K192469 · Nox Medical · OLZ · Nov 13, 2019 · Neurology
Device Facts
Record ID
K192469
Device Name
Nox Sleep System
Applicant
Nox Medical
Product Code
OLZ · Neurology
Decision Date
Nov 13, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1400
Device Class
Class 2
Attributes
AI/ML, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K192469 · Nov 13, 2019
Nox Sleep System
Nox Medical
Retrospective clinical sleep study recordings; Routine clinical care medical records
Retrospective analysis of pre-existing clinical sleep study data was used to validate the performance of the device's automatic scoring algorithms (Bruxism, PLM, Respiratory Flow/AHI/ODI, Apnea Classification, and Sleep Staging) against manual scoring performed by qualified technologists.
Retrospective analysis; Automatic scoring validation; Routine clinical care data
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Retrospective analysis of pre-existing clinical data
Adults from multiple U.S. dental clinics; Number of Sites: Multiple U.S. dental clinics
Manual scoring by qualified polysomnographic technologists
Sensitivity, specificity, PPV, NPV for bruxism-related events
Retrospective analysis of pre-existing clinical data
Adults seeking medical attention at a sleep clinic; Number of Sites: National hospital
Manual scoring by qualified polysomnographic technologists
ICC, Cohen's kappa, accuracy of sleep stage prediction
AI Performance
Output
Algorithm
Acceptance
Observed
Dev DS
Dev Readers
Test DS
Test Readers
Bruxism-related events
—
detect at least 90% of oromandibular movements with 95% confidence
sensitivity 95.7% (95% CI 93.2% - 97.4%)
—
—
Adult Polygraphy recordings from multiple U.S. dental clinics
>1 (trained healthcare professional)
Periodic Limb Movement Index
—
interclass correlation of 0.61 or greater
ICC 0.87
—
—
Adult Polysomnography recordings from a national hospital
>1 (polysomnographic technologists)
Apnea Hypopnea Index (AHI)
—
95% confidence in not misclassifying patients between AHI < 5 and AHI >= 15
Adult Polysomnography recordings from a national hospital
>1 (polysomnographic technologists)
Oxygen Desaturation Index (ODI)
—
—
Cohen's kappa 0.87
—
—
Adult Polysomnography recordings from a national hospital
>1 (polysomnographic technologists)
Central Apnea Index
—
ICC comparable to scientific literature of 0.46
ICC 0.91, Cohen's kappa 0.89
—
—
Adult Polygraphy recordings from a national hospital
>1 (polysomnographic technologists)
Sleep Staging
—
average accuracy of at least 60% when scoring wake epochs
Wake accuracy 66.7%, Cohen's Kappa <= 0.67
—
—
Adult recordings from a national hospital
>1 (polysomnographic technologists)
Indications for Use
The Nox Sleep System is used as an aid in the diagnosis of different sleep disorders and for the assessment of sleep. The Nox Sleep System is used to measure, record, display, organize, analyze, summarize, and retrieve physiological parameters during sleep and wake. The Nox Sleep System allows the user to decide on the complexity of the study by varying the number and types of physiological signals measured. The Nox Sleep System allows for generation of user/pre-defined reports based on subject's data. The user of the Nox Sleep System are medical professionals who have received training in the areas of hospital/clinical procedures, physiological monitoring of human subjects, or sleep disorder investigation. The intended environments are hospitals, institutions, sleep clinics, or other test environments, including patient's home.
Device Story
Nox Sleep System is a multi-channel physiological recording system for sleep assessment. Components include Nox A1 Recorder (patient-worn, battery-operated), Nox C1 Access Point (mains-powered, remote), Noxturnal App (mobile interface), and Noxturnal PSG software (PC-based). Inputs include EEG, EOG, EMG, respiratory effort (bands/belts), airflow (cannula/thermocouple), SpO2, pulse rate, and body position. System records, displays, and analyzes data; supports manual and automatic scoring of sleep stages, apneas, hypopneas, limb movements, and bruxism-related events. Used in hospitals, clinics, or homes by trained medical professionals. Output is analyzed data and reports for physician review. Automatic scoring assists diagnosis but requires manual verification. Benefits include efficient sleep disorder screening and diagnostic assessment.
