K112514 · Advanced Brain Monitoring, Inc. · MNR · Jan 9, 2012 · Anesthesiology
Device Facts
Record ID
K112514
Device Name
APNEA RISK EVALUATION SYSTEM (ARES)
Applicant
Advanced Brain Monitoring, Inc.
Product Code
MNR · Anesthesiology
Decision Date
Jan 9, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.2375
Device Class
Class 2
Attributes
Software as a Medical Device, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K112514 · Jan 9, 2012
APNEA RISK EVALUATION SYSTEM (ARES)
Advanced Brain Monitoring, Inc.
Published clinical literature; Retrospective clinical study data (previously acquired)
Published literature was used to support new labeling claims regarding treatment considerations and identification of patients for PAP titration. Retrospective clinical data was used to validate software filtering changes for the SpO2 signal.
Literature review; Retrospective analysis; Software validation; Clinical claims support
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
SpO2 Filtering Validation Study 1; Retrospective analysis of previously acquired data
—
Original ARES Model 610 (K111194)
Steady-state SpO2 accuracy
SpO2 Filtering Validation Study 2; Retrospective analysis of previously acquired data
—
Original ARES Model 610 (K111194)
Performance during dynamic SpO2 changes
Indications for Use
The Apnea Risk Evaluation System (ARES™), Model 610 is indicated for use in the diagnostic evaluation by a physician of adult patients with possible sleep apnea. The ARES™ can record and score respiratory events during sleep (e.g., apneas, hypopneas, mixed apneas and flow limiting events). The device is designed for prescription use in home diagnosis of adults with possible sleep-related breathing disorders.
Device Story
ARES™ Model 610 is a wearable Unicorder device for home sleep testing. Inputs: oxygen saturation (SpO2), pulse rate, snoring, head movement/position, airflow, and optional piezo respiratory effort belt. Device monitors signal quality during acquisition, providing voice alerts for adjustments. Data is uploaded via USB to a PC or cloud server. ARES™ Insight software processes raw signals to derive sleep metrics, including auto-detection of obstructive/mixed apneas, hypopneas, sleep/wake states, and REM/non-REM stages. Clinicians review waveforms and auto-detected events to finalize reports. Output includes sleep study reports with treatment consideration messages to assist physicians in planning follow-up or identifying candidates for laboratory PAP titration. Benefits include facilitating home-based diagnosis of sleep-related breathing disorders.
Clinical Evidence
Bench testing and analysis of previously acquired clinical data. Two studies: one analyzed 'breathe down' data to confirm steady-state accuracy; second analyzed 'breath hold' data to evaluate performance during dynamic SpO2 changes typical of sleep-disordered breathing. Results confirmed accuracy is equivalent to the original ARES™ device. Published literature used to support new report messages.
Technological Characteristics
Battery-powered Unicorder; USB connectivity for data transfer/charging. Sensors: pulse oximetry (red/IR), actigraphy, airflow, respiratory effort. Software: ARES™ Insight, local PC or cloud-server based. Filtering: improved digital filtering for SpO2 signal. Accuracy: SpO2 < 3.0% Arms. Connectivity: USB to host computer or web-portal access.
Indications for Use
Indicated for diagnostic evaluation of adult patients with possible sleep apnea or sleep-related breathing disorders. Prescription use only for home diagnosis.
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.
Predicate Devices
Apnea Risk Evaluation System (ARES), Model 610 (K111194)
ApneiCare Connection Center /Internet Analysis, ApneiCare, LLC (K082968)
Submission Summary (Full Text)
{0}------------------------------------------------
K112514
### Apnea Risk Evaluation System (ARES™), Model 610
JAN - 9 2012
## 510(K) SUMMARY
In accordance with 21 CFR 807.92 the following summary of information is provided:
January 5, 2012
## SUBMITTER:
Advanced Brain Monitoring 2237 Faraday Avenue, Suite 100 Carlsbad, CA 92008 T 760.720.0099 F 760.720.3337
PRIMARY CONTACT PERSON:
Adrienne Lenz, RAC Member Pathway Regulatory Consulting, LLC T 262-290-0023
## SECONDARY CONTACT PERSON:
Dan Levendowski President and Co-founder Advanced Brain Monitoring, Inc.
