The SmartLinx Vitals Plus Patient Monitoring System is intended for monitoring and alarming of physiologic parameters, including non-invasive blood pressure (systolic, diastolic, and mean arterial pressure), pulse rate, functional arterial oxygen saturation (SpO2), and temperature, on adult, pediatric, and neonatal patients in hospital environments when used by clinical physicians or appropriate medical staff under the direction of physicians.
Device Story
SmartLinx Vitals Plus Patient Monitoring System is a mobile medical application running on the SmartLinx Neuron 2 platform; integrates NIBP, SpO2, and temperature modules. Inputs: NIBP (SunTech Advantage A+), SpO2 (Masimo or Nellcor), and temperature (Exergen or Covidien) sensors. Operation: Neuron 2 platform collects, processes, and displays vital signs; evaluates values against user-defined limits to trigger visual/audible alarms via the Alarm Hub. Used in hospital environments by clinical staff. Output: Real-time physiological data, alarm notifications, and optional Early Warning Scoring System (EWSS) aggregate scores. Benefits: Enables active patient monitoring, trending, and timely clinical intervention.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, software verification and validation, and conformance to FDA-recognized consensus standards (e.g., IEC 60601-1, IEC 80601-2-30, ISO 80601-2-61).
Technological Characteristics
Mobile platform (Neuron 2) running Windows; integrates NIBP (oscillometric), SpO2 (serial digital interface), and temperature (predictive/direct) modules. Connectivity: Wired/integrated modules. Power: Li-ion batteries or AC supply. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-8, IEC 60601-2-49, ISO 80601-2-61, IEC 62304, IEC 62366-1.
Indications for Use
Indicated for monitoring and alarming of NIBP, pulse rate, SpO2, and temperature in adult, pediatric, and neonatal patients in hospital settings. Prescription use only.
Regulatory Classification
Identification
A cardiac monitor (including cardiotachometer and rate alarm) is a device used to measure the heart rate from an analog signal produced by an electrocardiograph, vectorcardiograph, or blood pressure monitor. This device may sound an alarm when the heart rate falls outside preset upper and lower limits.
Predicate Devices
SmartLinx Vitals Plus Patient Monitoring System (K180734)
Submission Summary (Full Text)
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## 510(k) Summary of Safety and Effectiveness
## per 21 CFR §807.92
### 1. Administrative Information
| Submitter's<br>Name and<br>Address | Capsule Technologie, SAS<br>76-78 avenue de France CS21416<br>75644 Paris Cedex 13 |
|-------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Name<br>and<br>Information | Maylin Truesdell<br>Senior Manager, Regulatory Affairs<br>Capsule Tech, Inc<br>300 Brickstone Square, Suite 203<br>Andover, MA 01810<br>Phone: 978-482-2365<br>e-mail: mtruesde@capsuletech.com |
| Date Prepare | December 20, 2018 |
| Device Trade<br>Name | SmartLinx Vitals Plus Patient Monitoring System |
| Common<br>Name | Physiological or Vital Signs Monitor, Patient Monitor |
| Class and<br>Classification<br>Name | Class II, 21 CFR Part 870.2300 - Cardiac monitor<br>(including cardiotachometer and rate alarm) |
| Product Code | MWI, DXN, DQA, FLL |
| Predicate<br>Devices | SmartLinx Vitals Plus Patient Monitoring System<br>K180734<br>Cleared August 8, 2018 |
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### 2. Device Description
The predicate device, SmartLinx Vitals Plus Patient Monitoring System, was cleared in K180734. The SmartLinx Vitals Plus Patient Monitoring System operates on top of the SmartLinx Medical Device Information System (MDIS) to present patient information to the clinical user for active monitoring purposes at the point of care.
