This device is indicated for diagnostic evaluation of patients who experience transient symptoms such as: Dizziness . . Palpitations Syncope . Chest pain .
Device Story
KOH Express AF is a compact cardiac event recorder for diagnostic evaluation of transient symptoms. Device uses a two-wire lead set for single-channel ECG acquisition. It features looping solid-state non-volatile memory, capturing ECG data automatically or via patient-activated 'RECORD' button. Device stores up to 10 minutes of ECG data across 16 events. When near a telephone, patient transmits stored ECG data to a monitoring center using FM-modulated acoustic tones. Device is intended for patient use in ambulatory settings. Healthcare providers receive transmitted ECG data to evaluate cardiac rhythms, aiding in diagnosis of arrhythmias including tachycardia, bradycardia, and atrial fibrillation. Benefits include remote monitoring of transient cardiac events.
Clinical Evidence
No clinical data provided. Evidence consists of bench testing, including software verification and validation (functional unit and system level), arrhythmia detection algorithm performance validation, and hardware verification. Device conforms to voluntary standards including ANSI/AAMI/ISO EC57:1998 (R) 2008 for rhythm/ST segment algorithms and ANSI/AAMI EC38:2007 for ambulatory ECG.
Technological Characteristics
Single-channel ECG recorder with 2-wire lead set and electrodes. Solid-state non-volatile 'Flash' memory. FM-modulated acoustic tone transmission. Compact form factor. Complies with IEC 60601-1 (safety), IEC 60601-1-2 (EMC), IEC 62304 (software lifecycle), and ISO 10993-1 (biocompatibility).
Indications for Use
Indicated for diagnostic evaluation of patients experiencing transient symptoms including dizziness, palpitations, syncope, or chest pain. Contraindicated for use with external cardiac defibrillators or high-frequency surgical equipment.
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.
Predicate Devices
King of Hearts Express +AF cardiac event recorder (K020825)
CG-6108 ACT-1L Continuous ECG Monitor and Arrhythmia Detector (K101639)
Submission Summary (Full Text)
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Special 510(k) for KOH Express AF cardiac event recorder Section 7: 510(k) Summary
# 510(k) Summary: KOH Express AF cardiac event recorder
### Introduction
This document contains the 510(k) summary for the KOH Express AF cardiac event recorder (a modified King of Hearts Express +AF cardiac event recorder). In order to ensure labeling clarity and software traceability, we have assigned a new name and Part Number (PN) to the modified device, as follows:
| Trade name of modified device: | KOH Express AF cardiac event recorder |
|--------------------------------|---------------------------------------|
| Internal Card Guard name | CG-2500 |
| Finished goods no.: | FG-00094 |
The content of this summary is based on the requirements of 21 CFR Section 807.92(c).
| Submitter | Card Guard Scientific Survival Ltd., | |
|-----------------------------------------|------------------------------------------------------------------------------------------------------|--------------------|
| Establishment<br>Registration<br>Number | 9681879 | |
| Address | 2 Pekeris St., P.O.B. 527, Rehovot, 76100, Israel | |
| Contact person: | Asher Kassel, Director of RA & QA, Card Guard Scientific Survival Ltd. | |
| Phone: | 972-8-9484010 (direct) | Fax: 972-8-9484044 |
| E-mail: | asherk@cardguard.com | |
| Date Prepared: | 16 June 2011 | |
| Primary predicate<br>device | King of Hearts Express +AF cardiac event recorder cleared in K020825<br>on April 5, 2002 | |
| Secondary<br>predicate device | CG-6108 ACT-1L Continuous ECG Monitor and Arrhythmia Detector<br>cleared in K101639 on June 25, 2010 | |
| Trade Name: | KOH Express AF cardiac event recorder | |
| Classification: | recorder, magnetic tape, medical | |
| Product Code: | DSH | |
| Regulation No: | 870.2800 | |
| Class: | II | |
### Device Description
The KOH Express AF cardiac event recorder ("KOH" or "KOH Express AF" in short) is designed for the diagnostic evaluation of transient cardiac symptoms. The KOH is capable of storing up to 10 minutes of ECG recordings in solid state non-volatile memory. The device uses a two-wire lead set for single channel ECG acquisition. Using looping memory, the device captures ECG data; both before and after the patient experiences a cardiac symptom through auto-recording, or manually after the patient presses the RECORD button. ECG events are transmitted later in the form of an FM-modulated acoustic tone, when the SEND button is depressed. The device is configured in a compact sized case.
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K111745 pg 2 of 3
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Special 510(k) for KOH Express AF cardiac event recorder Section 7: 510(k) Summary
### Indications for Use:
This device is indicated for diagnostic evaluation of patients who experience transient symptoms such as:
- Dizziness .
- . Palpitations
- Syncope .
- Chest pain .
### Contraindications for use:
### Warning:
This device is contraindicated for use in combination with external cardiac defibrillators or high frequency surgical equipment. Disconnect the patient leads from the electrodes prior to performing external defibrillation or using electrosurgical equipment.
There are no known safety hazards connected with the use and operation of a cardiac pacemaker or any electrical cardiac stimulator and the KOH Express AF cardiac event recorder.
