da Vinci Xi Surgical System, da Vinci X Surgical System
Applicant
Intuitive Surgical, Inc.
Product Code
NAY · Gastroenterology, Urology
Decision Date
Jul 19, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.1500
Device Class
Class 2
Attributes
Therapeutic, Real-World Evidence, Pediatric
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K173585 · Jul 19, 2018
da Vinci Xi Surgical System, da Vinci X Surgical System
Intuitive Surgical, Inc.
AHSQC (Abdominal Core Health Quality Collaborative) registry database; Published clinical literature
The sponsor used registry data to perform propensity-matched comparisons of robotic-assisted VHR against open and laparoscopic surgical cohorts to support a labeling expansion for VHR procedures. Literature review was used to provide additional context for complex laparoscopic VHR outcomes.
AHSQC Registry Analysis (Non-Complex and Complex VHR); Retrospective cohort study with propensity score matching; Follow-up/Duration: 30 days post-operative; Study Period: July 7, 2013 – January 1, 2017
Patients undergoing non-complex and complex ventral hernia repair (VHR); Sample Size: Varies by cohort (e.g., N=871 per arm for non-complex robotic vs open; N=615 per arm for non-complex robotic vs laparoscopic; N=297 per arm for complex robotic vs open)
Literature Review of Complex Laparoscopic VHR; Systematic literature review (6 comparative studies, 3 single-arm studies)
Patients undergoing complex laparoscopic ventral hernia repair; Sample Size: N=3 to 53 per study
Not applicable for this study
Complication rates, length of stay, operative time, mortality, reoperation rates
Indications for Use
The Intuitive Surgical Endoscopic Instrument Control System (da Vinci Xi Surgical System, Model: IS4000) is intended to assist in the accurate control of Intuitive Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, scissors, scalpels, forceps/pick-ups, needle holders, endoscopic retractors, electrocautery and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrocautery, suturing, and delivery and placement of microwave and cryogenic ablation probes and accessories, during urologic surgical procedures, general laparoscopic surgical procedures, gynecologic laparoscopic surgical procedures, general thoracoscopic surgical procedures and thoracoscopically-assisted cardiotomy procedures. The system can also be employed with adjunctive mediastinotomy to perform coronary anastomosis during cardiac revascularization. The system is indicated for adult and pediatric use. It is intended to be used by trained physicians in an operating room environment in accordance with the representative, specific procedures set forth in the Professional Instructions for Use. The Intuitive Surgical Endoscopic Instrument Control System (da Vinci X Surgical System, Model: IS4200) is intended to assist in the accurate control of Intuitive Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, scalpels, forceps/pick-ups, needle holders, endoscopic retractors, electrocautery and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrocautery, suturing, and delivery and placement of microwave and cryogenic ablation probes and accessories, during urologic surgical procedures, general laparoscopic surgical procedures, gynecologic laparoscopic surgical procedures, general thoracoscopic surgical procedures and thoracoscopically-assisted cardiotomy procedures. The system can also be employed with adjunctive mediastinotomy to perform coronary anastomosis during cardiac revascularization. The system is indicated for adult and pediatric use. It is intended to be used by trained physicians in an operating room environment in accordance with the representative, specific procedures set forth in the Professional Instructions for Use.
Device Story
Software-controlled, electro-mechanical surgical system; assists surgeons in minimally invasive procedures. Components: Surgeon Console, Patient Side Cart, Vision Side Cart; used with rigid endoscopes, EndoWrist instruments, and accessories. Surgeon operates console to control instruments for tissue manipulation (grasping, cutting, dissection, suturing, electrocautery). Provides enhanced visualization and precise instrument control in OR. Benefits: minimally invasive access, precise tissue handling. Used for urologic, general laparoscopic, gynecologic, and thoracoscopic procedures, including ventral hernia repair.
Clinical Evidence
Bench testing (animal studies) previously cleared under K131861. Clinical evidence provided via RWE from AHSQC registry (N=871 propensity-matched pairs for non-complex VHR; N=297 for complex VHR). Endpoints: length of stay, complications, readmission, reoperation, recurrence, mortality. Results showed robotic-assisted VHR had comparable 30-day outcomes to open and laparoscopic cohorts, with some shorter lengths of stay and lower clinic re-encounter rates in specific cohorts. No new safety/effectiveness issues identified.
Technological Characteristics
Software-controlled, electro-mechanical system. Components: Surgeon Console, Patient Side Cart, Vision Side Cart. Uses rigid endoscopes, EndoWrist instruments, and accessories. No changes to technological characteristics in this submission.
Indications for Use
Indicated for adult and pediatric patients undergoing urologic, general laparoscopic, gynecologic laparoscopic, general thoracoscopic, and thoracoscopically-assisted cardiotomy procedures; also for coronary anastomosis during cardiac revascularization via adjunctive mediastinotomy. No specific contraindications listed.
Regulatory Classification
Identification
An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.
Special Controls
*Classification* —(1)*Class II (special controls).* The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.
