Horizon® 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
Device Story
Computerized, electromechanical TMS system; delivers brief, rapidly alternating magnetic pulses to induce electrical currents in cerebral cortex. Used in clinics/hospitals by physicians to treat Major Depressive Disorder. System includes mainframe, power supply, interface unit, user interface, and stimulation coils. Features StimGuide+ for navigated coil positioning and Magstim Connect for patient data management (authentication, synchronization, remote updates). Physician uses system to determine motor threshold (MT) via visual monitoring or EMG, then applies stimulation to left dorsolateral prefrontal cortex. Treatment protocols (standard rTMS or iTBS) are pre-programmed. Device provides non-invasive therapy; helps patients resistant to antidepressant medication.
Clinical Evidence
Bench testing only. Validated via electrical safety (ANSI/AAMI ES60601-1), EMC (IEC 60601-1-2), alarm systems (IEC 60601-1-8), and biocompatibility (ISO 10993). Human factors engineering verified safe use in intended environments. Software lifecycle and cybersecurity risks evaluated per ISO 14971 and AAMI TIR57.
Indicated for adult patients with Major Depressive Disorder who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
Regulatory Classification
Identification
A repetitive transcranial magnetic stimulation system is an external device that delivers transcranial repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex to treat the symptoms of major depressive disorder without inducing seizure in patients who have failed at least one antidepressant medication and are currently not on any antidepressant therapy.
Special Controls
*Classification.* Class II (special controls). The special control is FDA's “Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation System.” See § 882.1(e) for the availability of this guidance document.
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September 14. 2021
Magstim Company Ltd. Tom Campbell Chief Quality and Regulatory Affairs Officer and UK Site Director Spring Gardens Whitland, Carmarthenshire SA34 0HR United Kingdom
Re: K211389
Trade/Device Name: Magstim Horizon 3.0 TMS Therapy System, Horizon 3.0 System, Horizon 3.0. Horizon 3.0 with Navigation Regulation Number: 21 CFR 882.5805 Regulation Name: Repetitive Transcranial Magnetic Stimulation System Regulatory Class: Class II Product Code: OBP Dated: May 5, 2021 Received: May 5, 2021
Dear Tom Campbell:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.
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
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Pamela Scott Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number K211389
Device Name
# Horizon® 3.0 TMS Therapy System
Indications for Use (Describe)
Horizon® 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
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)
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# K211389 Traditional 510(k) SUMMARY Maqstim's Horizon® 3.0 TMS Therapy System
Prepared according to the requirements outlined in 21 CFR 807.92
## Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Magstim® Company Limited Spring Gardens, Whitland, Carmarthenshire SA34 OHR, United Kingdom
Phone: +44 (0) 1994 240798 Facsimile: +44 (0) 1994 240061
Contact Person: Tom Campbell, Chief Quality & Regulatory Affairs Officer and UK Site Director
Date Prepared: September 14, 2021
#### Trade Name of Device
Horizon® 3.0 TMS Therapy System
#### Common or Usual Name
Repetitive Transcranial Magnetic Stimulation (rTMS) System
#### Classification
Repetitive Transcranial Magnetic Stimulation (rTMS) System
21 C.F.R. § 882.5805, Class II, product code OBP
#### Predicate Devices
K182853 Horizon® TMS Therapy System, The Maqstim® Company Limited (Primary Predicate Device), 21 C.F.R § 882.5805, OBP K183376 Horizon® TMS Therapy System with Navigation, The Magstim® Company Limited (Secondary Predicate Device), 21 C.F.R § 882.5805, OBP K201158 NeuroStar Advanced Therapy, Neuronetics Inc. (Reference Predicate Device), 21 C.F.R & 882.5805, OBP
#### Device Description
The Horizon® 3.0 TMS Therapy System is a computerized, electromechanical medical device that produces and delivers non-invasive, magnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation. ("TMS")
The Horizon® 3.0 TMS Therapy System is a non-invasive tool for the stimulation of cortical neurons for the treatment of Major Depressive Disorder in adult patients who have failed to
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achieve satisfactory improvement from antidepressant medication in the current episode. The Horizon® 3.0 TMS Therapy System is used for patient treatment by prescription only under the supervision of a licensed physician. It can be used in both inpatient settings, including physicians' offices, clinics, and hospitals.
