Otogram can perform the functions of: 1. Pure tone and speech audiometer. 2. Impedance audiometer (tympanometry, acoustic reflex), and 3. Distortion product otoacoustic emissions analyzer. The unit is intended for use by a qualified/trained audiologist on both adult and pediatric subjects for measurement of acoustic impedance.
Device Story
Otogram is a computer-controlled audiometric instrument combining pure tone/speech audiometry, impedance audiometry (tympanometry, acoustic reflex), and distortion product otoacoustic emissions (DPOAE) analysis. Device inputs include acoustic signals for testing; system is controlled via ASCII commands from a PC running proprietary software. Device performs measurements and outputs results to a display or printer. Used in clinical settings by audiologists to diagnose hearing and otologic disorders. System integrates with NOAH v.3 hearing aid fitting software. Benefits include comprehensive diagnostic capability in a single platform, aiding clinical decision-making regarding patient hearing health and cochlear function.
Clinical Evidence
Bench and user testing performed. No clinical trials on human subjects reported. Testing confirmed performance metrics and safety parameters (e.g., pressure range, frequency accuracy) are consistent with predicate devices and relevant standards (IEC 1027, ANSI S3.39).
Technological Characteristics
Combined audiometer, impedance meter, and DPOAE analyzer. Features peristaltic pump (stepper motor controlled), resistive touchscreen, and PC-based control via RS-232. Connectivity: RS-232, USB, parallel port. Standards: IEC 1027, ANSI S3.39, EN 60601-1 (Class I, Type B). Thermal printer output. Multi-language support.
Indications for Use
Indicated for adult and pediatric patients requiring audiometric testing, acoustic impedance measurement (tympanometry, acoustic reflex), and distortion product otoacoustic emissions analysis. Intended for use by qualified/trained audiologists.
Regulatory Classification
Identification
A hearing aid calibrator and analysis system is an electronic reference device intended to calibrate and assess the electroacoustic frequency and sound intensity characteristics emanating from a hearing aid, master hearing aid, group hearing aid or group auditory trainer. The device consists of an acoustic complex of known cavity volume, a sound level meter, a microphone, oscillators, frequency counters, microphone amplifiers, a distoration analyzer, a chart recorder, and a hearing aid test box.
Special Controls
*Classification.* Class II (special controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 874.9.
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## EXHIBIT 2 Tympany Inc. 12807 Royal Drive, Suite 101 Stafford, TX 77477 Phone 281.313.5858 Fax 281.313.5844 Toll-Free 866.316.3606 Contact: Kenneth Barrow, Vice President Prepared July 2, 2004 510(k) Summary
- 1. Identification of the Device: Proprietary-Trade Name: Otogram Classification Name: Audiometer 77 EWO. (Otoacoustic emission devices are not exempt) and 77 ETY, Admittance Meter (874.1090 Common/Usual Name: Audiometer, Impedance Audiometer, Otoacoustic Emissions Device
- 2. Equivalent legally marketed devices This product is similar in design and function to the Madsen Zodiac, K910247 and the Biologic Audx, K974076
- 3. Indications for Use (intended use) "Otogram" can perform the functions of:
- 1. Pure tone and speech audiometer.
- 2. Impedance audiometer (tympanometry, acoustic reflex), and
- 3. Distortion product otoacoustic emissions analyzer.
The unit is intended for use by a qualified/trained audiologist on both adult and pediatric subjects for measurement of acoustic impedance.
- 4. Description of the Device: The Otogram is a computer-controlled, audiometric instrument combining the functions of an Audiometer, a Impedance Instrument, and a DPOAE Instrument. The device is controlled through the use of ASCII commands transmitted over a standard RS-232 communication port. Control software is installed on the supplied PC. The device performs comprehensive audiometry; tympanometry, acoustic reflex; and otoacoustic emissions. Additional features include manual audiometer and NOAH v.3 compliant (hearing aid fitting software). Available in multiple languages, including English, Spanish, Russian, Mandarin, Vietnamese, and Korean.