Clinical Evidence
Retrospective clinical validation of automatic scoring algorithms using pre-existing clinical sleep study data. Algorithms evaluated: Bruxism (n=adults, sensitivity 95.7%, specificity 61.0%), PLM (ICC 0.87), AHI/ODI (Cohen's kappa 0.62-0.87 depending on signal type), Apnea Classification (ICC 0.91, Cohen's kappa 0.89), and Sleep Staging (accuracy 66.7%-87.0% per stage). Results demonstrate automatic scoring performs comparably to manual scoring by trained technologists.
Technological Characteristics
System includes Nox A1 Recorder (ABS/Polycarbonate), Nox C1 Access Point, and sensors (gold electrodes, respiratory bands). Connectivity via Bluetooth, Ethernet, and USB. Software (Noxturnal PSG) performs signal processing and automatic analysis. Biocompatibility per ISO 10993-5/10. Electrical safety per IEC 60601-1, 60601-1-2, 60601-1-11, 60601-2-25/26/40. Data storage via internal flash. 32-bit signal processing.
Indications for Use
Indicated for adult patients undergoing physiological measurements for sleep assessment and screening for sleep disorders. Used by trained medical professionals in clinical or home environments.
Regulatory Classification
Identification
An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.
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Nox Medical % John Smith Partner Hogan Lovells US, LLP 555 Thirteenth Street, NW Washington, DC 20004
### Re: K192469
Trade/Device Name: Nox Sleep System Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: Class II Product Code: OLZ, KZM Dated: September 9, 2019 Received: September 9, 2019
### Dear John Smith:
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 probibitions 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
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801); medical device reporting (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 (QS) 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-devices/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device (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,
Jay Gupta Assistant Director DHT5A: Division of Neurosurgical. Neurointerventional and Neurodiagnostic 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 (if known) K192469
Device Name Nox Sleep System
#### Indications for Use (Describe)
The Nox Sleep System is used as an aid in the diagnosis of different sleep disorders and for the assessment of sleep.
The Nox Sleep System is used to measure, record, display, organize, analyze, summarize, and retrieve physiological parameters during sleep and wake.
The Nox Sleep System allows the user to decide on the complexity of the study by varying the number and types of physiological signals measured.
The Nox Sleep System allows for generation of user/pre-defined reports based on subject's data.
The user of the Nox Sleep System are medical professionals who have received training in the areas of hospital/clinical procedures, physiological monitoring of human subjects, or sleep disorder investigation.
The intended environments are hospitals, institutions, sleep clinics, or other test environments, including patient's home.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--------------------------------------------------------------------|
| Prescription Use (Part 21 CFR 801 Subpart D) | <div> <span> <span style="font-size:16px;">☑</span> </span> </div> |
| Over-The-Counter Use (21 CFR 801 Subpart C) | <div> <span>☐</span> </div> |
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### 510(k) Summary
| Submitter: | Nox Medical<br>Katrinartuni 2<br>IS-105 Reykjavik<br>Iceland<br>Tel: +354 570 7170<br>Establishment Registration Number: 3007389703 |
|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Kolbrun E Ottosdottir<br>Chief Compliance Officer<br>Katrinartuni 2<br>IS-105 Reykjavik<br>Iceland |
| Application<br>Correspondent: | John J. Smith, MD, JD<br>Partner<br>Hogan Lovells US LLP<br>555 Thirteenth Street, NW<br>Washington, D.C. 20004 |
| Preparation Date: | November 12, 2019 |
| Device: | Device Proprietary Name: Nox Sleep System<br>Device Common or Usual Name: Sleep Assessment System<br>Classification Name: Electroencephalograph, Automatic<br>Event Detection Software for Polysomnograph with<br>Electroencephalograph<br>Regulation Number: 882.1400<br>Product Code: OLZ, KZM<br>Device Class: II<br>Review Panel: Neurology |
| Predicate Devices: | Substantial equivalence is claimed to Compumedics Somté<br>PSG System (K072201) from Compumedics Limited. |
| | The Nox T3 (K082113) from Nox Medical and Embletta<br>MPR (K122516) from Embla Systems are used as reference<br>devices. |
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### Device Description
The Nox Sleep System is intended for patients undergoing physiological measurements, for the assessment of sleep quality and the screening for sleep disorders.