#### SmartLinx Vitals Plus Application o
The SmartLinx Vitals Plus Application is a mobile medical application operating on the SmartLinx Neuron 2 Mobile Platform. The SmartLinx Vitals Plus Application controls the externally integrated vital signs modules and the Alarm Hub through interfaces on the SmartLinx Neuron 2 Mobile Platform, and presents patient information to the user for active monitoring purposes at the point of care:
- Supported physiological parameters: NIBP (systolic, diastolic, mean arterial > pressure (MAP), Pulse Rate, SpO2, and Temperature
- > Intervals mode for Intervals Mode for NIBP (Automatic repetition of NIBP measurements)
- Physiological alarms for NIBP (Sys, Dia, MAP), Pulse Rate, SpO2, and > Temperature; visibly annunciated on the Neuron 2; and audibly annunciated on the SmartLinx Vitals Plus Alarm Hub
- > Continuous Sp02 monitoring with pulse tone pitches that vary according to oxygen saturation, SpO2 alarm delay, and SpO2 sensor off alarm
- > Temperature measurements via the Exergen TAT-5000S or Covidien FILAC 3000 thermometer
- o SmartLinx Vitals Plus NIBP Module
The SmartLinx Vitals Plus NIBP Module incorporates the SunTech Medical Advantage A+ OEM NIBP module and associated blood pressure cuffs and hoses, it measures systolic, diastolic and mean arterial blood pressures (MAP), and pulse rates for adult, pediatric and neonatal patients, including Intervals Mode for NIBP (Automatic repetition of NIBP measurements). The module is controlled by the SmartLinx Vitals Plus Application to manage the inflation and deflation of blood pressure cuffs, and to measure blood pressures and pulse rates.
Masimo uSp02 Pulse Oximetry Cable o
The Masimo uSpO2 Pulse Oximetry Cable is a patient cable with an integrated MS-2000 series circuit board contained in an enclosure that connects to Masimo pulse oximetry sensors and provides functional oxygen saturation (SpO2) and pulse rate and other information via a serial digital interface. The SmartLinx Vitals Plus Application controls the operation of the uSpO2 to measure SpO2 and pulse rate in adult, pediatric, and neonatal patients.
- Nellcor Sp02 Pulse Oximetry Module o
The Nellcor SpO2 Oximetry Module is a module that connects with the Nellcor SpO2 Pulse Oximetry sensors and provides functional oxygen saturation
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(SpO2) and pulse rate and other information via a serial digital interface. The SmartLinx Vitals Plus Application measure SpO2 and pulse rate in adult, pediatric, and neonatal patients.
#### Exergen TAT-5000S Thermometer o
The Exergen TAT-5000S is designed for accurate, noninvasive temperature assessment by scanning the temporal artery. The thermometer operates independently, but communicates its results to the SmartLinx Vitals Plus Application for display and monitoring.
#### Covidien FILAC 3000 Thermometer o
The Covidien FILAC 3000 acquires temperature measurements through the application of a probe at Oral, Axillary, and Rectal sites. The typical measurement mode of the thermometer is a Predictive Mode that returns a measurement in 6-10. 8-12, and 10-14 seconds respectively for Oral, Axillary, and Rectal sites. The thermometer also has a Direct Mode (simulating a standard thermometer) and a Cold Mode (a predictive mode for patients at a lower temperature).
o SmartLinx Vitals Plus Alarm Hub
The Alarm Hub is used with the optional Advanced Monitoring license for the Vitals Plus Application. The Alarm Hub offers a primary speaker for alarm annunciations (with failover to a backup speaker), watchdog functionality, and a USB hub for expansion. The Vitals Plus App running on the Neuron 2 alone evaluates current vital signs values versus upper and lower limits in order to evaluate alarm conditions. When an alarm condition is found to be true, a visual alarm signal is annunciated within the app user interface and on the Neuron LED, and the app sends a command to the directly attached Alarm Hub to make an audible annunciation so long as the condition is true or until the clinical user acknowledges the alarm by touching the screen.
#### SmartLinx Neuron 2 Mobile Platform o
The SmartLinx Neuron 2 Mobile Platform is a mobile computer utilizing industry standard PC architecture and the Microsoft Windows operating system that is used within the SmartLinx Medical Device Information System and IEC 60601-1 Medical Electrical Systems for collection, transmission, conversion, storage and display of medical device data. The Neuron 2 runs different SmartLinx applications depending upon the care area and desired functionality, including SmartLinx Vitals Stream, SmartLinx Chart Xpress, and SmartLinx Vitals Plus. The Neuron 2 is utilized as part of an active monitoring system when running the SmartLinx Vitals Plus Application.
