K232525 · Watkins-Conti Products, Inc. · HHW · May 17, 2024 · Obstetrics/Gynecology
Device Facts
Record ID
K232525
Device Name
Yoni.Fit Bladder Support
Applicant
Watkins-Conti Products, Inc.
Product Code
HHW · Obstetrics/Gynecology
Decision Date
May 17, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 884.3575
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Yoni.Fit® Bladder Support is intended for the temporary management of urine leakage caused by stress urinary incontinence (SUI) in women, 18 years and older.
Device Story
Yoni.Fit Bladder Support is a cone-shaped, flexible vaginal pessary for temporary management of stress urinary incontinence (SUI). Prescribed by physicians for single-patient use; worn up to 12 hours per 24-hour period; reusable for 30 days. Device functions by applying pressure against the urethra and bladder neck to support the bladder and urethra. Patient inserts device manually; handle facilitates management. Cleaning requires warm water and mild, oil-free soap. Clinical benefit includes reduction in urine leakage, measured by pad weight reduction. Used in home settings by patients.
Clinical Evidence
Randomized, comparator-controlled, single-blinded, multicenter crossover study (n=58). Primary endpoint: >50% reduction in mean 12-hour pad weights. Yoni.Fit responder rate was 51.6% vs 25.9% for control (95% CI: 0.0235 to 0.504). Safety endpoint: adverse event rate 54.8% (Yoni.Fit) vs 29.6% (control); most common event was vaginal discomfort. No device-related serious adverse events reported. Study duration included 30-day safety follow-up.
Technological Characteristics
Injection-molded silicone (non-latex rubber) without color additives. Cone-shaped, flexible form factor. Sizes: 34mm, 42mm, 45mm, 48mm, 52mm. Non-sterile. Mechanical support principle. Biocompatibility per ISO 10993-1:2018 (cytotoxicity, sensitization, irritation, systemic toxicity).
Indications for Use
Indicated for temporary management of stress urinary incontinence (SUI) in women 18 years and older.
Regulatory Classification
Identification
A vaginal pessary is a removable structure placed in the vagina to support the pelvic organs and is used to treat conditions such as uterine prolapse (falling down of uterus), uterine retroposition (backward displacement), or gynecologic hernia.
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May 16, 2024
Watkins-Conti Products Inc. % Adrienne Lenz Principal Medical Device Regulatiory Expert Hyman, Phelps & McNamara, P.C. 700 Thirteenth Street, N.W., Suite 1200 Washington, District of Columbia 20005
Re: K232525
Trade/Device Name: Yoni.Fit Bladder Support Regulation Number: 21 CFR 884.3575 Regulation Name: Vaginal Pessary Regulatory Class: Class II Product Code: HHW Dated: April 16, 2024 Received: April 16, 2024
Dear Adrienne Lenz:
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 (the 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 available at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn).
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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-devices/deviceadvice-comprehensive-regulatory-assistance/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.
# Sharon M. Andrews -S
for
Jessica K. Nguyen, Ph.D. Assistant Director DHT3B: Division of Reproductive, Gynecology and Urology Devices OHT3: Office of Gastrorenal, ObGyn, General Hospital, and Urology 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) K232525
Device Name Yōni.Fit® Bladder Support
Indications for Use (Describe)
The Yoni.Fit® Bladder Support is intended for the temporary management of urine leakage caused by stress urinary incontinence (SUI) in women, 18 years and 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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## Watkins-Conti Products
## 510(k) for Yōni.Fit® Bladder Support
## K232525
## 510(k) SUMMARY
#### Submitter/Sponsor:
Watkins-Conti Products Inc. 3841 East Danforth Rd., Suite 109 Edmond, OK 73034
#### Contact Person:
Allison L. Watkins, CEO Watkins-Conti Products, Inc. 3841 East Danforth Rd., Suite 109 Edmond, OK 73034 Office: 1-405-330-3550
#### Date Prepared:
May 16, 2024
## General Device Information:
Generic Device Name
Pessary, Vaginal
Tradename
Yōni.Fit® Bladder Support
## Product Classification Codes
- Product Code HHW (pessary, vaginal) .
- Classification Panel - Obstetrical/Gynecological
- Device Class 2 ●
- Regulation Number and Name 21 CFR § 884.3575 Vaginal pessary ●
## Predicate Device:
Uresta™ Pessary (K083769)
Note: The predicate has not been subject to a design-related recall.
#### Reference Device:
Poise Impressa (K131198)
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## 1. INDICATIONS FOR USE
The Yoni.Fit® Bladder Support is intended for the temporary management of urine leakage caused by stress urinary incontinence (SUI) in women, 18 years and older.
