Cefaly® Acute is indicated for the acute treatment of migraine with or without aura in patients 18 years of age or older.
Device Story
Cefaly® Acute is a supraorbital transcutaneous electrical nerve stimulator (TENS) for migraine treatment. Device applies biphasic electrical impulses via a self-adhesive electrode placed on the forehead to stimulate supratrochlear and supraorbital nerves (branches of trigeminal nerve V1). Device is battery-operated; user initiates a 60-minute automated program via a single switch. Intensity ramps up linearly from 1mA to 16mA over 14 minutes, then remains constant. Output is delivered as rectangular biphasic pulses (250µs width, 100Hz frequency). Device is intended for patient use to provide analgesic effect during migraine attacks. Clinical benefit is demonstrated by reduction in pain scores on a visual analog scale (VAS) compared to sham.
Clinical Evidence
Randomized, sham-controlled clinical trial (N=106; 93 female, 13 male). Primary endpoint: change in VAS pain score from baseline to 1 hour. Mean change: -3.46±2.32 (Cefaly Acute) vs -1.78±1.89 (sham); treatment difference -1.68 (p<0.05). Results showed statistically significant pain relief at 1, 2, and 24 hours. One minor, reversible adverse event (nausea) reported.
Technological Characteristics
Plastic PC housing; 3.7V LiPo battery; bipolar self-adhesive electrode. Biphasic rectangular pulses; 100Hz frequency; 250µs pulse width; 16mA max current. Standards: IEC 60601-1, 60601-1-2, 60601-1-6, 60601-1-11, 60601-2-10, IEC 62366. Dimensions: 55mm x 40mm x 15mm; weight 12g.
Indications for Use
Indicated for acute treatment of migraine with or without aura in patients 18 years of age or older.
Regulatory Classification
Identification
A transcutaneous electrical nerve stimulator to treat headache is a device used to apply an electrical current to a patient's cranium through electrodes placed on the skin.
Special Controls
*Classification.* Class II (special controls). The special controls for this device are:(1) The patient-contacting components of the device must be demonstrated to be biocompatible.
(2) Appropriate analysis/testing must validate electromagnetic compatibility and electrical, mechanical, and thermal safety.
(3) The technical parameters of the device, including waveform, output modes, maximum output voltage and current (with 500, 2,000, and 10,000 ohm loads), pulse duration, frequency, net charge (µC) per pulse, maximum phase charge at 500 ohms, maximum current density (mA/cm
2 , r.m.s.), maximum average current (mA), maximum average power density (W/cm2 ), and the type of impedance monitoring system must be fully characterized.(4) Electrical performance, adhesive integrity, shelf life, reusability, and current distribution testing of the electrodes must be conducted.
(5) Appropriate software verification, validation, and hazard analysis must be performed.
(6) Clinical performance data must demonstrate that the device is safe and effective as a treatment for headache in the indicated patient population.
(7) Labeling must include the following:
(i) Appropriate contraindications such as not for use in subjects with an implanted metallic or electronic device in the head, a cardiac pacemaker, or an implanted or wearable defibrillator.
(ii) Appropriate warnings such as not to apply the device on the neck or chest, not to use the device in the presence of electronic monitoring equipment, not to use in the bath or shower, not to use while sleeping, not to use while driving, not to use while operating machinery.
(iii) Appropriate precautions such as the long-term effects of chronic use of the device are unknown.
(iv) A summary of the expected risks and benefits of using the device.
(v) A summary of the clinical performance data, including information on the patient population for which the device has and has not been demonstrated to be effective, and any adverse events and complications.
(vi) Information on how the device operates and the typical sensations experienced during treatment.
(vii) A detailed summary of the device technical parameters.
(viii) An expiration date/shelf life for the electrodes and the number of times they can be reused.
(ix) Disposal instructions.