- 5. Safety and Effectiveness, comparison to predicate device. The results of bench, user, and laboratory testing indicates that the new device is as safe and effective as the predicate device.
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# 6. Substantial Equivalence Chart
| Characteristic | | Predicate<br>Impedance<br>Audiometer<br>Madsen Zodiac 901<br>K910247 | Predicate<br>Otoacoustic<br>Emissions<br>Bio-Logic AuDX<br>K974076 | Tympany Otogram<br>Combined Device<br>Impedance<br>Audiometer<br>Otoacoustic<br>Emissions |
|------------------------------------------------|-------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use: | | To diagnose hearing and<br>otologic disorders in the<br>middle-ear and total ear<br>system, using audiometry,<br>tympanometry, and acoustic<br>reflex. | To test cochlear function<br>and presence of otoacoustic<br>emissions. | To diagnose hearing and<br>otologic disorders in the<br>middle-ear and total ear<br>system, using audiometry,<br>tympanometry, and acoustic<br>reflex. To test cochlear<br>function and presence of<br>otoacoustic emissions |
| Technical | | | | |
| characteristics | | | | |
| Probe tone: | | | | |
| | Probe tone<br>frequency | 226 Hz | NA | 226 Hz, +/- 3% |
| | Probe tone level | 85 dB SPL | NA | 70 dB SPL, +/- 3 dB |
| Admittance<br>measurement: | | | | |
| | Total range | 0.1 ml to 8.0 ml | NA | 0.2 ml to 6.0 ml |
| | Reflex range | 0 ul to 375 ul | NA | 0 ul to 375 ul |
| | Calibration | 2 cc cavity | | 0.5, 2, 5 cc cavity |
| Pressure system: | | | | |
| | Pump system | Plunger type; stepper motor,<br>digitally controlled | NA | Peristaltic pump; stepper<br>motor, digitally controlled |
| | Pressure range -<br>normal | +200 to -400 daPa | NA | +200 to -400 daPa |
| | Pressure range -<br>extended | +400 to -600 daPa | NA | NA |
| | Accuracy | +/- 10% or +/- 10 daPa<br>(whichever is greater) | NA | +/- 15% or +/- 10 daPa<br>(whichever is greater) |
| | Pump speed | As fast as possible: | NA | 50 daPa/sec to 150<br>daPa/sec |
| | | 400 daPa/sec, 200<br>daPa/sec, 100 daPa/sec, 50<br>daPa/sec | NA | |
| | | Manuals speed control | NA | NA |
| | Air release | Mechanical safety release<br>valve set to +600 and -800<br>daPa | NA | Mechanical safety release<br>valve set to +600 and -800<br>daPa |
| | | Manual & automatic air<br>release | NA | Manual & automatic air<br>release |
| Ipsi/contralateral<br>stimuli | | | | |
| | Pure tone | 0.5, 1, 2, 4 kHz | NA | 0.5, 1, 2, 4 kHz |
| | Step size | 1, 2, 5, 10 dB | NA | 1 to 10 dB |
| | Attenuator range,<br>ipsi lateral<br>stimulus | 0.5, 1.0, 2.0, kHz 50-115 dB<br>HL, 4.0 kHz 50-90 dB HL | NA | 0.5, 1.0, 2.0, 4.0 kHz 80-105<br>dB HL |
| | Attenuator range,<br>contra lateral<br>stimulus | 0.5, 1.0, 2.0, 4.0 kHz 50-100<br>dB HL, white noise | NA | 0.5, 1.0, 2.0, 4.0 kHz 80-100<br>dB HL |
| | Frequency<br>accuracy | +/- 0.5% | +/- 0.5% | +/-0.5% |
| Distortion Product<br>Otoacoustic<br>Emissions | | | | |
| | Stimulus | | NA | 2 pure tone stimulus |
| Characteristic | | Predicate<br>Impedance<br>Audiometer<br>Madsen Zodiac 901<br>K910247 | Predicate<br>Otoacoustic<br>Emissions<br>Bio-Logic AuDX<br>K974076 | Tympany Otogram<br>Combined Device<br>Impedance<br>Audiometer<br>Otoacoustic<br>Emissions |
| | | | channels | channels |
| | F2 test frequency | NA | 2.0, 3.0, 4.0, 5.0 kHz | 1.0, 1.5, 2.0, 3.0, 4.0 kHz |
| | Stimulus level<br>range | NA | 55 dB SPL and 65 dB SPL | 45-70 dB SPL |
| Physical<br>characteristics: | | | | |
| | Computer<br>interface | RS 232C | RS 232C | Computer included, RS<br>232C |
| | Internal printer | Thermal 112 mm, 4.5" | Thermal 59 mm, 2 1/4" | Thermal 58 mm, 2 1/4" |
| | Printer interface | Parallel port | RS 232C thermal printer | Parallel port or USB |