The Nox Sleep System does not provide any alarms and is not intended to be used for continuous monitoring where failure to operate can cause injuries or death of the patient.
The basic Nox Sleep System consists of two recording/acquisition devices (Nox A1 Recorder and Nox C1 Access Point), a software running on a PC (Noxturnal PSG), an Android application (Noxturnal App) running on mobile platform, along with sensors and accessories. The system supports full Polysomnography (PSG) studies both in ambulatory and online/attended setups but also more simple sleep study setups, recording only few channels. The ambulatory sleep studies may take place in the clinic or in the home environment, but the online/attended sleep studies are only conducted in the clinical environment.
The Nox A 1 Recorder is a small battery-operated recording unit that is worn by the patient during the study. It records signals from patient applied sensors that connect to the unit but also supports recording of signals from auxiliary devices over Bluetooth. The Nox A1 Recorder allows for communication over Bluetooth with the Noxturnal App during ambulatory setup and with the Nox C1 Access Point during online setup. The recorder is intended to be worn over clothing.
New accessories and sensors as part of this submission are the Nox A 1 EEG 5 Lead Gold Electrode Cable and Nox A1 EEG Head Cable that are used for recording of EEG/EOG. These components are in direct contact with the patient.
The Nox C1 Access Point is a separate mains powered unit located remotely from the patient that allows for recording of signals from auxiliary devices. It supports communication over LAN/Ethernet to the Noxturnal PSG, and communication with the Nox A1 Recorder and Noxturnal App over Bluetooth. The Nox C1 Access Point is only used for online study setup and is thus not intended to be used in the home environment.
The Noxturnal App is used as a mobile interface to the Nox A1 Recorder and Nox C1 Access Point. The communications are via Bluetooth link. The app is normally used in the beginning of a sleep study, for basic tasks such as device configuration, starting a recording, checking the signal quality of signals being recorded and marking events during bio calibration.
The Noxturnal PSG is used for configuration of the Nox recording/acquisition devices, to download a study from ambulatory recording or to collect an online study. The software supports the viewing, retrieving, storing and processing of data recorded/collected, manual and automatic analysis and reporting on the results from the recorded studies. The purpose with the automatic scoring function in Noxturnal PSG is to assist the trained physician in the diagnosis of a patient. It is not intended to provide the trained physician with a diagnostic results. The type of automatic analysis events scored by Noxturnal PSG include: Sleep Stages (Wake, N1, N2, N3, REM), Apneas, Hypopneas, Apnea Cassification (Obstructive, Mixed and Central Apneas), Limb Movements, Periodic Limb Movements, SpO2 Desaturation Events. and potential Bruxism-Related Events.
The result of the automatic analysis/scoring must always be manually verified by the trained physician prior to diagnosis.
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### Indication for Use
The Nox Sleep System is used as an aid in the diagnosis of different sleep disorders and for the assessment of sleep.
The Nox Sleep System is used to measure, record, display, organize, analyze, summarize, and retrieve physiological parameters during sleep and wake.
The Nox Sleep System allows the user to decide on the complexity of the study by varying the number and types of physiological signals measured.
The Nox Sleep System allows for generation of user/pre-defined reports based on subject's data.
The user of the Nox Sleep System are medical professionals who have received training in the areas of hospital/clinical procedures, physiological monitoring of human subjects, or sleep disorder investigation.
The intended environments are hospitals, institutions, sleep clinics, or other test environments, including patient's home.