In combination with the general controls of the Food Drug & Cosmetic Act, the Transcutaneous Electrical Nerve Stimulator to Treat Headache is subject to the following special controls:
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Image /page/0/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. 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 image of three human profiles facing to the right, stacked on top of each other, with a flowing design element below them.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 15, 2017
CEFALY Technology Jean-Yves Mignolet R&D Manager Rue Louis Plescia 34 Seraing, BE 4102 Liege
Re: K171446
Trade/Device Name: Cefaly® Acute Regulation Number: 21 CFR 882.5891 Regulation Name: Transcutaneous Electrical Nerve Stimulator To Treat Headache Regulatory Class: Class II Product Code: PCC Dated: May 16, 2017 Received: August 14, 2017
Dear Jean-Yves Mignolet:
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.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device
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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 contact the Division of Industry and Consumer Education (DICE) 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. 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
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 Industry and Consumer Education (DICE) 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,
William J. Heetderks -S 2017.09.15 16:45:15 -04'00'
- for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K171446
Device Name Cefaly® Acute
Indications for Use (Describe)
Cefaly® Acute is indicated for the acute treatment of migraine with or without aura in patients 18 years of age or older.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for CEFALY Technology. The logo consists of a red, curved line above the words "CEFALY" and "TECHNOLOGY", which are stacked on top of each other. The text is in a gray sans-serif font. The red line is composed of two curved lines that meet in the middle, forming a peak.
Rue Louis Plescia, 34
4102 Seraing - BELGIUM
Tél.: +32 4 367 67 22
Fax: +32 4 367 67 02
www.cefaly-technology.com
# Section 5
# 510(k) Summary
# 5.1. Submitter information
Submitter Name: CEFALY Technology Address: Rue Louis Plescia, 34 B-4102 SERAING BELGIUM + 32 4 367 67 22 Phone: + 32 4 367 67 02 Fax: Contact Person: Jean-Yves MIGNOLET (R&D Manager) This summary was prepared on: May 5, 2017
## 5.2. Device information
Device Trade or Proprietary Name: Cefaly® Acute Device Common or Usual Name (Regulation Description): Transcutaneous electrical nerve stimulator to treat headache Device Classification Name: Stimulator, Nerve, Electrical, Transcutaneous, For Migraine (21 CRF 882.5891. Product Code PCC) Device Class: Class II
# 5.3. Substantial equivalency
Substantial Equivalency is claimed against the following legally marketed device: Cefaly® (510(k) number K160237).
# 5.4. Description of the device
The Cefaly® Acute device is a supraorbital transcutaneous electrical nerve stimulator device to be applied on the forehead. A self-adhesive electrode with 2 conductive zones is placed on the forehead. This double electrode is directly connected to the device.
The Cefaly® Acute is operated by a rechargeable battery. A pressure on the single switch starts a program, which runs automatically for 60 minutes.
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Image /page/4/Picture/0 description: The image shows the logo for CEFALY Technology. The logo consists of a red curved line above the words "CEFALY" and "TECHNOLOGY", which are stacked on top of each other. The text is in a gray sans-serif font.
www.cefalv-technology.com
The electrical impulses generated by the Cefaly® Acute device are transmitted transcutaneously via the supraorbital electrode to excite (trigger action potentials on) the supratrochlearis and supraorbitalis nerves. Supratrochlearis and supraorbitalis (or supratrochlear and supraorbital) nerves belong to the upper branch of the trigeminal nerve (VI). Therefore, the supraorbital neurostimulation is also known as external trigeminal nerve stimulation. The supraorbital neurostimulation generates an analgesic effect and is intended to treat acute migraine headaches.
#### 5.5. Indications for use of the device
The Cefaly® Acute is indicated for the acute treatment of migraine with or without aura in patients 18 years of age or older.
## 5.6. Summary of the technological characteristics of the Cefaly® Acute in comparison with the predicate Cefaly®
The Cefaly® Acute device is significantly equivalent to the legally marketed device Cefaly® (K160237), in terms of shape and technology, except for two of the output parameters (frequency of the pulses and duration of a session) and for the button color.