In combination with the general controls of the FD&C Act, the integrated operating table-electromechanical surgical system is subject to the following special controls:
1. (1) Premarket clinical performance testing, or a combination of premarket clinical performance testing and postmarket surveillance (in accordance with special control (2)), must include the following:
1. (i) Objective performance measures (e.g., rate and number of conversions to other surgical modalities, rate of device related adverse events (including tissue injury, hematoma, and increased blood loss), and their severity, cause, and outcomes) must be reported with relevant descriptive comparator performance measures.
2. (ii) The data must demonstrate the performance of the device for providing accurate and precise control of attached surgical instruments in range of clinical conditions relevant to the device's intended use.
3. (iii) The test dataset must include data collected from a patient population representative of the intended patient population under anticipated conditions of use.
2. (2) Data obtained from postmarket surveillance must demonstrate, in consideration of the premarket data obtained in accordance with special control (1), that the device performs in accordance with special control (1), unless FDA determines, based on the totality of the premarket data, that data from postmarket surveillance is not required to demonstrate that the device performs as intended. Such postmarket surveillance must be conducted per a protocol determined appropriate by FDA to demonstrate that the device performs as intended (in consideration of the premarket data obtained in accordance with special control (1)), and must include initiation, enrollment, and reporting requirements to ensure timely periodic updates to FDA on post-market surveillance progress and outcomes.
3. (3) Animal performance testing must evaluate the extent of port site trauma due to repositioning of table during surgical procedures when utilizing robotic minimally invasive and laparoscopic approaches
4. (4) The device manufacturer must develop, and update as necessary, a device-specific use training program that ensures proper device setup/use/shutdown, accurate control of instruments to perform the intended surgical procedures, troubleshooting and handling during unexpected events or emergencies, and safe practices to mitigate use error.
5. (5) The device manufacturer may only distribute the device to facilities that implement and maintain the device-specific use training program and ensure that users of the device have completed the device-specific use training program.
(6) Human factors assessment must demonstrate that the user can correctly use the device system across all intended use environments with the provided instructions and training materials, including patient access during normal operating conditions and emergency situations, and effects arising from the integrated nature of the operating table and robotic surgical arms.
(7) Labeling must include:
(i) A detailed summary of clinical performance testing conducted with the device, including study population, results, adverse events, and comparisons to any comparator groups identified;
(ii) A statement in the labeling that the safety and effectiveness for the representative specific procedures was based on evaluation of the device as a surgical tool and did not include evaluation of outcomes related to the treatment of the patient's underlying disease or condition, unless FDA determines that it can be removed or modified based on clinical performance data submitted to FDA;
(iii) Identification of compatible devices;
(iv) The list of surgical procedures for which the device has been determined to be safe with clinical justification;
(v) Reprocessing instructions for reusable components;
(vi) A shelf life for any sterile components;
(vii) A description of the device-specific use training program;
(viii) A statement that the device is only for distribution to facilities that implement and maintain the device-specific use training program and ensure that users of the device have completed the device-specific use training program; and
(ix) A summary of any completed postmarket surveillance data collected as required by special control (2), including updated labeling to accurately reflect outcomes observed in postmarket surveillance.
(8) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use and must include:
(i) Device motion accuracy and repeatability;
(ii) System testing;
(iii) Instrument reliability;
(iv) Crosstalk;
(v) Table motion control;
(vi) Thermal effects on tissue;
(vii) User-device interface performance;
(viii) Workspace access testing; and
(ix) Performance testing with compatible devices.
(9) Software verification, validation, and hazard analysis must be performed.
(10) Electromagnetic compatibility and electrical, thermal, and mechanical safety testing must be performed.
(11) Performance data must demonstrate the sterility of all patient-contacting device components.
(12) Performance data must support the shelf life of the device components provided sterile by demonstrating continued sterility and package integrity over the labeled shelf life.
(13) Performance data must validate the reprocessing instructions for the reusable components of the device.
(14) Performance data must demonstrate that all patient-contacting components of the device are biocompatible.
(15) Performance data must demonstrate that all patient-contacting components of the device are non-pyrogenic.
(16) The device manufacturer must submit a report to the FDA annually on the anniversary of initial marketing authorization for the device, until such time as FDA may terminate such reporting, which comprises the following information:
(i) Cumulative summary, by year, of complaints and adverse events since date of initial marketing authorization; and
(ii) Identification and rationale for changes made to the device, labeling, or device specific use training program, which did not require submission of a premarket notification during the reporting period.
