The NeuroSystems 1TM monitor has been designed for use by a qualified neurosurgeon to display variables from existing legally marketed primary measuring devices used to monitor neurosurgical patients. The variables displayed by the NeuroSystems 1TM monitor include intracranial pressure, cerebral blood flow, brain tissue oxygen, brain temperature and pH, carbon dioxide and arterial blood pressure, and these are presented both continuously and as trends in these variables, and in the form of relationship graphs. The presentation of both measured variables and the relationships between them is intended as an adjunct to the information provided by existing primary monitors, and the NeuroSystems 1™ monitor should not be used alone as the sole basis for decisions as to diagnosis or therapy.
Device Story
NeuroSystems 1 Monitor acts as secondary display system for neurosurgical ICU. Collects analog data from primary monitors measuring intracranial pressure, cerebral blood flow, brain tissue oxygen, brain temperature, pH, CO2, and arterial blood pressure. Transforms inputs into digital/analog traces and trend graphs (1, 2, 8, 24 hours). Calculates cerebral perfusion pressure and displays interrelationships between variables to approximate cerebral autoregulation, vasoreactivity, and O2 metabolic index. Used in neurosurgical ICU by neurosurgeons. Output serves as clinical adjunct; not for sole diagnostic or therapeutic decision-making. Benefits include consolidated visualization of multi-modality data to assist clinical assessment.
Clinical Evidence
No clinical data provided. Substantial equivalence based on design, intended use, and performance characteristics compared to predicate devices.
Technological Characteristics
Secondary display monitor; receives analog inputs from primary monitoring devices. Displays digital/analog traces, trends, and relationship graphs. Connectivity via analog data inputs from primary monitors. No specific materials or software architecture details provided.
Indications for Use
Indicated for neurosurgical patients requiring multi-modality monitoring of intracranial pressure, cerebral blood flow, brain tissue oxygen, brain temperature, pH, carbon dioxide, and arterial blood pressure. Intended for use by qualified neurosurgeons as an adjunct to primary monitoring devices.
Regulatory Classification
Identification
An intracranial pressure monitoring device is a device used for short-term monitoring and recording of intracranial pressures and pressure trends. The device includes the transducer, monitor, and interconnecting hardware.
Predicate Devices
Novus Monitoring Limited NeuroSensor® System (K013930)
Diametrics Medical Limited Neurotrend System (K980380)
Submission Summary (Full Text)
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K05 c70.2
Page 1 of 2
3
## MAY 1 7 2005 510(k) Summary
March 16" 2005
#### 1 Submitter
NeuroSystems LLC 103 Pomfret Road Woodstock Vermont 05091-8029 USA
| Contact Person: | Dr James R Petite Jr |
|-----------------|----------------------|
| Telephone: | (802) 457 9866 |
| Facsimile: | (802) 457 5785 |
#### 2 Name of Device
| Proprietary Name: | NeuroSystems 1 TM Monitor |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | Multimodality Neurosurgical ICU monitor |
| Device Classification: | Intracranial pressure monitoring devices have been placed in<br>Class II as per 21 CFR Regulation Number 882.1620 and<br>assigned the Product Code GWM. |
### 3 Predicate Devices
The components of the NeuroSystems 1TM system are substantially equivalent to the following legally marketed devices:
Novus Monitoring Limited NeuroSensor® System K013930 Diametrics Medical Limited Neurotrend System K980380
This statement is based on the subject device's similarity to the predicate devices in intended use, design and principles of operation.
### 4 Device Description
The NeuroSystems 1TM monitor is a secondary display system that collects together on a single large color display screen all of the measured variables relevant to the multi-modality monitoring of the patient in a neurosurgical intensive care unit. The NeuroSystems 17M monitor has inputs to receive analog data from primary monitors used in the measurement of intracranial pressure, cerebral blood flow, brain tissue oxygen, brain temperature and pH, carbon dioxide and arterial blood pressure. The monitor can also derive the cerebral perfusion pressure.
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The NeuroSystems 17M monitor displays the measured and derived variables in digital and analog trace form, and can store and display trends over periods of 1,2,8 or 24 hours. The system also facilitates the display of the interrelationships between the measured and derived variables. This allows the approximation of Cerebral Autoregulation, Vasoreactivity and O2 Metabolic Index.