SmartLinx Early Warning Scoring System o
The SmartLinx Early Warning Scoring System (EWSS) is an optional software component that integrates with the SmartLinx Vitals Plus Application and runs on the SmartLinx Neuron 2 Mobile Platform. SmartLinx EWSS performs a medical calculation that aids clinical users in patient assessment and condition trending. This calculation, which would otherwise be completed manually, produces an aggregate patient score from a set of sub-scores determined from the values of measured vital signs and manually entered nursing observations. The resulting aggregate score is displayed on the Vitals Plus Application, and may be communicated to other
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healthcare information systems. EWSS requires the clinical user to attend the patient in order to function. There is no automatic or continuous scoring. The specific scoring method used within SmartLinx EWSS to calculate a patient's score is determined by the customer.
The current SmartLinx Vitals Plus Patient Monitoring System consists of the following components:
- · SmartLinx Vitals Plus Application
- · SmartLinx Vitals Plus NIBP Module
- · Masimo SET uSpO2 Pulse Oximetry Cable
- · Nellcor SpO2 Pulse Oximetry Module
- · Exergen TAT-5000S Thermometer
- · Covidien FILAC 3000 Thermometer
- · SmartLinx Vitals Plus Alarm Hub
- · SmartLinx Neuron 2 Mobile Platform
- · SmartLinx Early Warning Scoring System
The proposed SmartLinx SmartLinx Vitals Plus Patient Monitoring System is similar to the predicate SmartLinx Vitals Plus Patient Monitoring System, cleared in K180734. The change being proposed is to integrate the SmartLinx Vitals Plus NIBP Module, SmartLinx Vitals Plus Alarm Hub and Nellcor SpO2 Pulse Oximetry Module into one module or backpack configuration; and the alternative Masimo SpO2 pulse oximetry cable will continue to be connected to the same place as with the predicate. There is no change to the performance or functionality of the device. There is no change to the indications for use or intended use.
The proposed SmartLinx Vitals Plus Patient Monitoring System consists of the following components:
- · Monitoring Module (with swappable Nellcor SpO2 module)
- · SmartLinx Vitals Plus Application
- · Masimo SET uSpO2 Pulse Oximetry Cable
- · Exergen TAT-5000S Thermometer
- · Covidien FILAC 3000 Thermometer
- · SmartLinx Neuron 2 Mobile Platform
- · SmartLinx Early Warning Scoring System
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#### 3. Intended Use
The SmartLinx Vitals Plus Patient Monitoring System is intended for monitoring and alarming of physiologic parameters, including non-invasive blood pressure (systolic, diastolic, and mean arterial pressure), pulse rate, functional arterial oxygen saturation (SpO2), and temperature, on adult, pediatric, and neonatal patients in hospital environments when used by clinical physicians or appropriate medical staff under the direction of physicians.
The intended use of the proposed SmartLinx Vitals Plus Patient Monitoring System is identical to the intended use for the predicate SmartLinx Vitals Plus Patient Monitoring System, which serves as the primary predicate device.
#### 4. Comparison of Similarities and Differences
As previously, the proposed SmartLinx Vitals Plus Patient Monitoring System is similar to the predicate SmartLinx Vitals Plus Patient Monitoring System, cleared in K180734. The change being proposed is to integrate the SmartLinx Vitals Plus NIBP Module, SmartLinx Vitals Plus Alarm Hub and Nellcor SpO2 Pulse Oximetry Module into one module or backpack configuration; and the alternative Masimo SpO2 pulse oximetry cable will continue to be connected to the same place as with the predicate. There is no change to the performance or functionality of the device. There is no change to the indications for use or intended use.
The proposed SmartLinx Vitals Plus Patient Monitoring System consists of the following components:
- · Monitoring Module (with swappable Nellcor SpO2 module)
- · SmartLinx Vitals Plus Application
- · Masimo SET uSpO2 Pulse Oximetry Cable
- · Exergen TAT-5000S Thermometer
- · Covidien FILAC 3000 Thermometer
- · SmartLinx Neuron 2 Mobile Platform
- · SmartLinx Early Warning Scoring System
Table 1 shows the similarities and differences between the proposed and predicate SmartLinx Vitals Plus Patient Monitoring System.
