The Wireless(V14C, V14G, V17C, V17G)/Wired(V14C, V14G, V17C, V17G, V17Ge) Yushan X-Ray Flat Panel Detector with DROC is intended to capture for display radiographic images of human anatomy. It is intended for use in general projection radiographic applications wherever conventional film/screen or CR systems may be used. The Yushan X-Ray Flat Panel Detector with DROC is not intended for mammography, tomography, and angiography applications.
Device Story
Portable/non-portable digital X-ray detector system; captures radiographic images of human anatomy. Input: X-ray radiation from external source. Operation: Flat panel sensor (GOS or CsI scintillator) digitizes X-ray signals; transfers data via SDK to DROC (Digital Radiography Operating Console) software on Windows PC. Output: Digital radiographic images for display, measurement, and storage. Used in clinics/hospitals; operated by radiology staff. DROC provides status updates, exposure workflow, image viewing, annotation, and DICOM integration. Benefits: Faster image transfer via compression, easy identification via LED, and durable design for clinical handling.
Clinical Evidence
No clinical study performed. Substantial equivalence demonstrated through non-clinical bench testing, including image quality evaluation, load-bearing tests, water ingress protection, and EMC/wireless performance testing.
Technological Characteristics
Digital flat panel detector; scintillator materials: GOS or CsI. Pixel pitch: 140 μm. A/D conversion: 16-bit. Connectivity: Wired (Gigabit Ethernet) and Wireless (IEEE 802.11 ac/a/g/n). Power: Rechargeable Lithium battery (except V17Ge). Standards: ANSI/AAMI ES60601-1, IEC 60601-1-2, IEC 62304, ISO 10993. Software: DROC console on Windows PC.
Indications for Use
Indicated for general projection radiographic applications in human anatomy, excluding mammography, tomography, and angiography. Intended for use in clinical environments where conventional film/screen or CR systems are used.
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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October 11, 2020
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InnoCare Optoelectronics Corp. % Yumei Cheng Senior Engineer Rm. B, No. 2, Sec. 2, Huanxi Rd., Xinshi Dist., Tainan City, Taiwan 744 REPUBLIC OF CHINA
Re: K201528
Trade/Device Name: Yushan X-Ray Flat Panel Detector with DROC Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: Class II Product Code: MQB Dated: June 2, 2020 Received: August 31, 2020
Dear Yumei Cheng:
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 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-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
Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
### Indications for Use
510(k) Number (if known)
#### K201528
#### Device Name
Yushan X-Ray Flat Panel Detector with DROC
#### Indications for Use (Describe)
The Wireless(V14C, V14G, V17C, V17G)/Wired(V14C, V14G, V17C, V17G, V17Ge) Yushan X-Ray Flat Panel Detector with DROC is intended to capture for display radiographic images of human anatomy. It is intended for use in general projection radiographic applications wherever conventional film/screen or CR systems may be used. The Yushan X-Ray Flat Panel Detector with DROC is not intended for mammography, tomography, and angiography applications.
| Type of Use (Select one or both, as applicable) | | |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <table style="border:none"><tr><td><span> <div style="display:inline-block; border: 1px solid black; width: 10px; height: 10px; text-align: center;">X</div> Prescription Use (Part 21 CFR 801 Subpart D) </span></td><td><span> <div style="display:inline-block; border: 1px solid black; width: 10px; height: 10px; text-align: center;"></div> Over-The-Counter Use (21 CFR 801 Subpart C) </span></td></tr></table> | <span> <div style="display:inline-block; border: 1px solid black; width: 10px; height: 10px; text-align: center;">X</div> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> <div style="display:inline-block; border: 1px solid black; width: 10px; height: 10px; text-align: center;"></div> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
| <span> <div style="display:inline-block; border: 1px solid black; width: 10px; height: 10px; text-align: center;">X</div> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> <div style="display:inline-block; border: 1px solid black; width: 10px; height: 10px; text-align: center;"></div> Over-The-Counter Use (21 CFR 801 Subpart C) </span> | |
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# 510(k) Summary K201528
#### I. SUBMITTER
InnoCare Optoelectronics Corp. Rm. B, No. 2, Sec. 2, Huanxi Rd., Xinshi Dist., Tainan City 744, Taiwan (R.O.C.) TEL: +886-6-700-7238 # 22598 Email: yumei.cheng@innocare-x.com Contact Person: Yumei Cheng / Senior Engineer Date Prepared: Jun 02, 2020
### II. DEVICE
Trade name: Yushan X-Ray Flat Panel Detector with DROC Model name: V14C, V14G, V17C, V17G, V17G, V17Ge Regulation description: Stationary x-ray system. Review panel: Radiology Product code: MQB Regulation number: 21 CFR 892.1680 Device class: Class II
