K163322 · Tz Medical, Inc. · HBL · Feb 23, 2017 · Neurology
Device Facts
Record ID
K163322
Device Name
TZ SKULL PIN Adult
Applicant
Tz Medical, Inc.
Product Code
HBL · Neurology
Decision Date
Feb 23, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.4460
Device Class
Class 2
Indications for Use
The TZ Medical skull pin is placed in a clamp and is applied to the patient's skull to hold their head and neck securely in a particular position when rigid fixation is desired. The clamp is indicated for use in open and percutaneous craniotomies as well as spinal surgery when rigid fixation is necessary.
Device Story
TZ Skull Pin is a sterile, single-patient-use cervical traction skull pin; manufactured from implant-grade 316L stainless steel. Device is installed in sets of three into compatible skull clamps (e.g., V. Mueller Spetzler, Integra Mayfield) by neurosurgeons during craniotomies or spinal surgeries. Pins provide rigid skeletal fixation to immobilize the patient's head and neck relative to the torso. Output is mechanical stabilization of the surgical site; enabling precise surgical access. Device is MR unsafe. Benefits include secure, stable positioning during complex neurosurgical procedures.
Clinical Evidence
Bench testing only. Performance testing included maximum load and 24-hour creep tests per ASTM F1831-97, confirming stability in compatible skull clamps. Biocompatibility testing conducted per ISO 10993 standards: Cytotoxicity (ISO 10993-5), Sensitization (ISO 10993-10), Irritation (ISO 10993-10), and Systemic Toxicity (ISO 10993-11). All tests met requirements with no evidence of toxicity, lysis, or sensitization.
Indicated for use in open and percutaneous craniotomies and spinal surgery requiring rigid fixation of the head and neck in adult patients.
Regulatory Classification
Identification
A neurosurgical head holder (skull clamp) is a device used to clamp the patient's skull to hold head and neck in a particular position during surgical procedures.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 23, 2017
TZ Medical, Inc. Mr. John Lubisich President 17750 SW Upper Boones Ferry Rd, Suite #150 Portland, OR 97224
Re: K163322
Trade/Device Name: TZ Skull Pin Adult Regulation Number: 21 CFR 882.4460 Regulation Name: Neurosurgical Head Holder (Skull Clamp) Regulatory Class: Class II Product Code: HBL Dated: November 21, 2016 Received: November 25, 2016
Dear Mr. Lubisich:
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 devicerelated 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.
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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 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 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,
## Michael J. Hoffmann -S
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) K163322
Device Name TZ Skull Pin Adult
Indications for Use (Describe)
The TZ Medical skull pin is placed in a clamp and is applied to the patient's skull to hold their head and neck securely in a particular position when rigid fixation is desired.
The clamp is indicated for use in open and percutaneous craniotomies as well as spinal surgery when rigid fixation is necessary.
| Type of Use (Select one or both, as applicable) | |
|---------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|
| <div> <span> Prescription Use (Part 21 CER 801 Subpart D) </span> </div> | <div> <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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| Submitter Name and Address: | TZ Medical, Inc.<br>17750 SW Upper Boones Ferry Rd #150<br>Portland, OR 97224<br>Phone: 503-639-0282<br>FAX: 503-639-0239 |
|-----------------------------|---------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | John Lubisich<br>Management Representative<br>TEL: 503-639-0282<br>FAX: 503-639-0239 |
| Date of Summary: | Nov. 18, 2016 |
| Trade name/Proprietary: | TZ Skull Pin |
| Common Name: | Skull Pins |
| Model Number: | SP-001 |
| Classification Name: | Neurosurgical Head Holder (Skull Clamp) |
| Classification: | Class II, per 21 CFR 882.4460 |
| Panel: | Neurology |
| Product Code: | HBL |
| Predicate Device: | |
| Product | 510(k)<br>Number |
|--------------------------------------------|------------------|
| Mayfield Adult Disposable Steel Skull Pins | K923789 |
| Mayfield Adult Disposable Steel Skull Pins | K932860 |
Device Description: The TZ Skull Pin is a sterile cervical traction skull pin manufactured from implant grade 316L stainless steel alloy. The TZ Skull Pin is used during neurosurgical procedures to immobilize the head in reference to the torso and to provide cervical immobilization.