Intuitive Surgical da Vinci Si Surgical System, Model IS3000 (K081137, K123463, K090993)
Submission Summary (Full Text)
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July 19, 2018
Intuitive Surgical, Inc. % Ms. Cindy Domecus Principal, Domecus Consulting Services, LLC/ISI Chief Regulatory Advisor Domecus Consulting Services LLC 1171 Barroilhet Drive Hillsborough, California 94010
Re: K173585
Trade/Device Name: da Vinci Xi Surgical System (Model IS4000), da Vinci X Surgical System (Model IS4200) Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: Class II Product Code: NAY Dated: June 18, 2018 Received: June 19, 2018
Dear Ms. Domecus:
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, 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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
# Sincerely, Jennifer R. Stevenson -23
For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
#### 510(k) Number (if known)
# K173585
#### Device Name
Intuitive Surgical® da Vinci® Xi Endoscopic Instrument Control System (da Vinci Xi System, Model IS4000) and Endoscopic Instruments and Accessories
#### Indications for Use (Describe)
The Intuitive Surgical Endoscopic Instrument Control System (da Vinci Xi Surgical System Model IS4000) is intended to assist in the accurate control of Intuitive Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, scalpels, forceps/pick-ups, needle holders, endoscopic retractors, electrocautery and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrocautery, suturing, and delivery and placement of microwave and cryogenic ablation probes and accessories, during urologic surgical procedures, general laparoscopic surgical procedures, gynecologic laparoscopic surgical procedures, general thoracoscopic surgical procedures and thoracoscopically- assisted cardiotomy procedures. The system can also be employed with adjunctive mediastinotomy to perform coronary anastomosis during cardiac revascularization. The system is indicated for adult and pediatric use. It is intended to be used by trained physicians in an operating room environment in accordance with the representative, specific procedures set forth in the Professional Instructions for Use.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|---------------------------------------------|
| ☑ Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW *
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
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# Indications for Use
#### 510(k) Number (if known)
## K173585
#### Device Name
Intuitive Surgical® da Vinci® X Endoscopic Instrument Control System (da Vinci X System, Model IS4200) and Endoscopic Instruments and Accessories
(da Vinci X System, Model IS4200) and Endoscopic Instruments and Access
#### Indications for Use (Describe)
The Intuitive Surgical Endoscopic Instrument Control System (da Vinci X Surgical System Model IS4200) is intended to assist in the accurate control of Intuitive Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, scalpels, forceps/pick-ups, needle holders, endoscopic retractors, electrocautery and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrocautery, suturing, and delivery and placement of microwave and cryogenic ablation probes and accessories, during urologic surgical procedures, general laparoscopic surgical procedures, gynecologic laparoscopic surgical procedures, general thoracoscopic surgical procedures and thoracoscopically- assisted cardiotomy procedures. The system can also be employed with adjunctive mediastinotomy to perform coronary anastomosis during cardiac revascularization. The system is indicated for adult and pediatric use. It is intended to be used by trained physicians in an operating room environment in accordance with the representative, specific procedures set forth in the Professional Instructions for Use.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|---------------------------------------------|
| ☑ Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW *
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
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# 510(k) Summary (21 CFR § 807.92(c))
#### I. SUBMITTER INFORMATION
| Submitter: | Intuitive Surgical, Inc.<br>1266 Kifer Road<br>Sunnyvale, CA 94086 |
|--------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Cindy Domecus, R.A.C. (US & EU)<br>Principal, Domecus Consulting Services LLC<br>Chief Regulatory Advisor to Intuitive Surgical<br>Telephone: 650.343.4813<br>Fax: 650.343.7822<br>Email: domecusconsulting@comcast.net |
| Date Summary Prepared: | July 19, 2018 |
| II. SUBJECT DEVICE INFORMATION | |
| Device Trade Name: | da Vinci® Xi and X Surgical Systems, Model IS4000 and Model IS4200 |
| Common Name: | System, Surgical, Computer Controlled Instrument |
| Classification Name: | Endoscope and Accessories (21 CFR §876.1500) |
| Regulatory Class: | II |
| Product Code: | NAY |
| Submission Type: | Traditional 510(k) |
#### III. PREDICATE DEVICE INFORMATION:
Predicate Device: Intuitive Surgical da Vinci Xi and X Surgical Systems, Models IS4000 and IS4200 (K131861, K152578, K153276, K161178, K170713, K171294, K171632) Intuitive Surgical da Vinci Si Surgical System, Model IS3000 (K081137, K123463, K090993)
#### IV. DEVICE DESCRIPTION:
This 510(k) is for a labeling modification only, to include "Ventral Hernia Repair" (VHR) procedures under the cleared "general laparoscopic surgical procedures" Indication for Use of the da Vinci Xi Surgical System, Model IS4000 and the da Vinci X Surgical System, Model IS4200. There are no changes to the technological characteristics of the cleared da Vinci Xi or X Surgical Systems (Models IS4000 and IS4200) proposed in this submission. The da Vinci Xi and X Surgical Systems, Models IS4000 and IS4200, are software-controlled, electro-mechanical systems designed for surgeons to perform minimally invasive surgery. The Model IS4000 and Model IS4200 Surgical Systems consist of a Surgeon Console, a Patient Side Cart (PSC), and a Vision Side Cart (VSC) and are used with an Endoscope, EndoWrist Instruments, and Accessories.