## DEVICE:
TRADE NAME: Apnea Risk Evaluation System (ARES™), Model 610
COMMON/USUAL NAME: ARES
CLASSIFICATION NAMES: 868.2375 Ventilatory Effort Recorder
PRODUCT CODE: MNR
PREDICATE DEVICE(S):
K111194 Apnea Risk Evaluation System (ARES), Model 610
K082968 ApneiCare Connection Center /Internet Analysis, ApneiCare, LLC
{1}------------------------------------------------
### DEVICE DESCRIPTION:
The Apnea Risk Evaluation System (ARES™) includes a device called a Unicorder which records oxygen saturation, pulse rate, snoring level, head movement and head position, and airflow. Additionally, a physiological signal from the forehead used to stage sleep or respiratory effort signal obtained from an optional piezo respiratory effort belt can be acquired. The battery powered Unicorder provides sufficient capacity to record two nights of data. The device monitors signal quality during acquisition and notifies the user via voice messages when adjustments are required.
A standard USB cable connects the Unicorder to a USB port on a host computer when patient data is to be uploaded or downloaded. The USB cable provides power to the Unicorder during recharging from the host computer or from a USB wall charger. The Unicorder cannot record nor can it be worn by the patient when connected to the host computer or the wall charger.
Software, residing on a local PC or a physical or virtual server controls the uploading and downloading of data to the Unicorder, processes the sleep study data and generates a sleep study report. The ARES™ can auto-detect positional and non-positional obstructive and mixed apneas and hypopneas similarly to polysomnography. It can detect sleep/wake and REM and non-REM.
After the sleep study has been completed, data is transferred off the Unicorder is prepared for the next study. The downloaded sleep study record is then processed with the ARES™ Insight software to transform the raw signals and derive and assess changes in oxygen saturation (SpO2), pulse rate, head movement, head position, snoring sounds, airflow, and EEG or respiratory effort. The red and IR signals are used to calculate the SpO2 and pulse rate. The actigraphy signals are transformed to obtain head movement and head position. A clinician can convert an auto-detected obstructive apnea to a central apnea based on visual inspection of the waveforms.
ARES™ Screener can predict pre-test probability of obstructive sleep apnea (OSA). The ARES™ can also assist the physician to identify patients who will likely have a successful OSA treatment outcome, including CPAP and oral appliance therapies. ARES™ can help identify patients who would benefit from a laboratory PAP titration.
## INTENDED USE:
The Apnea Risk Evaluation System (ARES™), Model 610 is indicated for use in the diagnostic evaluation by a physician of adult patients with possible sleep apnea. The ARES™ can record and score respiratory events during sleep (e.g., apneas, hypopneas, mixed apneas and flow limiting events). The device is designed for prescription use in home diagnosis of adults with possible sleep-related breathing disorders.
{2}------------------------------------------------
### TECHNOLOGY:
The ARES™ Model 610 being submitted is identical to the predicate ARES™ Model 610 (K111194) with the changes:
- 1. Modification to run ARES™ software from a cloud server, which may be a physical or virtual server, and is accessed using web-portal software.
- 2. Modification to ARES Insight software to improve filtering of the SpO2 signal.
- 3. New claims, supported by published literature, are added to the ARES™ labeling and the ARES™ report:
- o The ARES report provides messages to help physicians plan for treatment and/or followup care.
- o ARES can help identify patients who would benefit from a laboratory PAP titration.
## DETERMINATION OF SUBSTANTIAL EQUIVALENCE:
#### COMPARISON TO PREDICATE DEVICES
The modified ARES™ Model 610 has the same intended use and fundamental scientific technology as the cleared ARES™ Model 610. All features are identical except those described in the table below.