#### 5 Intended Use
The NeuroSystems 1TM monitor has been designed for use by a qualified neurosurgeon to display variables from existing legally marketed primary measuring devices used to monitor neurosurgical patients. The variables displayed by the NeuroSystems 11M monitor include intracranial pressure, cerebral blood flow, brain tissue oxygen, brain temperature and pH, carbon dioxide and arterial blood pressure, and these are presented both continuously and as trends in these variables, and in the form of relationship graphs. The presentation of both measured variables and the relationships between them is intended as an adjunct to the information provided by existing primary monitors, and the NeuroSystems 1™ monitor should not be used alone as the sole basis for decisions as to diagnosis or therapy.
#### Summary of Substantial Equivalence 6
The NeuroSystems 1TM system is similar in design, intended use and performance characteristics to the predicate devices. It differs in requiring legally marketed primary monitors to be the interface between the secondary monitor and the patient connected sensors, and in providing the display of measured variables, derived variables and data relationships on a secondary monitor. No new issues of safety or effectiveness are introduced by using this device.
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Image /page/2/Picture/1 description: The image shows the seal of the Department of Health and Human Services (HHS). The seal features the department's name in a circular arrangement around a symbol. The symbol consists of four stylized human figures, representing the department's mission to protect the health of all Americans and provide essential human services.
MAY 1 7 2005
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Dr. James R. Petite Jr. President NeuroSystems LLC 103 Pomfret Road Woodstock, Vermont 05091-8029
Re: K050702
Trade/Device Name: NeuroSystems 1™ Monitor Regulation Number: 21 CFR 882.1620 Regulation Name: Intracranial pressure monitoring device Regulatory Class: II Product Code: GWM Dated: March 16, 2005 Received: March 18, 2005
Dear Dr. Petite:
We have reviewed your Section 510(k) premarket notification of intent to market the device we nave reviewed your bector 3 re(s) pe device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate for use stated in the encrosure) to regars and ment date of the Medical Device Amendments, or to Conniered phor to May 20, 1978, the encordance with the provisions of the Federal Food, Drug, devices that have been recuire approval of a premarket approval application (PMA). allu Cosmete Act (11ct) that do not request of the general controls provisions of the Act. The 1 ou may, therefore, market the Act include requirements for annual registration, listing of general controls provisions of the tice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device it may be subject to sadh additions, Title 21, Parts 800 to 898. In addition, FDA can be found in the Oods of reacts concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean I loast oc advised that I Dri brounder over device complies with other requirements of the Act that I DA has made a decemmandiations administered by other Federal agencies. You must of any it cutting and regaranents and regarents and limited to: registration and listing (21 comply with an the Act 3 requirements, neisang, and manufacturing practice requirements as set CITY art 807), labeling (21 CFR Part 820); and if applicable, the electronic 10:11 m in the quality systems (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 - Dr. James R. Petite Jr.
This letter will allow you to begin marketing your device as described in your Section 510(k) I his letter will anow you to begin manceing your antial equivalence of your device to a legally premarket notification. "The PDF Inturing of basistance of this permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please If you desire specific advice for your don't as a surver and the regulation entitled, comact and Office of Comphanes as (21 notification" (21CFR Part 807.97). You may obtain " Misoralianing by reference to premainteers. Internetions of Small other general information on your response Assistance at its toll-free number (800) 638-204 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Signature
Miriam C. Provost, Ph.D. Acting Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if Known): KOS C 70 Z
Device Name:
NeuroSystems 1 TM Monitor
The NeuroSystems 1™ monitor has been designed Indications for Use: for use by a qualified neurosurgeon to display variables from existing legally marketed primary measuring devices used to monitor neurosurgical patients. The variables displayed by the NeuroSystems 1™ monitor include intracranial pressure, cerebral blood flow, brain tissue oxygen, brain temperature and pH, carbon dioxide and arterial blood pressure, and these are presented both continuously and as trends in these variables, and in the form of relationship graphs. The presentation of both measured variables and the relationships between them is intended as an adjunct to the information provided by existing primary monitors, and the NeuroSystems 1 ™ monitor should not be used alone as the sole basis for decisions as to diagnosis or therapy.
Prescription Use x (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFGR 801 Subpart C)
(Please Do NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Soncurrence of CDRH Office of Device Evaluation (ODE)
concurrence
(Division Sign-Off Division of General, Restorative, and Neurological Devices
**510(k) Number** K050702
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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.
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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).
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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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.
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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.
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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.