### Technological Characteristics and Comparison
For the purpose of demonstrating substantially equivalency of the Nox Sleep System the Compumedics Somté PSG (K072201) System from Compumedics Limited has been selected as the primary predicate device.
Indication for Use: "The Somté PSG is intended for use in the recording, displaying, analysis, printing and storage of human biological parameters such as heart and muscle activity, eye movement, breathing and body movements to assist in the diagnosis of various sleep disorders or sleep related respiratory or cardiac disorders. The Somté PSG is designed for ambulatory and mobile operation and can be used in either the patient's home, the hospital or other environments, thus enabling patients to be investigated under as realistic conditions as possible. The Somté PSG is only to be used under the direction of a physician. "
The primary predicate Compumedics Somté PSG and the new device Nox Sleep System are both used for recording of physiological parameters of various origin to assist with diagnosis of sleep disorders/sleep related disorders and support the same types of sleep studies, i.e. full Polysomnography (PSG) studies both in ambulatory and online/attended setups but also more simple sleep study setups, recording only few channels. The intended environments and user groups are the same for both the primary predicate and the new device, and both devices are for prescription use only. The overall methodology relating to how the sleep studies are conducted and the recorded data displayed and analysed is also very similar for both the new device and the primary predicate.
It is thus concluded that the intended use of the Nox Sleep System may be regarded the same as that of the Compumedics Somté PSG System.
The comparison table below is provided as a summary of the most relevant characteristics of the Nox Sleep System relative to the primary predicate Compumedics Somté PSG.
| Technological<br>Characteristic | Nox Sleep System | Compumedics Somté<br>PSG System | Result of Comparison |
|-----------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Portable design | Yes | Yes | Equivalent |
| Technological<br>Characteristic | Nox Sleep System | Compumedics Somté<br>PSG System | Result of Comparison |
| Patient worn device | Yes | Yes | Substantially Equivalent |
| Physical dimensions | Nox A1 Recorder:<br>82x63x21 mm<br>Nox C1 Access Point:<br>135x149x26 mm | Somté PSG Recorder:<br>113x65x30mm<br>Patient input box:<br>53x133x25mm<br>Bedside unit (dimensions<br>not stated in labeling) | Substantially Equivalent<br>The Embletta MPR<br>(K122516) includes a<br>separate device located<br>remotely from the patient<br>with very similar size<br>115x110x26mm |
| Weight | Nox A1 Recorder:<br>92 g (120 g with battery)<br>Nox C1 Access Point:<br>264 g | Somté PSG Recorder:<br>110 g (172 g including<br>batteries)<br>Patient input box: 95 g<br>Bedside unit (weight not<br>stated in labeling) | Substantially Equivalent<br>The Embletta MPR<br>(K122516) includes a<br>separate device located<br>remotely from the patient<br>with very similar weight<br>160g |
| Case Material | Plastic,<br>ABS/Polycarbonate blend | Plastic,<br>ABS/Polycarbonate blend | Equivalent |
