Transcranial Doppler Ultrasound System is intended for use as a diagnostic ultrasound fluid flow analysis system: 1) For the measurement of cerebral artery blood velocities to determine the presence of hemo dynamically significant deviations from normal values; 2) To assess arterial cerebral blood flow for the occurrence of micro embolic signals. Vessels intended for observation include, but are not limited to the middle, anterior and posterior cerebral arteries, via the temporal windows, the vertebral mid basilar arteries via the foramen magnum and the ophthalmic artery and intracranial internal carotid artery via the eye. The Roboprobe Headband facilitates monitoring use by its ability to track the Doppler signal. Transcranial Doppler is intended for use during: 1) Diagnostic exams; 2) Surgical interventions. The device is not intended to replace other means of evaluating vital patient physiological processes, is not intended to be used in fetal applications, and is not intended to be used inside the sterile field. This device is intended for use by qualified and appropriately trained healthcare professionals. It can be used in hospitals or medical clinics. Mode of Operation is Pulsed Wave (PW) Doppler mode
Device Story
Transcranial Doppler (TCD) system; uses non-invasive pulsed wave (PW) ultrasound to measure blood flow velocities in major intracranial arteries. Input: ultrasonic signals via transducer; output: blood flow velocity data and micro-embolic signal detection. Used in hospitals/clinics by physicians or trained professionals for neurological vascular disease evaluation (e.g., vasospasm, intracranial stenosis) and intraoperative monitoring. Roboprobe headband tracks Doppler signals to facilitate monitoring. Output displayed to clinician to assist in identifying hemodynamically significant deviations or embolic events, supporting clinical decision-making regarding patient vascular status.
Clinical Evidence
No clinical data. Bench testing only. Compliance verified against IEC 60601-1 (safety), IEC 60601-2-37 (ultrasonic diagnostic equipment), IEC 60601-1-2 (EMC), and NEMA UD 2-2004 (acoustic output).
Technological Characteristics
Pulsed Wave (PW) Doppler ultrasound system. 2 MHz PW probe. Connectivity: USB, LAN, WIFI. Power: AC (100-240V) or internal 14.4V 3000mAH battery. Form factor: Main unit with external PC/laptop/surface. Standards: IEC 60601-1, IEC 60601-2-37, IEC 60601-1-2, NEMA UD 2-2004.
Indications for Use
Indicated for diagnostic ultrasound fluid flow analysis in patients requiring assessment of cerebral artery blood velocities or micro embolic signals. Applicable to middle, anterior, and posterior cerebral arteries, vertebral mid-basilar arteries, ophthalmic artery, and intracranial internal carotid artery. Intended for use by trained healthcare professionals in hospitals or clinics during diagnostic exams or surgical interventions. Not for fetal applications or use within the sterile field.
Regulatory Classification
Identification
An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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July 8, 2022
Shenzhen Delica Medical Equipment Co., Ltd. % Diana Hong General Manager Mid-Link Consulting Co., Ltd. P.O. Box 120-119 Shanghai, 200120 CHINA
Re: K213009
Trade/Device Name: Transcranial Doppler Ultrasound System Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic pulsed doppler imaging system Regulatory Class: Class II Product Code: IYN, ITX, OQQ Dated: May 30, 2022 Received: June 8, 2022
Dear Diana Hong:
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
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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 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 (OS) 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
Michael D. O'Hara, Ph.D. Deputy Director DHT 8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
### Device Name
Transcranial Doppler Ultrasound System
Indications for Use (Describe)
Transcranial Doppler Ultrasound System is intended for use as a diagnostic ultrasound fluid flow analysis system: 1) For the measurement of cerebral artery blood velocities to determine the presence of hemo dynamically significant deviations from normal values;
2) To assess arterial cerebral blood flow for the occurrence of micro embolic signals. Vessels intended for observation include, but are not limited to the middle, anterior and posterior cerebral arteries, via the temporal windows, the vertebral mid basilar arteries via the foramen magnum and the ophthalmic artery and intracranial internal carotid artery via the eye.
The Roboprobe Headband facilitates monitoring use by its ability to track the Doppler signal.