The Cefaly® Acute device is made of a plastic casing identical to that of the predicate Cefaly®. Only the button color is changed to easily differentiate the two devices. It works with the same electrode as the predicate device. It is powered by the same battery. The electronics inside the device is also the same: only the software has been adapted. The Cefaly® Acute device delivers biphasic impulses of the same pulse shape and width (250us) than the predicate device. The repetition frequency of the impulses in the Cefaly® Acute is 100Hz, while in the predicate Cefaly® it is 60Hz. A session for the Cefaly® Acute lasts 60 minutes, while for the predicate Cefaly® it lasts 20 minutes.
| | Cefaly® | Cefaly® Acute |
|--------------------|-----------------------------------|-----------------------------------|
| 510 (k) Number | K160237 | K171446 |
| Device Name | Cefaly® | Cefaly® Acute |
| Manufacturer | CEFALY Technology | CEFALY Technology |
| Power Source | 1 rechargeable LiPo 3.7 V battery | 1 rechargeable LiPo 3.7 V battery |
| Channels | | 1 |
| Computerized | Yes | Yes |
| Software provided | 1 fixed program | 1 fixed program |
| Constant current | Yes | Yes |
| Constant voltage | No | No |
| Max output current | 16 mA | 16 mA |
#### 5.6.1. Basic characteristics
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Rue Louis Plescia, 34 4102 Seraing - BELGIUM Tél. : +32 4 367 67 22 Fax: +32 4 367 67 02 www.cefaly-technology.com
| Max output voltage (2kOhms) | 32 Volts | 32 Volts |
|----------------------------------------|-------------------------|-------------------------|
| Automatic overload trip voltage level | Yes | Yes |
| Automatic no load trip | No | No |
| Patient override control method | On/Off button | On/Off button |
| Max leakage current | None (battery operated) | None (battery operated) |
| Electrodes | Cefaly® electrode | Cefaly® electrode |
| Indicator display:<br>Unit functioning | Yes | Yes |
| Low battery indicator | Yes | Yes |
| Set-up mAmp | Yes | Yes |
| Set-up parameters | No | No |
| Standards:<br>IEC 60601-1 | Yes | Yes |
| IEC 60601-1-2 | Yes | Yes |
| IEC 60601-1-6 | Yes | Yes |
| IEC 60601-1-11 | Yes | Yes |
| IEC 60601-2-10 | Yes | Yes |
| IEC 62366 | Yes | Yes |
| Timer setting | Yes | Yes |
| Weight | 12 g | 12 g |
| Dimensions | 55 mm x 40 mm x 15 mm | 55 mm x 40 mm x 15 mm |
| Housing materials | Plastic PC | Plastic PC |
Basic characteristics of the Cefaly® device and the Cefaly® Acute device are exactly the same.
