Retrospective clinical samples were used to establish threshold values for the assay and to evaluate the impact of potential biological interferences (e.g., rheumatoid factor, cryoglobulinemia, hemolyzed sera).
50 blood donors and 48 samples with potential biological interferences; Sample Size: 98
Not applicable for this study
Establishment of negative threshold values
Retrospective clinical sample testing
30 negative samples characterized as positive for various potential interferences; Sample Size: 30
Not applicable for this study
Assessment of assay interference from clinical factors (e.g., Rheumatoid factor, Complement, Hemolysis)
Indications for Use
The FIDIS™ Connective 10* kit is a fluorescent immunoassay for the semi-quantitative simultaneous detection of 10 autoantibody specificities directed against double stranded DNA (dsDNA), SSA (60 kDA and 52 kDA), SSB, Sm, Sm/RNP, Scl-70, Jo-1 ribosome and centromere in human serum. (*Antibodies to dsDNA, SSA, SSB, Sm, Sm/RNP, Scl-70, Jo-1, ribosome and centromere can be reported using this assay).
Device Story
Multiplex bead-based flow cytometric immunoassay; detects 10 autoantibody specificities in human serum. Input: serum samples; antigen-coupled color-coded microspheres; goat anti-human IgG phycoerythrin conjugate. Operation: microspheres mixed with serum; flow cytometer uses red laser to identify microsphere set (analyte) and green laser to quantify bound IgG fluorescence. Output: semi-quantitative results for 10 autoantibodies. Used in clinical laboratories; processed via FIDIS instrument (Luminex 200 platform) with MLX-Booster 2.2 software; optional CARIS system for automated dilution/dispensing. Results assist clinicians in diagnosing systemic autoimmune diseases.
Clinical Evidence
Bench testing only. Precision/reproducibility evaluated with four samples across reportable range (within-run CVs 2.1-12.7%; between-run CVs 4.5-14.6%). Method comparison (N=264) between modified and initial FIDIS device showed high positive/negative agreement (overall agreement 95.69-100% across parameters). Comparison between manual and automated CARIS system also performed, showing high agreement. No clinical sensitivity/specificity data provided.
Technological Characteristics
Multiplexed flow cytometry immunoassay. Components: color-coded microsphere beads, anti-human IgG-phycoerythrin conjugate, buffers. Energy source: laser-based flow cytometry (Luminex 200). Connectivity: standalone instrument with MLX-BOOSTER™ software. Software: MLX-BOOSTER™ version 2.2. Form factor: 96-well microplate assay.
Indications for Use
Indicated for the semi-quantitative detection of 10 autoantibody specificities (dsDNA, SSA 60kDa, SSA 52kDa, SSB, Sm, Sm/RNP, Scl70, Jo-1, ribosome, centromere) in human serum to aid in the diagnosis of connective tissue diseases including SLE, Sjogren's syndrome, MCTD, scleroderma, dermatomyositis, and CREST syndrome. For prescription use only.
Regulatory Classification
Identification
An antinuclear antibody immunological test system is a device that consists of the reagents used to measure by immunochemical techniques the autoimmune antibodies in serum, other body fluids, and tissues that react with cellular nuclear constituents (molecules present in the nucleus of a cell, such as ribonucleic acid, deoxyribonucleic acid, or nuclear proteins). The measurements aid in the diagnosis of systemic lupus erythematosus (a multisystem autoimmune disease in which antibodies attack the victim's own tissues), hepatitis (a liver disease), rheumatoid arthritis, Sjögren's syndrome (arthritis with inflammation of the eye, eyelid, and salivary glands), and systemic sclerosis (chronic hardening and shrinking of many body tissues).
Predicate Devices
FIDISTM Connective 10* (k053653)
Submission Summary (Full Text)
{0}
1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
k071210
B. Purpose for Submission:
Design changes (detection system with new platform software)
C. Measurand:
Anti-SS-A, anti-SS-B, anti-Sm, anti-Sm/RNP, anti-dsDNA, anti-Scl-70, anti-Jo1, ribosome and centromere
D. Type of Test:
Multiplex bead-based flow cytometric immunoassay
E. Applicant:
Biomedical Diagnostics (bmd) S.A.