| Method of Connection<br>to Patient | Respiratory bands/belts<br>for respiratory effort<br>Respiratory bands/belts<br>for attaching of device<br>and clip straps to secure<br>position of device<br>Plastic tubing and<br>cannula for pressure<br>sensing<br>Snap on electrode cables<br>with snap-on disposable<br>electrodes for EMG/EOG<br>Thermal flow<br>sensors/thermocouple for<br>measuring of nasal/oral<br>airflow<br>Nox A1 EEG 5 Lead<br>Gold Electrode Cable and<br>Nox A1 EEG Head Cable<br>for EEG/EOG | Respiratory bands/belts<br>for respiratory effort<br>Respiratory bands/belts<br>for attaching of device<br>and optional EZ Vest to<br>secure position of device<br>Plastic tubing and<br>cannula for pressure<br>sensing<br>Snap on electrode cables<br>with snap-on disposable<br>electrodes for EMG/EOG<br>Thermal flow<br>sensors/thermocouple for<br>measuring of nasal/oral<br>airflow | Substantially Equivalent<br>The use of an auxiliary<br>3rd party wireless<br>oximeter that is wrist<br>worn and connected via<br>Bluteooth® to the<br>recorder is substantially<br>equivalent to Nox T3<br>(K082113). |
| | Surface electrode leads<br>for EEG/EOG/EMG<br>Surface Electrodes for<br>measuring of leg<br>movements<br>Wrist worn oximeter and<br>probes for oximetry worn<br>on finger | Surface electrode leads<br>for EEG/EOG/EMG<br>Surface Piezo Limb<br>Sensor for measuring of<br>leg movements<br>Probes for oximetry worn<br>on finger | |
| Acquisition Units | Nox A1 Recorder<br>Nox C1 Access Point | Somté PSG Recorder<br>Patient Interface Box<br>Bedside unit for<br>recording of additional<br>AUX channels | Substantially Equivalent<br>Embletta MPR<br>(K122516) includes a<br>separate device allowing<br>recording of additional<br>AUX channels |
| Technological<br>Characteristic | Nox Sleep System | Compumedics Somté<br>PSG System | Result of Comparison |
| Local User Interface | Nox A1 Recorder:<br>Display (OLED), push<br>buttons and indicator<br>light on device<br><br>Nox C1 Access Point:<br>Light indicator on device,<br>factory reset button<br><br>Noxturnal App running<br>on Android™ platform | Somté PSG Recorder:<br>Display (LCD) and push<br>buttons and indicator<br>light on device | channels<br>Substantially Equivalent<br>The Noxturnal App is<br>used in a very similar<br>way as the display on the<br>Somté PSG Recorder and<br>may be regarded as an<br>extension of the display<br>screen on the Nox A1<br>Recorder. |
| Data Collection | Yes | Yes | Equivalent |
| Display Raw Data<br>during Recording | Yes, By use of the<br>Noxturnal PSG (PC)<br>during in-lab use or by<br>use of Noxturnal App | Yes, PC during in-lab<br>use, or LCD on unit | Substantially Equivalent |
| Real-time waveforms<br>preview | Yes - By use of the<br>Noxturnal App including<br>full disclosure waveform<br>preview | Yes - Integrated LCD<br>including full disclosure<br>waveform preview | Substantilly Equivalent |
| Data display on PC for<br>interpretation | Yes – during or after<br>recording | Yes - during or after<br>recording | Equivalent |
| Data Analysis | Yes - By use of<br>Noxturnal PSG SW (PC<br>application)<br>Automatic, result may be<br>manipulated (manual<br>review/verification must<br>be performed prior to<br>diagnosis)<br>Manual analysis<br>Event marking (scoring)<br>Technician Notes | Yes - By use of<br>Profusion Sleep SW (PC<br>application)<br>Automatic, result may be<br>manipulated (manual<br>review/verification must<br>be performed prior to<br>diagnosis)<br>Manual analysis<br>Event marking (scoring)<br>Technician Notes | Equivalent |
| Signal Sheets/Trace<br>Display Layout<br>properties - Adjust by<br>user | Yes - By use of<br>Noxturnal PSG SW (PC<br>application) - such as:<br>Timebase settings<br>Signal<br>grouping/arrangements<br>Grid Markers<br>Epoch Markers<br>Apply changes to data<br>type<br>Background color<br>Cursor color<br>Grid color | Yes - By use of<br>Profusion Sleep SW (PC<br>application) - such as:<br>Timebase settings<br>Signal<br>grouping/arrangements<br>Grid Markers<br>Epoch Markers<br>Apply changes to data<br>type<br>Background color<br>Cursor color<br>Grid color | Equivalent |