# 5.6.2. Output mode
| | Cefaly® | Cefaly® Acute |
|------------------------------|---------------------------------------------------------------------------------|------------------------------------------------------------------------------|
| Waveform | Biphasic | Biphasic |
| Shape | Rectangular | Rectangular |
| | Full compensated | Full compensated |
| | Symmetrical | Symmetrical |
| Net charge (µC) per pulse | 0 | 0 |
| Method | Same charge quantity on positive<br>and negative impulse | Same charge quantity on positive and<br>negative impulse |
| Max phase amplitude | 16 mA with a load of a 4.7 µF<br>capacitor parallel with 2.2Kohms<br>resistance | 16 mA with a load of a 4.7 µF capacitor<br>parallel with 2.2Kohms resistance |
| Maximum output voltage (V): | | |
| At 500 ohms | 8 | 8 |
| At 2,000 ohms | 32 | 32 |
| At 10,000 ohms | 60 | 60 |
| Maximum output current (mA): | | |
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ouis Plescia 4102 Seraing - BELGIUI Tél.: +32 4 367 67 22 Fax: +32 4 367 67 02 www.cefaly-technology.com
| At 500 ohms | 16 | 16 |
|------------------------------------------------------------------|-----------------------------------|-----------------------------------|
| At 2,000 ohms | 16 | 16 |
| At 10,000 ohms | 6 | 6 |
| Duration of the primary (depolarizing) phase (µS) | 250 | 250 |
| Standby duration between the two phases (µS) | 5 | 5 |
| Pulse duration (µS) | 505 | 505 |
| Maximum current density (mA/cm², r.m.s.) at 500 ohms | 2.37 | 2.37 |
| Maximum average power density (W/cm2) at 500 ohms | 0.000017 | 0.000047 |
| Maximum average current (average absolute value, mA) at 500 ohms | 0.48 | 0.8 |
| Phase rise time | 2 µS | 2 µS |
| Phase decay time | 2 µS | 2 µS |
| Interphase interval | nil | nil |
| Frequency range | 60 Hz fixed | 100 Hz fixed |
| Burst mode | No | No |
| Maximum Phase Charge (µC) @ 500 Ohms | 4 | 4 |
| Modulation options | | |
| Amplitude | 0 - 16 mA | 0 - 16 mA |
| Frequency | Fixed @ 60 Hz | Fixed @ 100 Hz |
| Duration | Fixed @ 250 µS | Fixed @ 250 µS |
| Ramp modulations | | |
| ramp up | 14 minutes | 14 minutes |
| ramp down | 1 minute | 1 minute |
| Amplitude modulation | Amplitude is adjusted by the user | Amplitude is adjusted by the user |
All output mode features are identical for the Cefaly® and the Cefaly® Acute, except the frequency of the stimulation, which has a direct impact on the maximum average power density and the maximum average current.
## 5.6.3. Materials
| | Cefaly® | Cefaly® Acute |
|--------------------------|------------|---------------|
| Device housing materials | Plastic PC | Plastic PC |
Materials of the Cefaly® device and the Cefaly® Acute device are exactly the same. The Cefaly® Acute device is made of a plastic casing identical to that of the Cefaly® device. Only the button color is changed to easily differentiate the two devices, which has no impact on substantial equivalence.
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Image /page/7/Picture/0 description: The image contains the logo for CEFALY Technology. The logo consists of the text "CEFALY" in a larger, bolder font above the word "TECHNOLOGY" in a smaller font. Above the text is a red, curved line that resembles an arch.
Fax: +32 4 367 67 0: www.cefaly-technology.com
# 5.6.4. Principle of operation
The Cefaly® device and the Cefaly® Acute device are both external cranial neurostimulators designed for supraorbital neurostimulation (also known as external trigeminal nerve stimulation). Trigeminal nerve stimulation induces a neuromodulation of the trigeminal system in order to treat migraine.
The Cefaly® device and the Cefaly® Acute device both generate electrical impulses which are transmitted transcutaneously via a bipolar self-adhesive electrode placed on the forehead.
The Cefaly® device and the Cefaly® Acute device both operate on direct electrical energy which is output from a rechargeable 3.7V LiPo battery.
The Cefaly® device and the Cefaly® Acute device both deliver electrical energy in the form of rectangular biphasic pulses. The intensity is increasing linearly from 1mA to a maximum of 16 mA during 14 minutes, and then stays constant for 6 minutes in the Cefaly® device and for 46 minutes in the Cefaly® Acute device. The pulse frequency is 60 Hz in the Cefaly® device and 100 Hz in the Cefaly® Acute device. The pulse width is 250 us in both devices.
The Cefaly® Acute device uses the legally marketed electrode cleared with the Cefaly® device (K160237). The supraorbital electrode of the Cefaly® device is designed in order to cover both sides of the supratrochlearis and supraorbitalis nerves, which are branches of the trigeminal nerve (Figure 1).