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| Attribute | Proposed SmartLinx Vitals Plus | Predicate SmartLinx Vitals Plus<br>LABELING | Similarities & Differences |
|--------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use/<br>Indications for Use | The SmartLinx Vitals Plus Patient Monitoring<br>System is intended for monitoring and alarming of<br>physiologic parameters, including non-invasive<br>blood pressure (systolic, diastolic, and mean arterial<br>pressure), pulse rate, functional arterial oxygen<br>saturation (SpO2), and temperature, on adult,<br>pediatric, and neonatal patients in hospital<br>environments when used by clinical physicians or<br>appropriate medical staff under the direction of<br>physicians. | The SmartLinx Vitals Plus Patient Monitoring<br>System is intended for monitoring and alarming of<br>physiologic parameters, including non-invasive<br>blood pressure (systolic, diastolic, and mean arterial<br>pressure), pulse rate, functional arterial oxygen<br>saturation (SpO2), and temperature, on adult,<br>pediatric, and neonatal patients in hospital<br>environments when used by clinical physicians or<br>appropriate medical staff under the direction of<br>physicians. | No change |
| | | TECHNOLOGICAL CHARACTERISTICS | |
| Design | Intervals Mode for NIBP (Automatic repetition of<br>NIBP measurements): SmartLinx Vitals Plus NIBP<br>Module using SunTech Advantage A+ oscillometric<br>OEM NIBP module with intervals at 1, 2, 3, 4, 5, 10,<br>15, 30, 60, 90, 120 and 240 minutes | Intervals Mode for NIBP (Automatic repetition of<br>NIBP measurements): SmartLinx Vitals Plus NIBP<br>Module using SunTech Advantage A+ oscillometric<br>OEM NIBP module with intervals at 1, 2, 3, 4, 5, 10,<br>15, 30, 60, 90, 120 and 240 minutes | No change |
| | SpO2 Measurement: Masimo or Nellcor<br>Continuous SpO2 Monitoring: Pulse tone pitch xxx,<br>sensor off alarm | SpO2 Measurement: Masimo or Nellcor<br>Continuous SpO2 Monitoring: Pulse tone pitch xxx,<br>sensor off alarm | No change |
| | SpO2 alarm delay: Selectable time (secs) for<br>Masimo, SatSeconds for Nellcor | SpO2 alarm delay: Selectable time (secs) for<br>Masimo, SatSeconds for Nellcor | No change |
| | Alarms: Configuration, annunciation, and<br>acknowledgement of physiological (Sys, Dia, MAP,<br>Pulse Rate, SpO2, and TEMP) and technical alarms | Alarms: Configuration, annunciation, and<br>acknowledgement of physiological (Sys, Dia, MAP,<br>Pulse Rate, SpO2, and TEMP) and technical alarms | No change |
| | Probe TEMP Measurement: FILAC 3000<br>Thermometer (oral / axillary / rectal) | Probe TEMP Measurement: FILAC 3000<br>Thermometer (oral / axillary / rectal) | No change |
| Attribute | Proposed SmartLinx Vitals Plus | Predicate SmartLinx Vitals Plus<br>TECHNOLOGICAL<br>CHARACTERISTICS (continued) | Similarities & Differences |
| Applied Part Materials | NIBP: SunTech Durable One-Piece, Disposable, and Vinyl blood pressure cuffs and hoses, and GE CRITIKON SOFT-CUF cuffs | NIBP: SunTech Durable One-Piece, Disposable, and Vinyl blood pressure cuffs and hoses, and GE CRITIKON SOFT-CUF cuffs | No change |
| | SpO2: Masimo LNCS family of reusable and disposable SpO2 sensors | SpO2: Masimo LNCS family of reusable and disposable SpO2 sensors | No change |
| | | Masimo® or Nellcor® SpO2 algorithms (optional)—both sensors and signal processing | No change |
| | | TEMP: Exergen disposable probe covers and sheaths | No change |
| | | Probe TEMP Measurement: Covidien<br>FILAC probe covers | No change |
| Configuration | NIBP Monitoring Module, “backpack” configuration, with embedded NIBP Monitoring and Alarm Hub | NIBP Module, Alarm Hub Module, and Nellcor module (provided separately) | Proposed device has a configuration change where one monitoring module houses both the NIBP module and Alarm Hub, and includes a Nellcor module that can be swappable into the monitoring module. |
| Energy Source | Main Battery Neuron 2: Lithium-Ion 3S1P 2600 mAh or 3050 mAh | Main Battery Neuron 2: Lithium-Ion 3S1P 2600 mAh or 3050 mAh | No change |
| | Extended Battery Neuron 2: Lithium-Ion 3S2P 5200 mAh or 6100 mAh (1 or 2 depending on use of Dual Battery Dock) | Extended Battery Neuron 2: Lithium-Ion 3S2P 5200 mAh or 6100 mAh (1 or 2 depending on use of Dual Battery Dock) | No change |
| | Exergen: 9V alkaline | Exergen: 9V alkaline | No change |
| | Power Supply: 100-240 V AC, 2.0-1.0 A, 50-60 Hz, 65 W max, Class I | Power Supply: 100-240 V AC, 2.0-1.0 A, 50-60 Hz, 65 W max, Class I | No change |
able 1: Comparison of Similarities and Difference
# K183638
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{7}------------------------------------------------
The discussion of similarities and differences is structured in accordance with FDA's guidance document "The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications Guidance for Industry and Food and Drug Administration Staff", July 28, 2014.