## 2. DEVICE DESCRIPTION
The Yoni.Fit® Bladder Support is a vaginal pessary prescribed by a physician for single patient use for the temporary management of stress urinary incontinence. The device is intended for a single 30-day duration per patient. It can be worn for up to 12 hours in a 24-hour period and is reusable after washing with warm water and mild. oil-free soap. The device is a single-patient. multi-use medical device that will be provided non-sterile and requires reprocessing prior its first and subsequent uses. The rim of the Yōni.Fit® Bladder Support applies pressure aqainst the urethra and bladder neck to support the bladder and urethra. The Yōni.Fit® Bladder Support is available in each of the following sizes: 34mm (Size 2), 42mm (Size 3), 42mm (Size 3), 45mm (Size 3.5), 48mm (Size 4), and 52mm (Size 5). The Yoni.Fit® Bladder Support is made of injection molded silicone (non-latex rubber) with no color additives.
Each package of the Yoni.Fit® Bladder Support comes with the following:
- 3 reusable Yōni.Fit® Bladder Supports for sizing .
- . Cleaning brush
- Storage case ●
- Instructions for Use ●
## 3. SUBSTANTIAL EQUIVALENCE
A comparison of the device characteristics between the Yoni.Fit® Bladder Support and the Uresta™ Pessary is shown in Table 1. The Yoni.Fit® Bladder Support and the Uresta™ Pessary have the same intended use. There are minor differences in technological characteristics between the Yoni.Fit® Bladder Support and the Uresta™ Pessary. These differences do not raise different questions of safety or effectiveness. Performance data, as discussed below, demonstrate that the Yoni.Fit® Bladder Support is as safe and effective as the Uresta™ Bladder Support. The two devices therefore are considered substantially equivalent.
| Characteristic | Uresta™ Bladder Support<br>(K083769) | Yōni.Fit® Bladder Support | Comparison |
|-----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| Indications for Use | For use in adult women, over 18<br>years of age, to prevent<br>involuntary urine loss with<br>physical activity (stress urinary<br>incontinence) (SUI). | The Yōni.Fit® Bladder Support is<br>intended for the temporary<br>management of urine leakage<br>caused by stress urinary<br>incontinence (SUI) in women, 18<br>years and older. | Similar |
| Mechanism<br>of Operation | Increases pressure through the<br>anterior wall onto the urethra. | Increases pressure through the<br>anterior wall onto the urethra. | Same |
| Characteristic | Uresta™ Bladder Support<br>(K083769) | Yōni.Fit® Bladder Support | Comparison |
| Materials of<br>Composition | Santoprene (non-latex<br>thermoplastic rubber) | Silicone (non-latex rubber) with no<br>color additives | Different |
| Shape<br>and<br>Structure | Bell shaped, flexible.<br>Tapered tip interacts with<br>upper more horizontal<br>portion of vagina and bell<br>shape falls into place<br>naturally under urethra. No folding or manipulation<br>of pessary required. Handle allows for easy<br>management. | Cone-shaped, flexible.<br>The rim of the Yōni.Fit®<br>Bladder Support applies<br>pressure against the urethra<br>and bladder neck. Collapses for insertion. Handle allows for easy<br>management. | Different |
| Wear Time | Up to 12-hours in a 24-hour period | Up to 12-hours in a 24-hour period | Same |
| Sterility | Non-sterile | Non-sterile | Same |
| Rx/OTC | Rx | Rx | Same |
| Use | Single patient use.<br>Reusable.<br>Removed daily. | Single patient use.<br>Reusable.<br>Removed daily. | Same |
| Sizes | Multiple sizes – 7<br>30 – 56 mm | Multiple sizes - 6<br>34 – 52 mm | Different |
| Use-life | 1-year | 30-days | Different |
| Cleaning | Use warm water and a mild, non-<br>perfumed soap to wash. Rinse<br>thoroughly with water after<br>washing. Dry with a towel or cloth.<br>Place in bottom unit of case and<br>leave the case open to air dry. | Wash with warm water and a mild,<br>scent free, oil-free liquid soap. Rinse<br>with warm water to make sure all soap<br>and material are removed. Air dry in a<br>clean, dry place or use the optional<br>Storage Case. | Similar |
#### Table 1: Comparison of Device Characteristics between the Yoni.Fit® Bladder Support and the Uresta™ Bladder Support (K083769)
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## 4. DEVICE PERFORMANCE DATA
## 4.1. Summary of Non-Clinical Performance Tests
## 4.1.1. Bench Tests
Bench performance tests confirmed the device met specifications for dimensions, fold force, fold width, fold height, pull tab strength, therapy force, and maximum force. The Poise Impressa (K131198) was used as a reference device to support the therapy force requirements of the Yōni.Fit®.
Cleaning validation studies were performed in accordance with FDA's 2015 guidance Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling, AAMI TIR12:2020, AAMI ST98:2022, and with ISO 10993-5 to validate the device cleaning procedures listed in the Instructions for Use.