F. Proprietary and Established Names:
FIDIS™ Connective 10*
G. Regulatory Information:
1. Regulation section:
21CFR§ 866.5100, Antinuclear Antibody Immunological Test System
2. Classification:
Class II
1. Product code:
LLL, Extractable Antinuclear Antibody, Antigen, and Control
LKJ, Antinuclear Antibody, Antigen, Control
LKO, Anti-RNP Antibody, Antigen, Control
LKP, Anti-Sm Antibody, Antigen, and Control
LSW, Anti-DNA Antibody, Antigen and Control
LJM, Antinuclear Antibody (Enzyme Labeled), Antigen, Controls
MQA, Anti-Ribosomal P Antibodies
4. Panel:
Immunology (82)
H. Intended Use:
1. Intended use(s):
The FIDIS™ Connective 10* kit is a fluorescent immunoassay for the semi-quantitative simultaneous detection of 10 autoantibody specificities directed against double stranded DNA (dsDNA), SSA (60 kDA and 52 kDA), SSB, Sm, Sm/RNP, Scl-70, Jo-1 ribosome and centromere in human serum. (*Antibodies to dsDNA, SSA, SSB, Sm, Sm/RNP, Scl-70, Jo-1, ribosome and centromere can be reported using this assay).
2. Indication(s) for use:
The test system is used to screen serum samples and detect the presence of antinuclear antibodies associated with connective diseases systemic lupus erythematosus (SLE), Sjogren’s syndrome, mixed connective tissue disease (MCTD), scleroderma, dermatomyositis, and CREST syndrome, in conjunction with clinical findings and other laboratory tests.
3. Special conditions for use statement(s):
{1}
This device is for prescription use only.
4. Special instrument requirements:
FIDISTM Instrument (Luminex $200^{\mathrm{TM}}$ plus FIDISTM MLX-Booster 2.2Software)
CARISTM (Optional diluting and dispensing device)
# I. Device Description:
The device consists of the following: color-coded sets of microspheres (lyophilized). Each microsphere set is conjugated to one of the following antigens: dsDNA, SSa (60 kDA and 52 kDA), SSB, Sm, Sm/RNP, Scl-70, Jo-1, ribosome and centromere; calibrator (ready to use); positive control (to be diluted); negative control (to be diluted); goat anti-human IgG conjugate coupled phycoerythrin (ready to use) and washing buffer (ready to use).
# J. Substantial Equivalence Information:
1. Predicate device name(s):
FIDISTM Connective 10*
2. Predicate 510(k) number(s):
k053653
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| | Modified FIDISTM Connective 10* | Initial FIDISTM Connective 10* |
| Intended Use | Individual determination of IgG antibodies to dsDNA, SSA 60 kDA and 52 kDA, SSB, Sm, Sm/RNP, ScL-70, Jo-1, ribosome and centromere | Same |
| Assay type | Flow cytometer based | Same |
| Assay format | Multiplexed | Same |
| Solid phase capture | Color-coded microsphere | Same |
| Conjugate | Phycoerythrin | Same |
| Sample type | Serum | Same |
| Type of test | Semi-quantitative | Same |
| Differences | | |
| --- | --- | --- |
| Item | Modified FIDISTM Connective 10* | Initial FIDISTM Connective 10* |
| Material supplied | Microplate without caps | Microplate with caps |
| Beads | Vial of color-coded microsphere set Lyophilized (sp 6mL) | 6mL of vial of color-coded microsphere set ready to use |
| Sample Dilution | Sample dilution buffer ready to use | PBS-Tween concentrated |
| Wash buffer | Sample dilution buffer ready to use | PBS-Tween concentrated |
| Assay configuration | 1 “reagent-blank” well 1 “negative control” well | 1 “reagent-blank” well 1 “calibrator” well |
{2}
| Differences | | |
| --- | --- | --- |
| Item | Modified FIDISTM Connective 10* | Initial FIDISTM Connective 10* |
| | 1 “positive control” well
2 “calibrator” wells
Diluted sample wells | 1 “negative control” well
1 “positive control” well
Diluted sample wells
A second calibrator well every 32 well series |
| Assay protocol | Final wash step (not optional) | Optional final wash step |
| Software | Booster Version 2.2 | Booster Version 1.35 |
| Detection | Based on Luminex 200 | Based on Luminex 100 |
K. Standard/Guidance Document Referenced (if applicable):
CLSI C24A - Statistical Quality Control for Quantitative Measurement Procedures: Principles and Definitions
CLSI M29A – Protection of Laboratory Workers from Occupationally Acquired Infection
CLSI H18A – Procedures for the Handling and Processing of Blood Specimens
L. Test Principle:
FIDISTM CONNECTIVE 10* is based on the use of distinct uniform size color-coded microspheres and a benchtop flow cytometer interfaced to a digital signal processing hardware and software. A red diode laser beam of the flow cytometer classifies each set of microspheres on the basis of its unique fluorescence intensity (red to orange) which allows to identify which analyte is being tested. At the same time, a green laser beam illuminates the external second molecule fluorescence to quantify the specific reaction related to each analyte.
