The MobCardio System is intended to be used by trained operators under the direct supervision of a licensed healthcare practitioner on adult populations. The device is designed to collect, transmit, and display resting 12 lead EKG data. The clinical and diagnostic evaluation of acquired EKG signals should be made by a physician, who has experience or is specialized in Cardiology. No clinical interpretation of EKG is provided.
Device Story
System comprises EKG acquisition module, 12-lead patient cable, medical-grade laptop, and software. Inputs: electrical signals from patient via disposable electrodes. Operation: module connects to PC via USB; software collects, transmits, and displays resting 12-lead EKG data. Used in healthcare facilities/hospitals by trained operators. Output: visual display and printout of EKG waveforms. No automated interpretation provided; physician performs clinical/diagnostic evaluation. Benefits: enables acquisition and review of resting EKG data for clinical decision-making.
Clinical Evidence
Bench testing only. Device components underwent safety and functional performance testing. No clinical data provided.
Technological Characteristics
PC-USB based EKG acquisition module; 12-lead patient cable; medical-grade laptop. Standards: IEC 60601-1:2006, IEC 60601-1-2:2007, IEC 60601-2-25:1999, IEC 60601-2-51:2005, AAMI EC11:2007. Type BF applied part. Connectivity: USB 1.0 or higher. Software-based display and printing.
Indications for Use
Indicated for adult patients. Used by trained operators under direct supervision of licensed healthcare practitioner for collection, transmission, and display of resting 12-lead EKG data. No contraindications specified.
Regulatory Classification
Identification
An electrocardiograph is a device used to process the electrical signal transmitted through two or more electrocardiograph electrodes and to produce a visual display of the electrical signal produced by the heart.
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# V. 510(k) Summary
This 510(k) summary is submitted in accordance to the requirements of 21 CFR 807.92.
The assigned 510(k) number is:
## General Information
| Criteria | Information |
|------------------|---------------------------------------------------------------------------|
| Trade Name | MobCardio System |
| Model Name | MHC2011.1.0 |
| Common Name | Electrocardiography |
| Classification | Class II |
| 510(k) Submitter | MobHealth Corporation<br>5227 Village Circle Dr.<br>Temple City, CA 91780 |
| Contact Person | Patricia Lin, Director of Technology Marketing<br>patricial@mobhealth.com |
| Date Prepared | May 12th, 2011 |
# Substantially Equivalent Devices
| Manufacturer | Substantially Equivalent Device | 510(k) |
|--------------------------|-------------------------------------------|---------|
| Kardiosis Ltd. | ARS-EKG 12K<br>Electrocardiography System | K914206 |
| ET Medical Devices Spa | Cardioline AR600 | K051534 |
| Midmark Diagnostic Group | Midmark IQecg | K103640 |
# Predicate Device Comparison Summary:
The MobCardio System has in many instances, identical or nearly identical technological characteristics to the substantially equivalent devices. See device comparison table below:
| Device name | ARS-EKG 12K<br>ECG System<br>(K914206) | Cardioline<br>AR 600<br>(K051534) | Midmark<br>IQecg<br>(K103640) | MobCardio<br>System |
|----------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|
| Intended use | Acquisition and<br>display of resting<br>12-lead ECG; no<br>interpretation | Acquisition,<br>display, and<br>interpretation of<br>resting 12-lead ECG | Acquisition,<br>display, and<br>interpretation of<br>resting 12-lead<br>ECG | Acquisition and<br>display of resting<br>12-lead ECG; no<br>interpretation |
| Indications<br>for use | Prescription use by<br>trained physicians<br>and/or medical<br>personnel only | Prescription use by<br>trained physicians<br>and/or medical<br>personnel only | Prescription use by<br>trained physicians<br>and/or medical<br>personnel only | Prescription use by<br>trained physicians<br>and/or medical<br>personnel only |
| Target<br>population | Adult | For non interpretive<br>applications, no<br>limitations to age,<br>sex and race | Adult and pediatric | Adult |
| Device name | ARS-EKG 12K<br>ECG System<br>(K914206) | Cardioline<br>AR 600<br>(K051534) | Midmark<br>IQecg<br>(K103640) | MobCardio<br>System |
| Anatomical<br>sites | External surface of<br>chest and limbs | External surface of<br>chest and limbs | External surface of<br>chest and limbs | External surface of<br>chest and limbs |
| Where used | Healthcare<br>facilities/Hospitals | Healthcare<br>facilities/Hospitals | Healthcare<br>facilities/Hospitals | Healthcare<br>facilities/Hospitals |
| Energy used<br>and/or<br>delivered | PC powered (PC<br>EKG add-on card) | AC Main/External<br>battery power | External battery<br>power/PC-USB<br>powered | USB powered/AC<br>adapter and<br>rechargeable<br>battery for medical<br>grade laptop |
| Design | EKG data<br>acquisition module<br>(PC-ISA) with<br>software for data<br>processing,<br>display, storage,<br>and print | EKG data<br>acquisition, storage<br>and print device<br>(infrared serial)<br>with software for<br>interpretation,<br>display, storage, and<br>print | EKG data<br>acquisition module<br>(USB/RS232) with<br>software for data<br>processing,<br>interpretation,<br>display, storage,<br>and print | EKG data<br>acquisition module<br>(PC-USB) AND<br>medical grade PC<br>with software for<br>data processing,<br>display, storage,<br>and print |
