The EMPIRA Rx PTCA Catheter and EMPIRA NC Rx PTCA Dilatation Catheter are indicated for balloon dilatation of the stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion. The EMPIRA NC Rx PTCA Dilatation Catheter is also indicated for post-delivery expansion of balloon expandable stents.
Device Story
Rapid exchange PTCA dilatation catheter; sterile; single-use. Distal section: dual-lumen coaxial design; nylon-blend balloon; hydrophilic coating; radiopaque marker bands for fluoroscopic visualization. Proximal section: stainless steel PTFE-coated hypotube with luer port. Operated by physician in clinical setting (e.g., cath lab) using standard inflation device and 0.014" guide wire. Principle: hydraulic pressurization of balloon to dilate stenosis or expand stents. Benefits: improved myocardial perfusion; stent apposition. Output: mechanical force applied to vessel wall/stent.
Clinical Evidence
No clinical trial data provided. Evidence consists of bench testing (cytotoxicity, hemolysis, thromboresistance, dimensional verification, balloon burst pressure, fatigue, compliance, bond strength, flexibility, torque, radiopacity, coating integrity, particulate evaluation) and GLP-compliant animal studies comparing performance to legally marketed predicate devices. All tests passed.
Technological Characteristics
Rapid exchange PTCA catheter; dual-lumen coaxial shaft; nylon-blend balloon; stainless steel PTFE-coated hypotube; hydrophilic coating. Compatible with 0.014" guide wires and 5F guiding catheters. Sterilized via Ethylene Oxide. Radiopaque marker bands for fluoroscopy. Nominal pressures: 8 atm (EMPIRA) and 14 atm (EMPIRA NC).
Indications for Use
Indicated for patients requiring balloon dilatation of stenotic coronary arteries or bypass grafts to improve myocardial perfusion. EMPIRA NC model also indicated for post-delivery expansion of balloon-expandable stents.
Regulatory Classification
Identification
Standard PTCA Catheter: A PTCA catheter is a device that operates on the principle of hydraulic pressurization applied through an inflatable balloon attached to the distal end. A PTCA balloon catheter has a single or double lumen shaft. The catheter features a balloon of appropriate compliance for the clinical application, constructed from a polymer. The balloon is designed to uniformly expand to a specified diameter and length at a specific pressure as labeled, with well characterized rates of inflation and deflation and a defined burst pressure. The device generally features a type of radiographic marker to facilitate fluoroscopic visualization of the balloon during use. A PTCA catheter is intended for balloon dilatation of a hemodynamically significant coronary artery or bypass graft stenosis in patients evidencing coronary ischemia for the purpose of improving myocardial perfusion. A PTCA catheter may also be intended for the treatment of acute myocardial infarction; treatment of in-stent restenosis (ISR) and/or post-deployment stent expansion. Cutting/scoring PTCA Catheter: A cutting/scoring PTCA catheter is a balloon-tipped catheter with cutting/scoring elements attached, which is used in those circumstances where a high pressure balloon resistant lesion is encountered. A cutting/scoring PTCA catheter is intended for the treatment of hemodynamically significant coronary artery stenosis for the purpose of improving myocardial perfusion. A cutting/scoring PTCA catheter may also be indicated for use in complex type C lesions or for the treatment of in-stent restenosis.
Special Controls
*Classification.* Class II (special controls). The special control for this device is “Class II Special Controls Guidance Document for Certain Percutaneous Transluminal Coronary Angioplasty (PTCA) Catheters.” See § 870.1(e) for the availability of this guidance document.(b)
*Cutting/scoring PTCA Catheter* —(1)*Identification.* A cutting/scoring PTCA catheter is a balloon-tipped catheter with cutting/scoring elements attached, which is used in those circumstances where a high pressure balloon resistant lesion is encountered. A cutting/scoring PTCA catheter is intended for the treatment of hemodynamically significant coronary artery stenosis for the purpose of improving myocardial perfusion. A cutting/scoring PTCA catheter may also be indicated for use in complex type C lesions or for the treatment of in-stent restenosis.(2)
*Classification.* Class III (premarket approval). As of May 28, 1976, an approval under section 515 of the act is required before this device may be commercially distributed. See § 870.3.
Boston Scientific's Quantum Maverick Monorail (P860019)
Submission Summary (Full Text)
{0}------------------------------------------------
K110133
Image /page/0/Picture/1 description: The image shows the text "CREGANNA" in large, bold, sans-serif font. Below this, in a smaller font size, is the text "TACTX MEDICAL". The text appears to be slightly distressed or textured, giving it a somewhat vintage or weathered look.
