K140190 · Advanced Brain Monitoring, Inc. · MYB · May 29, 2014 · Dental
Device Facts
Record ID
K140190
Device Name
NIGHT SHIFT
Applicant
Advanced Brain Monitoring, Inc.
Product Code
MYB · Dental
Decision Date
May 29, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.5570
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Night Shift is indicated for prescription use for the treatment of adult patients with positional obstructive sleep apnea with a non-supine apnea-hypopnea index < 20, and to reduce or alleviate snoring. It records position, movement, and sound so that positional changes in sleep quality and snoring can be assessed.
Device Story
Night Shift is a neck-worn device for positional obstructive sleep apnea (OSA) treatment. It uses 3-D actigraphy and an acoustic microphone to monitor sleep position, movement, and snoring. When the device detects the user in a supine position, it initiates vibro-tactile feedback via haptic motors, increasing in intensity until the user shifts to a non-supine position. The device is used at home by the patient. Data is stored on the device and can be transferred via USB to a web portal or desktop software for report generation, allowing users and clinicians to assess sleep quality, snoring levels, and therapy efficacy. The device helps patients avoid supine sleep, potentially reducing apnea events and snoring.
Clinical Evidence
Clinical study of 27 patients with positional OSA (non-supine AHI < 20). Primary endpoint: 85.2% of participants achieved >50% reduction in AHI. Secondary endpoints met: 92% accuracy in supine position detection (vs. video/chest sensor), 100% compliance (min 20/28 nights), and significant improvements in snoring. No adverse events reported. Bench testing confirmed electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), and biocompatibility (ISO 10993-1).
Technological Characteristics
Neck-worn device with silicone enclosure. Sensing: 3-D actigraphy and acoustic microphone. Actuation: Haptic motors for vibro-tactile feedback. Connectivity: USB for data transfer to web portal/desktop software. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-11, ISO 10993-1. Cleaning: Alcohol wipes/detergent. Firmware-based control.
Indications for Use
Indicated for adult patients with positional obstructive sleep apnea (non-supine AHI < 20) and to reduce or alleviate snoring.
Regulatory Classification
Identification
Intraoral devices for snoring and intraoral devices for snoring and obstructive sleep apnea are devices that are worn during sleep to reduce the incidence of snoring and to treat obstructive sleep apnea. The devices are designed to increase the patency of the airway and to decrease air turbulence and airway obstruction. The classification includes palatal lifting devices, tongue retaining devices, and mandibular repositioning devices.
Special Controls
*Classification.* Class II (special controls). The special control for these devices is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intraoral Devices for Snoring and/or Obstructive Sleep Apnea; Guidance for Industry and FDA.”
Apnea Risk Evaluation System (ARES), Model 610 (K112514)
Submission Summary (Full Text)
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K140190
Advanced Brain Monitoring, Inc. Night Shift
# MAY 2 9 2014
## 510(k) Summary
In accordance with 21 CFR 807.92 the following summary of information is provided:
DATE: May 29, 2014
### 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:
Daniel J. Levendowski President and Co-founder Advanced Brain Monitoring, Inc.
#### DEVICE:
TRADE NAME: Night Shift - Sleep Positioner
COMMON/USUAL NAME: Night Shift
CLASSIFICATION NAMES: 872.5570 Intraoral Devices for Snoring and Intraoral Devices for Snoring and Sleep Apnea
PRODUCT CODE: MYB
| PREDICATE DEVICE(S): | |
|----------------------|--|
|----------------------|--|
K100160 ZZOMA Positional Sleeper
K112514 Apnea Risk Evaluation System (ARES), Model 610
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## DEVICE DESCRIPTION:
The Night Shift is worn around the neck to reduce the amount of time the user sleeps in the supine position as a treatment for positional obstructive sleep apnea. Night Shift combines hardware and firmware to detect when the user attempts to sleep in the supine position and can initiate vibro-tactile feedback with increasing intensity until the user shifts to a non-supine position. The initiation of positional feedback from the Night Shift is turned on is programmable to allow the user to fall asleep (if they must) on their back. Each night the Night Shift is worn, it monitors sleep position (% time supine), behavioral sleep efficiency, and snoring levels (% time snoring > 40 and 50 dB) as well as the frequency, duration and intensity of the feedback (when applied). These data can be optionally transferred via the USB port to the Night Shift Web Portal where the user can generate a report to assess how well the positional feedback is working. A "trial" protocol can include one night with no feedback to establish a baseline and two nights with feedback to assess compliance/efficacy. Utilization information is saved on the device that allows reports to be generated that compares daily use by month and monthly averages for one year. The portal also allows the device to be reformatted (to eliminate all previously recorded data) for a new user, adjust the feedback settings to a new user's personal preferences, and/or upgrade the firmware. For large healthcare organizations that limit internet access, desktop software is provided as an alternative to the portal.