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#### V. INDICATIONS FOR USE
#### da Vinci Xi Surgical System
The Intuitive Surgical Endoscopic Instrument Control System (da Vinci Xi Surgical System, Model: IS4000) is intended to assist in the accurate control of Intuitive Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, scissors, scalpels, forceps/pick-ups, needle holders, endoscopic retractors, electrocautery and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrocautery, suturing, and delivery and placement of microwave and cryogenic ablation probes and accessories, during urologic surgical procedures, general laparoscopic surgical procedures, gynecologic laparoscopic surgical procedures, general thoracoscopic surgical procedures and thoracoscopically-assisted cardiotomy procedures. The system can also be employed with adjunctive mediastinotomy to perform coronary anastomosis during cardiac revascularization. The system is indicated for adult and pediatric use. It is intended to be used by trained physicians in an operating room environment in accordance with the representative, specific procedures set forth in the Professional Instructions for Use.
#### da Vinci X Surgical System
The Intuitive Surgical Endoscopic Instrument Control System (da Vinci X Surgical System, Model: IS4200) is intended to assist in the accurate control of Intuitive Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp endoscopic dissectors, scalpels, forceps/pick-ups, needle holders, endoscopic retractors, electrocautery and accessories for endoscopic manipulation of tissue, including grasping, cutting, blunt and sharp dissection, approximation, ligation, electrocautery, suturing, and delivery and placement of microwave and cryogenic ablation probes and accessories, during urologic surgical procedures, general laparoscopic surgical procedures, gynecologic laparoscopic surgical procedures, general thoracoscopic surgical procedures and thoracoscopically-assisted cardiotomy procedures. The system can also be employed with adjunctive mediastinotomy to perform coronary anastomosis during cardiac revascularization. The system is indicated for adult and pediatric use. It is intended to be used by trained physicians in an operating room environment in accordance with the representative, specific procedures set forth in the Professional Instructions for Use.
#### Precaution for Representative Uses
The demonstration of safety and effectiveness for the representative specific procedures was based on evaluation of the device as a surgical tool and did not include evaluation of outcomes related to the treatment of cancer (overall survival, disease-free survival, local recurrence) or treatment of the patient's underlying disease/condition. Device usage in all surgical procedures should be guided by the clinical judgment of an adequately trained surgeon.
#### VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
There are no changes to the technological characteristics of the cleared da Vinci Xi or X Surgical Systems (IS4000 and IS4200) proposed in this submission.
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#### VII. PERFORMANCE DATA
## Pre-Clinical Animal Study Data
This premarket notification is supported by animal study data including the results from six (6) evaluations in a total of 24 animals demonstrating use of da Vinci Xi Surgical System in the following procedures: Hysterectomy and Salpingectomy/Oophorectomy (Adnexectomy), Pyeloplasty, Nephrectomy, Nissen Fundoplication, Colectomy and Mitral Valve Repair. These data were initially submitted in support of clearance of the da Vinci Xi Surgical System (K131861).
## Real World Evidence from the AHSQC Registry Database
Real world evidence (RWE) from the AHSQC registry database support use of the da Vinci Xi and X Surgical Systems (Models IS4000 and IS4200) in "Ventral Hernia Repair" (VHR) procedures that fall under the cleared "general laparoscopic surgical procedures" Indication for Use. The RWE provided included propensity matched comparative data from robotic-assisted, open and laparoscopic cohorts in noncomplex VHR procedures. Non-complex VHR procedures were defined as ventral (e.g., incisional, epigastric, umbilical) hernia repairs without myofascial release. Additionally, propensity matched comparative data from robotic-assisted and open cohorts and unmatched comparative data from robotic-assisted and laparoscopic cohorts in complex VHR procedures were also included. Complex VHR procedures were defined as incisional hernia repair plus myofascial release. Longer term endpoints beyond 30 days, such as ventral hernia repair recurrence and chronic pain were not assessed in this analysis, and thus no claims regarding these clinical outcomes data should be inferred. The results demonstrated the safety and effectiveness of robotic-assisted ventral hernia repair procedures.
## Non-Complex VHR Procedures: Robotic-Assisted v. Open Surgery
Table 1 summarizes the results of the RWE that compared the results of non-complex robotic-assisted and open VHR procedures. The RWE included information comparing the use of the da Vinci System in non-complex Ventral Hernia Repair procedures with open surgery in the following key measures:
- Length of Stay: comparable lengths of hospital stay were reported for both the robotic-assisted and open cohorts.
- Intraoperative Complications: comparable intraoperative complication rates were reported for both the robotic-assisted and open cohorts.
- Transfusions: comparable intraoperative blood transfusion rates were reported in both the robotic-assisted and open cohorts.
- Postoperative Complications through 30 days: comparable postoperative complications through 30 days follow up were reported for both the robotic-assisted and open cohorts.
- Readmission Rates through 30 days: comparable readmission rates through 30 days follow up were reported for both the robotic-assisted and open cohorts.
- Re-encounter Rates through 30 days: a lower clinic re-encounter rate through 30 days follow up was reported for the robotic-assisted cohort (29%) as compared to the open cohort (41%). Comparable emergency room re-encounter rates through 30 days follow up were reported for both the roboticassisted and open cohorts.