| | Display | Graphic supertwist LCD<br>backlight, 256 lines x 128<br>dots | LCD 1" x 3" | Computer LCD 1024 x 768 |
| | | White text/graphics on blue<br>background | Black and white | Color, resistive touchscreen |
| | Control interface | Keyboard | Touchpad | Keyboard, touchscreen |
| | Size/weight -<br>metric | 370 x 385 x 120 mm (W x D<br>x H), 7.6kg | 98 x 41 x 197 mm (W x D x<br>H), 0.45 kg | 410 x 300 x 480 mm (W x D<br>x H), 20.4 kg |
| | Size/weight -<br>American | 14.8" x 15.4" x 4.8", 16.8 lbs | 3 7/8" x 1 5/8" x 7 3/4", 1 lbs | 16" x 19" x 12", 45 lbs |
| | Energy source | AC 50/60 Hz, 100-240 V | AC 50/60 Hz, 100-240 V | AC 50/60 Hz, 100-120 V |
| | Hardcopy output | Thermal paper or external<br>printer paper | External thermal printer | Thermal paper or external<br>printer paper |
| Standard and safety<br>characteristics | | | | |
| | Performance and<br>calibration | IEC 1027, ANSI S3.39 | NA | IEC 1027, ANSI S3.39 |
| | Electrical safety | EN 60601-1, class I, type B | EN 55011: 1991 Group 1<br>Class B | EN 60601-1, class I, type B |
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#### 7. Conclusion
After analyzing both bench and user testing data, it is the conclusion of Tympany Inc. that the Tympany OTOGRAM is safe and effective as the predicate device, has few technological differences, and has no new indications for use, thus rendering it substantially equivalent to the predicate device.
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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized graphic of three abstract human figures, represented by curved lines, facing to the right.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP - 3 2004
Tympany, Inc. c/o Daniel Kamm, P.E. Kamm & Associates P.O. Box 7007 Deerfield, IL 60015
Re: K041853
Trade/Device Name: Otogram, Audiometer, Impedance Audiometer, and Otoacoustics Emissions Device Regulation Number: 21 CFR 874.1050 Regulation Name: Audiometer Regulatory Class: Class II Product Code: ETY; ETW Dated: July 6, 2004
Received: July 9, 2004
Dear Mr. Kamm:
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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), 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 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean I hat 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); 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.
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### Page 2 - Daniel Kamm, P.E.
This letter will allow you to begin marketing your device as described in your Section 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), please contact the Office of Compliance at (301) 594-4613. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). 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) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
A kalgi korenthal
A. Ralph Rosenthal, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known):
K041853
Device Name: "Otogram" Combination -(Pure tone and speech audiometer, impedance audiometer, and distortion product otoacoustic emissions analyzer.)
Indications For Use:
"Otogram" can perform the functions of:
- Pure tone and speech audiometer, 1.
- Impedance audiometer (tympanometry, acoustic reflex), and 2.
- Distortion product otoacoustic emissions analyzer. 3.
The unit is intended for use by a qualified/trained audiologist on both adult and pediatric subjects for measurement of acoustic impedance.
Prescription Use _ X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 801.109) TVC 8/30/04
TYC 8/30/04
Jivision of Onl Nose and Throat
510(k) Number K041853
Page 1 of 1
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.