K210085 · Zebra Medical Vision, Ltd. · JAK · Sep 15, 2021 · Radiology
Device Facts
Record ID
K210085
Device Name
HealthCCSng
Applicant
Zebra Medical Vision, Ltd.
Product Code
JAK · Radiology
Decision Date
Sep 15, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1750
Device Class
Class 2
Attributes
AI/ML, Software as a Medical Device, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K210085 · Sep 15, 2021
HealthCCSng
Zebra Medical Vision, Ltd.
Anonymized clinical CT chest scans from two healthcare institutions
A retrospective performance validation study was conducted to compare the device's automated coronary calcium detection category against a ground truth established by radiologist adjudication on routine clinical CT scans.
Retrospective performance validation study; Retrospective study
Adult patients (age 30-93) undergoing CT chest scans; Sample Size: 447 cases; Number of Sites: Two healthcare institutions (multiple clinical sites)
Not applicable for this study
Overall agreement between device output and ground truth (majority agreement of two of three radiologists)
AI Performance
Output
Algorithm
Acceptance
Observed
Dev DS
Dev Readers
Test DS
Test Readers
Coronary Artery Calcium Detection Category
—
Overall agreement >= 85%
Overall agreement 92.5% (95% CI: [89.7%, 95.5%])
—
—
Retrospective study: 447 anonymized CT chest cases from two healthcare institutions.
2 (radiologists) + 1 (radiologist)
Indications for Use
The HealthCCSng device is intended for use as a non-invasive post-processing software to evaluate calcified plaques in the coronary arteries, which present a risk for coronary artery disease. The software generates an estimated coronary artery calcium detection category. The HealthCCSng device analyzes existing non-cardiac-gated CT studies that include the heart of adult patients above the age of 30. The device generates a three-category output representing the estimated quantity of calcium detected together with preview axial images of the detected calcium meant for informational purposes only. The device output will be available to the radiologist as part of their standard workflow. The HealthCCSng results are not intended to be used on a stand-alone basis for risk attribution, clinical decision-making or otherwise preclude clinical assessment of CT studies.
Device Story
HealthCCSng is non-invasive post-processing software for opportunistic coronary artery calcium (CAC) detection in non-cardiac-gated adult CT scans. Input: DICOM CT studies (slice thickness up to 3mm). Operation: AI algorithm validates input data, analyzes heart region, detects calcifications (threshold ≥130 HU), and quantifies calcium into three categories (Low: 0-99, Medium: 100-399, High: ≥400). Output: Estimated CAC category and preview axial images with annotations. Usage: Integrated into radiologist's standard workflow via Zebra's Imaging Analytics Platform (IMA). The radiologist reviews software output alongside original images to inform clinical assessment. Benefits: Enables automated, opportunistic screening for coronary artery disease risk during routine CT scans without requiring dedicated cardiac-gated protocols.
Clinical Evidence
Bench-only validation using a retrospective dataset of 447 anonymized chest CT scans from two institutions. Ground truth established by majority agreement of three radiologists. Primary endpoint: overall agreement with ground truth. Results: 92.5% overall agreement (95% CI: 89.7%-95.5%), exceeding the 85% performance goal. Data included diverse imaging parameters (slice thickness 0.625-3mm, KVP 100-140, various manufacturers).
Indicated for adult patients >30 years old undergoing non-cardiac-gated CT scans of the chest/heart to evaluate calcified plaques in coronary arteries.
Regulatory Classification
Identification
A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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September 15, 2021
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Zebra Medical Vision Ltd. % Shlomit Cymbalista Regulatory Affairs Lead Shefayim Commercial Center, PO Box 25 Shefavim. 6099000 ISRAEL
Re: K210085
Trade/Device Name: HealthCCSng Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: Class II Product Code: JAK Dated: August 4, 2021 Received: August 9, 2021
#### Dear Shlomit Cymbalista:
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.
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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/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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## Indications for Use
510(k) Number (if known) K210085
Device Name HealthCCSng
Indications for Use (Describe)
The HealthCCSng device is intended for use as a non-invasive post-processing software to evaluate calcified plaques in the coronary arteries, which present a risk for coronary artery disease. The software generates an estimated coronary artery calcium detection category.
The HealthCCSng device analyzes existing non-cardiac-gated CT studies that include the heart of adult patients above the age of 30. The device generates a three-category output representing the estimated quantity of calcium detected together with preview axial images of the detected calcium meant for informational purposes only. The device output will be available to the radiologist as part of their standard workflow. The HealthCCSng results are not intended to be used on a stand-alone basis for risk attribution, clinical decision-making or otherwise preclude clinical assessment of CT studies.