- Reoperation Rates through 30 days: comparable reoperation rates were reported for both the robotic-assisted and open cohorts.
- Recurrence Rates through 30 days: comparable surgeon reported recurrence rates were reported for both the robotic-assisted and open cohorts through the 30-day postoperative period.
- Mortality through 30 days: comparable mortality rates were reported in both the robotic-assisted and open cohorts through the 30-day postoperative period.
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- Operative Time: longer operative times were reported for the robotic-assisted cohort as compared to the open cohort1.
| | | TABLE 1: Propensity Score Matched da Vinci and Open Non-Complex Ventral Hernia Repair (without | | | | | | |
|----------------------|--|-------------------------------------------------------------------------------------------------|--|--|--|--|--|--|
| myofascial release)^ | | | | | | | | |
| Outcome | Robotic-Assisted Cohort (N=871) | Open Cohort (N=871) |
|-------------------------------------|---------------------------------|---------------------|
| Patient Demographics | | |
| Mean age, y (± SD) | 56 ± 14 | 55 ± 14 |
| Female Gender, n (%) | 399 (46) | 361 (41) |
| Male Gender, n (%) | 472 (54) | 510 (59) |
| Mean BMI, kg/ m2 (± SD) | 33 ± 7 | 32 ± 7 |
| Length of Stay (days), mean ± SD | 2 ± 7 | 2 ± 14 |
| Intraoperative Complications, n (%) | 11 (1) | 5 (1) |
| Transfusions, n (%) | | |
| Intraoperative | 1 (< 1) | 0 (0) |
| Postoperative | 0 (0) | 2 (< 1) |
| Postoperative Complications, n (%)* | 64 (9) | 75 (11) |
| Readmission Rates, n (%)* | 14 (2) | 21 (3) |
| Reoperation Rates, n (%)* | 3 (< 1) | 8 (1) |
| Re-encounter Rates, n (%)* | | |
| Clinic | 207 (29) | 291 (41) |
| Emergency Room | 31 (4) | 20 (3) |
| Mortality, n (%)* | 1 (< 1) | 0 (0) |
| Operative Time, minutes, n (%) | | |
| 0 – 59 | 111 (13) | 432 (50) |
| 60 – 119 | 396 (45) | 304 (35) |
| 120 - 179 | 247 (28) | 86 (10) |
| 180 - 239 | 81 (9) | 28 (3) |
| 240+ | 36 (4) | 21 (2) |
| Conversion Rate, n (%) | 5 (1) | Not Applicable |
| Recurrence Rate, n (%)* | 5 (1) | 0 (0) |
^ Includes data from the AHSQC registry for procedures that occurred between July 7, 2017 . The total number of non-complex VHR procedures in the registry during this time period was 873 and 3,979 for the robotic-assisted and open cohorts, respectively. The total number in the propensity matched cohorts is 871 as noted in the column header of the above table.
#### Non-Complex VHR Procedures: Robotic-Assisted v. Laparoscopic Surgery
Table 2 summarizes the results of the RWE that compared the results of non-complex robotic-assisted and open VHR procedures. The RWE included information comparing the use of the da Vinci System in non-complex Ventral Hernia Repair procedures with laparoscopic surgery in the following key measures:
- Length of Stay: a shorter length of hospital stay was reported for the robotic-assisted cohort (2 days ± 7) as compared to the laparoscopic cohort (4 days ± 13).
- Intraoperative Complications: comparable intraoperative complication rates were reported for both the robotic-assisted and laparoscopic cohorts.
- Transfusions: comparable intraoperative blood transfusion rates were reported in both the robotic-assisted and laparoscopic cohorts.
<sup>4</sup> The longer operative time for the robotic-assisted cohort was not associated with increases in the complication, readmission, reoperation or mortality rates.
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- Conversion Rate: a comparable conversion rate was reported for the robotic-assisted cohort as compared to the laparoscopic cohort.
- Postoperative Complications through 30 days: comparable postoperative complications through 30 days follow up were reported for both the robotic-assisted and laparoscopic cohorts.
- Readmission Rates through 30 days: comparable readmission rates through 30 days follow up were reported for both the robotic-assisted and laparoscopic cohorts.
- Re-encounter Rates through 30 days: comparable clinic and emergency room re-encounter rates through 30 days follow up were reported for the robotic-assisted cohort as compared to the laparoscopic cohort.
- Reoperation Rates through 30 days: comparable reoperation rates were reported for both the robotic-assisted and laparoscopic cohorts.
- Recurrence Rates through 30 days: comparable surgeon reported recurrence rates were reported for both the robotic-assisted and laparoscopic cohorts through the 30-day postoperative period.
- Mortality through 30 days: comparable mortality rates were reported in both the robotic-assisted and laparoscopic cohorts through the 30-day postoperative period.
- Operative Time: longer operative times were reported for the robotic-assisted cohort as compared to the laparoscopic cohort2.