## III. PREDICATE DEVICE
Substantial equivalence to the following predicate device is as follows: Trade/Device Name: Yushan X-Ray Flat Panel Detector FDA 510(k) clearance number: K191939 Manufacturer: InnoCare Optoelectronics Corp. Decision Date: 08/29/2019 Regulation description: Stationary x-ray system. Review panel: Radiology Product code: MQB Regulation number: 21 CFR 892.1680 Device class: Class II
> FDA-Summary-A1 10f8
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## IV. DESCRIPTION OF THE DEVICE SUBJECT TO PREMERKET NOTIFI-CATION
InnoCare's Yushan X-Ray Flat Panel Detector with DROC, model V14C, V14G, V17C, V17G are portable digital detector system, while V17Ge is a non-protable digital detector. The Yushan X-Ray Flat Panel Detector with DROC is designed to be used in any environment that would typically use a radiographic cassette for examinations. Model V14C, V14G, V17C, V17G support both wireless and wired/tethered data communication between the detector and the system, while model V17Ge is only applicable for wired use. Detectors can be placed in a wall bucky for upright exams, a table bucky for recumbent exams, or removed from the bucky for non-grid or free cassette exams. Every model have memory exposure mode, and extended image readout feature. Additionally, rounded-edge design for easy handling, image compression algorithm for faster image transfer, LED design for easy detector identification, extra protection against ingress of water.
The Yushan X-Ray Flat Panel Detector with DROC is currently indicated for general projection radiographic applications and offers two different detector types in terms of scintillator materials (gadolinium oxysulfide (GOS) and cesium iodide (Csl)).
The Yushan X-Ray Flat Panel Detector with DROC sensor can automatically collects x-ray images from an x-ray source. It collects x-rays and digitizes the images for their transfer and display to a computer. The sensor does not have an x-ray source, which is provided and controlled by independent system manufacturers. The sensor includes a flat panel for x-ray acquisition and digitization and a computer (including proprietary processing software) for processing, annotating and storing x-ray images.
Yushan series is working due to the combination of SDK(software development kit) and DROC(Digital Radiography Operating Console).
The SDK provides the interface for DROC to control the Yushan X-Ray Flat Panel Detector. SDK initiates the taking of X-ray images from the Yushan X-Ray Flat Panel Detector, through the Sensor Driver application. Once an X-ray is taken, Sensor Driver reads it from the flat panel and transfers it to SDK. Then the DROC will take
> FDA-Summary-A1 2of8
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the image data from SDK for further image process and display.
The DROC is a software running on a Windows PC as an user interface for radiologist to perform a general radiography exam. The function include:
- 1. Detector status update
- 2. Xray exposure workflow
- 3. Image viewer and measurement.
- 4. Post image process and DICOM file I/O
- 5. Image database: DROC support the necessary DICOM Services to allow a smooth integration into the clinical network
The software level of concern for the Yushan X-Ray Flat Panel Detector with DROC has been determined to be moderate based on the "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.
The cybersecurity risks of the Yushan X-Ray Flat Panel Detector with DROC have been addressed to assure that no new or increased cybersecurity risks were introduced as a part of device risk analysis. These risks are defined as sequence of events leading to a hazardous situation, and the controls for these risks were treated and implemented as proposed in the risk analysis (e.g., requirements, verification).
## V. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
Yushan X-Ray Flat Panel Detector with DROC (V14C, V14G, V17C, V17G) and its predicate device, Yushan X-Ray Flat Panel Detector (V14C, V14G) are portable digital detector systems, while the model V17Ge is a non-portable type, that are used to acquire x-ray exposures. Yushan X-Ray Flat Panel Detector with DROC has the same Indications for Use, and very similar functional and technical requirements as the predicate device, K191939. The comparison of technological characteristics are listed in the following table. Yushan X-Ray Flat Panel Detector with DROC has been successfully tested and validated, there are 5 models in this submission, V14C, V14G, V17C, V17G, V17Ge, and V14C, V14G are exactly the same device in K191939 named V14C and V14G, except for the modification of the user interface which has
> FDA-Summary-A1 3of8
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been changed into DROC version, and V17C, V17G, V17Ge are the serial models using the same user interface, DROC. Please refer to the following table for more detailed information.
