The X-VIEW, IMAGEN, a panoramic x-ray imaging system with cephalometric capabilities, is an extraoral source x-ray system intended for dental radiographic examination of the teeth, jaw, and oral structures, specifically for panoramic examinations and implantology and for TMI studies and cephalometry. It has the capability of using cone beam volumetric technology techniques to generate dento-maxillofacial 3D images. The device uses a cone shaped x-ray beam projected onto a flat panel detector, and the examined volume image is reconstructed to be viewed via 3D viewing stations. 2D Images are obtained using the standard narrow beam technique. The device is to be operated and used by dentists, radiologists and other legally qualified health care professionals.
Device Story
X-VIEW, IMAGEN is a dental CBCT system capturing 3D volumetric and 2D panoramic x-ray images. Input: cone-shaped x-ray beam projected onto a 5th Gen CMOS flat-panel detector (100 µm pixel pitch). Operation: device captures images; external PC with OnDemand3D software performs reconstruction, storage, and optimization. Used in dental clinics by dentists, radiologists, or orthodontists. Output: 3D volumetric renderings and 2D panoramic images viewed on 3D workstations. Clinical utility: aids in diagnosis, treatment planning, and implantology. Benefits: high-sensitivity sensor reduces patient radiation dose compared to standard technologies.
Clinical Evidence
Clinical evaluation report included acquisition of volumetric reconstructive images of a human subject. Bench testing included MTF (50-57% at 1.0 lp/mm), DQE (~70% at 0 lp/mm), and dynamic range (66-69 dB). Compliance with IEC 60601-1, 60601-1-3, 60601-2-63, 60601-1-2, 60601-1-6, and IEC 62366 confirmed.
Technological Characteristics
CBCT system; high-frequency x-ray generator; 5th Gen CMOS flat-panel detector (100 µm pixel pitch, 1300x1300 resolution, integrated Faraday cage). Connectivity: external PC via imaging software. Standards: IEC 60601-1, IEC 60601-1-3, IEC 60601-2-63, IEC 60601-1-2, IEC 60601-1-6, IEC 62366, EN 62304.
Indications for Use
Indicated for dental radiographic examination of teeth, jaw, and oral structures in patients requiring panoramic, cephalometric, or 3D CBCT imaging for implantology and TMJ studies. Operated by dentists, radiologists, or qualified healthcare professionals.
Regulatory Classification
Identification
A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 7, 2016
EDLEN IMAGING LLC % Mr. Nick Radachi General Manager 16441 North 91st Street, Suite 102 SCOTTSDALE AZ 85260
Re: K151137
Trade/Device Name: X-VIEW, IMAGEN Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: II Product Code: OAS, MUH Dated: April 21, 2016 Received: April 27, 2016
Dear Mr. Radachi:
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 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.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Robert Ocko
Robert Ochs. Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K151137
Device Name X-VIEW, IMAGEN
#### Indications for Use (Describe)
The X-VIEW, IMAGEN, a panoramic x-ray imaging system with cephalometric capabilities, is an extraoral source x-ray system intended for dental radiographic examination of the teeth, jaw, and oral structures, specifically for panoramic examinations and implantology and for TMI studies and cephalometry. It has the capability of using cone beam volumetric technology techniques to generate dento-maxillofacial 3D images. The device uses a cone shaped x-ray beam projected onto a flat panel detector, and the examined volume image is reconstructed to be viewed via 3D viewing stations. 2D Images are obtained using the standard narrow beam technique. The device is to be operated and used by dentists, radiologists and other legally qualified health care professionals.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <span> <b> Prescription Use (Part 21 CFR 801 Subpart D) </b> </span> |
|-----------------------------------------------------------------------------------------|
| <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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### 510 (k) Summary
This summary of safety and effectiveness information is submitted in accordance with the requirements of 21 CFR 892.1750.
| Submitter: | Edlen Imaging LLC<br>16441 N 91st Street Suite 102<br>Scottsdale, Arizona USA 85260 |
|----------------------|-------------------------------------------------------------------------------------|
| Contact Person: | Nick Radachi |
| | 480-452-2939 |
| | nick@edlenimaging.com |
| Date Prepared: | April 22, 2015 |
| Subject Device: | X-VIEW, IMAGEN |
| Common Name: | Dental CBCT |
| Classification Name: | Computed Tomography X-ray System |
| Class: | II |
| Product Code: | OAS, MUH |
| Predicate Device: | Planmeca ProMax |
| Classification Name: | Extraoral source x-ray system |
| Class: | II |
| 510K Number: | K060328 |
| Product Code: | MUH |
| Predicate Device: | Papaya 3D Plus |
| Classification Name: | X-ray, tomography, computed, dental |
| Class: | II |
| 510K Number: | K150354 |
| Product Code: | OAS |
| Regulation Number: | 21 CFR 892.1750 |
### Product Description
X-VIEW, IMAGEN is a 3-dimensional CBCT system that allows the execution of all commonly used x-rays in both dental and orthodontic fields (excluding intraoral radiographs) and also allows the acquisition of tomographic radiographs, or volumetric 3D. It uses CBCT (Cone Beam Computed Tomography) with a flat panel detector to provide high-definition volumetric images.