Transcranial Doppler is intended for use during:
1) Diagnostic exams;
2) Surgical interventions.
The device is not intended to replace other means of evaluating vital patient physiological processes, is not intended to be used in fetal applications, and is not intended to be used inside the sterile field.
This device is intended for use by qualified and appropriately trained healthcare professionals. It can be used in hospitals or medical clinics. Mode of Operation is Pulsed Wave (PW) Doppler mode
| Type of Use ( <i>Select one or both, as applicable</i> ) | |
|----------------------------------------------------------|-----------------------------------------------|
| ☑ Prescription Use (Part 21 CFR 801 Subpart D) | ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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# 510(k) Summary
This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92(a)(2).
The assigned 510(k) Number: K213009
- 1. Date of Preparation: 7/7/2022
- 2. Sponsor Identification
### Shenzhen Delica Medical Equipment Co., Ltd.
18F, Building B, High-tech park, Guangqiao Road, Tianliao Community, Yutang Street, Guangming District, Shenzhen, 518107, P.R. China
Establishment Registration Number: 3006441164
Contact Person: Zhenhua Xiao Position: Management Representative Tel: +86-755-86210116 Fax: +86-755-86210002 Email: overseas(@delicasz.com
#### 3. Designated Submission Correspondent
Ms. Diana Hong (Primary Contact Person) Ms. Jing Cheng (Alternative Contact Person)
### Mid-Link Consulting Co., Ltd.
P.O. Box 120-119, Shanghai, 200120, China
Tel: +86-21-22815850, Fax: 360-925-3199 Email: info@mid-link.net
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#### 4. Identification of Proposed Device
Trade Name: Transcranial Doppler Ultrasound System Common Name: Transcranial Doppler Models: EMS-9M1/EMS-9M2
Regulatory Information Classification: II Classification name: Ultrasonic pulsed doppler imaging system Product Code: IYN: Regulation Number: 21 CFR 892.1550; Review Panel: Radiology;
Classification: II Classification name: Diagnostic ultrasonic transducer Product Code: ITX, OQQ; Regulation Number: 21 CFR 892.1570; Review Panel: Radiology;
Indication for use:
Transcranial Doppler Ultrasound System is intended for use as a diagnostic ultrasound fluid flow analysis system:
For the measurement of cerebral artery blood velocities to determine the presence of hemo 1) dynamically significant deviations from normal values;
2) To assess arterial cerebral blood flow for the occurrence of micro embolic signals. Vessels intended for observation include, but are not limited to the middle, anterior and posterior cerebral arteries, via the temporal windows, the vertebral mid basilar arteries via the foramen magnum and the ophthalmic artery and intracranial internal carotid artery via the eye.
The Roboprobe Headband facilitates monitoring use by its ability to track the Doppler signal. Transcranial Doppler is intended for use during:
- 1) Diagnostic exams;
- 2) Surgical interventions.
The device is not intended to replace other means of evaluating vital patient physiological processes, is not intended to be used in fetal applications, and is not intended to be used inside the sterile field.
This device is intended for use by qualified and appropriately trained healthcare professionals. It can be used in hospitals or medical clinics. Mode of Operation is Pulsed Wave (PW) Doppler mode.
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Device Description:
The EMS-9M1 and EMS-9M2 Transcranial Doppler Ultrasound System is a Transcranial Doppler (TCD) system using non-invasive technique to obtain the information of blood flow velocities throughout the body. This method of measurement is particularly useful for examining the major arteries supplying blood to the brain.
TCD is useful for evaluation of numerous neurological vascular diseases such as vasospasm and intracranial stenosis. TCD is also extremely valuable for intraoperative monitoring to help detect sudden changes in blood flow.
Both the EMS-9Ml and EMS-9M2 are Track 1 devices.
EMS-9M1 and EMS-9M2 should be used in hospitals or healthcare facilities by doctors or trained healthcare professionals.
- ડ. Identification of Predicate Device
510(k) Number: K173801 Product Name: Transcranial Doppler Ultrasound System
- 6. Non-Clinical Test Conclusion
Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
- > IEC 60601-1:2005+CORR.1:2006+CORR.2:2007+AM1:2012, Medical electrical equipment - Part 1: General requirements for basic safety, and essential performance.