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| | In preparation for surgery three skull pins are installed in a compatible skull<br>clamp (such as the V. Mueller Spetzler Skull Clamp or the Integra Mayfield Skull<br>Clamp). Two skull pins are inserted in the rocker arm side of the clamp and a<br>single skull pin is inserted on the opposite side. |
|----------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Testing was conducted to evaluate the performance characteristics of the TZ<br>Skull Pin. |
| Indications for Use: | The TZ Medical skull pin is placed in a clamp and is applied to the patient's skull<br>to hold their head and neck securely in a particular position when rigid fixation<br>is desired. The clamp is indicated for use in open and percutaneous<br>craniotomies as well as spinal surgery when rigid fixation is necessary. |
| Contraindications: | Not indicated for use in an MR environment. |
| Compatibility Information: | The TZ Medical Skull Pin is placed in a compatible skull clamp such as the V.<br>Mueller Spetzler Skull Clamp or the Integra Mayfield Skull Clamp |
Comparison to Predicate Devices:
The substantial equivalence of the TZ Skull Pin is based on an equivalence to the predicate devices in intended use, technological characteristics and indications for use:
| | Proposed Medical Device | Predicate Device | Predicate Device |
|--------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | TZ Skull Pin | Mayfield Adult Disposable Skull Pins | Mayfield Adult Disposable Skull Pins |
| | | (K923789) | (K932860) |
| Applicant | TZ Medical | Ohio Medical Instrument Co., Inc. | Ohio Medical Instrument Co., Inc. |
| Regulation Number | 882.4460 | 882.4460 | 882.4460 |
| Product Code | HBL | HBL | HBL |
| | Proposed Medical Device | Predicate Device | Predicate Device |
| | TZ Skull Pin | Mayfield Adult Disposable<br>Skull Pins | Mayfield Adult Disposable<br>Skull Pins |
| | | (K923789) | (K932860) |
| Intended Use | The TZ Medical skull pin is<br>placed in a clamp and is<br>applied to the patient's skull<br>to hold their head and neck<br>securely in a particular<br>position when rigid fixation is<br>desired. The clamp is<br>indicated for use in open and<br>percutaneous craniotomies<br>as well as spinal surgery<br>when rigid fixation is<br>necessary. | Used with head holders to<br>clamp the patient's skull and<br>hold the head and neck in<br>position during surgical<br>procedures. | Used with head holders to<br>clamp the patient's skull and<br>hold the head and neck in<br>position during surgical<br>procedures. The MAYFIELD<br>Disposable Adult Skull Pins<br>are indicated for use with a<br>MAYFIELD Skull clamp that is<br>placed on the patient's skull<br>to hold their head and neck<br>in a particular position during<br>surgical procedures when<br>rigid skeletal fixation is<br>desired. |
| Indications for<br>Use | Indicated for use in open and<br>percutaneous craniotomies<br>as well as spinal surgery<br>when rigid fixation is<br>necessary. | Indicated for use in open and<br>percutaneous craniotomies<br>as well as spinal surgery<br>when rigid fixation is<br>necessary. | Indicated for use in open and<br>percutaneous craniotomies<br>as well as spinal surgery<br>when rigid fixation is<br>necessary. |
| Material | 316L Stainless Steel | The pin point is 17-4PH<br>stainless steel and the<br>polymer base is ABS plastic. | The pin point is 17-4PH<br>stainless steel and the<br>polymer base is ABS plastic. |
| Dimensions | | | |
| Tip to<br>Shoulder<br>Distance | 0.5 Inches | 0.5 Inches | 0.5 Inches |
| Width of<br>back | 0.31 inches | 0.31 inches | 0.31 inches |
| O-ring | Silicone O-Ring | Silicone O-Ring | Silicone O-Ring |
| Manufacturing | The pin is machined to the<br>dimensions specified. O-Ring<br>is placed on device when<br>manufacturing and cleaning<br>is completed. | The pin is machined to the<br>dimensions specified. O-Ring<br>is placed on device when<br>manufacturing and cleaning<br>is completed. | The pin is machined to the<br>dimensions specified. O-Ring<br>is placed on device when<br>manufacturing and cleaning<br>is completed. |
| Preparation for<br>surgery | None, the pins are supplied<br>sterile in a 3-pack pouch<br>ready for use | None, the pins are supplied<br>sterile in a 3-pack pouch<br>ready for use | None, the pins are supplied<br>sterile in a 3-pack pouch<br>ready for use |
| | Proposed Medical Device | Predicate Device | Predicate Device |
| | TZ Skull Pin | Mayfield Adult Disposable<br>Skull Pins | Mayfield Adult Disposable<br>Skull Pins |
| | | (K923789) | (K932860) |
| Method of Use | Typically, three pins are<br>installed in receptacles of the<br>head holder | Typically, three pins are<br>installed in receptacles of the<br>head holder | Typically, three pins are<br>installed in receptacles of the<br>head holder |
| Performance<br>Testing | ASTM F1831-97: | ASTM F1831-97: | ASTM F1831-97: |
| | Passed maximum load test | Passed maximum load test | Passed maximum load test |
