The M12 Matrix Holter System is intended to be used as a Holter ambulatory electrocardiograph system for the purpose of screening for ECG rhythm disturbances over periods up to 48-hours. The Matrix Holter System is intended for use under the supervision of a Physician or those knowledgeable in all aspects of ECG morphology, rhythm and arrhythmia. This procedure is commonly called a Holter procedure which captures ECG rhythm abnormalities which may be infrequent or provoked by activities outside of the physician office. The M12 Matrix Holter System is comprised of the Matrix Holter Recorder (M12R) and the Matrix Holter System Application (M12A). The Matrix Holter Recorder component of the system will be worn by the patient and is used to record ambulatory electrocardiograph data from the patient. The Matrix Holter System Application is used to analyze the data recorded by the Matrix Holter Recorder. The subject Devices will provide the following diagnostic functions: - Acquiring, viewing, storing and printing ambulatory ECG waveforms from patients using the Matrix Holter Recorder and associated accessories that provide signal acquisition for up to twelve (12) leads of patient ECG waveforms through surface electrodes adhered to the body. - Using optional Holter algorithms to generate measurements, data presentations and graphical presentations on an advisory basis for patients. These are presented for review and interpretation by the clinician based upon knowledge of the patient, the results of the physical examination, the ambulatory ECG data full disclosure displays, and other clinical findings. - Using optional interpretive algorithms to generate measurements, data presentations, graphical presentations, and interpretive statements on an advisory basis for patients of sixteen (16) years of age and above. These are presented for review and interpretation by the clinician based upon knowledge of the patient, the results of the physical examination, the ambulatory ECG data full disclosure displays, and other clinical findings.
Device Story
Matrix Holter System consists of M12R recorder and PC-based M12A application. Recorder acquires up to 12-lead ECG data continuously for 48 hours via surface electrodes; stores data digitally on removable memory card. Patient uses keypad for event marking; recorder display shows status/lead quality. Data transferred to PC application via memory card or optional wireless interface. Clinician uses PC application to analyze, view, print, and edit ECG data. Optional algorithms provide advisory measurements, graphical presentations, and interpretive statements. System assists clinicians in diagnosing rhythm patterns and abnormalities. Used in clinical settings by trained operators; results support clinical decision-making based on full disclosure displays and patient findings.
Clinical Evidence
No clinical data provided. Substantial equivalence is based on technological characteristics and intended use compared to predicate devices.
Technological Characteristics
Ambulatory electrocardiograph system; 7 or 10 lead electrode configuration for up to 12-lead ECG acquisition. Powered by two AA batteries. Data storage on removable memory card. PC-based analysis application with graphical display, printer, and communication interfaces. Optional wireless data transfer. Software provides advisory measurements and interpretive statements.
Indications for Use
Indicated for patients 16 years of age and older requiring screening for ECG rhythm disturbances via ambulatory electrocardiography for up to 48 hours. Used under supervision of a physician or qualified clinician.
Regulatory Classification
Identification
A medical magnetic tape recorder is a device used to record and play back signals from, for example, physiological amplifiers, signal conditioners, or computers.
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# SEP 2 6 2005
# 12. Premarket Notification [510(k)] Summary
## Submitted By:
Global Instrumentation LLC 8104 Cazenovia Road Manlius, NY 13104 Telephone: 315-682-0272 ext 213 Fax: 315-682-0278 Contact Person: Craig Sellers Prepared June 24th, 2005
| Common Name: | Electrocardiograph, Ambulatory, With Analysis Algorithm |
|--------------|---------------------------------------------------------|
|--------------|---------------------------------------------------------|
- Trade Name: Matrix Holter System
- Classification: 21 CFR 870.2800
- Predicate Device: The legally marketed medical devices which are substantially equivalent are:
Mortara H-Scribe Holter Analysis System (K004017) Mortara H12+ Holter Recorder (K021373) Burdick PC Holter Scanning System (K945985) Burdick Altair-Disc Recorder (K942565)
Confidential Material
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# 051730
#### Description:
The M12 Matrix Holter System is a Holter system consisting of the Matrix Holter recorder (M12R) and the PC-based Matrix Holter System Application (M12A). The complete system is referred to as the M12 Matrix Holter System.
The Matrix recorder is a Holter Recorder (ambulatory electrocardiograph) designed to be used with the PC-based Matrix Holter System Application. The Matrix recorder acquires ECG data, converts the data to digital format and stores the digital data. The data is not analyzed by the Matrix recorder. The Matrix recorder uses a 7 or 10 lead electrode hookup and placement to obtain data for use by the Matrix Holter System Application. The Matrix Holter System Application is a PC-based application which is used to analyze, view, print, and edit the data collected by the Matrix recorder. The ambulatory electrocardiograph data recorded by the Matrix recorder is transferred to the Holter System Application, where it is used by trained medical personnel to assist in the diagnosis of patients with various rhythm patterns.
The Matrix Holter recorder acquires up to 12 leads of ECG data continuously for a period of up to 48 hours. The data is stored in digital format and is intended to be retrieved from the recorder by the Matrix Holter System Application for data review and analysis.
The Matrix Holter recorder contains a keypad to provide means to configure the recorder, check hookup lead quality, and start the recording. The patient can use the keypad to enter patient activated event marks into the recording.