JUN 1 0 2011
1353 Dell Avenue Campbell, California 95008, USA Tel: +1 408 364 7100 Fax: +1 408 871 2425 www.cregannatactx.com
## General Information:
| Submitter: | Creganna Tactx Medical, Inc. |
|-----------------|----------------------------------------------------------------|
| | 1353 Dell Avenue |
| | Campbell, Ca 95008 |
| | Ph: (408) 364-7100 |
| | Fax: (408) 871-2425 |
| Contact Person: | Dennis Wong |
| | Director of Quality |
| Date Prepared: | January 17, 2011 |
| Device Trade | EMPIRA Rx PTCA Dilatation Catheter and |
| name(s): | EMPIRA NC Rx PTCA Dilatation Catheter |
| Device Common | PTCA Catheter |
| name: | |
| Class: | II |
| Classification | Percutaneous Transluminal Coronary Angioplasty (PTCA) Catheter |
| Name: | (21 CFR 870.5100) |
| Product Code: | LOX |
## Predicate Device(s):
| Device Name | Reference(s) |
|-----------------------------------------------|-----------------|
| EMPIRA Rx PTCA Dilatation Catheter | |
| Standard PTCA Catheter | 21 CFR 870.5100 |
| Cordis Fire Star | P880003 |
| Boston Scientific's Maverick2 Monorail | P860019 |
| EMPIRA NC Rx PTCA Dilatation Catheter | |
| Standard PTCA Catheter | 21 CFR 870.5100 |
| Cordis Dura Star | P880003 |
| Boston Scientific's Quantum Maverick Monorail | P860019 |
Note: Recently, PTCA Catheters were reclassified by the agency from Class II with Special Controls per FDA Guidance Document - Class II Special Controls Guidance Document for Certain Perculaneous Transluminal Coronary Angioplasty (PTCA) Catheters issued September 8, 2010.
## Intended Use:
The EMPIRA Rx PTCA Catheter and EMPIRA NC Rx PTCA Dilatation Catheter are indicated for balloon dilatation of the stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion.
The EMPIRA NC Rx PTCA Dilatation Catheter is also indicated for post-delivery expansion of balloon expandable stents.
Partners from Idea to Reality
Creganna. Registered in Dublin, Ireland: · Reg No 324172
Creganna Medical Devices Inc.
Drectors: - In Quinn, Endrac Clarke, Beenard Collers, Helen Ryan, Benard E. Lyons, Daniel G. Tully, George Altien-Daves
{1}------------------------------------------------
## Device Description:
The EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters, hereafter referred to as the EMPIRA Catheter, are similar in design. The catheters differ in available configurations (diameter versus balloon working length). The EMPIRA Catheter is a sterile, single-use rapid exchange catheter with a nylon-blend balloon near the distal tip. The distal section of the catheter is dual lumen and coaxial. The outer lumen is used for inflation of the balloon and the inner lumen permits the use of a guide wire (≤ 0.014 in. / 0.36 mm) to facilitate advancement of the catheter to and through the stenosis to be dilated. The proximal section of the catheter is a single lumen stainless steel PTFE coated hypotube with a single luer port for the inflation of the balloon. The balloon is designed to provide an inflatable segment of specified diameter and length at recommended pressures. The balloon is folded to achieve a low crossing profile and is connected to a tapered, soft tip. The tapered tip facilitates advancement of the catheter to and through the stenosis. A hydrophilic coating is applied from the distal tip to the guide wire port and over the balloon for increased lubricity. All models have two radiopaque marker bands that aid in the placement of the catheter's balloon segment under fluoroscopy. A balloon protector is placed over the balloon to maintain a low profile and a mandrel is placed in the lumen to maintain patency. The proximal end of the catheter is comprised of a hypotube connected to a plastic hub. The hub can be connected to a standard inflation device and is used to inflate/deflate the balloon. A needle with a luer port is included for flushing the distal lumen prior to the insertion of a guide wire.
The EMPIRA Catheter is compatible with standard 0.014" coronary guide wires and 5F guiding catheters. The catheter length is approximately 139 cm. The EMPIRA and EMPIRA NC Rx PTCA Catheters are offered in diameters of 1.5- 4.0 mm and 2.0-4.0, respectively. The working lengths of the treatment balloon are offered in lengths from 6.0 to 30mm. The EMPIRA and EMPIRA NC Rx PTCA Balloon Dilatation Catheter product family consists of multiple sizes.
## Partners from Idea to Reality
Creganna. Registered in Dublin, Ireland: Reg No 324177.
Creganna Mecical Davires Inc
Drectors: Jan Quinn, Enda Quinn, Patrair Collins, Helen Ryan, Banard E. I yoos, Caniel G. Tully, George Atlen-Daves
{2}------------------------------------------------
### Device Comparison:
Below is a comparison of the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters with Standard PTCA Catheter as defined by 21 CFR 870.5100:
- 1. Like Standard PTCA Catheters, the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters operate on the principle of hydraulic pressurization applied through an inflatable balloon attached to the distal end of the catheter.