Decision 1: Is the predicate device legally marketed?
YES: the predicate device SmartLinx Vitals Plus Patient Monitoring System is legally marketed and was cleared in K180734.
Decision 2: Do the devices have the same intended use?
YES: as shown in Table 1 above, the intended use/indication statement for the proposed SmartLinx Vitals Plus Patient Monitoring System is identical to the indication statement for the predicate, primary predicate device SmartLinx Vitals Plus Patient Monitoring System.
Decision 3: Do the devices have the same technological characteristics?
NO: the proposed SmartLinx Vitals Plus Patient Monitoring System does not have the same technological characteristics as the predicate SmartLinx Vitals Plus Patient Monitoring System as follows:
The proposed device has a confiquration change where one monitoring module now houses both the NIBP module and Alarm Hub and includes a Nellcor module that can be swappable into the monitoring module. Whereas, the predicate offered these modules separately.
Decision 4: Do the different technological characteristics of the device raise different questions of safety and effectiveness?
NO: the design changes as described in this Special 510(k) resulting in the proposed SmartLinx Vitals Plus Patient Monitoring System do not raise different questions of safety and effectiveness compared to the predicate SmartLinx Vitals Plus Patient Monitoring System. The change does not impact the performance and functionality of the device.
Decision 5a: Are the proposed scientific methods for evaluating new/different characteristics' effects on safety and effectiveness acceptable?
YES: the safety and effectiveness of the proposed SmartLinx Vitals Plus Patient Monitoring System have been confirmed through performance testing, i.e., bench testing, testing to FDA recognized consensus standards, and software verification and validation testing.
Decision 5b: Are the proposed scientific methods for evaluating new/different characteristics' effects on safety and effectiveness acceptable?
YES: The proposed scientific methods for evaluating new/different characteristics' effects on safety and effectiveness are drawn from a robust Design Control, Risk Management, Software Development programs, and testing to FDA recognized consensus standards.
{8}------------------------------------------------
Decision 6: Do the data demonstrate substantial equivalence?
YES: The results from performance testing of safety and effectiveness demonstrate that the proposed SmartLinx Vitals Plus Patient Monitoring System is substantially equivalent to the predicate SmartLinx Vitals Plus Patient Monitoring System.
#### 5. Performance Testing
Performance testing assures that essential device characteristics have been appropriately implemented to provide safe and effective function and performance for the device's intended use. The performance testing consists of hardware and software verification and validation, as well as testing to FDA recognized consensus standards.
{9}------------------------------------------------
The SmartLinx Vitals Plus Patient Monitoring System conforms with FDA recognized consensus standards listed in the Table 2 below.