| Product name | Yushan X-Ray Flat Panel Detector<br>with DROC | Yushan X-Ray Flat Panel Detector |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Model name | V14G<br>V14C<br>V17G<br>V17C<br>V17Ge | V14G<br>V14C |
| Manufacturer | InnoCare Optoelectronics Corp. | InnoCare Optoelectronics Corp. |
| Qualified<br>number | - | K191939 |
| Clinical | | |
| Indications for<br>use | The Wireless(V14C, V14G, V17C,<br>V17G)/Wired(V14C, V14G,<br>V17C, V17G, V17Ge) Yushan X-<br>Ray Flat Panel Detector with<br>DROC is intended to capture for<br>display radiographic images of<br>human anatomy. It is intended for<br>use in general projection radio-<br>graphic applications wherever<br>conventional film/screen or CR<br>systems may be used. The Yushan<br>X-Ray Flat Panel Detector with<br>DROC is not intended for mam-<br>mography, fluoroscopy, tomogra-<br>phy, and angiography applications. | The Wireless/Wired Yushan X-Ray<br>Flat Panel Detector is intended to<br>capture for display radiographic<br>images of human anatomy. It is<br>intended for use in general projec-<br>tion radiographic applications<br>wherever conventional film/screen<br>or CR systems may be used. The<br>Yushan X-Ray Flat Panel Detector<br>is not intended for mammography,<br>fluoroscopy, tomography, and an-<br>giography applications. |
| | | |
| | - FDA Standards 21 CFR<br>- 892.1680 for stationary x-ray<br>- system<br>- European Medical Devices<br>- Directive (93/42/EEC)<br>- EN ISO 13485<br>- ISO 14971<br>- ANSI/AAMI ES60601-1<br>- CAN/CSA C22.2 No. 60601-<br>- 1:14<br>- IEC 60601-1-2<br>- IEC 62304<br>- IEC 60601-1-6<br>- IEC 62366-1<br>- ISO 10993-1<br>- ISO 10993-5<br>- ISO 10993-10<br>- ISO 15223-1 | - FDA Standards 21 CFR<br>- 892.1680 for stationary x-ray<br>- system<br>- European Medical Devices<br>- Directive (93/42/EEC)<br>- EN ISO 13485<br>- ISO 14971<br>- ANSI/AAMI ES60601-1<br>- CAN/CSA C22.2 No. 60601-<br>- 1:14<br>- IEC 60601-1-2<br>- IEC 62304<br>- IEC 60601-1-6<br>- IEC 62366-1<br>- ISO 10993-1<br>- ISO 10993-5<br>- ISO 10993-10<br>- ISO 15223-1 |
| Compliance<br>standard | Technical | |
| | V14G:<br>460(W)×383(L)×15(H)<br>V14C:<br>460(W)×383(L)×15(H)<br>V17G:<br>460(W)×460(L)×15(H)<br>V17C:<br>460(W)×460(L)×15(H)<br>V17Ge:<br>460(W)×460(L)×15(H) | V14G:<br>460(W)×383(L)×15(H)<br>V14C:<br>460(W)×383(L)×15(H) |
| Dimensions<br>(mm) | | |
| Weight (Kg) | V14G: 2.7 | V14G: 2.7 |
| | | |
| | V14C: 2.7 | V14C: 2.7 |
| | V17G: 3.2 | |
| | V17C: 3.2 | |
| | V17Ge: 3.5 | |
| Scintillator | V14G: GOS | |
| | V14C: CsI | |
| | V17G: GOS | V14G: GOS |
| | V17C: CsI | V14C: CsI |
| | V17Ge: GOS | |
| Pixel Pitch | 140 μm | 140 μm |
| DQE | GOS: at 1 lp/mm, RQA5 is 0.27<br>CsI: at 1 lp/mm, RQA5 is 0.48 | GOS: at 1 lp/mm, RQA5 is 0.27<br>CsI: at 1 lp/mm, RQA5 is 0.48 |
| MTF | GOS: at 1 lp/mm, RQA5 is 0.52<br>CsI: at 1 lp/mm, RQA5 is 0.69 | GOS: at 1 lp/mm, RQA5 is 0.52<br>CsI: at 1 lp/mm, RQA5 is 0.69 |
| Max.<br>resolution | GOS: 3.57 lp/mm<br>CsI: 3.57 lp/mm | GOS: 3.57 lp/mm<br>CsI: 3.57 lp/mm |
| A/D Conversion | 16 bit | 16 bit |
| Pixels | V14G: 2500 x 3052 | |
| | V14C: 2500 x 3052 | |
| | V17G: 3072 x 3072 | V14G: 2500 x 3052 |
| | V17C: 3072 x 3072 | V14C: 2500 x 3052 |
| | V17Ge: 3072 x 3072 | |
| Interface | Wired: Gigabit Ethernet<br>(100BASE-TX or 10BASE-T)<br>Wireless: IEEE802.11 ac /a/g/n<br>* V17Ge is not applicable for<br>wireless function. | |
| | | Wired: Gigabit Ethernet<br>(100BASE-TX or 10BASE-T)<br>Wireless: IEEE802.11 ac /a/g/n |