- 2. Like Standard PTCA Catheters, the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters have a double-lumen coaxial shaft.
- 3. Like Standard PTCA Catheters, the balloons on the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters are constructed from a polymer (nylon) and have nominal rated pressures of 8 and 14atm, respectively.
- 4. Like Standard PTCA Catheters, the balloon on the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters are available in different diameters and lengths.
- 5. Like Standard PTCA Catheters, the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters have radiopaque marker bands to allow for visualization under fluoroscopy.
- 6. Like Standard PTCA Catheters, the EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters have the same intended use - indicated for the balloon dilatation of stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion. In addition, the EMPIRA NC Rx PTCA Balloon Dilatation Catheter is also indicated for the post-delivery expansion of balloon expandable stents.
# Partners from Idea to Reality
Registered in Dublin, Treland .- Reg No 324172
reganna Medical Devices Inc.
Directurs: Jan Quinn, Enda Quan, Padrac Callins, Helen Ryan, Bernard E. Lyons, Daniel G. Tully, George Arken-Davies
{3}------------------------------------------------
CREGANNA
TACTX MEDICAL
| | | | Pre-Dilatation Catheters | | | Post-Dilatation Catheters | | |
|-----------------------------|----------------------------|--|--------------------------|--------------------------|-------------------|---------------------------|--------------------------|---------------------------|
| | | | EMPIRA | Fire Star | Maverick Monorail | EMPIRA NC | Dura Star | Quantum Maverick Monorail |
| Item | | | | | | | | |
| Manufacturer | | | Creganna-TACTX Medical | Cordis-Johnson & Johnson | Boston Scientific | Creganna-TACTX Medical | Cordis-Johnson & Johnson | Boston Scientific |
| Submission Reference | | | Current Submission | P880003 | P860019 | Current Submission | P880003 | P860019 |
| Intended Use | | | Note 1 | Same | Same | Note 1 | Same | Same |
| Principle of Operation | | | Note 2 | Same | Same | Note 2 | Same | Same |
| Catheter<br>Characteristics | Configuration | | Rapid Exchange | Same | Same | Rapid Exchange | Same | Same |
| | Effective Length (cm) | | 139 | 145 | 143 | 139 | 145 | 143 |
| Balloon<br>Characteristics | Balloon Lengths (mm) | | 6.0-30mm | 10-30mm | 9.0-30mm | 6.0-30mm | 10-30mm | 8.0-30mm |
| | Balloon Diameters (mm) | | 1.5-4.0mm | 1.5-3.5mm | 1.5-4.0mm | 2.0 - 4.0mm | 2.25-4.0mm | 2.0-5.0mm |
| | Nominal Pressure (atm) | | 8 | 8 | 6 | 14 | 14 | 12 |
| | Rated Burst Pressure (atm) | | 14 | 14 | 12-14 | 20 | 20 | 16-18 |
| Other<br>Characteristics | Guidewire compatibility | | ≤0.014in | Same | Same | ≤0.014in | Same | same |
| | Sterilization Method | | Ethylene Oxide | Same | Same | Ethylene Oxide | Same | same |
| | Single-Use? | | Yes | Same | Same | Same | Same | Same |
| | Hydrophilic Coating | | Yes | Yes | Yes | Yes | Yes | Yes |
The table below also provides a comparison to other legally marketed devices.
Note 1: Indicated for balloon dilatation of the stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion. Also, indicated for post-delivery stent expansion.
Note 2: Operates on the principle of hydraulic pressurization applied through an inflatable balloon attached to the distal end.
# Partners from Idea to Reality
Creganna. Registered in Oublin, Treland:- Reg No 324172
Creganna Medical Devices Inc.
