K230691 · Spectrawave, Inc. · NQQ · Jun 7, 2023 · Radiology
Device Facts
Record ID
K230691
Device Name
HyperVue™ Imaging System
Applicant
Spectrawave, Inc.
Product Code
NQQ · Radiology
Decision Date
Jun 7, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1560
Device Class
Class 2
Indications for Use
The HyperVue™ Imaging System is intended for the imaging of coronary arteries and is indicated in patients who are candidates for transluminal interventional procedures. The Starlight™ Imaging Catheter is intended for use in vessels 2.0 to 5.2 mm in diameter. The Starlight Imaging Catheter is not intended for use in a target vessel which has undergone a previous bypass procedure. The NIRS capability of the HyperVue Imaging System is intended for the detection of lipid core containing plaques of interest. The NIRS capability of the HyperVue Imaging System is intended for the assessment of coronary artery lipid core burden. The NIRS capability of the HyperVue Imaging System is intended for the identification of patients and plaques at increased risk of major adverse cardiac events.
Device Story
HyperVue™ Imaging System is an intravascular imaging device combining Optical Coherence Tomography (OCT) and Near Infrared Spectroscopy (NIRS) to assess coronary artery vessel composition and structure. System comprises a mobile console, proprietary application software, a tethered Catheter Interface Unit (CIU), and a sterile, single-use 2.5 French dual-modality imaging catheter. During procedures in the cardiac catheterization laboratory, physicians insert the catheter into the artery under fluoroscopic guidance. The fiber optic imaging core delivers infrared light to tissue; the system measures reflected light to construct high-resolution, real-time images. Software processes signals to calculate vessel cross-sectional area, diameter, and percent stenosis. Output is displayed on console monitors for physician evaluation alongside other clinical tests. Device aids in identifying lipid core-containing plaques and assessing lipid core burden to inform clinical decision-making regarding interventional procedures.
Clinical Evidence
No clinical testing provided. Evidence consists of bench testing, software verification/validation per IEC 62304, and summative human factors engineering (HFE) usability testing per ANSI/AAMI/IEC 62366-1.
Technological Characteristics
Dual-modality OCT and NIRS imaging system. Components: mobile console, CIU, and 2.5 French fiber-optic imaging catheter. Connectivity: Windows Enterprise IoT-based platform. Software: proprietary application for data acquisition, processing, and display. Features include automated measurement tools (border contours, cross-sectional area, percent stenosis). Sterilization: single-use sterile catheter. Standards: IEC 62304 (software), ANSI/AAMI/IEC 62366-1 (usability).
Indications for Use
Indicated for patients who are candidates for transluminal interventional procedures requiring coronary artery imaging. Starlight™ Imaging Catheter for vessels 2.0-5.2 mm diameter; contraindicated for vessels with previous bypass procedures.
Regulatory Classification
Identification
An ultrasonic pulsed echo imaging system is a device intended to project a pulsed sound beam into body tissue to determine the depth or location of the tissue interfaces and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A biopsy needle guide kit intended for use with an ultrasonic pulsed echo imaging system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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June 7, 2023
SpectraWAVE, Inc. Farzad Parsaie VP, Quality Assurance & Regulatory Affairs 12 Oak Park Drive Bedford, Massachusetts 01730
Re: K230691
Trade/Device Name: HyperVue™ Imaging System Regulation Number: 21 CFR 892.1560 Regulation Name: Ultrasonic Pulsed Echo Imaging System Regulatory Class: Class II Product Code: NQQ, ORD, OGZ, IYO Dated: March 13, 2023 Received: March 13, 2023
Dear Farzad Parsaie:
We have reviewed vour Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal
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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 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-device-safety/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 Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE(@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Aneesh S. Deoras -S
Aneesh Deoras Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known)
K230691
Device Name
HyperVue™ Imaging System
### Indications for Use (Describe)
The HyperVue™ Imaging System is intended for the imaging of coronary arteries and is indicated in patients who are candidates for transluminal interventional procedures.
The Starlight™ Imaging Catheter is intended for use in vessels 2.0 to 5.2 mm in diameter.
The Starlight Imaging Catheter is not intended for use in a target vessel which has undergone a previous bypass procedure.
The NIRS capability of the HyperVue Imaging System is intended for the detection of lipid core containing plaques of interest.
The NIRS capability of the HyperVue Imaging System is intended for the assessment of coronary artery lipid core burden.