#### INTENDED USE:
The Night Shift is indicated for prescription use for the treatment of adult patients with positional obstructive sleep apnea with a non-supine apnea-hypopnea index < 20, and to reduce or alleviate snoring. It records position, movement, and sound so that positional changes in sleep quality and snoring can be assessed.
#### TECHNOLOGY:
The Night Shift uses the same fundamental technology as a therapeutic massager (i.e., regulation number 890.5975) to deliver vibro-tactile feedback with haptic motors when the user attempts to sleep on their back. The Night Shift is functionally equivalent to the ZZOMA positional sleeper as both devices prevent users from sleeping on his or her back. The Night Shift provides information used to assess user benefit by recording position, movement, snoring and feedback frequency and duration using the actigraphy and acoustic microphone signals equivalent to Apnea Risk Evaluation System. The technologies used in the Night Shift are used in the same manner as the predicate products and do not raise new questions of safety and effectiveness.
Table 5.1 summarizes the similarities and differences of the Night Shift to the legally marketed predicate devices to which substantial equivalency is claimed. The Night Shift is equivalent to the ZZOMA Sleep Positioner (K100160) for treatment of positional OSA and equivalent to the
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Apnea Risk Evaluation System (ARES), Model 610 (K112514) for recording position, movement, and sound so that positional changes in sleep quality and snoring can be assessed.
| Specification | Night Shift | ZZOMA Positional<br>Sleeper (K100160) | ARES Model 610<br>(K112514) |
|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications<br>for Use | The Night Shift is<br>indicated for<br>prescription use for the<br>treatment of patients<br>with positional<br>obstructive sleep apnea<br>with a non-supine<br>apnea-hypopnea index <<br>20, and to reduce or<br>alleviate snoring. It<br>records position,<br>movement, and sound<br>so that positional<br>changes in sleep quality<br>and snoring can be<br>assessed. | The ZZOMA Positional<br>Sleeper is indicated for<br>use and intended for<br>professional use for the<br>treatment of mild to<br>moderate obstructive<br>sleep apnea (OSA) and<br>to reduce or alleviate<br>snoring. | The Apnea Risk<br>Evaluation System<br>(ARES) Model 610 is<br>indicated for use in the<br>diagnostic evaluation by<br>a physician of adult<br>patients with possible<br>sleep apnea. The ARES<br>can record and score<br>respiratory events<br>during sleep (e.g.,<br>apneas, hypopneas,<br>mixed apneas and flow<br>limiting events). The<br>device is designed for<br>prescription use in home<br>diagnosis of adults with<br>possible sleep-related<br>breathing disorders. |
| Patient<br>Population | Adults | Adults | Adults |
| Anatomical<br>Sites | Positions on the back of<br>the neck | Positions on the back | Positions on the<br>forehead |
| Therapeutic<br>Methodology | Vibro-tactile feedback<br>with increasing intensity<br>when user is detected to<br>be sleeping supine | Backpack style pillow<br>that prevents user from<br>sleeping supine. | Not applicable. |
| Environment<br>of Use | Home during sleep every<br>night | Home during sleep every<br>night | Home during sleep for<br>up to three nights |
| Specification | Night Shift | ZZOMA Positional<br>Sleeper (K100160) | ARES Model 610<br>(K112514) |
| User<br>Interface | User control, visual and<br>vibro-tactile indicators | N/A | User control, visual and<br>audio indicators |
| Accessories | Silicone enclosure strap | Velcro elastic belt | Elastic enclosure strap.<br>EEG and ECG electrodes<br>and nasal cannula |
| Signals<br>Acquired | 3-D actigraphy<br>Microphone | None | 3-D actigraphy<br>Microphone<br>Nasal Pressure &<br>cannula<br>Respiratory Effort<br>Forehead EEG<br>Red and infra-red<br>(IR) optical signals |
| Acquisition<br>modes | Records sleep data. | None | Records sleep data. |