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Image /page/4/Figure/0 description: The image shows a technical drawing of a piece of equipment. The drawing includes two views: a side view showing a height of 2290, and a top view showing dimensions of 910 and 1070. The drawing appears to be for manufacturing or installation purposes, providing precise measurements for the equipment.
The flat panel detector operates via 5 th Generation X-ray CMOS technology. This sensor delivers three times more sensitivity and five times more signal-to-noise performance than other standard technologies of its kind, reducing patient dose in dynamic x-ray imaging modalities like computed tomography. It features a 1300 x 1300 pixel resolution, with 100 um pixel pitch, integrated memory buffer and integrated faraday cage. The detector captures Medium Field of View Cone Beam Computed Tomography images at 30 frames per second, and frame-based panoramic images at 300 frames per second.
All images are acquired by the device and processed via an external PC and imaging software. The device will utilize OnDemand3D (K113543) imaging software to store, manipulate and optimize the images acquired by the X-VIEW, IMAGEN. It is a complete imaging solution used by dentists, researchers and orthodontists. It provides a module-based software that allows DICOM data storage, and includes customizable tools to aid in diagnosis and treatment planning.
# Indication for Use
X-VIEW, IMAGEN is an extra-oral source x-ray system intended for dental radiographic examination of the teeth, jaw, and oral structures. It uses Cone Beam Computed Tomography and a flat panel detector to generate 3-dimensional volumetric images that are reconstructed via software. 2D panoramic images can be obtained using a standard narrow-beam technique. The device is to be operated and used by dentists, radiologists and other legally qualified health care professionals.
### Rationale for Substantial Equivalence
The X-VIEW, IMAGEN is defined as Substantially Equivalent (SE) to the ProMax3D, manufactured by Planmeca (060328) and the Papaya 3D Plus, manufactured by Genoray. X-VIEW, IMAGEN has the same indication for use as the predicate devices. It shares the same technological characteristics as the predicate devices. Minor technological differences do not raise any new questions regarding safety or effectiveness of the devices. X-VIEW, IMAGEN has the same indication for use as the predicate devices. lt performs the same functions based on well-known technology and shares the same technological
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characteristics as the predicate devices in identical environments. Minor technological differences do not raise any new questions regarding safety or effectiveness of the devices, so it is as safe and effective as the predicate devices.
| | Edlen Imaging<br>X-VIEW, IMAGEN<br>K151137/S001 | Planmeca<br>ProMax 3D<br>K060328 | Genoray<br>Papaya 3D Plus<br>K150354 |
|-----------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | X-VIEW, IMAGEN is<br>an extra-oral source<br>x-ray system<br>intended for dental<br>radiographic<br>examination of the<br>teeth, jaw, and oral<br>structures. It uses<br>Cone Beam<br>Computed<br>Tomography and a<br>flat panel detector to<br>generate 3-<br>dimensional<br>volumetric images<br>that are<br>reconstructed via<br>software. 2D<br>panoramic images<br>can be obtained<br>using a standard<br>narrow-beam<br>technique. The<br>device is to be<br>operated and used<br>by dentists,<br>radiologists and<br>other legally qualified<br>health care<br>professionals. | Planmeca Promax 3D is a<br>three dimensional Cone<br>Beam Computed<br>Tomographic (CBCT) x-<br>ray system, which is<br>intended for dental<br>radiographic examination<br>and diagnosis of diseases<br>of the teeth, jaw, and<br>oral structures. The<br>device uses cone shaped<br>x-ray beams projected on<br>to a flat panel detector,<br>and the examined<br>volume image is<br>reconstructed to be<br>viewed in 3D viewing<br>stations. The device is to<br>be operated and used by<br>dentists and other legally<br>qualified professionals | PAPAYA 3D Plus is a digital<br>panoramic, cephalometric and<br>tomographic extra-oral X-ray<br>system, indicated for use in: (i)<br>producing panoramic X-ray<br>images of the maxillofacial<br>area, for diagnostic<br>examination of dentition<br>(teeth), jaws and oral<br>structures; and (ii) producing<br>radiographs of jaws, parts of<br>the skull and carpus for the<br>purpose of cephalometric<br>examination, when equipped<br>with the cephalometric arm;<br>(iii) producing tomographic<br>images of the oral and<br>maxillofacial structure, for<br>diagnostic examination of<br>dentition(teeth), jaws ,oral<br>structures and some cranial<br>bones if equipped with CBCT<br>option. The system<br>accomplishes tomographic<br>exam by acquiring a 360-<br>degree rotational X-ray<br>sequence of images and<br>reconstructing a three-<br>dimensional matrix of the<br>examined volume, producing<br>two dimensional views of this<br>volume and displaying both<br>two dimensional images and<br>three-dimensional renderings |