Laboratory studies were performed to evaluate the impact of the device on Staphylococcus aureus growth and TSST-1 production, following FDA guidance for Menstrual Tampons and Pads: Information for Premarket Notification Submissions. These studies demonstrated that the Yōni.Fit® does not enhance TSST-1 production above the no product controls or marketed tampons and does not alter the growth of vaginal microflora, including TSST-1 producing S. aureus, as compared to no product controls.
## 4.1.2. Biocompatibility
The Yoni.Fit® Bladder Support has undergone biocompatibility evaluation and testing in conformance with ISO 10993-1:2018 and FDA's quidance Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process." The Yōni.Fit® Bladder Support is categorized as a surface device in contact with mucosal membrane for prolonged (>24 hours up to 30 days) contact duration. Cytotoxicity, sensitization, vaqinal irritation, acute systemic toxicity, material-mediated pyrogenicity, and subchronic systemic toxicity tests were performed, and the results of the biocompatibility testing were acceptable.
## 4.2. Summary of Clinical Performance Tests
## 4.2.1. Summary of Clinical Testing
The clinical study, "Randomized, Comparator-controlled, Single Blinded, Multicenter Study Evaluating the Efficacy and Safety of Yōni. Fit® in Women with Stress Urinary Incontinence (SUI)." was conducted to evaluate the safety and effectiveness of the Yoni.Fit® Bladder Support in temporary management of SUI in women in comparison to a sham comparator device. This was a randomized, comparator-controlled, single blinded, multicenter crossover study in which participants from three US sites with SUI were enrolled in the study. Study participants included females 18 years of age or older diagnosed with SUI by both a cough supine test and ≥ 3 month history of experiencing SUI. Clinical study participants were randomized to either the Yōni.Fit® or a control device (Ring type pessary). After a brief training and fitting with the appropriate size of the device, each participant wore a study device for 12 hours per day. Participants wore incontinence pads
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to measure any potential leakage, recorded voiding (urination) in diaries, and provided responses to questionnaires. At baseline (1-week post-randomization with no device), fitting (1 week after baseline), and efficacy evaluation (1 week after fitting), 12-hour pad weights, and participant questionnaires were collected. After completion of the fitting and treatment period, the Yōni.Fit® subjects and comparator device subjects wishing to cross-over to the Yōni.Fit® entered a 4-week open-label follow-up phase of daily tvpical use.
A total of 58 participants (31 Yōni.Fit® and 27 control) were enrolled and randomized. Participants were between the ages of 30 – 71 years old in the treatment arm and 36 – 73 years old in the control-comparator arm. Of these, 5 postmenopausal participants were randomized in the treatment arm and 12 in the control-comparator arm, but a total of 7 postmenopausal participants were exposed to Yōni.Fit®. Other demographics of total study subjects included 2.2% (1) American Indian/Alaskan Native, 13.3% (6) Asian, 20% (9) Black/African American, 2.2% (1) Native Hawaiian/Pacific Islander, 55.6% (25) White/Caucasian and 6.6% (3) Not disclosed/Other. Fifty-six (56) participants completed the treatment phase and 54 continued to the open label phase. Forty-two (42) participants completed 30 days of safety follow-up and 38 participants completed 6 weeks of safety follow-up. There were four participants (2 Yōni.Fit®, 2 control) who had completely missing data for the efficacy evaluation phase. Participants with completely missing data for the efficacy evaluation phase were considered non- responders in the analyses and assumed to have less than a 50% reduction in their average 12-hour pad weights during the efficacy evaluation phase.
The primary effectiveness endpoint was a responder rate, defined as >50% reduction in mean 12-hour pad weights during the efficacy evaluation period compared to the baseline period. A statistically significantly higher percentage of participants experiencing more than a 50% reduction in their average 12-hour pad weights was observed with the Yoni.Fit® device compared to the control device. Of the participants randomized to use the Yoni.Fit®, 51.6% had a >50% reduction in 12-hour pad weight compared to 25.9% in the control group. The two-sided 95% confidence interval for the difference in the percentage of participants experiencing more than a 50% reduction in 12-hour pad weights between the control groups was 0.0235 to 0.504.
The primary safety endpoint was the incidence and nature of adverse events. The adverse event rate was 54.8% for participants with the Yoni.Fit® Bladder Support and 29.6% for Control participants. The most common adverse event was vaginal discomfort in 9 (29.0%) Yoni.Fit® Bladder Support participants compared to 5 (18.5%) Control participants. Among study participants experiencing adverse events, the severity was mild or moderate and there were no device-related serious adverse events. Vaginal bleeding was noted among 8 participants (4 postmenopausal participants) who wore the Yōni.Fit® Bladder Support and 1 in the control arm.
## 5. CONCLUSION
The results of the nonclinical tests demonstrate that the device is as safe, as effective, and performs as well as the predicate device for the intended 30 days use of which clinical and non-clinical testing was performed. Therefore, the Yoni.Fit® Bladder Support and the Uresta™ Pessary are determined to be substantially equivalent.
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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
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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.