The NIRS capability of the HyperVue Imaging System is intended for the identification of patients and plaques at increased risk of major adverse cardiac events.
| Type of Use (Select one or both, as applicable) | |
|--------------------------------------------------------------------------------------------------------------------|--|
| <div> <span> <span style="font-size:16px">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | |
| <div> <span> <span style="font-size:16px">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> | |
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# Traditional 510(k) Summary
#### 1. Submitter Name & Address:
| 510(k) Owner: | SpectraWAVE, Inc. |
|-------------------|------------------------------------------------------------------------------------------------------------|
| Address: | 12 Oak Park Drive<br>Bedford, MA 01730<br>(781) 701-8148 |
| Official Contact: | Farzad Parsaie<br>VP, Quality Assurance & Regulatory Affairs<br>(781) 701-8148<br>fparsaie@spectrawave.com |
| Date Prepared: | 6/5/2023 |
## 2. Device Name:
| Trade Name: | HyperVue™ Imaging System |
|----------------------|------------------------------------------------------------------------------------|
| Model Number: | System: 931 |
| Common Name: | Optical Coherence Tomography Imaging System |
| Classification Name: | System, Imaging, Optical Coherence Tomography<br>Diagnostic intravascular catheter |
| Regulation Numbers: | 21 CFR 892.1560, 21 CFR 870.1200 |
| Product Code: | NQQ, ORD, OGZ, IYO |
| Classification: | Class II |
#### 3. Predicate Device:
- . K221257, SpectraWAVE Imaging System and Catheter
#### Device Description: 4.
The HyperVue™ Imaging System is an intravascular imaging device with the ability to simultaneously assess vessel composition and structure by combining Optical Coherence Tomography (OCT) and Near Infrared Spectroscopy (NIRS) in a single catheter-based system.
The HyperVue™ Imaging System consists of the following components:
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- . Console: A mobile platform containing the optical and computing engine, physician and technologist touch displays, power distribution system, and input/output interface.
- Software: A proprietary application software that orchestrates the control, . acquisition, processing, and display of the OCT-NIRS data.
- . Catheter Interface Unit (CIU): A tethered CIU that controls the motion of the fiber optic imaging core within the Catheter sheath and connects the Catheter to the Console.
- . Imaging Catheter: A sterile, single patient use 2.5 French dual-modality imaging catheter containing a rotating fiber optic imaging core inside a protective sterile sheath.
#### 5. Indications for Use Statement:
The HyperVue™ Imaging System is intended for the imaging of coronary arteries and is indicated in patients who are candidates for transluminal interventional procedures.
The Starlight™ Imaging Catheter is intended for use in vessels 2.0 to 5.2 mm in diameter.
The Starlight Imaging Catheter is not intended for use in a target vessel which has undergone a previous bypass procedure.
The NIRS capability of the HyperVue Imaging System is intended for the detection of lipid core containing plaques of interest.
The NIRS capability of the HyperVue Imaging System is intended for the assessment of coronary artery lipid core burden.
The NIRS capability of the HyperVue Imaging System is intended for the identification of patients and plaques at increased risk of major adverse cardiac events.
#### 6. Technological Characteristics:
Three of the four system components in the HyperVue™ Imaging System - Console, CIU and Imaging Catheter - are the same as the predicate device. The subject of this application is for the Software module which contains updates with similar technological characteristics and substantially equivalent performance to the cited predicate. Table 1 below provides a comparative summary (predicate vs proposed device) for the relevant system characteristics/features.