Each antigen required for the assay is covalently coupled to an individual set of microspheres through its surface functional groups. The different antigen-coupled microspheres are mixed together to constitute the final microsphere reagent.
FIDISTM CONNECTIVE 10* allows the detection of 10 autoantibody specificities: double stranded DNA (dsDNA), SSA 60kDa, SSA 52kDa, SSB, Sm, Sm/RNP, Scl70, Jo-1, Ribosomes and Centromeres. The microspheres are classified on the basis of their unique fluorescence intensity ratio that allows the identity of analyte being tested. Each dot in a white plot corresponds to an individual microsphere.
Seventy (70) µL of each sample are needed for each analysis. FIDISTM Connective 10* assay was optimized by flow cytometry for the average binding capacity at the given dilution (1:200) from the median fluorescence value using 200 microspheres per parameter.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
To evaluate intra-assay and inter assay reproducibility, four samples covering the reportable range of the assay were analyzed on the modified FIDISTM Connective 10*. For within-run, the four samples were assayed 6 times in one run and for between-run; the four samples were assayed 2 times per run for 6 runs. Additional study was performed for dsDNA on the low end of the measuring range. Results
{3}
were as follows:
| | Within-run
(10 tests in the same run) | | Between-run
(3 tests in 6 different runs) | |
| --- | --- | --- | --- | --- |
| Antigen | Mean value | CV (%) | Mean value | CV (%) |
| dsDNA | 496 | 5.9 | 508 | 10.5 |
| | 87 | 6.1 | 104 | 13.8 |
| | 63 | 8.9 | 63 | 6.7 |
| | 52 | 8.0 | 64 | 12.6 |
| | 14 | 8.2 | 14 | 10.8 |
| | 12 | 8.6 | 14 | 8.3 |
| SSA 60 kDa and 52 kDa | 209 | 2.1 | 202 | 5.4 |
| | 81 | 7.8 | 81 | 4.5 |
| | 64 | 5.3 | 64 | 5.5 |
| | 19 | 11.2 | 23 | 8.8 |
| SSB | 192 | 2.6 | 176 | 8.8 |
| | 74 | 8.0 | 76 | 7.0 |
| | 26 | 5.2 | 25 | 14.6 |
| | 19 | 2.5 | 18 | 10.9 |
| Sm | 306 | 3.2 | 303 | 6.8 |
| | 81 | 9.1 | 87 | 9.4 |
| | 66 | 8.6 | 63 | 10.8 |
| | 49 | 12.7 | 48 | 12.7 |
| Sm/RNP | 236 | 8.4 | 236 | 9.3 |
| | 133 | 7.9 | 139 | 7.6 |
| | 92 | 11.5 | 100 | 14.3 |
| | 75 | 6.2 | 70 | 9.5 |
| Scl70 | 278 | 4.5 | 281 | 7.1 |
| | 162 | 5.4 | 153 | 9.2 |
| | 67 | 4.7 | 67 | 6.5 |
| | 5 | 5.9 | 6 | 13.6 |
| Jo1 | 282 | 9.7 | 268 | 9.7 |
| | 100 | 3.0 | 92 | 9.4 |
| | 57 | 7.7 | 65 | 11.5 |
| | 9 | 12.8 | 9 | 12.2 |
| Centromere | 225 | 9.0 | 223 | 10.1 |
| | 94 | 3.6 | 92 | 6.7 |
| | 25 | 9.0 | 25 | 8.2 |
| | 22 | 6.7 | 21 | 8.5 |
| Ribosome | 154 | 6.9 | 152 | 10.1 |
| | 73 | 6.9 | 79 | 11.8 |
| | 50 | 6.4 | 53 | 8.4 |
| | 15 | 4.2 | 17 | 14.4 |
{4}
b. Linearity/assay reportable range:
Linearity is not claimed for this assay.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The dsDNA values in the calibrator are established using the WHO International Standard for anti-double stranded DNA (dsDNA), human code: WO/80. Other calibrator titers are expressed in arbitrary units per mL (AU/mL).