# TABLE 2: Propensity Score Matched da Vinci and Laparoscopic Non-Complex Ventral Hernia Repair (without myofascial release)^
| Outcome | Robotic-Assisted Cohort (N=615) | Laparoscopic Cohort (N=615) |
|-------------------------------------|---------------------------------|-----------------------------|
| Patient Demographics | | |
| Mean age, y (± SD) | 55 ± 14 | 56 ± 14 |
| Female Gender, n (%) | 305 (50) | 284 (46) |
| Male Gender, n (%) | 310 (50) | 331 (54) |
| Mean BMI, kg/ m² (± SD) | 33 ± 7 | 33 ± 8 |
| Length of Stay (days), mean ± SD | 2 ± 7 | 4 ± 13 |
| Intraoperative Complications, n (%) | 6 (1) | 8 (1) |
| Transfusions, n (%) | | |
| Intraoperative | 1 (< 1) | 0 (0) |
| Postoperative | 0 (0) | 1 (< 1) |
| Postoperative Complications, n (%)* | 55 (10) | 59 (11) |
| Readmission Rates, n (%)* | 8 (2) | 17 (3) |
| Reoperation Rates*, n (%) | 1 (<1) | 5 (1) |
| Re-encounter Rates*, (%) | | |
| Clinic | 153 (29) | 181 (35) |
| Emergency Room | 21 (4) | 18 (4) |
| Mortality, n (%)* | 1 (<1) | 0 (0) |
| Operative Time, minutes, n (%) | | |
| 0 – 59 | 86 (14) | 175 (28) |
| 60 - 119 | 265 (43) | 308 (50) |
| 120 - 179 | 175 (28) | 103 (17) |
| 180 - 239 | 60 (10) | 21 (3) |
| 240+ | 29 (5) | 8 (1) |
| Conversion Rate, n (%) | 3 (< 1) | 14 (2) |
| Recurrence Rate, n (%) | 4 (1) | 4 (1) |
<sup>2</sup> The longer operative time for the robotic-assisted cohort was not associated with increases in the complication, readmission, reoperation or mortality rates.
{9}------------------------------------------------
^ Includes data from the AHSQC registry for procedures that occurred between July 7, 2013 and January 1, 2017. The total number of non-complex VHR procedures in the registry during this time period was 873 and 1,961 for the robotic-assisted and laparoscopic cohorts, respectively. The total number in the propensity matched cohorts is 615 as noted in the column header of the above table.
#### Complex VHR Procedures: Robotic-Assisted v. Open Surgery
Table 3 summarizes the results of the RWE that compared the results of complex robotic-assisted and open VHR procedures. The RWE included information comparing the use of the da Vinci System in complex Ventral Hernia Repair procedures with open surgery in the following key measures:
- Length of Stay: a shorter length of hospital stay was reported in the robotic-assisted cohort (2 days ± 3) as compared to the open cohort (5 days ± 7).
- Intraoperative Complications: comparable intraoperative complication rates were reported for both the robotic-assisted and open cohorts.
- Transfusions: comparable intraoperative blood transfusion rates were reported in both the robotic-assisted and open cohorts.
- Postoperative Complications through 30 days: comparable postoperative complication rates through 30 days follow up were reported for both the robotic-assisted cohort and open cohort.
- Readmission Rates through 30 days: comparable readmission rates through 30 days follow up were reported for both the robotic-assisted and open cohorts.
- Re-encounter Rates through 30 days: a lower clinic re-encounter rate through 30 days follow up was reported for the robotic-assisted cohort (16%) as compared to the open cohort (27%). Comparable emergency room re-encounter rates through 30 days follow up were reported for both the roboticassisted and open cohorts.
- Reoperation Rates through 30 days: comparable reoperation rates were reported for both the robotic-assisted cohort and open cohorts.
- Recurrence Rates through 30 days: comparable surgeon reported recurrence rates were reported for both the robotic-assisted and open cohorts through the 30-day postoperative period.
- Mortality through 30 days: comparable mortality rates were reported in both the robotic-assisted and open cohorts through the 30-day postoperative period.
- Operative Time: longer operative times were reported for the robotic-assisted cohort as compared to the open cohort3.
## TABLE 3: Propensity Score Matched da Vinci and Open Complex Ventral Hernia Repair (with myofascial release)^
| Outcome | Robotic-Assisted Cohort (N=297) | Open Cohort (N=297) |
|-------------------------------------|---------------------------------|---------------------|
| Patient Demographics | | |
| Mean age, y (± SD) | 57 ± 13 | 57 ± 13 |
| Female Gender, n (%) | 169 (57) | 159 (54) |
| Male Gender, n (%) | 128 (43) | 138 (46) |
| Mean BMI, kg/ m² (± SD) | 33 ± 7 | 33 ± 7 |
| Length of Stay (days), mean ± SD | 2 ± 3 | 5 ± 7 |
| Intraoperative Complications, n (%) | 7 (2) | 9 (3) |
<sup>3</sup> The longer operative time for the robotic-assisted cohort was not associated with increases in the intraoperative complication, readmission, recurrence or mortality rates.