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| Predicate Device Comparison | | | |
|-----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer<br>& Model | PREDICATE DEVICE<br>SpectraWAVE, Inc.<br>SpectraWAVE Imaging System (K221257) | PROPOSED DEVICE<br>SpectraWAVE, Inc.<br>HyperVue™ Imaging System | Discussion of<br>Equivalence &<br>Differences |
| Product Code | NQQ - System, imaging, optical coherence<br>tomography<br>ORD - Optical Coherence Tomography,<br>Intravascular Catheter<br>OGZ - Catheter, Intravascular, Plaque<br>Morphology Evaluation<br>IYO - System, Imaging, Pulsed Echo,<br>Ultrasonic | NQQ - System, imaging, optical coherence<br>tomography<br>ORD - Optical Coherence Tomography,<br>Intravascular Catheter<br>OGZ - Catheter, Intravascular, Plaque<br>Morphology Evaluation<br>IYO - System, Imaging, Pulsed Echo,<br>Ultrasonic | Same |
| Intended Use | The SpectraWAVE Imaging System and the<br>SpectraWAVE Imaging Catheter are intended<br>for the imaging of coronary arteries. | The HyperVue™ Imaging System and the<br>Starlight™ Imaging Catheter are intended for<br>the imaging of coronary arteries. | Same<br>Added tradenames<br>only |
| Intended<br>Users | Physicians and healthcare professionals | Physicians and healthcare professionals | Same |
| Operational<br>Environment | Cardiac catheterization laboratory | Cardiac catheterization laboratory | Same |
| Indications<br>For Use | The SpectraWAVE Imaging System is intended<br>for the imaging of coronary arteries and is<br>indicated in patients who are candidates for<br>transluminal interventional procedures.<br>The SpectraWAVE Imaging Catheter is<br>intended for use in vessels 2.0 to 5.2 mm in<br>diameter.<br>The SpectraWAVE Imaging Catheter is not<br>intended for use in a target vessel which has<br>undergone a previous bypass procedure. | The HyperVue™ Imaging System is intended<br>for the imaging of coronary arteries and is<br>indicated in patients who are candidates for<br>transluminal interventional procedures.<br>The Starlight™ Imaging Catheter is intended<br>for use in vessels 2.0 to 5.2 mm in diameter.<br>The Starlight Imaging Catheter is not intended<br>for use in a target vessel which has undergone<br>a previous bypass procedure.<br>The NIRS capability of the HyperVue Imaging<br>System is intended for the detection of lipid<br>core containing plaques of interest. | Same<br>Added tradenames<br>only |
| Predicate Device Comparison | | | |
| Manufacturer<br>& Model | PREDICATE DEVICE<br>SpectraWAVE, Inc.<br>SpectraWAVE Imaging System (K221257) | PROPOSED DEVICE<br>SpectraWAVE, Inc.<br>HyperVue™ Imaging System | Discussion of<br>Equivalence &<br>Differences |
| | The NIRS capability of the SpectraWAVE<br>Imaging System is intended for the detection of<br>lipid core containing plaques of interest.<br>The NIRS capability of the SpectraWAVE<br>Imaging System is intended for the<br>assessment of coronary artery lipid core<br>burden.<br>The NIRS capability of the SpectraWAVE<br>Imaging System is intended for the<br>identification of patients and plaques at<br>increased risk of major adverse cardiac events. | The NIRS capability of the HyperVue Imaging<br>System is intended for the assessment of<br>coronary artery lipid core burden.<br>The NIRS capability of the HyperVue Imaging<br>System is intended for the identification of<br>patients and plaques at increased risk of major<br>adverse cardiac events. | |
| Primary<br>Functions | Delivers energy (infrared light) to the tissue.<br>Measures the depth and pattern of reflections<br>from the tissue from the return near-infrared<br>light to create high-resolution, real-time<br>images.<br>Stores images for evaluation and review. | Delivers energy (infrared light) to the tissue.<br>Measures the depth and pattern of reflections<br>from the tissue from the return near-infrared<br>light to create high-resolution, real-time<br>images.<br>Stores images for evaluation and review. | Same |
| Image<br>Creation.<br>Display and<br>Storage | Process reflected optical signals to construct<br>images.<br>Display images.<br>Store images. | Process reflected optical signals to construct<br>images.<br>Display images.<br>Store images. | Same |
| Measure<br>Vessel Cross<br>Sectional Area | Calculate and report vessel cross-sectional<br>area | Calculate and report vessel cross-sectional<br>area | Same |
| Measure<br>Vessel Linear<br>Dimensions | Calculate and display vessel diameter at user<br>specified locations within the displayed image | Calculate and display vessel diameter at user<br>specified locations within the displayed image | Same |
| Predicate Device Comparison | | | |
| Manufacturer<br>& Model | PREDICATE DEVICE<br>SpectraWAVE, Inc.<br>SpectraWAVE Imaging System (K221257) | PROPOSED DEVICE<br>SpectraWAVE, Inc.<br>HyperVue™ Imaging System | Discussion of<br>Equivalence &<br>Differences |
| Calculate<br>Vessel<br>Physical<br>Parameters | Calculate and display mathematical<br>comparisons of image data such as %<br>reduction from average, length of narrowing. | Calculate and display mathematical<br>comparisons of image data such as %<br>reduction from average, length of narrowing. | Same |