Type of Use (Select one or both, as applicable)X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for Zebra Medical Vision. The logo consists of a stylized letter Z on the left and the words "zebra medical VISION" on the right. The letter Z is made up of three curved lines that are stacked on top of each other. The words "zebra medical" are stacked on top of the word "VISION".
## 510(K) Summary - HealthCCSng Zebra Medical Vision Ltd.
#### 510(k) Number – K210085
| Applicant's Name: | Zebra Medical Vision Ltd.<br>Shefayim Commercial Center<br>PO Box 25<br>Shefayim, 6099000<br>ISRAEL<br>Telephone: +972-9-8827795<br>Fax: +972-9-8827795 |
|-------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|
| Date Prepared: | September 14, 2021 |
#### Trade Name: HealthCCSng
#### Classification Name:
JAK - Computed tomography x-ray system
# Regulation Number:
21 CFR 892.1750
## Classification:
Class II, Radiology
### Predicate Device:
The HealthCCSng device is substantially equivalent to the following Primary Predicate Device:
| Proprietary Name | HealthCCS |
|------------------------|-----------------------------------|
| Premarket Notification | K172983 |
| Classification Name | Computed tomography x-ray system. |
| Regulation Number | 21 CFR 892.1750 |
| Product Code | JAK |
| Regulatory Class | II |
### Secondary Predicate Device:
| Proprietary Name | AI-Rad Companion |
|------------------------|-----------------------------------|
| Premarket Notification | K183268 |
| Classification Name | Computed tomography x-ray system. |
| Regulation Number | 21 CFR 892.1750 |
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Image /page/4/Picture/0 description: The image shows the logo for Zebra Medical Vision. The logo consists of a stylized letter Z on the left and the words "zebra medical VISION" on the right. The letter Z is made up of three curved lines that are stacked on top of each other. The words "zebra medical VISION" are written in a sans-serif font, with "zebra" on the top line, "medical" on the second line, and "VISION" on the third line.
| Product Code | JAK |
|------------------|-----|
| Regulatory Class | II |
#### Performance Standards:
No performance standards have been established for such device under Section 514 of the Federal Food. Drug. and Cosmetic Act.
#### Intended Use/Indication for Use:
The HealthCCSng device is intended for use as a non-invasive post-processing software to evaluate calcified plaques in the coronary arteries, which present a risk for coronary artery disease. The software generates an estimated coronary artery calcium detection category. The HealthCCSng device analyzes existing non-cardiac-gated CT studies that include the heart of adult patients above the age of 30. The device generates a three-category output representing the estimated quantity of calcium detected together with preview axial images of the detected calcium meant for informational purposes only. The device output will be available to the radiologist as part of their standard workflow. The HealthCCSng results are not intended to be used on a stand-alone basis for risk attribution, clinical decision-making or otherwise preclude clinical assessment of CT studies.
#### Device Description:
HealthCCSng product is a software device that automatically estimates the coronary arterv calcium category from non-cardiac-gated adult CT scans. The product is aimed to leverage the high utilization of CT scans in the medical care environment (both inpatient and outpatient), including lung cancer screening programs, in order to automatically detect calcification in the coronary arteries of patients in an opportunistic manner.
Zebra's HealthCCSng product analyzes cases using an artificial intelligence algorithm for the automated detection and estimation of coronary calcium and outputs a result for review by the radiologist. The device works in parallel to and in conjunction with the standard of care workflow. The final diagnosis is made by the radiologist after reviewing the scan independently of the software. The device is intended for use by the radiologists as a non-diagnostic analysis software in conjunction with additional patient information and professional judgment.
HealthCCSng receives a non-cardiac-gated CT study from the storage application, Zebra's Imaging Analytics Platform (IMA). For each CT study received, the software shall validate there is at least one compliant series in which the entire heart is present, and perform an analysis. For each compliant study, the software shall output:
1.Estimated Coronary Calcium Detection, based on the measurement of calcium deposits in the coronary arteries.
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Image /page/5/Picture/0 description: The image shows the logo for Zebra Medical Vision. The logo consists of a stylized letter Z on the left and the words "zebra medical VISION" on the right. The letter Z is made up of three nested Z shapes, creating a layered effect. The text is in a simple, sans-serif font, with "zebra" and "medical" stacked on top of each other and "VISION" below them.
