K173953 · Shanghai United Imaging Healthcare Co., Ltd. · KPR · Jan 26, 2018 · Radiology
Device Facts
Record ID
K173953
Device Name
uDR 780i
Applicant
Shanghai United Imaging Healthcare Co., Ltd.
Product Code
KPR · Radiology
Decision Date
Jan 26, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1680
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The uDR 780i digital medical x-ray system is intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other anatomic sites. Applications can be performed with the subject sitting, standing, or lying in the prone or supine position. Not for mammography.
Device Story
uDR 780i is a digital radiography (DR) system for diagnostic imaging of adult and pediatric patients. System components include tube ceiling suspension, collimator, bucky wall stand, elevating table, high voltage generator, wireless flat panel detectors (amorphous silicon/cesium iodide), and acquisition workstation. Operated by qualified doctors or technicians in clinical settings. Device captures X-ray signals, converts them to digital images via flat panel detectors, and processes them for display, review, and storage. Images are transferred via DICOM network. System features auto-tracking for table height, longitudinal tube travel, and tube rotation to maintain source-image distance and centering. Output assists clinicians in diagnostic decision-making by providing radiographic images of various anatomical sites.
Clinical Evidence
No clinical trials were conducted. Evidence consists of bench testing and a review of sample clinical images by a board-certified radiologist, who confirmed the images were of diagnostic quality.
Technological Characteristics
Stationary X-ray system; 65kW/80kW generator; amorphous silicon (a-Si) flat panel detector with cesium iodide (CsI) scintillator (125μm pixel size); 150kV max tube voltage; DICOM 3.0 connectivity; motorized auto-tracking for tube/detector alignment. Complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-54, and IEC 60601-2-28. Biocompatibility per ISO 10993-5 and ISO 10993-10.
Indications for Use
Indicated for adult and pediatric patients requiring diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other anatomic sites. Not for mammography.
Regulatory Classification
Identification
A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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Shanghai United Imaging Healthcare Co., Ltd. % Xin GAO Regulatory Affairs Specialist No. 2258 Chengbei Rd., Jiading Industrial District Shanghai. 201807 CHINA
January 26, 2018
# Re: K173953
Trade/Device Name: uDR 780i Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: II Product Code: KPR Dated: December 25, 2017 Received: December 27, 2017
Dear Xin GAO:
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 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.
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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.
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,
Michael D.'Hara
For
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) K173953
Device Name uDR 780i
#### Indications for Use (Describe)
The uDR 780i digital medical x-ray system is intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other anatomic sites. Applications can be performed with the subject sitting, standing, or lying in the prone or supine position. Not for mammography.
Type of Use (Select one or both, as applicable)
| <div> <span style="font-size:10pt">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </div> |
|--------------------------------------------------------------------------------------------------------|
| <div> <span style="font-size:10pt">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
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Image /page/3/Picture/1 description: The image shows the logo for United Imaging. The logo consists of the word "UNITED" stacked on top of the word "IMAGING", both in a bold, sans-serif font. To the right of the text is a stylized "U" shape, also in a bold, sans-serif font, with a horizontal line running through the middle of the "U".
# 510 (k) SUMMARY
- 1. Date of Preparation: December 25, 2017
#### 2. Sponsor Identification
Shanghai United Imaging Healthcare Co..Ltd. No.2258 Chengbei Rd. Jiading District, 201807, Shanghai, China
Establishment Registration Number: Not yet registered or the Number
Contact Person: Xin Gao Tel: +86-021-67076888-5386 Fax: +86-021-67076889 Email: xin.gao@united-imaging.com
#### 3. Identification of Proposed Device
Trade Name: uDR 780i Common Name: Digital Medical X-ray System Model(s): uDR 780i
# Regulatory Information
Classification Name: Stationary X-Ray System Classification: II Product Code: KPR Regulation Number: 21 CFR 892. 1680 Review Panel: Radiology
### Intended Use Statement:
The uDR 780i digital medical X-ray system is intended for use by a qualified/trained doctor or technician on both adult and pediatric subjects for taking diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other anatomic sites. Applications can be performed with the subject sitting, standing, or lying in the prone or supine position. Not for mammography.