### Summary of the Technological Characteristics / Principles of Operation
The principles of operation and inputs/outputs of the modified device (KOH Express AF cardiac event recorder) are the same or substantially equivalent to those of the predicate devices. The KOH Express AF cardiac event recorder device is comprised of an ECG sensor with a 2-wire ECG cable and electrodes. The sensor is carried by the patient and is snapped into two electrodes by using the ECG cable.
The KOH Express AF cardiac event recorder device records the ECG data and analyzes it for arrhythmias. The following arrhythmias are automatically detected by the KOH Express AF cardiac event recorder:
- 1. Tachycardia
- 2. Bradycardia
- 3. Atrial Fibrillation
The KOH Express AF device also supports manual recording of ECG data by the patient by means of pressing the "RECORD" button. The KOH Express AF stores the ECG data in a cyclic nonvolatile ("Flash") memory. When an event is automatically or manually triggered, the ECG data since the pre-event time until the post-event time is copied into the event buffer. The event buffer can hold up 16 events with total time of up to 10 minutes of ECG data.
When the user is near a telephone, the sensor can transmit to the Monitoring Center the ECG data of the events that are stored using an FM modulation acoustic protocol.
### Non-clinical performance data for the KOH Express AF device:
The modified KOH Express AF device has been subjected to extensive verification / validation testing. Final testing of the system included various performance tests and software validation tests designed to ensure that the device meets all of its functional and performance requirements and is fit for its intended use. The following list summarizes the testing performed on the device:
- Software Verification and Validation .
- Software Functional Unit Verification 0
- System Level Software Validation ಂ
- Arrhythmia Detection Algorithm Performance Validation 0
- Hardware Verification and Validation .
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K111745 pg 3 of 3
CARD GUARD
Special 510(k) for KOH Express AF cardiac event recorder Section 7: 510(k) Summary
### Voluntary Performance Standards:
This 510(k) submission was written in accordance with the FDA Guidance document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 11 2005". The design of the KOH Express AF device conforms to the following voluntary standards:
- 1. ANSI/AAMI/ISO EC57:1998 (R) 2008: Testing and Reporting Performance Results of Cardiac Rhythm and ST Segment Measurement Algorithms
- 2. ANSI/AAMI EC38:2007 Ambulatory Electrocardiograph
- 3. ISO 14971:2007: Medical devices application of risk management to medical devices;
- IEC 60601-1:1988, 200 edition, Part 1, plus A1:1991 and A2:1995: Medical electrical 4. equipment; Part 1: General requirements for safety
- IEC 60601-1-4:2000, plus Amendment 1:2004: Medical electrical equipment; Part 1: 4. 5. Collateral Std: Programmable electric medical systems
- IEC 62304:2006: Medical device software Software life cycle processes ട്.
- 7. ISO 15223:2007: Medical devices Symbols to be used with medical device labels, labeling and information to be supplied
- ISO 10993-1:2009, Biological evaluation of medical devices -- Part 1: Evaluation and ထဲ testing within a risk management process
- 9. IEC 60601-1-2:2007, Medical electrical equipment; Part 1: 2. Collateral Std.: EMC; requirements and tests
### Substantial Equivalence:
The KOH Express AF cardiac event recorder is substantially equivalent with respect to indications for use, technological characteristics and performance characteristics to the identified legally marketed predicate devices.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized depiction of an eagle or bird-like figure with three curved lines representing its wings or body. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Card Guard Scientific Survival, Ltd. c/o Mr. Clay Anselmo President and CEO Reglera, LLC 11925 W 1-70 Frontage Road North Wheat Ridge, CO 80033 USA
AUG - 1 2011
Re: K111745
Trade/Device Name: King of Hearts Express AF Cardiac Event Recorder Regulation Number: 21 CFR 870.2800 Regulation Name: Medical magnetic tape recorder Regulatory Class: Class II (two) Product Code: DSH Dated: July 25, 2011 Received: July 26, 2011
Dear Mr. Anselmo:
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.
{4}------------------------------------------------
Page 2 -- Mr. Clay Anselmo
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 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/CDRHQffices/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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Sincerely yours,
C. From 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
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K111745 pg lofl
# Indications for Use
510(k) Number (if known):
Device Name: KOH Express AF cardiac event recorder
# Indications for Use:
This device is indicated for diagnostic evaluation of patients who experience transient symptoms such as:
- . Dizziness
- Palpitations .
- . Syncope
- Chest pain .
## Contraindications for Use:
### Warning:
This device is contraindicated for use in combination with external cardiac defibrillators or high frequency surgical equipment. Disconnect the patient leads from the electrodes prior to performing external defibrillation or using electrosurgical equipment.
There are no known safety hazards connected with the use and operation of a cardiac pacemaker or any electrical cardiac stimulator and the King of Hearts Express AF cardiac event recorder.
Prescription Use __ X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (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) | |
|--------------------------------------------------------|-------------|
| (Division Sign-Off) Division of Cardiovascular Devices | Page 1 of 1 |
| 510(k) Number | K111745 |
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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 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.
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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.
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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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.