### Table 2: Applicable Recognized Consensus Standards
| Category | Standard Reference | Standards Title |
|-----------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Electromagnetic<br>Compatibility,<br>Electrical Safety<br>and Safety<br>Standards | ANSI AAMI ES 60601-<br>1:2005/ (R):2012 &<br>A1:2012 &<br>C1:2009/ (R):2012 &<br>A2:2010/ (R):2012 | Medical electrical equipment - Part 1: General<br>requirements for basic safety and essential performance<br>(IEC 60601-1:2005, MOD) |
| | IEC 80601-2-30:2013 | Medical electrical equipment -- Part 2-30: Particular<br>requirements for basic safety and essential performance<br>of automated non-invasive sphygmomanometers |
| | IEC 60601-1-2:2007 | Medical electrical equipment - Part 1-2: General<br>requirements for basic safety and essential performance<br>- Collateral standard: Electromagnetic compatibility –<br>Requirements and tests |
| | IEC 60601-2-49:2011 | Medical electrical equipment - Part 2-49: Particular<br>requirements for the basic safety and essential<br>performance of multifunction patient monitoring<br>equipment |
| | ISO 80601-2-61:2011 | Medical electrical equipment -- Part 2-61: Particular<br>requirements for basic safety and essential performance<br>of pulse oximeter equipment |
| Usability | IEC 60601-1-6:2013 | Medical electrical equipment - Part 1-6: General<br>requirements for basic safety and essential performance<br>- Collateral standard: Usability |
| | IEC 62366-1:2015 | Medical devices - Part 1: Application of usability<br>engineering to medical devices |
| Software | IEC 62304:2006 | Medical device software—Software life cycle processes<br>13-32 Declaration of Conformity |
| Batteries | IEC 62133:2012 | Secondary Cells And Batteries Containing Alkaline Or<br>Other Non-Acid Electrolytes - Safety Requirements<br>For Portable Sealed Secondary Cells, And For Batteries<br>Made From Them, For Use In Portable Applications<br>[Including: Corrigendum 1 (2013)] |
| Alarms | IEC 60601-1-8:2012 | Medical electrical equipment - Part 1-8: General<br>requirements for basic safety and essential performance<br>- Collateral Standard: General requirements, tests and<br>guidance for alarm systems in<br>medical electrical equipment and medical electrical<br>systems |
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### 6. Clinical Studies
This Special 510(k) for the proposed SmartLinx Vitals Plus Patient Monitoring System did not require clinical studies to support substantial equivalence.
### 7. Conclusions
Substantial equivalence of the proposed SmartLinx Vitals Plus Patient Monitoring System is demonstrated through performance testing and conformance with FDA recognized consensus standards. The proposed SmartLinx Vitals Plus Patient Monitoring System results in an equivalent design, features and functionality as compared to the predicate SmartLinx Vitals Plus Patient Monitoring System with few exceptions that do not raise new questions of safety or effectiveness. Capsule Tech, therefore, views the proposed SmartLinx Vitals Plus Patient Monitoring System to be eligible for a decision of substantial equivalence when compared to the predicate SmartLinx Vitals Plus Patient Monitoring System.
{11}------------------------------------------------
Image /page/11/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol representing the Department of Health & Human Services on the left, and the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue on the right. The text is arranged in three lines, with "FDA" in a larger font size and a blue square behind it.
April 17, 2019
Capsule Technologie Maylin Truesdell Sr. Regulatory Affairs Manager 300 Brickstone Square, Suite 203 Andover, Massachusetts 01810
Re: K183638
Trade/Device Name: SmartLinx Vitals Plus Patient Monitoring System Regulation Number: 21 CFR 870.2300 Regulation Name: Cardiac Monitor (Including Cardiotachometer And Rate Alarm) Regulatory Class: Class II Product Code: MWI, DXN, DOA, FLL Dated: March 19, 2019 Received: March 20, 2019
Dear Maylin Truesdell:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
{12}------------------------------------------------
801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 medical devices and radiation-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.
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K183638
Device Name
SmartLinx Vitals Plus Patient Monitoring System
Indications for Use (Describe)
The SmartLinx Vitals Plus Patient Monitoring System is intended for monitoring and alarming of physiologic parameters, including non-invasive blood pressure (systolic, and mean arterial pressure), pulse rate, functional arterial oxygen saturation (SpO2), and temperature, on adult, pediatric, and neonatal patients in hospital environments when used by clinical physicians or appropriate medical staff under the direction of physicians.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | <span style="white-space: nowrap;">☑ Prescription Use (Part 21 CFR 801 Subpart D)</span> <span style="white-space: nowrap;">☐ Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
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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.
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.