| Cleaning | Enclosure is disinfected<br>using alcohol wipes; the<br>strap is cleaned with<br>dish detergent | None | Cleaned and disinfected<br>by rubbing with alcohol-<br>based hand sanitizer and<br>isopropyl alcohol. |
| Data transfer<br>from SD card | Data transfer from flash<br>storage via native USB<br>on microcontroller | None | Data transfer from SD<br>Card via Native USB |
| Software | Software provides<br>device management,<br>data analysis and report<br>presentation on a web-<br>portal | None | Software provides<br>device management,<br>data analysis and report<br>presentation on a web-<br>portal |
Table 5.1 Comparison of Night Shift to Predicate Device
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## DETERMINATION OF SUBSTANTIAL EQUIVALENCE:
## SUMMARY OF NON-CLINICAL TESTS:
Support for the substantial equivalence of the Night Shift was provided as a result of risk management and testing which included electrical and biological safety, performance and software tests. This testing includes conformity to voluntary standards as follows:
| Standard Number | Standard Title |
|-----------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-1: 2005 +<br>CORR. 1 (2006) +<br>CORR. 2 (2007) | Part 1: General requirements for basic safety and essential<br>performance. |
| Comments | Complied with use and labeling with respect to environmental<br>conditions of transport and storage, after removal from protective<br>package and subsequent use, and indicated instructions for use.<br>Maintained basic safety and essential performance in the presence of<br>condensation and thermal shock. Met accessibility requirements of<br>60601-1 Part 1-11. Passed usability assessment of the design,<br>identification, markings and accompanying documents met<br>requirements for a lay operator with 8 years of education. Tested<br>against excessive temperatures and other hazards. Confirmed a lay<br>operator can perform cleaning and sterilization. Passed IEC<br>60529:1989 for IP22, and mechanical strength, shock, vibration, free<br>fall tests. Confirmed design protects against strangulation or<br>asphyxiation |
| IEC 60601-1-2: 2007 | Medical Electrical Equipment Part 1-2: Collateral standard:<br>Electromagnetic compatibility - requirements and tests. |
| Comments | Passed conducted emissions, radiated emissions, harmonics and<br>Flicker, electrostatic discharge, radio frequency immunity, EFT<br>immunity, power lines surge immunity, RF common mode immunity,<br>power frequency magnetic field immunity test and voltage dips/short<br>interruptions test. |
| ISO 10993-1: 2009 | Biological evaluation of medical devices Part 1 |
| Comments | Passed irritation, sensitization, and cytotoxicity tests. |
| IEC 60601-1-11: 2010 | Medical electrical equipment - Part 1-11: General requirements for<br>basic safety and essential performance - Collateral Standard:<br>Requirements for medical electrical equipment and medical electrical<br>systems used in the home healthcare environment. |
| Comments | Met standards for: Temperature and Humidity, Operating<br>Environmental/Atmospheric Pressure, Operating Environment/<br>Temperature and Relative Humidity, Operating Environment/Shock,<br>Operating Environment/Random Vibration, and Push Test. |
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Additional verification and validation testing confirmed:
- All features of the Night Shift were compliant with the system, software and firmware . level requirements.
- . Night Shift provides information useful in assessing user benefit equivalent to the predicate device.
## SUMMARY OF CLINICAL TESTS:
A clinical study was conducted to evaluate safety and efficacy of the Night Shift. For this evaluation, patients who had completed a baseline PSG with a minimum of four hours of sleep time were to wear the Night Shift for two nights without feedback to confirm their willingness to continue with the study, followed by 28 nights of vibro-tactile position therapy. A follow-up PSG was conducted as soon as possible to the completion of the 28-nights of treatment.