Horizon® 3.0 TMS Therapy System is an integrated system consisting of a combination of hardware, software, and accessories. Its technological characteristics are described in further detail below.
## Intended Use
Horizon® 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
## Technological Characteristics
Horizon® 3.0 TMS Therapy System is offered in two system configurations: Horizon® 3.0 and Horizon® 3.0 with StimGuide+. These system configurations are comprised of the following physical components:
| Horizon® 3.0 | Horizon® 3.0 with StimGuide+ |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 1. Horizon® 3.0 Stimulator<br>a. Horizon® 3.0 Mainframe;<br>b. Horizon® 3.0 PSU (Power Supply Unit);<br>c. Horizon® 3.0 Interface Unit;<br>d. Horizon® 3.0 User Interface.<br>2. Horizon® 3.0 Coil for MT Determination<br>a. Horizon® MT Coil;<br>3. Horizon® 3.0 Coil for Treatment<br>a. Horizon® 3.0 E-z Cool Coil.<br>4. Horizon® 3.0 Cart and Coil Holder<br>a. Horizon® 3.0 E-z Cart;<br>b. Horizon® 3.0 Coil Holder.<br>5. Horizon® 3.0 Camera Stand<br>6. Accessories<br>a. Horizon® 3.0 Accessory Kit. | 1. Horizon® 3.0 Stimulator<br>a. Horizon® 3.0 Mainframe;<br>b. Horizon® 3.0 PSU (Power Supply Unit);<br>c. Horizon® 3.0 Interface Unit (Nav);<br>d. Horizon® 3.0 User Interface;<br>e. StimGuide+ User Interface.<br>2. Horizon® 3.0 Coil for MT Determination<br>a. Horizon® MT Coil.<br>3. Horizon® 3.0 Coil for Treatment<br>a. Horizon® E-z Cool Coil (Nav).<br>4. Horizon® 3.0 Cart and Coil Holder<br>a. Horizon® 3.0 E-z Cart;<br>b. Horizon® 3.0 Coil Holder.<br>5. Horizon® 3.0 Camera Stand<br>6. Accessories<br>a. Horizon® 3.0 Accessory Kit;<br>b. StimGuide+ Accessory Kit. |
The technological differences between Horizon® 3.0 TMS Therapy System and its primary and secondary predicate devices (K182853 & K183376) includes:
- . An upgraded mainframe to address component obsolescence including component upgrades to improve reliability, whilst also enabling remote upgradeability.
- . A minor design change to the Power Supply Unit to facilitate the introduction of the Horizon® 3.0 Interface Unit.
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- . The introduction of the Horizon® 3.0 Interface Unit that runs the graphical user interface (Horizon® and StimGuide+), houses the StimGuide+ accessories for full system integration, whilst also enabling wireless network connectivity.
- . Improved touch panels and graphical user interface to improve the user experience.
- . An upgraded cart and arm to refine and improve the user experience for coil positioning for treatment.
- An update to StimGuide to allow users to place additional helper landmarks at any . position on the patient's head. StimGuide+ can display distances to the selected landmarks.
Horizon® 3.0 TMS Therapy System also enables patients to be treated in multi-site clinics through its integration with a Patient Data Management (PDM) system, Magstim Connect. Integration of Horizon® 3.0 and Magstim Connect includes the following three functions:
- 1. Authentication Service
- 2. Synchronization Service
- 3. Remote Update Service
Software documentation for a "moderate" level of concern has been provided.
## Non-Clinical Testing
Non-clinical testing was conducted to validate the performance of the Horizon® 3.0 TMS Therapy System and to ensure that the device performs as intended and meets the design specifications, consistent with FDA's guidance "Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation (rTMS).
Electrical safety and electromagnetic compatibility ("EMC") testing were conducted on the Horizon® 3.0 TMS Therapy System to demonstrate that the device is compliant with IEC 60601-1 (Ed. 3.1.) and IEC 60601-1-2 (Ed. 4.). Environmental testing and acoustic output measurements has been conducted during IEC 60601-1 (Ed. 3.1) testing to demonstrate safety and performance.