{10}------------------------------------------------
| Outcome | Robotic-Assisted Cohort (N=297) | Open Cohort (N=297) |
|-------------------------------------|---------------------------------|---------------------|
| Transfusions, n (%) | | |
| Intraoperative | 0 (0) | 0 (0) |
| Postoperative | 0 (0) | 1 (< 1) |
| Postoperative Complications, n (%)* | 66 (24) | 54 (20) |
| Readmission Rates, n (%)* | 19 (7) | 12 (4) |
| Reoperation Rates, n (%)* | 8 (3) | 4 (1) |
| Re-encounter Rates, n (%)* | | |
| Clinic | 44 (16) | 74 (27) |
| Emergency Room | 14 (5) | 12 (4) |
| Mortality, n (%)* | 1 (< 1) | 0 (0) |
| Operative Time, minutes, n (%) | | |
| 0 – 59 | 0 (0) | 8 (3) |
| 60 - 119 | 12 (4) | 84 (28) |
| 120 - 179 | 53 (18) | 106 (36) |
| 180 - 239 | 98 (33) | 48 (16) |
| 240+ | 134 (45) | 51 (17) |
| Conversion Rate, n (%) | 12 (4) | Not Applicable |
| Recurrence Rate, n (%)* | 4 (1) | 2 (1) |
^ Includes data from the AHSQC registry for procedures that occurred between July 7, 2013 and January 1, 2017. The total number of complex VHR procedures in the registry during this time period was 305 and 3,106 for the robotic-assisted and open cohorts, respectively. The total number in the propensity matched in the column header of the above table.
#### Complex VHR Procedures: Robotic-Assisted v. Laparoscopic Surgery
Table 4a provides a summary of the results of the RWE that compared the results of complex roboticassisted and laparoscopic VHR procedures and a summary of the published literature on complex laparoscopic VHR procedures. The limited sample size of the complex laparoscopic cohort in the AHSQC Registry Database precluded matching and a comparative analysis between these cohorts in the AHSQC Registry Database. Table 4b includes the detailed data from nine (9) publications reporting on complex laparoscopic VHR procedures. These publications were selected based on specific search criteria and filters and included 6 comparative studies (LOE 2 & 3b) and 3 single-arm studies (LOE 5). The results from the literature were not matched with the available robotic-assisted data from the AHSQC Registry Database and no comparative analysis was conducted. Clinical analysis of the da Vinci Surgical Systems in robotically-assisted complex ventral hernia repair procedures raises no new issues of safety or effectiveness for the proposed labeling modification and therefore is substantially equivalent.
## TABLE 4a: Unmatched** da Vinci and Laparoscopic Complex Ventral Hernia Repair from the AHSQC Registry Database (with myofascial release)
| Outcome | Robotic-Assisted<br>Cohort (N=305) | AHSQC Laparoscopic<br>Cohort (N=27) | Summary of Table 4b<br>Published Literature<br>Laparoscopic Cohort<br>(N = 3 - 53) |
|-------------------------------------|------------------------------------|-------------------------------------|------------------------------------------------------------------------------------|
| Patient Demographics | | | |
| Mean age, y (± SD) | 57 ± 13 | 58 ± 12 | 48.6 - 70 years |
| Female Gender, n (%) | 175 (57) | 14 (52) | 20 - 68% |
| Male Gender, n (%) | 130 (43) | 13 (48) | 32 - 80% |
| Mean BMI, kg/ m² (± SD) | 33 ± 7 | 34 ± 7 | 29.71 - 36 kg/ m² |
| Length of Stay (days), mean ± SD | 2 ± 3 | 4 ± 3 | 1 - 9.2 days |
| Intraoperative Complications, n (%) | 7 (2) | 3 (11) | 0 - 1.5% |
{11}------------------------------------------------
| Outcome | Robotic-Assisted<br>Cohort (N=305) | AHSQC Laparoscopic<br>Cohort (N=27) | Summary of Table 4b<br>Published Literature<br>Laparoscopic Cohort<br>(N = 3 - 53) |
|-------------------------------------|------------------------------------|-------------------------------------|------------------------------------------------------------------------------------|
| Transfusions, n (%) | | | Transfusions: 0 |
| Intraoperative | 0 (0) | 0 (0) | Estimated Blood Loss: |
| Postoperative | 0 (0) | 0 (0) | 51 – 91.7 ml |
| Postoperative Complications, n (%)* | 66 (24) | 3 (11) | 0 – 60% |
| Readmission Rates, n (%)* | 19 (7) | 2 (7) | 0 – 13% |
| Reoperation Rates, n (%)* | 8 (3) | 0 (0) | 0 – 20% |
| Re-encounter Rates, n (%)* | | | |
| Clinic | 48 (17) | 6 (22) | 0 |
| Emergency Room | 14 (5) | 4 (15) | |
| Mortality, n (%)* | 1 (< 1) | 0 (0) | 0 – 1.9% |
| Operative Time, minutes, n (%) | | | |
| 0 – 59 | 0 (0) | 0 (0) | 125 – 372 minutes |
| 60 – 119 | 12 (4) | 3 (11) | |
| 120 - 179 | 54 (18) | 8 (30) | |
| 180 - 239 | 100 (33) | 11 (41) | |
| 240+ | 139 (46) | 5 (19) | |
| Conversion Rate, n (%) | 12 (4) | 19 (70) | 0 |
| Recurrence Rate, n (%)* | 4 (1) | 0 (0) | Not Reported |
** The data presented in this table are not propensity score matched and include the results for all complex VHR cases in the AHSQC registry during the access dates between July 7, 2013 and January 1, 2017 for both the robotic-assisted and laparoscopic cohorts.