d. Detection limit:
Not applicable
e. Analytical specificity:
Interfering substances
To evaluate the system for potential cross reactivity to other antibodies and interference from blood components, 30 samples were tested. High level of complement proteins were used but the specific kind of complement was not provided. A statement to avoid the use of abnormal concentration of these samples was added to the Limitations of the Procedure. The following results were obtained:
| | Number of Positive Samples | | | | | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | dsDNA | SSA 60/52kD | SSB | Sm | Sm/RNP | Scl70 | Jo1 | Centromere | Ribosome |
| Cryoglobulinemia (2) | | | | | | | | | |
| Complement (7) | 2 | 1 | 1 | 1 | 1 | | | | |
| IgG monoclonal Ig (1) | | | | | | | | | |
| IgM monoclonal Ig (5) | | | | | | | | | |
| Rheumatoid Factor (8) | 1 | 2/2 | 1 | | | | | | |
| Blood Plasma (3) | | | | | | | | | |
| Hemolyzed sera (3) | | | | | | | | | |
| Anti-smooth muscle antibodies (1) | | | | | | | | | |
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
The tables below show the comparison of serum samples (N=264) that were tested with the Modified FIDISTM Connective 10* and the predicate device (Initial FIDISTM Connective 10*). No information about age, gender, and clinical status was provided.
- 194 positive samples for one or more parameters related to systemic autoimmune diseases
- 70 negative samples
All borderline results with the two devices were considered negative.
| | Initial FIDISTM Connective 10* dsDNA | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM Connective 10* dsDNA | Pos | 45 | 1 | 46 |
| | Neg | 4 | 66 | 70 |
| | Total | 49 | 67 | 116 |
Positive % agreement: 91.84% (95% CI: 84.2% - 99.5%)
{5}
Negative % agreement: 98.51% (95% CI: 95.6% - 100%)
Overall % agreement: 95.69% (95% CI: 92.0% - 99.4%)
| | Initial FIDISTM Connective 10*
SSA 60/kDa | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM
Connective 10*
SSA 60/kDa | Pos | 48 | 1 | 49 |
| | Neg | 0 | 69 | 70 |
| | Total | 48 | 70 | 119 |
| Positive % agreement: 100%
Negative % agreement: 98.57% (95% CI: 95.8%-100%)
Overall % agreement: 99.15% (95% CI: 97.52% - 100%) | | | | |
| | Initial FIDISTM Connective 10*
SSA 52kDa | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM
Connective 10*
SSA 52kDa | Pos | 58 | 2 | 60 |
| | Neg | 3 | 64 | 67 |
| | Total | 61 | 66 | 127 |
| Positive % agreement: 95.08% (95% CI: 89.7%, -100.0%)
Negative % agreement: 96.97% (95% CI: 92.8 - 100%)
Overall % agreement: 96.06% (95% CI: 92.7% -99.4%) | | | | |
| | Initial FIDISTM Connective 10* SSB | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM
Connective 10*
SSB | Pos | 23 | 2 | 25 |
| | Neg | 0 | 68 | 68 |
| | Total | 23 | 70 | 93 |
| Positive % agreement: 100%
Negative % agreement: 97.14% (95%CI: 93.2% - 100%)
Overall % agreement: 97.85% (95% CI: 94.9% - 100%) | | | | |
| | Initial FIDISTM Connective 10* Sm | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM
Connective 10* Sm | Pos | 23 | 2 | 25 |
| | Neg | 1 | 73 | 74 |
| | Total | 24 | 75 | 99 |
| Positive % agreement: 95.83% (95% CI: 87.8% - 100%)
Negative % agreement: 97.33% (95%CI: 93.7% - 100%)
Overall % agreement: 96.97% (95% CI: 93.6%- 100%) | | | | |
| | Initial FIDISTM Connective 10* Sm/RNP | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM
Connective 10*
Sm/RNP | Pos | 31 | 2 | 33 |
| | Neg | 1 | 76 | 77 |
| | Total | 32 | 78 | 110 |
{6}
Positive % agreement: 96.88% (95% CI: 90.8% - 100%)
Negative % agreement: 97.44% (95%CI: 93.9% - 100%)
Overall % agreement: 97.27% (95% CI: 94.2% - 100%)
| | Initial FIDISTM Connective 10* Scl70 | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM Connective 10* Scl70 | Pos | 27 | 2 | 29 |
| | Neg | 1 | 68 | 69 |
| | Total | 28 | 70 | 98 |
Positive % agreement: 96.43% (95%CI: 89.2%-100%)
Negative % agreement: 97.14% (95%CI: 93.2% - 100%)
Overall % agreement: 96.94% (95% CI: 93.5% - 100%)
| | Initial FIDISTM Connective 10* Jo1 | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM Connective 10* Jo1 | Pos | 26 | 0 | 26 |
| | Neg | 1 | 69 | 70 |
| | Total | 27 | 69 | 96 |
Positive % agreement: 96.3% (95%CI: 89.2% - 100.0%)
Negative % agreement: 100%
Overall % agreement: 98.96% (95% CI: 96.9% - 100%)
| | Initial FIDISTM Connective 10* Centromere | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM Connective 10* Centromere | Pos | 20 | 0 | 20 |
| | Neg | 0 | 69 | 69 |
| | Total | 20 | 69 | 89 |
Positive % agreement: 83.33% (95%CI: 68.4% - 98.2%)
Negative % agreement: 100%
Overall % agreement: 95.83% (95% CI: 91.8% - 99.8%)
| | Initial FIDISTM Connective 10* Ribosome | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Modified FIDISTM Connective 10* Ribosome | Pos | 18 | 0 | 18 |
| | Neg | 0 | 69 | 69 |
| | Total | 18 | 69 | 87 |
Positive % agreement: 100%
Negative % agreement: 100%
Overall % agreement: 100%
Comparison of the automated CARIS system and manual method
A comparison study between the manual method and the automated CARISTM system was also performed. All borderline results with the two methods were considered negative.