Biocompatibility evaluation has demonstrated that patient-contacting components of Horizon® 3.0 TMS Therapy System meet the requirements of ISO 10993-1 (Ed. 4.) standards. In addition, acoustic output measurements have been conducted during IEC 60601-1 (Ed. 3.1) testing to demonstrate safety and performance.
A summary of the non-clinical testing performed on the Horizon® 3.0 TMS Therapy System is provided in Table 1.
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# Table 1: Summary of Non-Clinical Testing
| Test | Method | Results/ Comment |
|----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Electrical Safety<br>Mechanical Safety | ANSI/AAMI ES60601-1:2005/(R)2012 and<br>A1:2012-<br>Medical electrical equipment - Part 1:<br>General requirements for<br>basic safety and essential performance;<br>FDA Recognition Number: 19-4 | A sample Horizon® 3.0 TMS Therapy<br>System (specifically Horizon® 3.0 with<br>StimGuide+) has been tested and found<br>to be compliant to the requirements of<br>ANSI/AAMI ES 60601-1 by independent<br>test laboratory BSI Appliances, to<br>demonstrate safety and effectiveness of<br>the system following incorporation of<br>new/ different characteristics as<br>compared to the predicate device. |
| Electromagnetic<br>Compatibility | IEC 60601-1-2: 2014 -<br>Medical electrical equipment - Part 1-2:<br>General requirements for basic safety and<br>essential performance -<br>Collateral standard: Electromagnetic<br>compatibility -Requirements and tests;<br>FDA recognition number: 19-8 | A sample of the Horizon® 3.0 TMS<br>Therapy System (specifically Horizon®<br>3.0 with StimGuide+) has been tested<br>and found to be compliant to the<br>requirements of IEC 60601-1-2 by<br>independent test laboratory Eurofins<br>Hursley, to demonstrate safety and<br>effectiveness of the system following<br>incorporation of new/ different<br>characteristics as compared to the<br>predicate device. |
| Alarm Systems | IEC 60601-1-8 -<br>Medical electrical equipment - Part 1-8:<br>General requirements for basic safety and<br>essential performance - Collateral<br>Standard: General requirements, tests and<br>guidance for alarm systems in medical<br>electrical equipment and medical electrical<br>systems; FDA Recognition Number: 5-76 | A sample Horizon® 3.0 TMS Therapy<br>System has been tested and found to be<br>compliant to the requirements of IEC<br>60601-1-8 by independent test<br>laboratory BSI Appliances, thus<br>demonstrating the Horizon® 3.0 TMS<br>Therapy System is substantially<br>equivalent to the legally marketed<br>predicate device. |
| Biocompatibility | ISO 10993-1:2009 - Biological Evaluation<br>of Medical Devices - Part 1: Evaluation and<br>testing within a risk management process<br><br>ISO 10993-5:2009 - Biological evaluation<br>of medical devices -- Part 5: Tests for in<br>vitro cytotoxicity; FDA Recognition<br>Number: 2-245 | Patient-contacting components of the<br>Horizon® 3.0 TMS Therapy System<br>include:<br>• Enclosure of the Horizon® MT Coil;<br>• Enclosure of the Horizon® E-z Cool<br>Coil 3.0:<br>• Enclosure of Horizon® E-z Cool Coil<br>(Nav) 3.0, |
| | | |
| | ISO 10993-10:2010 - Biological evaluation<br>of medical devices - Part 10: Tests for<br>irritation and skin sensitization; FDA<br>Recognition Number: 2-174 | All these have limited contact duration<br>with skin (surface contacting, less than<br>24-hour duration).<br>Samples of these materials have been<br>tested and found to be compliant to the<br>requirements of ISO 10993-1, ISO<br>10993-5 and ISO 10993-10 by an<br>independent test laboratory, thus<br>demonstrating the Horizon® TMS<br>Therapy System is substantially<br>equivalent to the legally marketed<br>predicate devices. |
| Human Factors Testing | AAMI/ANSI HE75 - Human Factors<br>Engineering - Design of Medical Devices;<br>FDA Recognition Number: 5-57 | Usability testing was performed to<br>Horizon® 3.0 TMS Therapy System.<br>The Human Factors Engineering report<br>verifies the Horizon® 3.0 TMS Therapy<br>System, to be safe and effective for the<br>intended users, uses, and use<br>environments thus demonstrating the<br>Horizon® 3.0 TMS Therapy System is<br>substantially equivalent to the legally<br>marketed predicate devices. |
| | IEC 62366-1 - Medical Devices - Part 1:<br>Application of Usability Engineering To<br>Medical Devices; FDA Recognition<br>Number: 5-114 | intended users, uses, and use<br>environments thus demonstrating the<br>Horizon® 3.0 TMS Therapy System is<br>substantially equivalent to the legally<br>marketed predicate devices. |
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The Software lifecycle process, which includes verification and validation testing assures that the software performs as intended and in accordance with specifications. The potential risks of Horizon 3.0 have been identified and evaluated in compliance with ISO 14971 (Ed 2.0), and the risks were determined to be acceptable, or have been addressed with risk control measures. In addition to ISO 14971, AAMI TIR57:2016/(R)2019 – Principles for Medical Device Security – Risk Manaqement was also applied to evaluate and control cyber security risks associated with the Horizon 3.0 device and the risks were determined to be acceptable.