{12}------------------------------------------------
# K173585
| Author/Year | Lap/Endoscopic<br>Study Size (N) | Mean Age, y (±SD) | Gender (M/F) | Mean BMI,<br>kg/m² (SD) | Mean Operation Time<br>(minutes) (SD) | EBL (ml) or Tranfusions | Length of Stay,<br>days (SD) | Conversion<br>Rate (%) | Intraoperative<br>Complication<br>Rate (%) | Postoperative<br>Complication Rate (%) | Mortality<br>(in-hospital or<br>30 days) | Reoperation<br>Rate (30d) | Re-encounter<br>Rate (30d) | Readmission<br>Rate (30 d) | Recurrence<br>Rate (30d) |
|----------------|----------------------------------|-------------------|---------------------------------|-------------------------|---------------------------------------|---------------------------------------------------------|------------------------------|------------------------|--------------------------------------------|----------------------------------------------------------------------|------------------------------------------|---------------------------|------------------------------------|----------------------------|---------------------------------------------------|
| Azoury 2014 | 25 | 59 (11) | 32% / 68% | 35.4 (8) | 278 (73) | 63 (29) | 4 (2) | NR | NR | 20%<br>(Wound complications) | 0.0% | NR | NR | NR | NR |
| Belyanksy 2016 | 3 | 70 | 66.7% / 33.3% | 30.1 | 329 (OR time) | 91.7 | 4.7 | 0.0% | 0.0% | 33%<br>(1/3 subjects, prolonged<br>ileus prior to discharge) | 0.0% | 0.0% | 0.0% | 0.0% | NR |
| Belyanksy 2017 | 38 | NR | NR<br>Not stratified by cohort | NR | NR | NR | NR | NR | NR | 2.6% (1/38) | 0% | 0 (90d) | NR<br>(likely 0 from<br>inference) | 0 (90d) | NR |
| Daes 2014 | 5 | NR | NR<br>Not stratified by cohort | NR | NR | NR | 1 | NR | 0 | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | NR |
| Giurgius 2012 | 21 | 51 (13) | 48% / 52% | 36 (7) | 229 (57) | NR | 6.3 (3.6) | NR | NR | 19.0% | NR | NR | NR | NR | NR |
| Moazzez 2013 | 5 | 48.6 (7.9) | 80%/20% | 29.71 (3.4) | 372 (104) | 0 transfusions<br>(No significant bleeding<br>reported) | 9.2 (5.4) | 0.0% | 0.0% | 60% (3/5) subjects with<br>acute (<30d)/in-hospital<br>complications | 0.0% | 20% (1/5) | NR | NR | NR for 30 day<br>(60% with<br>median of<br>12.6m) |
| Muse 2018 | 53 | 54.4 | 40%/60% | 35.3 | 224 | NR | 5 | NR | NR | 13%<br>(Wound complications) | 1.9%<br>(Timeframe NR) | NR | NR | 13% | NR for 30 day<br>(15% overall) |
| Parker 2011 | 8 | 64.4 | 1.7:1<br>(reported as<br>ratio) | 30.5 | 226.8 | 51 mL<br>0 units transfused | 5.4 | NR | NR | 0%<br>(Wound complications,<br>timeframe NR) | 1.9% | NR | NR | 0% | NR |
| Schroeder 2013 | 43<br>(27 incisional) | 57 | 62.8% / 37.2% | NR | 125 | NR | 3.4 | NR | 1.5% | 7.0% | NR | NR | NR | NR | NR for 30 d<br>(0 overall<br>through f/u) |
|--|
NR = Not Reported
{13}------------------------------------------------
#### VIII. CONCLUSION
Based on the information provided in this premarket notification, the inclusion of "Ventral Hernia Repair" procedures under the da Vinci Xi and X Surgical Systems (Models IS4000 and IS4200) previously cleared "general laparoscopic surgical procedure" Indication for Use is substantially equivalent to the predicate devices. The basis of this substantial equivalence determination was an assessment of the immediate post-operative outcomes through 30 days comparing the robotic-assisted surgery ventral hernia repair versus laparoscopic ventral hernia repair.
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
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.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.