{7}
8
| dsDNA | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 43 | 0 | 43 |
| | Neg | 0 | 69 | 69 |
| | Total | 43 | 69 | 112 |
Positive % agreement: 100.0%
Negative % agreement: 100.0%
Overall % agreement: 100.0%
| SSA (60kDa) | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 42 | 0 | 42 |
| | Neg | 0 | 68 | 68 |
| | Total | 42 | 68 | 110 |
Positive % agreement: 100.0%
Negative % agreement: 100.0%
Overall % agreement: 100.0%
| SSA (52kDa) | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 52 | 1 | 53 |
| | Neg | 0 | 65 | 65 |
| | Total | 52 | 66 | 118 |
Positive % agreement: 100.0%
Negative % agreement: 98.5%
Overall % agreement: 99.2%
| SSB | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 25 | 0 | 25 |
| | Neg | 0 | 67 | 67 |
| | Total | 25 | 67 | 92 |
Positive % agreement: 100.0%
Negative % agreement: 100.0%
Overall % agreement: 100.0%
| Sm | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 24 | 3 | 27 |
| | Neg | 0 | 69 | 69 |
| | Total | 24 | 72 | 96 |
Positive % agreement: 100.0%
Negative % agreement: 95.8%
Overall % agreement: 96.9%
{8}
9
| Sm/RNP | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 32 | 3 | 35 |
| | Neg | 0 | 68 | 68 |
| | Total | 32 | 71 | 103 |
Positive % agreement: 100.0%
Negative % agreement: 95.8%
Overall % agreement: 97.1%
| Scl70 | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 29 | 0 | 29 |
| | Neg | 0 | 68 | 68 |
| | Total | 29 | 68 | 97 |
Positive % agreement: 100.0%
Negative % agreement: 100.0%
Overall % agreement: 100.0%
| Jo1 | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 26 | 0 | 26 |
| | Neg | 0 | 69 | 69 |
| | Total | 26 | 69 | 112 |
Positive % agreement: 100.0%
Negative % agreement: 100.0%
Overall % agreement: 100.0%
| Centromere | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 20 | 4 | 24 |
| | Neg | 0 | 69 | 69 |
| | Total | 20 | 73 | 93 |
Positive % agreement: 100.0%
Negative % agreement: 94.5%
Overall % agreement: 95.7%
| Ribosome | Manual FIDIS | | | |
| --- | --- | --- | --- | --- |
| | | Pos | Neg | Total |
| Caris FIDIS | Pos | 8 | 0 | 8 |
| | Neg | 0 | 68 | 68 |
| | Total | 8 | 68 | 78 |
Positive % agreement: 100.0%
Negative % agreement: 100.0%
Overall % agreement: 100.0%
{9}
b. Matrix comparison: Serum is the only recommended matrix.
3. Clinical studies:
a. Clinical Sensitivity: Not provided
b. Clinical specificity: Not provided
c. Other clinical supportive data (when a. and b. are not applicable): Not applicable
4. Clinical cut-off: Not applicable
5. Expected values/Reference range: The reported expected ranges were estimated from 2 populations:
50 samples from blood donors
48 samples selected from their potential biological interferences and according to WHO standard for dsDNA specificity
| Arbitrary units (AU/mL) | <30 AU/mL | 30-40 AU/mL | >40 AU/mL |
| --- | --- | --- | --- |
| International units (IU/mL) | <30 | 30-40 | >40 |
| For dsDNA | IU/mL | IU/mL | IU/mL |
| Interpretation | Negative | Equivocal1 | Positive |
The negative thresholds (30 AU/mL or 30 IU/mL) correspond to the $97.9^{\text{th}}$ percentile for dsDNA, SSA, Sm/RNP; $99.0\%$ for centromere and ribosome, and $100\%$ for SSB, Sm, Scl70 and Jo1 for the populations studied.
# N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
# O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.