## Substantial Equivalence Discussion
The Horizon® 3.0 TMS Therapy System is substantially equivalent to the primary and secondary predicate devices, the Horizon® TMS Therapy System (K182853) and the Horizon® TMS Therapy System with Navigation (K183376).
The intended use and indications for use of the Horizon® 3.0 TMS Therapy System and the primary and secondary predicate devices is identical: all devices are intended to treat Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
The basic design of Horizon® 3.0 TMS Therapy System is substantially equivalent to the design of the predicate devices (K182853 and K183376), as all systems are based on applying transcranial magnetic stimulation by means of repetitive pulse trains at a predetermined frequency. All systems use the same mechanism of action, i.e., an electromechanical instrument that produces and delivers brief duration, rapidly alternating (pulsed) magnetic fields to induce electrical currents in localized regions of the prefrontal cortex.
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The coil head geometry of the Horizon® 3.0 E-z Cool Coil and Horizon® 3.0 E-z Cool Coil (Nav) are identical to the predicate devices, the Horizon® E-z Cool Coil and Horizon® E-z Cool Coil (SG), cleared under K182853 and K183376. For this reason, the magnetic field characteristics of the system are identical to the predicate devices, therefore equivalent safety and performance is assured. Consequently, no additional testing of the magnetic field characteristics of the system is necessary to meet the requirement of FDA's quidance document "Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation (rTMS) Systems" in order to demonstrate safety and performance.
The remaining technological characteristics of the Horizon® 3.0 TMS Therapy System, the Horizon® TMS Therapy System (K182853) and the Horizon® TMS Therapy System with Navigation®, including mechanism of action, specifications, treatment procedure, are very similar, and in most cases, identical.
The integration of Magstim Connect that could adversely affect the device (Authentication and Synchronization) have been evaluated, controlled and validated. Magstim has concluded that these functions do not compromise the established safety and effectiveness of the device and that the benefit of introducing these networked functions to enable greater patient management, and the ability for patient information to be persisted across multiple clinics/sites, outweighs the identified risk and the risk has been controlled to an acceptable level. The ability for Horizon® to integrate with Magstim Connect is supported by the FDAs clearance of the Neurostar Advanced Therapy (K201158) which includes the integration of TrakStar (MDDS) with their NeuroStar Advanced Therapy System for patient data manaqement.
The principles of operation of the Horizon® 3.0 TMS Therapy System is equivalent to the primary and secondary predicate devices. The methods for determining Motor Threshold both with and without EMG and determining the coil position for treatment in both navigated and non-navigated device configurations remain unchanged compared to the predicate devices. The the FDA cleared standard rTMS protocol and the FDA cleared iTBS protocol are identical to those of the predicate devices.
A summary of the similarities and minor differences between the Horizon® 3.0 TMS Therapy System and its primary and secondary predicate devices; the Horizon TMS Therapy System (K182853) and the Horizon TMS Therapy System with Navigation (K183376) are described in Table 2.