Drectors - Isn Quinn, Enda Quinn, Padrair Collins, Helen Ryan, Benaud E. Lyons, Datiel G. Tully, George Altien-Daves
{4}------------------------------------------------
## Summary of Non-Clinical Testing:
The EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters were tested in accordance of FDA Guidance Document - Class II Special Controls Guidance Document for Certain Percutaneous Transluminal Coronary Angioplasty (PTCA) Catheters. The following testing was completed:
| Test | Method | Results |
|--------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Cytotoxicity | In accordance with ISO 10993 | PASS |
| Hemolysis | | |
| Platelet and Leukocyte Counts | | |
| Partial Thromboplastin Time (PTT) | | |
| Complement Activation | | |
| Thromboresistance | | |
| Bacterial Mutagenicity Test | | |
| Intracutaneous Reactivity | | |
| Materials Mediated Pyrogen | | |
| Sensitization | | |
| Acute Systemic Toxicity | | |
| USP Physico-chemical | | |
| Dimensional Verification | In accordance with applicable | PASS |
| Balloon Preparation, Deployment and Retraction | requirements of FDA Guidance<br>Document - Class II Special<br>Controls Guidance Document for<br>Certain Percutaneous Transluminal<br>Coronary Angioplasty (PTCA)<br>Catheters | |
| Balloon Rated Burst Pressure | | |
| Balloon Fatigue | | |
| Balloon Compliance (diameter vs. Pressure) | | |
| Balloon Inflation and Deflation Time | | |
| Catheter Bond Strength(s) | | |
| Tip Pull | | |
| Flexibility and Kink | | |
| Torque Strength | | |
| Radiopacity | | |
| Coating Integrity | | |
| Particulate Evaluation | | |
| Catheter Body Burst Pressure | | |
| *Catheter Body Burst Pressure (In-Stent) | | |
| *Balloon Rated Burst Pressure (In-Stent) | | |
| *Balloon Fatigue (repeat balloon inflations; In-stent) | | |
| Packaging Integrity Testing | In accordance with ISO 11607-1<br>and ISO 11607-2 | PASS |
| Sterilization | In accordance with ISO 11135-1<br>and ISO 10993-7 | PASS |
# Partners from Idea to Reality
Creganna. Registerad in Dublin, Ireland: - Reg No 324172
Creganna Medical Devices Inc.
Drectors: Jan Quinn, Ende Quinn, Padract Collins, Helmi Ryan, Bernard E. Lyons, Daniel G. Titly, George Airken-Davies
{5}------------------------------------------------
| Test | Method | Results |
|--------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Shelf Life | In accordance with applicable<br>requirements of FDA Guidance<br>Document - Class II Special<br>Controls Guidance Document for<br>Certain Percutaneous Transluminal<br>Coronary Angioplasty (PTCA)<br>Catheters | PASS |
| Animal Study | Comparative testing to currently<br>legally marketed devices in<br>compliance with 21 CFR 58 - GLP | PASS |
*This testing is not applicable to the EMPIRA Rx PTCA Dilatation Catheter because it is not intended for use In Stents.
### Conclusion:
The EMPIRA and EMPIRA NC Rx PTCA Catheters are substantially equivalent to a Standard PTCA Catheter as defined in 21 CFR 870.5100 and other legally marketed devices with respect to intended use, principle of operation, technological characteristics and safety features.
## Partners from Idea to Reality
Creganna. Registered in Dublin, Treland: - Reg No 324172 Creganna Medical Devices Inc.
Drectors: - Inn Quinn, Enda Quinn, Patrare Collins, Helen Ryan, Benard !!. I,yons, Damel G. Tolly, George Arken-Daves
{6}------------------------------------------------
Image /page/6/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal features a stylized eagle with three wing strokes, representing health, services, and human aspects. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
JUN 1 0 2011
Creganna Tactx Medical, Inc. c/o Mr. Dennis Wong Director of Quality 1353 Dell Avenue Campbell, CA 95008
Re: K110133
EMPIRA™ Rx PTCA Dilatation Catheter Trade/Device Name: EMPIRA™ NC Rx PTCA Dilatation Catheter Regulation Number: 21 CFR 870.5100 Regulation Name: Percutaneous Transluminal Coronary Angioplasty (PTCA) Catheter Regulatory Class: Class II Product Code: LOX Dated: May 23, 2011 Received: May 24, 2011
Dear Mr. Wong:
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. 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 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
{7}------------------------------------------------
Page 2 – Mr. Dennis Wong
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21.CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803). please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industrv/default.htm.
Sincerely yours,
Bram D. Zuckerman, M.D.
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health.
Enclosure
{8}------------------------------------------------
## 4. Indications for Use Statement 510(k) Number (if known): _ K |(0133
Device Name: _ EMPIRA and EMPIRA NC Rx PTCA Dilatation Catheters
Indications for Use:
"The EMPIRA Rx PTCA Catheter and EMPIRA NC Rx PTCA Dilatation Catheter are indicated for balloon dilatation of the stenotic portion of a coronary artery or bypass graft stenosis for the purpose of improving myocardial perfusion.
The EMPIRA NC Rx PTCA Dilatation Catheter is also indicated for post-delivery expansion of balloon expandable stents."
Prescription Use X (Part 21 CFR 801 Subpart D)
Over-The-Counter Use AND/OR (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Page of of
| Traditional 510(k) | 23 |
|--------------------|------------------------------------|
| | (Division Sign-Off) |
| | Division of Cardiovascular Devices |
| 510(k) Number | K110133 |
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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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?
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.
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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.
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What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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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.
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.