| | Passed 24 hour load test | Passed 24 hour load test | Passed 24 hour load test |
| Clamp<br>compatibility | V. Mueller Spetzler Skull<br>Clamp-Model # M-1500<br>Integra Mayfield Skull Clamp-<br>Model # A-1059<br>Integra Mayfield Skull Clamp-<br>Model # A-2000 | All generations of MAYFIELD<br>brand Skull Clamps (REF A-<br>1013, A-1014, A-1059, A-<br>1108, or A-2000), MAYFIELD<br>brand Radiolucent Skull<br>Clamps (REF A-1058 or A-<br>2002), and the Improved<br>GARDNER brand Skull Clamp<br>(REF A-1035) when rigid<br>skeletal fixation is required<br>Not compatible with Original<br>GARDNER brand Skull Clamp | All generations of MAYFIELD<br>brand Skull Clamps (REF A-<br>1013, A-1014, A-1059, A-<br>1108, or A-2000), MAYFIELD<br>brand Radiolucent Skull<br>Clamps (REF A-1058 or A-<br>2002), and the Improved<br>GARDNER brand Skull Clamp<br>(REF A-1035) when rigid<br>skeletal fixation is required<br>Not compatible with Original<br>GARDNER brand Skull Clamp |
| MR<br>compatibility | MR unsafe | MR unsafe | MR unsafe |
| Method of<br>Sterilization | Ethylene Oxide | Ethylene Oxide | Ethylene Oxide |
| Use | Disposable; Single-Patient<br>Use Only | Disposable; Single-Patient<br>Use Only | Disposable; Single-Patient<br>Use Only |
| Packaging | Medical grade packaging<br>(sealed TYVEK/flexible film<br>pouches) | Medical grade packaging<br>(sealed TYVEK/flexible film<br>pouches) | Medical grade packaging<br>(sealed TYVEK/flexible film<br>pouches) |
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Summary of Technological Characteristics:
The TZ Skull Pins are equivalent in materials used, dimensions and design to the predicate devices. The Skull Pin is made of equivalent stainless steel material. All critical dimensions of the TZ Skull Pin are equivalent to the predicate device.
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Summary of Performance Testing:
| Test | Test Method Summary | Results |
|---------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Skull Pin System<br>Testing | To demonstrate skull pin perform safely and<br>effectively in the 3 skull clamps recommended in<br>the labelling (V. Mueller Spetzler Skull Clamp-<br>Model # M-1500; Integra Mayfield Skull Clamp-<br>Model # A-1059; Integra Mayfield Skull Clamp-<br>Model # A-2000.)<br>Apply maximum force allowed by skull clamp for<br>specified time period. Inspect deformation of<br>skull pins. | Skull pins are safe to use in all 3 skull<br>clamps |
| Skull Pin testing | To test the radial loading skull pin subjected in<br>the 3 skull clamps recommended in the labelling<br>(V. Mueller Spetzler Skull Clamp-Model # M-<br>1500; Integra Mayfield Skull Clamp-Model # A-<br>1059; Integra Mayfield Skull Clamp-Model # A-<br>2000.)<br>Max Load test: Apply axial load, radial load for<br>specified time period. Inspect deformation of<br>skull pins.<br>Creep test: Apply axial load, radial load for<br>specified time frame, Inspect deformation of skill<br>pins | The pins for both the max load and<br>creep tests held the load for the required<br>amount of time without slipping or<br>material failure. |
| Cytotoxicity<br>study using the<br>ISO Elution<br>method | Evaluate cytotoxic effects using in vitro<br>mammalian cell culture. Study was conducted<br>following the ISO 10993-5 (2009) standard. | Skull pin extract showed no evidence of<br>causing cell lysis or toxicity |
| Sensitization:<br>ISO Guinea Pig<br>maximization<br>Sensitization<br>Test | Evaluate the potential to cause delayed dermal<br>contact sensitization in a guinea pig<br>maximization test. Study was conducted<br>following the ISO 10993-10 (2010) standard. | Skull pin extract showed no evidence of<br>causing delayed dermal contact<br>sensitization in the guinea pig. Skull pin<br>was not considered a sensitizer in this<br>test. |
| Irritation:<br>ISO<br>intracutaneous<br>Study in Rabbits | Evaluate the potential to cause irritation in<br>rabbits. Study was conducted following the ISO<br>10993-10 (2010) standard. | Test article met requirements of the test. |
| ISO Systemic<br>Toxicity in Mice | Evaluate skull pin's acute systemic toxicity in<br>mice. Study was conducted following the ISO<br>10993-11 (2006) standard. | No mortality or evidence of systemic<br>toxicity from the skull pin extracts<br>injected into mice. |
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Conclusion: The TZ Skull Pin is assembled, packaged and sterilized in a similar manner as the predicate devices. The bench testing performed and type of clamps used for the proposed device and predicate devices is also similar. The TZ Skull Pin is similar to the predicate devices in the intended use, indications for use and the technological characteristics.
Based on the information provided, the TZ Skull Pin is substantially equivalent to the predicate devices, Mayfield Adult Disposable Steel Skull Pins (K923789 and K932860), and does not raise new issues of safety and effectiveness.
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.