| Signal trace properties<br>- Adjust by user | Yes - By use of<br>Noxturnal PSG SW (PC<br>application) - such as:<br>Select Input and<br>reference<br>Name<br>Trace color | Yes - By use of<br>Profusion Sleep SW (PC<br>application) - such as:<br>Select Input and<br>reference<br>Name<br>Trace color | Equivalent |
| Technological<br>Characteristic | Nox Sleep System | Compumedics Somté<br>PSG System | Result of Comparison |
| | Zoom | Zoom | |
| | Size | Size | |
| | Grids | Grids | |
| | Polarity | Polarity | |
| | Upper/lower display<br>bounds | Upper/lower display<br>bounds | |
| | Filtering (HP/LP/Notch) | Filtering (HP/LP/Notch) | |
| | Auto Scale | Auto Scale | |
| | Numeric | Numeric | |
| | Offset | Offset | |
| | Adding/Deleting | Adding/Deleting | |
| Display of graphical<br>summary for selected<br>traces and data for the<br>entire study | Yes - By use of<br>Noxturnal PSG SW (PC<br>application) | Yes - By use of Profusion<br>Sleep SW (PC<br>application) | Equivalent |
| User defined event types | Yes - By use of<br>Noxturnal PSG SW (PC<br>application) | Yes - By use of Profusion<br>Sleep SW (PC<br>application) | Equivalent |
| Automatic<br>Analysis/Detector<br>Output for User<br>Interpretation - per<br>AASM<br>recommendations/scoring<br>rules | Yes - By use of<br>Noxturnal SW (PC<br>application) | Yes - By use of Profusion<br>Sleep SW (PC<br>application) | Substantially Equivalent<br><br>All automatic analysis<br>provided in the new<br>device is also provided in<br>the primary predicate<br>device. |
| | Sleep Stages: Wake, N1,<br>N2, N3, REM | Sleep Stages: Wake, N1,<br>N2, N3, REM | |
| | | Arousal detection and<br>arousal classification | Relating to automatic<br>analysis not included in<br>the new device: The raw<br>data necessary for the<br>analysis of these events<br>may be recorded and<br>displayed in the<br>Noxturnal PSG software<br>for manual analysis |
| | Apneas, Hypopneas<br>Classification of apneas:<br>Obstructive, Mixed or<br>Central | Apneas, Hypopneas<br>Classification of apneas:<br>Obstructive, Mixed or<br>Central | |
| | | Unsure respiratory event | |
| | Limb Movements,<br>Periodic Limb<br>Movements | Limb Movements,<br>Periodic Limb<br>Movements | |
| | | Snores (detection from<br>sound input baseline) | |
| | | Eye movements, singular,<br>anti-phase and in-phase<br>(EOG) | |
| | SpO2 desaturation events | SpO2 desaturation events<br>and artifacts, min/max<br>SpO2 values | |
| | Potential Bruxism<br>Related events | Potential Bruxism<br>Related events | |
| Technological<br>Characteristic | Nox Sleep System | Compumedics Somté<br>PSG System | Result of Comparison |
| | | epoch<br>Average CPAP for each<br>epoch<br>Average TcCO2 value for<br>each epoch<br><br>Peak EtCO2 value of<br>each respiratory cycle<br><br>PTT event detection<br><br>pH event detection | |
| Report Generation | Yes - By use of<br>Nocturnal PSG SW (PC<br>application) | Yes - By use of<br>Profusion Sleep SW (PC<br>application) | Equivalent |
| Statistics available for<br>report fields | Statistics and graphs from<br>manual scored events and<br>automatic analysis | Statistics and graphs from<br>manual scored events and<br>automatic analysis | Equivalent |
| MSLT/MWT¹ studies<br>supported | Yes | Yes | Equivalent |
| Data Inputs | Generic and custom<br>sensors/auxiliary devices. | Generic and custom<br>sensors/auxiliary devices. | Substantially Equivalent |
| Signal Conditioning | Yes | Yes | Substantially Equivalent |
| Remote Sleep<br>Surveillance | Yes, via Ethernet | Yes, via Ethernet | Equivalent |
| Remote Capability to<br>Monitor Lead Quality | Yes | Yes | Equivalent |
| Remote Capability to<br>Monitor Recording<br>Parameters | Yes…
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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.