2. A corresponding Estimated Coronary Calcium Detection Category, based on the Estimated Coronary Calcium measurement.
The software output will include the following calcium categories:
| Estimated Coronary Calcium<br>Detection | Corresponding Estimated Coronary Calcium<br>Detection Category |
|-----------------------------------------|----------------------------------------------------------------|
| 0-99 | Low |
| 100-399 | Medium |
| ≥400 | High |
For patients in which calcium was detected, the user will be presented with representative images - all the slices containing the measured coronary calcifications (130 HU and above). On these images, the calcified areas will be annotated (with an option for the user to toggle on and off the annotation).
The following modules compose the HealthCCSng software:
Data input and validation: Following retrieval of a study, the validation feature assessed the input data (i.e. age, modality, view, etc.) to ensure compatibility for processing by the algorithm.
HealthCCSng algorithm: Once a study has been validated, the algorithm analyzes the CT for analysis and quantification.
IMA Integration feature: The study analysis and the results of a successful study analysis is provided to IMA.
Error codes feature: In the case of a study failure during data validation or the analysis by the algorithm, an error is provided to the system.
## Performance Data:
Safety and performance of HealthCCSng has been evaluated and verified in accordance with software specifications and applicable performance standards through Software Development and Validation & Verification Process to ensure performance according to specifications, User Requirements and Federal Regulations and Guidance documents. "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices".
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Image /page/6/Picture/0 description: The image contains the logo for Zebra Medical Vision. The logo consists of a stylized letter "Z" on the left and the words "zebra medical VISION" on the right. The "Z" is made up of three curved lines that overlap each other. The words "zebra medical" are stacked on top of each other, and the word "VISION" is below them.
The HealthCCSng software device performance was validated in a stand-alone retrospective study for its overall agreement compared to the established ground truth and respective to the predicate device. The validation data-set consisted of anonymized CT scans of the chest from two healthcare institutions composed of multiple clinical sites. The sample included representation of each coronary calcium detection category. Ground truth category was determined by the majority agreement of two of three radiologists.
The objective of the study was to establish the safety, effectiveness and substantial equivalence of the HealthCCSng software as compared to the predicate device (HealthCCS, K172983). The HealthCCSng overall agreement was determined by comparing the device output coronary calcium detection category, to the ground truth coronary calcium detection category. For overall agreement to be considered successful it had to be equal or superior to the 85% performance goals defined by the predicate device.
The performance results were analyzed for 447 anonymized CT chest cases. Patient age ranged from 30-93 v.o (mean age of 62.6 years: SD=14.4) and 57.7% (258) were male. The validation data-set represented the following imaging parameters: Modality (CT), Slice Thickness (0.625, 1, 1.25, 1.5, 2, 2.5 and 3 mm), Slice Increment (0.625, 1, 1.25, 1.5, 2, 2.5 and 3 mm), Exposure in mAs (Radiation Dose) i(15-966), KVP (100, 120, 130 and 140), and four (4) manufacturers of CT devices (GE, Philips, Siemens and Toshiba).
The HealthCCSng device demonstrated an overall agreement of 92.5% (95% CI: [89.7%, 95.5%) exceeding the stated performance goal and the predicate performance. All CT data across, slice thickness, slice increment, exposure, KVP, manufacturers and reconstruction type were well supported by the HealthCCSng device. In conclusion, this study demonstrated the HealthCCSng overall agreement with the ground truth coronary calcium detection category and establishes its substantial equivalence to the predicate device. It also validated the performance of the HealthCCSng across important cohorts, and applicable subsets of imaging acquisition characteristics.
## Technological Characteristics Compared to Predicate Device:
Zebra Medical Vision believes that the HealthCCSng device is substantially equivalent to the HealthCCSng Device K172983 (primary predicate) and the AI-Rad Companion (Cardiovascular) K183268 (secondary predicate).
The two predicate devices listed (K172983 and K183268) have the same intended use as the predicate device, namely, coronary calcium detection and quantification, and support substantial equivalence with respect to technological characteristics.
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Image /page/7/Picture/0 description: The image is a logo for Zebra Medical Vision. The logo consists of a stylized letter Z on the left and the words "zebra medical VISION" on the right. The letter Z is made up of three curved black lines that are stacked on top of each other. The words "zebra medical" are stacked on top of the word "VISION".