| Power Source | Rechargeable Lithium Battery<br>* V17Ge is not applicable | Rechargeable Lithium Battery |
| Biological | | |
| Biological<br>safety | All material contact with patients<br>are in accordance with ISO 10993. | All material contact with patients<br>are in accordance with ISO 10993. |
| Others | | |
| Accessories | - Battery (Optional)* V17Ge is<br>not applicable<br>- Power supply (Adapter)<br>- SE cable (Back-up cable)<br>- Power Cord | - Battery (Optional)<br>- Power supply (Adapter)<br>- SE cable (Back-up cable)<br>- Power Cord |
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## INCX
#### VI. PERFORMANCE DATA
Non-clinical Performance Data: Yushan X-Ray Flat Panel Detector with DROC (V14C, V14G, V17C, V17G, V17Ge) confirms to the voluntary standards such as AAMI/ANSI ES60601-1, IEC 60601-1, IEC 60601-1-2, IEC 62304, IEC 60601-1-6, ANSI AAMI IEC 62366-1 and ANSI/AAMI HE75. In addition, the FDA's Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices (issued on September 1, 2016) was followed to describe the detector characteristics; Radio Frequency Wireless Technology in Medical Devices (issued on August 14, 2013), FCC 47 CFR PART 15 SUBPART C, FCC 47 CFR PART 15 SUBPART E and FCC SAR were followed to test the wireless features, which V17Ge is not applicable for this test; Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (issued on May 11, 2005) was followed to evaluate the level of concern as moderate; Content of Premarket Submissions for Management of Cybersecurity in Medical Devices (issued on October 2, 2014) was also followed to consider issues related to cybersecurity in the design and development process of this device. Additionaly, the risk analysis, necessary verification and validation activities were performed. Load-bearing characteristics and protection against ingress of water were tested and passed. The internal circuit design was demonstrated through EMC emission testing: IEC60601-1-2, FCC 47 CFR PART 15 SUBPART B, ETSI EN 301 489-
> FDA-Summary-A1 7of8
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17 V3.1.1:2017 and ETSI EN 301 489-1 V2.1.1:2017, and the results were satisfactory. Biocompatibilities were demonstrated through ISO 10993 series to prove the using material safe and effective. Furthermore, the image quality evaluation confirmed that the image quality of the Yushan X-Ray Flat Panel Detector with DROC is substantially equivalent to that of the predicate device.
Clinical Performance Data: No clinical study has been performed. The substantial equivalence has been demonstrated by non-clinical studies.
#### VII. CONCLUSIONS
Yushan X-Ray Flat Panel Detector with DROC is substantially equivalent to the predicate device in technical characteristics, design features, operating principles, functional and performance characteristics, and for the intended uses in the stated medical specialties.
Yushan X-Ray Flat Panel Detector with DROC is designed to comply with applicable federal and international safety and performance standards.
Based upon the supporting data summarized above, we concluded the Yushan X-Ray Flat Panel Detector with DROC (V14C, V14G, V17C, V17G, V17Ge) is as safe and effective as the legally marketed device Yushan X-Ray Flat Panel Detector (Yushan V14C, Yushan V14G) (K191939), and do not raise different questions of safety and effectiveness than K191939.
> FDA-Summary-A1 8of8
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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.
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.