### Device Description:
The uDR 780i is a digital radiography (DR) system that is designed to provide radiography examinations of sitting, standing or lying patients. It consists of the following components: Tube Ceiling Suspension with tube and collimator, Bucky Wall Stand, Elevating Table, High Voltage Generator, wireless flat panel detectors and an acquisition workstation. The system generates images which can be transferred through DICOM network for printing, review and storage.
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Image /page/4/Picture/1 description: The image contains the logo for United Imaging. The text "UNITED IMAGING" is displayed in bold, sans-serif font. To the right of the text is a stylized "U" symbol, which is also in a dark color. The logo appears to be clean and modern in design.
#### Identification of Predicate Device(s) 4.
### Predicate Device
510(k) Number: K133782 Device Name: NOVA FA DR System
Regulatory Information Classification Name: Stationary X-Ray System Classification: II Product Code: KPR Regulation Number: 21 CFR 892. 1680 Review Panel: Radiology
#### 5. Non-Clinical Test Conclusion
Non clinical tests were conducted to verify that the proposed device met all design specifications as it is Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
- > ES60601-1:2005(R)2012+A1:2012+C1:2009/(R)2012+A2:2010/(R)2012 Medical electrical equipment Part 1: General requirements for basic safety and essential performance.
- > IEC 60601-1-2 Edition 4.0 2014-02, Medical Electrical Equipment - Part 1-2: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility - Requirements And Tests.
- > IEC 60601-1-3 Edition 2.1 2013-04. Medical Electrical Equipment - Part 1-3: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Radiation Protection In Diagnostic X-Ray Equipment.
- A IEC 60601-2-54 Edition1.1 2015-04 Medical electrical equipment-Part 2-54: Particular requirements for the basic safety and essential performance of X-ray equipment for radiography and radioscopy.
- > IEC 60601-2-28 Edition 2.0 2010-03 Medical electrical equipment -Part 2-28: Particular requirements for the basic safety and essential performance of X-ray tube assemblies for medical diagnosis
#### 6. Clinical Test Conclusion
Sample clinical images accompanied by dose information and information detailing acquisition protocols and parameters were reviewed by a board certified radiologist with a statement indicating that images are of diagnostic quality.
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Image /page/5/Picture/1 description: The image contains the logo for United Imaging. The logo consists of the word "UNITED" stacked on top of the word "IMAGING", both in a bold, sans-serif font. To the right of the words is a stylized "U" symbol, which is also in a bold, sans-serif font and is colored in a dark teal.