| Procedural<br>Steps | System set-up, patient data entry, catheter<br>preparation insertion of catheter into the artery<br>under fluoroscopic guidance, proper<br>positioning of the catheter distal to the target<br>vessel, image acquisition, and evaluation of the<br>acquired images. | System set-up, patient data entry, catheter<br>preparation insertion of catheter into the artery<br>under fluoroscopic guidance, proper<br>positioning of the catheter distal to the target<br>vessel, image acquisition, and evaluation of the<br>acquired images. | Same |
| Use of Results | Physicians evaluate the images in combination<br>with other tests and evaluations to assess the<br>patient's coronary arteries. | Physicians evaluate the images in combination<br>with other tests and evaluations to assess the<br>patient's coronary arteries. | Same |
| Operating<br>System (OS) | Windows-based (Windows Professional<br>Desktop) | Windows-based (Windows Enterprise IoT)<br>Windows Enterprise IoT OS provides<br>configurability for deploying a single-<br>purpose dedicated system. | Substantially<br>equivalent<br>There is no<br>difference in the<br>fundamental<br>performance and<br>intended use of the<br>software due to<br>change to OS |
| User<br>Convenience<br>Features | Computer-aided measurement tools, such as<br>border contours, computation of cross-<br>sectional area, and percent stenosis.<br>Display of live angiography imagery on the<br>SpectraWAVE Imaging System display<br>monitors. | Computer-aided measurement tools, such as<br>border contours, computation of cross-<br>sectional area, and percent stenosis.<br>Display of live angiography imagery on the<br>HyperVue™ Imaging System display monitors. | Substantially<br>equivalent<br>The additional<br>features are minor<br>changes compared<br>to the predicate and<br>were added to the |
| Predicate Device Comparison | | | |
| Manufacturer<br>& Model | PREDICATE DEVICE | PROPOSED DEVICE | Discussion of<br>Equivalence &<br>Differences |
| | SpectraWAVE, Inc.<br>SpectraWAVE Imaging System (K221257) | SpectraWAVE, Inc.<br>HyperVue™ Imaging System | proposed device to<br>provide user-<br>selectable and<br>optional user<br>convenience<br>features.<br>No changes were<br>made to the<br>intended use or<br>indications of use of<br>the device. |
| | | The following updates have been added<br>compared to the predicate device:<br>• Addition of new user-selectable and<br>optional image overlays on the displayed<br>viewports (Angiography & OCT-NIRS) to<br>highlight OCT/NIRS-derived features.<br>• Update to User Interface (UI) look-and-feel<br>and clinical workflow | |
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#### 7. Performance Testing:
#### 7.1 Summary of Performance Testing:
Design verification and validation (V&V) of the HyperVue™ Imaging System with the updated software were performed in compliance with external standards and internal design control procedures. V&V testing comprised of system/software verification and summative usability testing to confirm device performance.
#### 7.2 Sterilization and Shelf Life:
No change from K221257. Sterilization and shelf life are not impacted since this 510(k) submission covers only a software update for the HyperVue™ Imaging System.
#### 7.3 Biocompatibility:
No change from K221257. Biocompatibility is not impacted since this 510(k) submission covers only a software update for the HyperVue™ Imaging System.
#### 7.4 Software:
HyperVue™ Imaging System and Application Software were developed and tested in compliance with IEC 62304. Software verification and validation were conducted to FDA requlations, standards, and quidance document requirements. The results of this testing conclude the software has met these requirements.
#### 7.5 EMC/Basic Electrical Safety:
No change from K221257. This 510(k) submission covers only a software update package for the HyperVue™ Imaging System. EMC & Basic Electrical Safety are not impacted by this software update.
#### 7.6 Bench testing:
In addition to the software verification testing described above, benchtop testing of the entire device was conducted to evaluate certain system-level features, such as measurements, that require both hardware and software to evaluate. The results of this testing conclude the system has met these requirements.
#### 7.7 Animal Testing:
Not applicable. No animal testing was necessary to demonstrate equivalence.
#### 7.8 Human Factors Engineering (HFE) Usability Study:
Usability evaluation was conducted to establish that the updated software for the HyperVue™ Imaging System meets the needs of the intended users to perform OCT-NIRS imaging safely and effectively according to ANSI/AAMI/IEC 62366-1.
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The updated software for the HyperVue™ Imaging System has been found to be safe and effective for the intended users, uses, and use environments.
#### 7.9 Clinical Testing:
No clinical testing is provided in this pre-market notification.
#### 8. Conclusion and Statement of Equivalence:
Modifications to the software of the device presented in this 510(k) submission do not raise new questions of safety or effectiveness. As demonstrated by risk management activities, software verification, and HFE usability study testing, the proposed HyperVue™ Imaging System does not raise new questions of safety or effectiveness and is therefore considered substantially equivalent to the predicate device.
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.