#### Conclusions
The intended use and indications for use are identical between the Horizon® 3.0 TMS Therapy System (subject of this submission) and the primary and secondary predicate devices (K182853 and K183376).
Although the technological characteristics of the Horizon® 3.0 TMS Therapy System differ slightly following the introduction of product improvements and patient data management integration, non-clinical testing demonstrates that the Horizon® 3.0 is as safe and effective compared to its primary and secondary predicate devices, the Horizon® TMS Therapy System (K182853) and the Horizon® TMS Therapy System with Navigation (K183376).
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Furthermore, the principles of operation remain unchanged between the Horizon® 3.0 TMS Therapy System and its primary and secondary predicates. The labeling for both the Horizon® 3.0 TMS Therapy System and its primary and secondary predicates instruct users that the FDA cleared Standard Treatment Protocol and FDA cleared iTBS Treatment Protocol are the only stimulation parameters that have been established to be safe and effective for treating MDD in clinical trials and should be set as the default treatment parameters for treating adult patients with MDD who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
Thus, the information and data provided in this 510(k) premarket notification submission support a finding of substantial equivalence for the Horizon® 3.0 TMS Therapy System.
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## Table 2: Substantial Equivalence Summary
| Criteria | Horizon® 3.0 TMS Therapy System<br>(Subject of this submission) | Horizon® TMS Therapy<br>System with Navigation<br>(K182853)<br>(Primary Predicate) | Horizon® TMS Therapy<br>System<br>(K183376<br>(Secondary Predicate) |
|--------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Magstim Company Limited | Magstim Company Limited | Magstim Company Limited |
| Device Name | Horizon® 3.0 TMS Therapy System | Horizon® TMS Therapy System<br>with Navigation | Horizon® Therapy System |
| Clearance date | | 04/03/2019 | 03/15/2019 |
| 510(k) number | K211389 | K183376 | K182853 |
| Device code | OBP | OBP | OBP |
| Intended Use/<br>Indications for Use | The Horizon® 3.0 TMS Therapy System is indicated for the treatment of<br>Major Depressive Disorder in adult patients who have failed to achieve<br>satisfactory improvement from prior antidepressant medication in the<br>current episode. | The Horizon® TMS Therapy System is<br>indicated for the treatment of Major<br>Depressive Disorder in adult patients<br>who have failed to achieve satisfactory<br>improvement from prior antidepressant<br>medication in the current episode. | The Horizon® Therapy System is<br>indicated for the treatment of Major<br>Depressive Disorder in adult patients<br>who have failed to achieve satisfactory<br>improvement from prior antidepressant<br>medication in the current episode. |
| Standard Treatment Protocol | | | |
| Magnetic Field Intensity | 120% of the MT | 120% of the MT | 120% of the MT |
| Stimulus Frequency | 10 Hz | 10 Hz | 10 Hz |
| Stimulus Train duration | 4 sec | 4 sec | 4 sec |
| Inter-train interval | 11-26 sec | 11-26 sec | 11-26 sec |
| Number of trains | 75 | 75 | 75 |
| Magnetic Pulses per<br>Session | 3000 | 3000 | 3000 |
| Treatment Session<br>Duration | 18.8 min-37.5 min | 18.8 min-37.5 min | 18.8 min-37.5 min |
| Sessions/week | 5 | 5 | 5 |
| Treatment Schedule | 5 daily sessions for 6 weeks | 5 daily sessions for 6 weeks | 5 daily sessions for 6 weeks |
| Area of brain to be stimulated | Left Dorsolateral Prefrontal Cortex | Left Dorsolateral Prefrontal Cortex | Left Dorsolateral Prefrontal Cortex |
| iTBS Treatment Protocol | | | |
| Stimulation Intensity | 120% of the MT | 120% of the MT | N/A |
| Repetition Rate | 50 Hz (5 pulses per sec) | 50 Hz (5 pulses per sec) | N/A |
| Train Duration | 2 sec | 2 sec | N/A |