| Generator/Tube<br>X-ray Generator | High Frequency | High Frequency | High Frequency |
The following table compares the X-VIEW, IMAGEN to the predicate devices:
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| Focal Spot Size (mm) | 0.5 | 0.5 | 0.5 |
|--------------------------|-------------------------------|-------------------------------|-----------------------------------------------------------|
| Tube Voltage (kV) | 61-85 | 54-84 | 60-90 |
| Tube Current (mA) | 4-10 | 1-16 | 4-12 |
| Device Details | | | |
| Power Supply Voltage (V) | 115 | 110-120 | 100-120 |
| Dimensions (mm) | 2230 x 1200 x 1200 | 2432 x 1000 x 1250 | 1832 x 1130 x 2383 |
| Weight (kg) | 150 | 113 | 160 |
| 2D/3D Exams | | | |
| 3D Technology | Cone-beam computed tomography | Cone-beam computed tomography | Cone-beam computed tomography |
| FOV (D x H) (mm) | 85 x 85 | 80 x 80 | 140 x 140 (max) |
| Exposure Time (sec) | 13.8 (PAN)<br>18 (CT) | 6 (PAN)<br>18 (CT) | 17 (PAN)<br>15 (CT)<br>12 (CEPH) |
| Sensor Technology | CMOS Flat-panel detector | CMOS Flat-panel detector | CMOS Flat-panel detector |
| Sensor Pixel Pitch (µm) | 100 x 100 | 127 x 127 | 75 x 75 (PAN/CEPH)<br>100 x 100 (CT) |
| Active Area (mm) | 130 x 130 | 130 x 130 | 152 x 6.45 (PAN)<br>130.2 x 128 (CT)<br>228 x 6.45 (CEPH) |
# Safety and Effectiveness Information
The device labeling contains operating instructions for safe and effective use of X-VIEW, IMAGEN. Final device validation and risk assessment has been conducted to identify any potential hazards that could cause an error or injury based on its use. Appropriate steps have been taken to control all identified risks.
# Safety, EMC and Performance Data Comparison to Predicate
The device has been tested for compliance to IEC 60601-1 Medical Electrical Equipment Part 1: General Requirements for Safety and its derivatives. Specifically:
- . IEC 60601-1: Medical electrical equipment Part 1: General requirements for basic safety and essential performance
- . IEC 60601-1-3: Medical electric equipment Part 1-3: General requirements for basic safety and essential performance – Collateral Standard: Radiation protection in diagnostic X-ray equipment
- . IEC 60601-2-63: Medical electrical equipment – Part 2-63: Particular requirements for the basic safety and essential performance of dental extra-oral x-ray equipment
- . IEC 60601-1-2: Medical electrical equipment Part 1: General requirements for basic safety and essential performance – Collateral standard: Electromagnetic compatibility – Requirements and tests
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- o IEC 60601-1-6: Medical electrical equipment – Part 1-6: General requirements for basic safety and essential performance – Collateral standard: Usability
IEC 62366: Medical devices – Application of usability engineering to medical devices
EN 62304: Medical device software – software life cycle processes
FDA Guidance "Guidance for the Submissions of 510(k)'s for Solid State X-Ray Imaging Devices" was performed for the detector of X-VIEW, IMAGEN. Detector test results are as follows: The MTF of the X-VIEW, IMAGEN detector shows the resolution of 50-57% at 1.0 lp/mm and the DQE of them shows the performance of about 70% at 0 lp/mm. The dynamic range of them shows 66-69 dB.
X-VIEW, IMAGEN was tested for safety and effectiveness related in a Clinical Evaluation report in which volumetric reconstructive images of a human subject were acquired.
All test results were satisfactory. The result of bench and clinical evaluation indicates that the new device is as safe and effective as the predicate devices.
### Conclusion
X-VIEW, IMAGEN performs the same functions in the same environment as the predicate device. It shares the same technology as the predicate device. It is based on wellknown technology. It is as safe and effective as the predicate devices. We believe it does not introduce any new potential safety risks and is substantially equivalent to the predicate devices.
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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.
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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.
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.