| Feature | Original Device<br>(Model 610, K111194) | Modified Device<br>(Model 610) | Reason for Change |
|-------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Software Platform | All software operates on a local PC. | Software operates on a PC, or via a web portal. | Equivalent. The Portal Software was designed to emulate existing ARES software that communicates with the ARES Unicorder, allows for data entry, and manages the workflow of an ARES sleep study. The portal software and server configuration is similar to ApneiCare Connection Center /Internet Analysis which analyzes sleep data over the internet (K082968). |
| Derived Signals | SpO2 Pulse rate Apneas and hypopneas Hypopnea severity Snoring loudness Head movement and position Sleep/wake Stages rapid eye movement (REM) vs. non-REM | SpO2 Pulse rate Apneas and hypopneas Hypopnea severity Snoring loudness Head movement and position Sleep/wake Stages rapid eye movement (REM) vs. non-REM | Equivalent. Improved filtering has been added in the processing of the SpO₂ signal prior to identification of desaturation events. The raw signal acquired from the Unicorder is unchanged. |
{3}------------------------------------------------
| Feature | Original Device<br>(Model 610, K111194) | | Modified Device<br>(Model 610) | | Reason for Change |
|------------------------|-----------------------------------------------------------------------|----------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Saturation<br>Accuracy | SpO2 range | Arms (%) | SpO2 range | Arms (%) | Equivalent. The Arms has changed due<br>to the filtering changes but labeling<br>will reflect specification of <3.0%.<br>Accuracy in all ranges is less than 3.5%<br>as recommended in Draft Guidance<br>for Industry and FDA Staff - Pulse<br>Oximeters - Premarket Notification<br>Submissions [510(k)s] July 19, 2007. |
| | 60-100% | 2.4 | 60-100% | < 3.0 | |
| | 90-100% | 1.5 | 90-100% | < 3.0 | |
| | 80-90% | 2.6 | 80-90% | < 3.0 | |
| | 70-80% | 2.6 | 70-80% | < 3.0 | |
| | 60-70% | 2.7 | 60-70% | < 3.0 | |
| | * Up to 32% of the reading may fall<br>outside the listed error range | | * Up to 32% of the reading may fall<br>outside the listed error range | | |
| Reports | Multiple report formats available. | | Multiple report formats available.<br>Treatment considerations messages<br>are updated to help physicians plan<br>for treatment and/or follow-up care<br>and ARES can help identify patients<br>who would benefit from a laboratory<br>PAP titration. | | Equivalent. The new statement is<br>based on and supported by studies<br>described in Section 20. The<br>treatment messages are optional, and<br>are presented in a report generated<br>after the signals have been reviewed<br>by the interpreting physician. The<br>treatment consideration messages are<br>not an automated diagnosis, but assist<br>the physician in providing standard<br>text for common messages in their<br>reports. These messages are derived<br>from published literature. |
#### SUMMARY OF NON-CLINICAL TESTS:
Support for the substantial equivalence of the ARES™ Model 610 was provided as a result of risk management and software validation, which confirmed.
- All features of the ARES™ Model 610 were compliant with the system level requirements. .
- . The ARES™ software operates properly from a cloud server which is accessed using web-portal software.
### SUMMARY OF CLINICAL TESTS:
The filtering changes to the SpO2 signal were validated by analysis of clinical data previously acquired in two clinical studies. The first study analyzed original breathe down data and demonstrated steady-state accuracy is equivalent before and after implementation of the filtering changes. The second study analyzed breath hold data to evaluate performance of ARES™ during dynamic SpO2 changes, as are typical in sleep disordered breathing. Both studies confirmed that the accuracy of the ARES " after the implementation of the filtering changes is equivalent to the original ARES "" accuracy.
Evaluation of published literature was also used to support the new claims and report messages introduced for ARESTM.
## CONCLUSION:
The conclusions drawn from the nonclinical tests demonstrate equivalent performance of the Apnea Risk Evaluation System (ARES™), Model 610 and the legally marketed devices. The Apnea Risk Evaluation System (ARES'"), Model 610 is substantially equivalent to the predicate devices.
{4}------------------------------------------------
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized image of an eagle with three stripes forming its body and wing. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Advanced Brain Monitoring, Incorporation C/O Ms. Adrienne Lenz Regulatory Affairs Consultant Pathway Regulatory Consulting, LLC 2511 Fox River Circle Waukesha. Wisconsin 53189
JAN - 9 2012
Re: K112514
Trade/Device Name: Apnea Risk Evaluation System (ARES) Regulation Number: 21 CFR 868.2375 Regulation Name: Breathing Frequency Monitor Regulatory Class: II Product Code: MNR Dated: December 29, 2011 Received: January 3, 2011
Dear Ms. Lenz:
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 (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. 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.
{5}------------------------------------------------
## Page 2 - Ms. Lenz
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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Susan Quinn
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{6}------------------------------------------------
510(k) Number (if known):
Apnea Risk Evaluation System (ARES) Device Name:
Indications for Use:
The Apnea Risk Evaluation System (ARES™), Model 610 is indicated for use in the diagnostic evaluation by a physician of adult patients with possible sleep apnea. The ARES™ can record and score respiratory events during sleep (e.g., apneas, hypopneas, mixed apneas and flow limiting events). The device is designed for prescription use in home diagnosis of adults with possible sleep-related breathing disorders.
Prescription Use_ X
AND/OR
Over-The-Counter Use
(Part 21 CFR 801 Subpart D)
(Part 21 CFR 801 Subpart C)
# (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
L Schilttin
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: k112574
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.