polygraf HR<br>- K 872712<br>• Polygram software,<br>base module<br>- K 946322<br>• Esophageal<br>Manometry Analysis<br>Module<br>- K 961070 | Modified Device<br>Esophageal Manometry System,<br>(EM System) i.e<br>- Polygraf ID &<br>- Polygram 98,<br>Esophageal Manometry<br>Application<br><br>K number to be decided | - |
| General: | Predicate devics:<br>- all | Modified Device<br>- EM System | Explanation of the differences<br>compared |
| | | | to the Predicate devices |
| Intended Use /<br>Indication of Use | Record, store, view and<br>analyze data on line in the<br>gastrointestinal tract to<br>assist in the diagnoses of<br>gastrointestinal disorders.. | Same | -- |
| Intended Populations | Infant, Pediatric to Adults | Same | -- |
| Sterilization | Accessories are not<br>supplied sterile,<br>manufacturer label the<br>accessories with cleaning<br>instructions. | Same | -- |
| Biocompatibility | The Sensors are the only<br>part that comes into<br>contact with the patients. | Same | -- |
#### COMPANY CONFIDENTIAL
Medtronic Functional Diagnostics A/S
Tonsbakken 16-18 DK-2740 SKOVLUNDE
Tel: + 45 44 57 90 00 Fax: + 45 44 57 90 10
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| Technical Features: | Predicate devices<br>- Polygraf HR | Modified Device<br>- Polygraf ID | Explanation of the differences<br>compared<br>to the Predicate devices |
|----------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Number of Channels | Up to 16 | 4-16 channels | Enhanced performance |
| Sampling rate | 1/128 to 128 Hz | 105-1674 Hz | Enhanced performance |
| Power supply | 9-12 V DC | 24 V DC | 110-230 V Power Supply in one |
| Measuring range | 0-9 pH | -2.5 Vpm, 5 % to 2.5 Vpm 5% | Enhanced performance |
| Insulation | Burr Brown722 dual<br>isolated DC/DC converter | HCPL-0710. NMV 2405S, and<br>safety power supply: class I | Enhanced performance, isolation<br>provided also within each module of 4<br>channels (4, 8, 12, 16.) |
| Current consumption | 260 mA nom standard<br>(8bit) | Max 0.8 A | Enhanced performance requires more<br>power |
| Communication | Optical serial RS 232 | USB (Universal Serial Bus) | Enhanced performance (band width) |
| Resolution | 8 bit | 22 bit | Enhanced performance |
| Dimension | 11.2" x 2" x 6 " | 14" x 8.8" x 2.8" | More channels require more space |
| Weight | 1 050 g | < 3 000 g | Larger box weight more |
| On-line monitoring | Via PC Screen | Same | --- |
| Features: | Predicate devices<br>- Base module<br>&<br>- pH Analysis Module,<br>EsopHogram pH Reflux<br>Analysis | Modified Device<br>- Polygram '98, EM Extension | Explanation of the differences<br>compared<br>to the Predicate devices |
| Signals to analyze | Ph, pressure, flow, volume,<br>respiration, oxygen<br>saturation, pulse rate, body<br>position, snoring | Pressure, respiration and<br>swallow | Not all are implemented in this first<br>version. |
| User commands | Menu selections, keyboard<br>combinations, screen<br>"buttons" | Same | -- |
| Esophageal Analysis | - LES analysis<br>- Esophageal motility<br>analysis<br>- UES analysis | - LES analysis<br>- Esophageal motility analysis | - UES analysis, will be introduced in<br>coming versions of the SW. |
| Calculated<br>parameters | LES location<br>LES resting pressure<br>LES relaxation<br>LES residual pressure<br><br>Esophageal motility:<br>amplitude<br>duration<br>velocity<br><br>UES location<br>UES resting pressure<br>UES residual pressure<br>Quick calculations | LES location<br>LES resting pressure<br>LES relaxation<br>LES residual pressure<br><br>Esophageal motility:<br>amplitude<br>duration<br>velocity | The following parameters will be<br>introduced in coming versions of the<br>SW:<br>UES location<br>UES resting pressure<br>UES residual pressure<br>Quick calculations |
| Reports | Signal tracings and reports.<br>Optionally selections only. | Same | -- |
| Patient database | Relational database with<br>logical patient- recording<br>relations | Same | -- |
| Additional data | User definable additional<br>patient/recording<br>parameters | Same | -- |
| User help system | Online help system with<br>descriptions of procedures | Same | -- |
| Signal review method | Time - tracing based | Same | -- |
| Recording control | Real time monitoring of<br>signals | Same | -- |
| Calibration | Adjustable and fixed gain<br>method. Monitoring of<br>calibration result for range<br>and resolution requirement. | Same | -- |
| Recording<br>configuration | A template is used for each<br>type of recording. User<br>definable. Once used, not<br>possible to change,<br>ensuring recording<br>integrity | Same ('templates' are now<br>called 'protocols') | -- |
| Programming<br>language | 'C' | C++, Visual Basic | -- |
| Operating system | Windows 3.11, 95 | Windows 98 | Enhanced performance |
# 3 (4)
# COMPANY CONFIDENTIAL
Medtronic Functional Diagnostics A/S
Tonsbakken 16-18 DK-2740 SKOVLUNDE
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### 7. Assessment of non-clinical performance data for equivalence:
Verifications results shows that the enhanced system performs as its predicate system.
#### 8. Assessment of clinical performance data for equivalence:
Clinical trials are not performed. This new system doesn't raise any new safety or performance issues.
#### 9. Biocompatability:
Not applicable .
### 10. Sterilization:
Not applicable
#### 11. Standards and Guidances:
The Esophageal Manometry System complies to the following standards:
- EN 60601-1:1990 and Amendments A1, A11, A12 and A13
- UL 2601-1, Second Edition, 1997
- CAN/CSA C22.2 No.610.1-M90
### 4 (4)
### COMPANY CONFIDENTIAL
Medtronic Functional Diagnostics A/S
Tonsbakken 16-18 DK-2740 SKOVLUNDE
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Image /page/4/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of an eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
NOV 1 0 1999
Ms. Ann-Christine Jönsson Regulatory Affairs Medtronic Functional Diagnostics A/S Tonsbakken 16-18 Skovlunde DK-2740 DENMARK
Re: K992713 Esophageal Manometry Testing Application (Polygraf ID, Polygram '98) Dated: August 6, 1999 Received: August 12, 1999 Regulatory Class: II 21 CFR 876.1725/Procode: 78 FFX
Dear Ms. Jönsson:
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). 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 regulatory 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.
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) 594-4613. 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,
CAPT Daniel G. Schultz, M.D. Acting Director, Division of Reproductive, Abdominal, Ear, Nose and Throat, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indication for Use Statement
Page 1 of 1 --
510(k) Number (if known): K992713
Device Name: _________________________________________________________________________________________________________________________________________________________________
Indications for Use:
The Esophageal Manometry System is intended to record, store, view and analyze data on line in the gastrointestinal tract to assist in the diagnoses of gastrointestinal disorders.
MRI Compatibility Statement:
The Esophageal Manometry System is not compatible for use in a MRI magnetic field.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use_ V (Per 21 CFR 801.109)
OR
Over-The-Counter Use_
(Optional Format 1-2-96)
(Division Sign-Off)
Division of Reproductive, Abdominal, ENT,
and Radiological Devices
| 510(k) Number | K992713 |
|---------------|---------|
|---------------|---------|
### COMPANY CONFIDENTIAL
Medtronic Functional Diagnostics A/S
Tonsbakken 16-18 DK-2740 SKOVLUNDE
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.