# 7. Substantially Equivalent (SE) Comparison
Table 1 Comparison of Technology Characteristics
| Item | Proposed Device<br>uDR 780i | Predicate Device<br>NOVA FA DR System | Remark |
|---------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|
| General | | | |
| Product Code | KPR | KPR | Same |
| Regulation No. | 892.1680 | 896.1680 | Same |
| Class | II | II | Same |
| Intended Use | The uDR 780i digital medical<br>X-ray system is intended for<br>use by a qualified/trained<br>doctor or technician on both<br>adult and pediatric subjects for<br>taking diagnostic radiographic<br>exposures of the skull, spinal<br>column, chest, abdomen,<br>extremities, and other anatomic<br>sites. Applications can be<br>performed with the subject<br>sitting, standing, or lying in the<br>prone or supine position. Not<br>for mammography. | Sedecal "NOVA FA DR<br>System" is intended for use<br>by qualified/trained doctor or<br>technician on both adult and<br>pediatric subjects for taking<br>diagnostic radiographic<br>exposures of the skull, spinal<br>column, chest, abdomen,<br>extremities, and other body<br>parts. Applications can be<br>performed with the patient<br>sitting, standing, or lying in<br>the prone or supine position.<br>Not for mammography. | Same |
| Specifications | | | |
| High Voltage Generator | | | |
| Rated<br>Power/kW | 65kW/80kW | 50kW/65kW/80kW | Note1 |
| Max. tube<br>Voltage(kV) | 150kV | 150kV | Same |
| Shortest<br>exposure time | 1ms | 1ms | Same |
| X-Ray Tube Assemble | | | |
| Focus Nominal<br>Value | 0.6/1.2mm | 0.6/1.2mm | Same |
| Maximum peak<br>voltage | 150kV | 150kV | Same |
| Anode Heat<br>Content | 300kHU/400kHU | 300kHU/400kHU | Same |
| Anode Target<br>Angle | 12° | 12° | Same |
| X-ray tube<br>assembly Heat<br>content | 900kJ (1.3MHU)<br>1111kJ (1.5MHU) | 900kJ(1.3MHU)<br>950kJ(1.33MHU) | Note2 |
| Flat Panel Detector | | | |
| Configuration of | Battery or AC operated | Battery or AC operated | Same |
| Item | Proposed Device<br>uDR 780i | Predicate Device<br>NOVA FA DR System | Remark |
| Digital Panels | Semiconductor material<br>Amorphous silicon (a-Si) | Semiconductor material<br>Amorphous silicon (a-Si) | Same |
| Scintillator<br>Cesium iodide<br>(CsI) | Scintillator Cesium iodide<br>(CsI) | Scintillator Cesium iodide<br>(CsI) | Same |
| specifications | 3320x3408 125μm | 3320x3408 125μm | Same |
| Effective<br>radiographic<br>size | 41.5cm x 42.6cm | 41.5cm x 42.6cm | Same |
| Collimator | | | |
| Inherent<br>filtration | 1mm Al | 1mm Al | Same |
| Copper prefilter | without filter,<br>0.1 mm,<br>0.2 mm,<br>0.3 mm; | without filter,<br>0.1 mm,<br>0.2 mm,<br>0.3 mm; | Same |
| Display | | | |
| Specification | 24inch, 1200x1920 | 19inch, 1024 x 1280 | Note3 |
| Standards | | | |
| DICOM | DICOM3 | DICOM3 | Same |
| Power Source | AC Line, Various voltages<br>available | AC Line, Various voltages<br>available | Same |
| Patient Table | | | |
| Motorized<br>vertical travel | 38.2cm | 40cm | Note4 |
| X-ray<br>absorption | ≤0.8mmAl | ≤1mmAl | Note5 |
| Tabletop travel | Longitudinal: ±40cm<br>Transverse:±12.5cm | Longitudinal:+50cm, -60cm<br>Transverse:±12cm | Note6 |
| Max. patient<br>weight | 225kg | 350kg | Note7 |
| Detector travel<br>range | ≤67cm | ≤60cm | Note8 |
| Auto tracking<br>for adjusting the<br>table height is<br>maintained | Yes, X-ray tube follows table<br>height adjustment; source-<br>image distance is maintained. | Yes, X-ray tube follows table<br>height adjustment; source-<br>image distance is maintained. | Same |
| Auto tracking<br>for longitudinal<br>tube travel | Yes, detector follows tube<br>movement; centering<br>maintained | Yes, detector follows tube<br>movement; centering<br>maintained | Same |
| Item | Proposed Device<br>uDR 780i | Predicate Device<br>NOVA FA DR System | Remark |
| Auto tracking<br>for tube rotation | Yes, detector follows tube<br>movement; centering<br>maintained. | Yes, detector follows tube<br>movement; centering<br>maintained. | Same |
| Software<br>function | | | |
| Import/Export<br>images | Yes | Yes | Same |
| Image Search<br>available | Yes | Yes | Same |
| Image Viewing | Yes | Yes | Same |
| Image<br>measurement | Yes | Yes | Same |
| Image<br>Annotation | Yes | Yes | Same |
| Image<br>Operations | Yes | Yes | Same |
| Generator | Yes | Yes | Same |
| Raw image Data<br>processing | Yes | Yes | Same |
| Post image data<br>processing | Yes | Yes | Same |
| Safety | | | |