The Matrix recorder has a display which provides operational status information to the hook-up technician and to the patient. This information includes hook-up lead quality and system status.
Page 39 of 41
#### Confidential Material
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The Matrix recorder uses two AA batteries for power supply. Data is stored on a removable memory card. The data is transferred from the Matrix recorder to the Matrix Holter System Application by removing the memory card from the recorder and inserting the card into the memory card interface of the PC running the application. An optional wireless communication interface can also be used to transfer data from the recorder to the Matrix Holter System Application.
The Matrix Holter System Application is a PC-based application. This application runs on a conventional PC system with a processing/data storage module, a graphical color display, a user interface keyboard, a printer, memory card interface and communication interfaces.
#### Intended Use:
The M12 Matrix Holter System is intended to be used as a Holter ambulatory electrocardiograph system for the purpose of screening for ECG rhythm disturbances over periods up to 48-hours. The Matrix Holter System is intended for use under the supervision of a Physician or those knowledgeable in all aspects of ECG morphology, rhythm and arrhythmia.
This procedure is commonly called a Holter procedure which captures ECG rhythm abnormalities which may be infrequent or provoked by activities outside of the physician office.
The M12 Matrix Holter System is comprised of the Matrix Holter Recorder (M12R) and the Matrix Holter System Application (M12A).
The Matrix Holter Recorder component of the system will be worn by the patient and is used to record ambulatory electrocardiograph data from the patient. The Matrix Holter System Application is used to analyze the data recorded by the Matrix Holter Recorder.
The subject Devices will provide the following diagnostic functions:
- Acquiring, viewing, storing and printing ambulatory ECG waveforms from . patients using the Matrix Holter Recorder and associated accessories that provide signal acquisition for up to twelve (12) leads of patient ECG waveforms through surface electrodes adhered to the body.
- Using optional Holter algorithms to generate measurements, data presentations . and graphical presentations on an advisory basis for patients. These are presented for review and interpretation by the clinician based upon knowledge of the patient, the results of the physical examination, the ambulatory ECG data full disclosure displays, and other clinical findings.
- Using optional interpretive algorithms to generate measurements, data . presentations, graphical presentations, and interpretive statements on an advisory
Page 40 of 41
Confidential Material
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basis for patients of sixteen (16) years of age and above. These are presented for review and interpretation by the clinician based upon knowledge of the patient, the results of the physical examination, the ambulatory ECG data full disclosure displays, and other clinical findings.
.
Page 41 of 41
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Image /page/4/Picture/2 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized caduceus symbol, which is a staff with two snakes coiled around it. The logo also includes the text "DEPARTMENT OF HEALTH AND HUMAN SERVICES . USA" arranged in a circular fashion around the caduceus symbol.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP 26 2005
Global Instrumentation, LLC c/o Mr. Craig Sellers Manager of Regulatory Affairs 8104 Cazenovia Road Manlius. NY 13104
Re: K051730
Trade Name: Matrix Holter System Regulation Number: 21 CFR 870.2800 Regulation Name: Electrocardiograph, Ambulatory, With Analysis Algorithm Regulatory Class: Class II (two) Product Code: MLO Dated: September 9, 2005 Received: September 12, 2005
Dear Mr. Sellers:
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.
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 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.
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Page 2 - Mr. Craig Sellers
Please be advised that FDA's issuance of a substantial equivalence determination does not mean r lease oc advised that I DTP of localites complies with other requirements of the Act that IDA has made a decemination administered by other Federal agencies. You must of ally it cachar statutes and regaranents and limited to: registration and listing (21 comply with an the Her Stequirements, we see manufacturing practice requirements as set CTN Fat 807, adomig (21 OF RT 820), government (21 CFR Part 820); and if applicable, the electronic forul in the quality systems (Sections 531-542 of the Act); 21 CFR 1000-1050. product ladiation control pro herens (seeins (seting your device as described in your Section 510(k) I mis letter will anow you to oegin maining of substantial equivalence of your device to a legally premarket notineation: The PDF Intamisgsification for your device and thus, 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 acries in 1984 (240) 276-0295. Also, please note the regulation entitled, Contact the Ories of Collier of Collier of Collication" (21CFR Part 807.97) you may obtain. Missuranding of reference to promazionsibilities under the Act may be obtained from the Other general information on your respectional and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Bfimmermanfor
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## 11. Statement of Indications For Use
Page 1 of 1
510(k) Number (if known):
K051730
Matrix Holter System Device Name:
Indications For Use:
The M12 Matrix Holter System is intended for use by trained operators in health
facilities. The subject Device will provide the following diagnostic functions:
- Acquiring, viewing, storing and printing Ambulatory ECG waveforms for up to twelve . (12) leads of patient ECG waveforms through surface electrodes adhered to the body.
- Using optional algorithms to generate measurements, data presentations, and graphical . presentations on an advisory basis for the subject patients. These are presented for review probentation by the clinician based upon knowledge of the patient, the results of the physical examination, the ambulatory ECG tracings, and other clinical findings.
Prescription Use X (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (Part 21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)
or
Bhimmar
Eulian Slan Off
(Optional Format 3-10-98)
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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.