With respect to effectiveness of Night Shift therapy, the following primary endpoint was evaluated: 65% of positional therapy (PT) compliant participants with baseline overall AH > 10 will demonstrate a clinically important reduction in sleep apnea severity based on a minimum 50% reduction. The indication for use for Night Shift was further refined to include only those patients with a non-supine AHI <20. Results from 27 patients with pre-treatment positional obstructive sleep apnea with a non-supine AHI < 20 were included in the analysis. They are stratified by outcome and the post-treatment overall AHI in the table below. This analysis confirms that the primary endpoint was met and that Night Shift is efficacious in the treatment of patients with positional obstructive sleep apnea (POSA) with a non-supine AHI <20.
| | Pre-treatment | | | 95% Confidence | |
|--------------------------|---------------|--------------|-----------|----------------|--------------|
| | >5 AHI <15 | >15 AHI < 30 | AHI > 30 | Total | Interval |
| Treatment outcome | n = 11 | n = 10 | n = 6 | n =27 | |
| AHI >50% decrease, % (n) | 81.8 (9) | 80.0 (8) | 100.0 (6) | 85.2 (23) | 71.8 – 98.6 |
| AHI >35% decrease, % (n) | 9.1 (1) | 0.0 (0) | 0.0 (0) | 3.7 (1) | -3.4 - 10.8 |
| Non-responder, % (n) | 9.1 (1) | 20.0 (2) | 0.0 (0) | 11.1 (3) | -0.8 -- 23.0 |
In addition to the primary endpoint discussed above, the study evaluated the following additional primary, secondary and exploratory endpoints. For these endpoints, the analysis includes an additional 3 subjects that were part of the full study but had a pre-study non-supine AHI >20 and were therefore outside of the indication evaluated for effectiveness.
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## Advanced Brain Monitoring, Inc. Night Shift
.
.
| Endpoint | Study Result | Conclusion |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Primary Endpoints | | |
| 80% of participants will complete the<br>study with no adverse events resulting<br>in him/her voluntarily dropping from<br>the Study (primary) | 100% of the subjects who were<br>provided an intention to treat and<br>were compliant with the protocol<br>successfully completed the study.<br>No adverse events were reported. | The primary endpoint is met. |
| Secondary Endpoints | | |
| Night Shift will accurately measure<br>the supine position such that the<br>computation of percent time supine<br>by Night Shift is within+/- 5% of the<br>percent time supine by video<br>recordings plus chest sensor in 73% of<br>subjects. | Night Shift was within 5% of<br>chest/video supine time in 92% of<br>the studies. | The secondary endpoint is met. |
| At least 80% of participants will be<br>compliant i.e., use Night Shift for a<br>minimum of 5.5 hours/night or the<br>length of their time in bed, five .<br>nights/week (e.g., 20 of 28 nights). | 100% of the participants wore the<br>Night Shift for a minimum of 20<br>nights across the 28 nights of<br>intended use. | The secondary endpoint is met. |
| At least 70% of participants will<br>average less than 15% time supine<br>across the four weeks of home use. | 97% of the participants averaged<br>less than 15% of time in bed in the<br>supine position when therapy was<br>delivery. | The secondary endpoint is met. |
| 50% of PT compliant participants will<br>show an improved Epworth<br>Sleepiness Score (ESS) of $≥$ 2. | 50% of participants exhibited an<br>improvement of 2 or more, and<br>50% showed no change. None of<br>the ESS scores worsened by 2 or<br>more. | The secondary endpoint is met. |
| The Functional Outcomes of Sleep<br>(FOSQ) total will improve by $≥$ 2 points<br>in at least 50% of subjects. | 57% exhibited an improvement of 2<br>or more, 23% showed no change,<br>and 20% showed a worsening of 2<br>or more. | The secondary endpoint is met. |
| The mean sensitivity (sleep) and<br>specificity (wake) for Night Shift will<br>be 0.85 and 0.50, respectively. | The endpoint was met based on the<br>sensitivity and specificity of 90%<br>and 58% across 65 studies. | The secondary endpoint is met. |
| Endpoint | Study Result | Conclusion |
| 73% of subjects will be within the<br>range of the predicate when<br>subtracting PSG Total Sleep Time (TST)<br>from Night Shift TST (i.e., range 151<br>and -129 minutes, respectively). | 99% of the studies had TST derived<br>from Night Shift within the<br>maximum error (based on two<br>standard deviations of the TST error<br>for the predicate device) vs. PSG<br>TST. | The secondary endpoint is met. |
| 73% of subjects will be within the<br>range of the predicate when<br>subtracting PSG Sleep Efficiency (SE)<br>from Night Shift SE (i.e., range 19.1<br>and -17.2%, respectively). | 92% of studies had SE values<br>derived from Night Shift within the<br>maximum error (based on two<br>standard deviations of the SE error<br>for the predicate device) vs. PSG SE.<br>80% of subjects had sleep onset<br>values <15-minutes. 82% of<br>subjects had wake after sleep onset<br>(WASO) values <45 minutes | The secondary endpoint is met. |
| Exploratory Endpoints | | |