| Electrical Safety | AAMI ANSI ES60601-<br>1:C1:2009/(R)2012 and<br>A2:2010/(R)2012<br>(Consolidated Text) Medical<br>electrical equipment - Part 1:<br>General requirements for basic<br>safety and essential<br>performance (IEC 60601-<br>1:2005, MOD) | Comply with IEC60601-1 | Same |
| EMC | Comply with IEC60601-1-2 | Comply with IEC60601-1-2 | Same |
| Biocompatibility | Patient Contact Materials were<br>tested and demonstrated no<br>cytotoxicity (ISO 10993-5), no<br>evidence for irritation and<br>sensitization (ISO 10993-10). | Comply with ISO10993-5,<br>ISO10993-10 | Same |
| Justification | | | |
| Note ID | Justification | | |
| Note 1 | The proposed device does not have rated power of 50kW compare with<br>the predicate device. However, the all clinical application can be achieved<br>under 65kW and 80kW, which the predicate device also has. Therefore,<br>this difference does not affect safety and effectiveness in digital | | |
| Item | Proposed Device | Predicate Device | Remark |
| | uDR 780i | NOVA FA DR System | |
| | radiography. | | |
| Note 2 | The heat content of tube assembly determines the continuous exposure time but not affect the image quality, which does not affect safety and effectiveness in digital radiography. | | |
| Note 3 | The display with big size is user friendly for the users, which does not affect the safety and effectiveness in digital radiography. | | |
| Note 4 | The small difference in table height affects the user experience but not the clinical application. So it is not affect safety and effectiveness. | | |
| Note 5 | The x-ray absorption of the table top should as small as possible, it will optimize the image quality. So it is not affect safety and effectiveness. | | |
| Note6 | The top travel range affect the user experience but not the clinical application, and the travel range of uDR 780i is enough for the radiography on adults. So it is not affect safety and effectiveness. | | |
| Note7 | The Max. Patient weight (225kg) is enough to satisfy the radiography in most patients, which is not affect the safety and effectiveness. | | |
| Note8 | The detector travel range affect the user experience, the grater the range the better user experience, which is not affect safety and effectiveness. | | |
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Image /page/6/Picture/1 description: The image contains the logo for United Imaging. The text "UNITED IMAGING" is stacked on top of each other and is in a bold, sans-serif font. To the right of the text is a stylized "U" shape that is divided into three sections. The logo is in a dark teal color.
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Image /page/7/Picture/1 description: The image contains the logo for United Imaging. The logo consists of the words "UNITED IMAGING" stacked on top of each other in a bold, sans-serif font. To the right of the text is a stylized "U" symbol, which is also in a bold, sans-serif font and is a dark teal color.
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Image /page/8/Picture/1 description: The image contains the logo for United Imaging. The words "UNITED" and "IMAGING" are stacked on top of each other in a bold, sans-serif font. To the right of the text is a stylized "U" shape, which is also in a bold font. The logo is simple and modern, and the use of a bold font gives it a strong and confident look.
## Substantially Equivalent (SE) Conclusion
Based on the comparison and analysis above, the proposed device has same intended use, similar performance, equivalence safety and effeteness as the predicate device. The differences above between the proposed device and predicate device do not affect the intended use, technology characteristics, safety and effectiveness. And no issues are raised regarding to safety and effectiveness.
The proposed device is determined to be Substantially Equivalent (SE) to the predicate device.
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1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
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Reading rule for every project: how many summaries do you read in full?
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Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
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Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click "Show Chart" and segment by Regulation Number. 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.