| Standards<br>met | • IEC 60601-<br>1:1990<br>• AAMI<br>EC11:1982<br>• AAMI<br>ES1:1985 | • IEC 60601-<br>1:2006<br>• IEC 60601-1-<br>2:1993<br>• IEC 60601-2-<br>25:1995<br>• IEC 60601-2-<br>51:2003 | • IEC 60601-<br>1:2006<br>• IEC 60601-1-<br>2:2007<br>• IEC 60601-2-<br>25:1999<br>• AAMI<br>EC11:2007 | • IEC 60601-<br>1:2006<br>• IEC 60601-1-<br>2:2007<br>• IEC 60601-2-<br>25:1999<br>• IEC 60601-2-<br>51:2005<br>• AAMI<br>EC11:2007 |
| Bio-<br>compatibility | Not applicable | Not applicable | Not applicable | Not applicable |
| Sterility | Not applicable | Not applicable | Not applicable | Not applicable |
| Electrical/Co<br>mpatibility<br>w/environme<br>nt & other<br>devices | Passed EMC test -<br>met IEC 60601-1,<br>AAMI ES11 and<br>ES1 requirements | Passed EMC and<br>LVD tests - met<br>IEC 60601-1, IEC<br>60601-1-2, IEC<br>60601-2-25<br>requirements | Passed EMC and<br>LVD tests - met<br>IEC 60601-1, IEC<br>60601-1-2, IEC<br>60601-2-25<br>requirements | Passed EMC and<br>LVD tests - met<br>IEC 60601-1, IEC<br>60601-1-2, IEC<br>60601-2-25<br>requirements |
| Mechanical<br>safety | ECG amplifiers<br>(e.g. input<br>protection against<br>defibrillation<br>shocks, type BF<br>applied part) | ECG amplifiers<br>(e.g. input<br>protection against<br>defibrillation<br>shocks, type CF<br>applied part) | ECG amplifiers<br>(e.g. input<br>protection against<br>defibrillation<br>shocks, type CF<br>applied part) | ECG amplifiers<br>(e.g. input<br>protection against<br>defibrillation<br>shocks, type BF<br>applied part) |
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..............................................................................................................................................................................
# Summary of Substantial Equivalence
After comparing the indications for use, technology, and performance specifications of the listed predicate devices and the MobCardio System, we have concluded that the proposed device does not raise any new safety or effectiveness issues and is substantially equivalent to the listed predicate devices.
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### Device Description
The MobCardio System is comprised of an EKG acquisition module (connected via a PC-USB cable), a 12-lead EKG patient cable, a medical grade laptop, and the user software. The device is used to collect, transmit, and display resting 12-lead EKG data using FDA cleared disposable EKG electrodes and manufacturer supplied 12-lead EKG patient cable.
The user software is pre-installed for the user and provides necessary menus and user interfaces for displaying and printing the acquired 12-lead EKG data.
The MobCardio System is compatible with any desktop or notebook computer with a suitable USB port (1.0 or above) and Windows operating system. While we offer the EKG acquisition module and the medical grade laptop as a system, the user has the option to use a personal computer that fits the requirements listed in the device user manual. Without being connected to a computer, the EKG data acquired will not be displayed and no EKG prints out can be obtained.
#### Indications for Use
The MobCardio System is intended to be used by trained operators under the direct supervision of a licensed healthcare practitioner on adult populations. The device is designed to collect, transmit, and display resting 12 lead EKG data. The clinical and diagnostic evaluation of acquired EKG signals should be made by a physician, who has experience or is specialized in Cardiology. No clinical interpretation of EKG is provided.
#### Functional and Safety Testing
Device components underwent safety and bench testing on both hardware and software and demonstrated acceptable functional and performance results. No safety and effectiveness issues were raised.
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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a stylized eagle or bird symbol, 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
NOV 1 7 2011
MobHealth Corporation c/o Mr. Mark Job Reviewer Regulatory Technology Services LLC 1394 25th Street NW Buffalo, MN 53313
Re: K113234
> Trade/Device Name: MobCardio System Regulatory Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: II (two) Product Code: DPS Dated: November 1, 2011 Received: November 2, 2011
Dear Mr. Job:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined honice 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 (Act (Act to not require approval of a proval 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 misbillions and adulteration.
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. Mark Job
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/CDRHOffices/ucm115809.html 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.hum.
Sincerely yours,
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation -Center for Devices and Radiological Health
Enclosure
{5}------------------------------------------------
#### IV. Indications for Use Statement
510(k) Number (if known):
Device Name: MobCardio System
#### Indications For Use:
The MobCardio System is intended to be used by trained operators under the direct supervision of a licensed healthcare practitioner on adult populations. The device is designed to collect, transmit, and display resting 12 lead EKG data. The clinical and diagnostic evaluation of acquired EKG signals should be made by a physician, who has experience or is specialized in Cardiology. No clinical interpretation of EKG is provided.
K113234
Prescription Use X (21 CFR Part 801 Subpart D) AND/OR
Over the Counter Use (21 CFR Part 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 d Cardiovasc I Devices 5 ! Onk) Nümber
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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.
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.
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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.