| There are no consistent patterns of<br>increased N1 and cortical arousals or<br>decreased N3 and REM. | 87% showed in decrease in N1, 80%<br>a decrease in cortical arousals, 17%<br>an increase in N3, and 33% an<br>increase in REM sleep.<br>Only 3% of subjects showed<br>increase in N1, 7% an increase in<br>cortical arousals, 13% a decrease in<br>N3, and 17% a decrease in REM<br>sleep. | The exploratory endpoint is met. |
| The percent time snoring > 50 dB can<br>be used to identify patients with an<br>AHI ≥ 10 with a sensitivity > 0.80 and a<br>specificity > 0.65 so that these Night<br>Shift users will recognize the need to<br>be evaluated for undiagnosed<br>obstructive sleep apnea. | When the percentage of time<br>snoring above 50 dB exceeds 10%<br>of sleep time, the sensitivity was<br>0.85 and the specificity exceeded<br>0.58. | The exploratory endpoint was not<br>met. |
| Supplemental analysis | Statistically significant<br>improvements in loud snoring was<br>observed. Loud snoring decreased<br>in 59% of subjects, and only<br>increased in 10% of the cases. | |
| Endpoint | Study Result | Conclusion |
| Those successfully or unsuccessfully<br>treated with Night Shift can be<br>identified via combination of changes<br>in the AHI, daytime drowsiness (ESS),<br>depression (PHQ9), Insomnia (ISI),<br>anxiety (GAD7) and quality of life<br>(FOSQ). | Evaluating trends across these<br>measures, 50% of subjects showed<br>a substantial improvement as a<br>result of Night Shift therapy and an<br>additional 10% showed<br>improvement, and 33% showed no<br>change. None showed a worsening<br>and two cases (7%) showed<br>substantial overall worsening of<br>subjective measures. There was no<br>consistent patterns which can be<br>used to identify those who would<br>likely benefit from therapy, in part,<br>because most subjects benefited<br>either physiologically,<br>symptomatically or both. There<br>was some evidence to suggest that<br>limited time in-home untreated in<br>the supine position was associated<br>with no change in subjective<br>measures. | This exploratory endpoint was<br>suggested by the FDA under the<br>assumption that there would be<br>treatment failures and it would be<br>beneficial to a clinician to identify<br>patterns which define treatment<br>success/ failure.<br>In this study, the numbers of<br>failures were too few to<br>characterize. |
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## Advanced Brain Monitoring, Inc. Night Shift
ﺎ
.
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## Advanced Brain Monitoring, Inc. Night Shift
## CONCLUSION:
Advanced Brain Monitoring considers the Night Shift to be as safe, as effective, and substantially equivalent to the predicate devices.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002
DEPARTMENT OF HEALTH & HUMAN SERVICES
May 29, 2014
Advanced Brain Monitoring, Inc. c/o Mr. Daniel J. Levendowski President and Co-Founder 2237 Faraday Ave., Suite 100 Carlsbad, CA 92008
Re: K140190
Trade/Device Name: Night Shift Regulation Number: 21 CFR 872.5570 Regulation Name: Intraoral Devices for Snoring and Intraoral Devices for Snoring and Obstructive Sleep Apnea Regulatory Class: Class II Product Code: MYB, MNR Dated: April 23, 2014 Received: April 24, 2014
Dear Mr. Levendowski:
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.
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#### Page 2 - Mr. Daniel J. Levendowski
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 (2 l 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/ucm } 1,5809.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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
# Eric A. Mann -S
for Malvina B. Eydelman, 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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## K140190
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
## Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.
510(k) Number (if known) K140190
Device Name Night Shift
#### Indications for Use (Describe)
The Night Shift is indicated for prescription use for the treatment of adult pational obstructive sleep apnea with a nonsupine apnea-hypopnea index < 20, and to reduce or alleviate snoring. It records position, movement, and sound so that positional changes in sleep quality and snoring can be assessed.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
### PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
## FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signalure)
# Vasant G. Malshet -S
FORM FDA 3881 (1/14)
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This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and mainlain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
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"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
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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.
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Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
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.
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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.