| Inter-train Interval | 8 sec | 8 sec | N/A |
| Burst Pulses | 3 | 3 | N/A |
| Bursts | 200 | 200 | N/A |
| Inter Pulse interval | 20 msec | 20 msec | N/A |
| Number of trains | 20 | 20 | N/A |
| Number of Pulses per Session | 600 | 600 | N/A |
| Treatment Session Duration | 3 minutes 9 seconds | 3 minutes 9 seconds | N/A |
| Sessions/week | 5 | 5 | N/A |
| Treatment Schedule | 5 daily sessions for 6 weeks | 5 daily sessions for 6 weeks | N/A |
| Area of brain to be stimulated | Left Dorsolateral Prefrontal Cortex | Left Dorsolateral Prefrontal Cortex | N/A |
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| Stimulating Coils | | | | | | | | |
|----------------------------------------------------------------------------------|---------------------|---------------------------------|----------------------------------------|----------------------------|----------------------------------------|----------------------------|---------------------------|--|
| Coil Reference | Horizon®<br>MT Coil | Horizon®<br>3.0 E-z Cool Coil | Horizon®<br>3.0 E-z Cool Coil<br>(Nav) | Horizon®<br>MT Remote Coil | Horizon®<br>E-z Cool Coil<br>(SG) | Horizon®<br>MT Remote Coil | Horizon®<br>E-z Cool Coil | |
| Waveform | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic | Biphasic | |
| Configuration | Figure of 8 | Figure of 8 | Figure of 8 | Figure of 8 | Figure of 8 | Figure of 8 | Figure of 8 | |
| Core Material | Air | Air | Air | Air | Air | Air | Air | |
| Inductance (nominal) | 15μH | 16.5μH | 16.5μH | 15μH | 16.5μH | 15μH | 16.5μH | |
| Pulse Width | 330μs | 340μs | 340μs | 330μs | 340μs | 330μs | 340μs | |
| Horizon 3.0 Specifications | | | | | | | | |
| Amplitude in SMT units<br>(Standard Motor Threshold) | 0.28 - 1.9 | | | 0.28 - 1.9 | | | 0.28 - 1.9 | |
| Frequency range (Hz) at<br>100% | 1 - 20 | | | 1 - 20 | | | 1 - 20 | |
| Maximum output<br>amplitude (V/m) at a<br>depth of 2cm below the<br>coil surface | 150 V/m | | | 150 V/m | | | 150 V/m | |
| Maximum magnetic field<br>strength (T) at coil<br>surface | 1.0T | | | 1.0T | | | 1.0T | |
| Maximum magnetic field<br>strength (T) at a depth of<br>2cm | 0.4T | | | 0.4T | | | 0.4T | |
| Maximum magnetic field<br>gradient (dB/dt) (kT/s) at<br>coil surface | 18 kT/s | | | 18 kT/s | | | 18 kT/s | |
| Coil Positioning and MT Determination Principle | | | | | | | | |
| System Configuration | Horizon® 3.0 | Horizon® 3.0 with<br>StimGuide+ | Horizon® Performance | | Horizon® Performance with<br>StimGuide | | | |
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| Coil Position Principle | Indirect targeting of treatment<br>target through measured<br>distance and direction (5.5cm)<br>from MT Hotspot. Measure<br>derived from statistical<br>distance of DLPFC from MT<br>hotspot. | Indirect targeting of treatment<br>target through measured<br>distance and direction (5.5cm)<br>from MT Hotspot using<br>stereotactic navigation.<br>Measure derived from<br>statistical distance of DLPFC<br>from MT hotspot. | Indirect targeting of treatment<br>target through measured distance<br>and direction (5.5cm) from MT<br>Hotspot. Measure derived from<br>statistical distance of DLPFC from<br>MT hotspot. | Indirect targeting of treatment<br>target through measured distance<br>and direction (5.5cm) from MT<br>Hotspot using stereotactic<br>navigation. Measure derived from<br>statistical distance of DLPFC from<br>MT hotspot. |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| MT Response Detection | Visual qualitative monitoring<br>for APB response | Option 1. EMG provides<br>quantitative data based on<br>which user defines MT.<br>Option 2. Visual qualitative<br>monitoring for APB response | Visual qualitative monitoring for<br>APB response | Option 1. EMG provides<br>quantitative data based on which<br>user defines MT.<br>Option 2. Visual qualitative<br>monitoring for APB response |
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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.