Image /page/7/Figure/8 description: This image shows a diagram of a person's head with a medical device attached. The device consists of a gray, mesh-like forehead pad and a red strap that wraps around the head and connects to the ears. The diagram also highlights areas of the head in red, possibly indicating areas of pain or pressure. The person's facial features are drawn in a simple, stylized manner.
Figure 1: The electrode placed on the forehead covers the supraorbitalis nerves for both the Cefaly® device and the Cefaly® Acute device.
The electrical impulses generated by the Cefaly® device and the Cefaly® Acute device are both transmitted transcutaneously via the supraorbital electrode to excite (trigger action potentials) the supratrochlearis and supraorbitalis nerves. Supratrochlearis and supraorbitalis (or supratrochlear
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Image /page/8/Picture/0 description: The image contains the logo for CEFALY Technology. The logo consists of the word "CEFALY" in large, gray, sans-serif font, with the word "TECHNOLOGY" in a smaller font directly below it. Above the word "CEFALY" is a red, curved line that resembles a stylized roof or arch.
Rue Louis Plescia, 34
4102 Seraing - BELGIUM
Tél.: +32 4 367 67 22
Fax: +32 4 367 67 02
www.cefaly-technology.com
and supraorbital) nerves belong to the upper branch of the trigeminal nerve (V1). Therefore, the supraorbital neurostimulation is also known as external trigeminal nerve stimulation.
The principle of operation of the Cefaly® device and the Cefaly® Acute device is exactly the same.
## 5.7. Pre-Clinical Testing
The Cefaly® Acute device is compliant to the same international standards that of the legally marketed Cefaly® device (K160237).
| Standards | Cefaly® | Cefaly® Acute |
|----------------|---------|---------------|
| IEC 60601-1 | Yes | Yes |
| IEC 60601-1-2 | Yes | Yes |
| IEC 60601-1-6 | Yes | Yes |
| IEC 60601-1-11 | Yes | Yes |
| IEC 60601-2-10 | Yes | Yes |
| IEC 62366 | Yes | Yes |
# 5.8. Clinical Testing
## Randomized, sham-controlled clinical trial
Purpose: To provide evidence of safety and efficacy of the Cefaly® Acute for the acute treatment of migraine with or without aura in patients 18 years of age or older
Study population: 106 patients (93 females and 13 males) having a migraine attack with or without aura
Adverse events encountered: One adverse event (nausea) occurred but this event was minor and totally reversible (nausea resolved by itself after 20 minutes). There were adverse events (SAE), nor were any subjective complaints or side effects reported in either group within the 24 hours after the beginning of the treatment
Results: In the ITT analysis, the primary outcome was the change of pain score from baseline to one hour of treatment. The pain score was measured on an 11-point visual analog scale (VAS). Based on the ITT population (N=106) with the missing value imputed by the last observation carried forward, the mean change in VAS pain score from baseline to 1 hour was -3.46±2.32 in Cefaly Acute group and -1.78±1.89 in sham group. The treatment difference (Cefaly Acute sham) was -1.68, which was statistically significant at two-sided 0.05 alpha level. The pain relief was as well observed in the verum group compared to the sham group at 2-hour and 24-hour time
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Image /page/9/Picture/0 description: The image shows the logo for CEFALY Technology. The logo consists of a red curved line above the words "CEFALY" and "TECHNOLOGY", which are stacked on top of each other. The text is in a gray sans-serif font.
-32 4 367 67 7 Fax: +32 4 367 67 02 www.cefaly-technology.com
> points. Anti-migraine rescue medication intake within the 24 hours after the beginning of the treatment is not significantly lower in the verum group.
## 5.9. Conclusion
Data from the nonclinical and clinical tests demonstrate that the subject device is significantly equivalent to the legally marketed device identified in paragraph (5.3) of this section.
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.