| | Proposed Device:<br>HealthCCSng | Primary Predicate Device:<br>HealthCCS Device v3.0<br>(K172983) | Secondary Predicate Device:<br>AI-Rad Companion (K183268) | |
|-----------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------|
| Intended<br>Use/<br>Indications<br>for Use | The HealthCCSng device<br>is intended for use as a<br>non-invasive<br>post-processing software to<br>evaluate calcified plaques<br>in the coronary arteries,<br>which present a risk for<br>coronary artery disease.<br>The software generates an<br>estimated coronary artery<br>calcium detection category.<br>The HealthCCSng device<br>analyzes existing<br>non-cardiac-gated CT<br>studies that include the<br>heart of adult patients<br>above the age of 30. The<br>device generates a<br>three-category output<br>representing the estimated<br>quantity of calcium<br>detected together with<br>preview axial images of the<br>detected calcium meant for<br>informational purposes<br>only. The device output<br>will be available to the<br>radiologist as part of their<br>standard workflow. The<br>HealthCCSng results are<br>not intended to be used on<br>a stand-alone basis for risk<br>attribution, clinical<br>decision-making or<br>otherwise preclude clinical<br>assessment of CT studies. | The HealthCCS Device is<br>intended for use as a<br>non-invasive<br>post-processing software<br>that can be used to evaluate<br>calcified plaques in the<br>coronary arteries, which<br>may be a risk factor for<br>coronary artery disease.<br>The software can be used to<br>generate reports of the total<br>risk category of coronary<br>calcium. This information<br>can then be used by a<br>physician for further<br>analysis and treatment. The<br>HealthCCS Device<br>analyzes pre-existing heart<br>or chest<br>ECG-Gated/Triggered CT<br>scans. The Device is<br>indicated for use only on<br>patients whose age at the<br>time, when the CT scan<br>was taken, was above 20<br>years old. This device<br>generates a 4-category<br>Agatston-equivalent risk<br>score, and the patient<br>management, especially for<br>the patient with the score<br>from 0-10, will depend on<br>the physician's own<br>judgment. It may require<br>further testing to evaluate<br>the appropriate clinical<br>management. | AI-Rad Companion<br>(Cardiovascular) is image<br>processing software that<br>provides quantitative and<br>qualitative analysis from<br>previously acquired Computed<br>Tomography DICOM images to<br>support radiologists and<br>physicians from emergency<br>medicine, specialty care, urgent<br>care, and general practice in the<br>evaluation and assessment of<br>cardiovascular diseases.<br>It provides the following<br>functionality:<br>• Segmentation and volume<br>measurement of the heart<br>• Quantification of the total<br>calcium volume in the coronary<br>arteries<br>• Segmentation of the aorta<br>• Measurement of maximum<br>diameters of the aorta at typical<br>landmarks<br>•Threshold-based highlighting<br>of enlarged diameters The<br>software has been validated for<br>non-cardiac chest CT data with<br>filtered backprojection<br>reconstruction from Siemens<br>Healthineers, GE Healthcare,<br>Philips, and Toshiba/Canon.<br>Additionally, the calcium<br>detection feature has been<br>validated on non-cardiac chest<br>CT data with iterative<br>reconstruction from Siemens<br>Healthineers.<br>Only DICOM images of adult<br>patients are considered to be<br>valid input. | |
| Technological<br>Characteristics | Proposed Device:<br>HealthCCSng<br>Device v1.0 | Primary Predicate<br>Device:<br>HealthCCS Device<br>v3.0 (K172983) | Secondary<br>Predicate Device:<br>AI-Rad Companion<br>(K183268) | Summary |
| Regulation | | | | |
| Product Code | JAK | JAK | JAK | Same |
| Regulation Number | 21 CFR §892.1750 | 21 CFR §892.1750 | 21 CFR §892.1750 | Same |
| General | | | | |
| Modality | CT | CT | CT | Same |
| Image format | DICOM | DICOM | DICOM | Same |
| Contrast | Non-contrast | Non-contrast | Non-contrast | Same |
| Supported CT scan | Non-cardiac-gated<br>CT scan | Cardiac-gated CT<br>scan | Non-cardiac-gated<br>CT scan | Different<br>supported CT<br>scans by the<br>subject device<br>and primary<br>predicate device. |
| Slice thickness | Up to 3mm | Up to 3mm | Up to 3mm | Same |
| Quantification | | | | |
| Calcification<br>detection | Automatic | Automatic | Automatic | Same |
| Default threshold of<br>calcium | 130 HU<br>(Hounsfield Units) | 130 HU<br>(Hounsfield Units) | 130 HU<br>(Hounsfield Units) | Same |
| Coronary artery<br>calcification<br>quantification method | CAC detection<br>category | Agatston<br>equivalent CAC<br>risk category,<br>based on the<br>Agatston method | Calcium volume | Similar, provide<br>detected calcium<br>for assessment. |
| Display and Visualization | | | | |
| Main Image Quality | DICOM | DICOM | Not applicable…
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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.