- > IEC 60601-2-37:2015, Medical electrical equipment - Part 2-37: Particular requirements for the basic safety and essential performance of ultrasonic medical diagnostic and monitoring equipment
- > IEC 60601-1-2: 2014, Medical electrical equipment, Part 1-2: General requirements for basic safety and essential performance- Collateral standard: Electromagnetic compatibility- Requirements and teats.
- > NEMA UD 2-2004 (R2009), Acoustic Output Measurement Standard for Diagnostic Ultrasound Equipment Revision 3.
- 7. Clinical Test Conclusion
No clinical study is included in this submission.
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### 8. Summary of Technological characteristics
| ITEM | Proposed Device | Predicate Device, K173801 | Remark |
|-----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| | Table 1 General Comparison | | |
| Model | EMS-9M1 / EMS-9M2 | EMS-9F | / |
| Product Code | IYN, ITX and OQQ | IYN, ITX and OQQ | Same |
| Regulation<br>No. | 21 CFR 892.1570 | 21 CFR 892.1570 | Same |
| Class | II | II | Same |
| Indication for<br>Use | Transcranial Doppler Ultrasound<br>System is intended for use as a<br>diagnostic ultrasound fluid flow<br>analysis system:<br>1) For the measurement of<br>cerebral artery blood velocities to<br>determine the presence of hemo<br>dynamically significant deviations<br>from normal values;<br>2) To assess arterial cerebral blood<br>flow for the occurrence of micro<br>embolic signals. Vessels intended<br>for observation include, but are<br>not limited to the middle, anterior<br>and posterior cerebral arteries, via<br>the temporal windows, the<br>vertebral mid basilar arteries via<br>the foramen magnum and the<br>ophthalmic artery and intracranial<br>internal carotid artery via the eye.<br>The Roboprobe Headband<br>facilitates monitoring use by its<br>ability to track the Doppler signal.<br>Transcranial Doppler is intended<br>for use during:<br>1) Diagnostic exams;<br>2) Surgical interventions.<br>The device is not intended to<br>replace other means of evaluating<br>vital patient physiological<br>processes is not intended to be | Transcranial Doppler Ultrasound<br>System is intended for use as a<br>diagnostic ultrasound fluid flow<br>analysis system:<br>1) For the measurement of cerebral<br>artery blood velocities to determine<br>the presence of hemo dynamically<br>significant deviations from normal<br>values;<br>2) To assess arterial cerebral blood<br>flow for the occurrence of micro<br>embolic signals. Vessels intended for<br>observation include, but are not<br>limited to the middle, anterior and<br>posterior cerebral arteries, via the<br>temporal windows, the vertebral mid<br>basilar arteries via the foramen<br>magnum and the ophthalmic artery<br>and intracranial internal carotid<br>artery via the eye.<br>The Roboprobe Headband facilitates<br>monitoring use by its ability to track<br>the Doppler signal.<br>Transcranial Doppler is intended for<br>use during:<br>1) Diagnostic exams;<br>2) Surgical interventions.<br>The device is not intended to replace<br>other means of evaluating vital<br>patient physiological processes, is not<br>intended to be used in fetal | Same |
| | used in fetal applications, and is<br>not intended to be used inside the<br>sterile field. | applications, and is not intended to be<br>used inside the sterile field. | |
| | This device is intended for use by<br>qualified and appropriately trained<br>healthcare professionals. It can be<br>used in hospitals or medical<br>clinics. Mode of Operation is<br>Pulsed Wave (PW) Doppler mode. | | |
| Configuration | EMS-9M1: Main Unit+<br>PC/Laptop/Surface+ Transducer<br>EMS-9M2:Main Unit+<br>PC/Laptop/Surface+ Transducer | Main Unit+ PC/Laptop+ Transducer | Same |
| Connection<br>modes | EMS-9M1: USB/LAN/WIFI<br>EMS-9M2: USB/LAN/WIFI | USB | Difference |
#### ты e ﺍﻟﻤﻌﺎﺭﺿﺔ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘ 1
{7}------------------------------------------------
Difference-Connection mode
Compared with the predicate device, the connection mode of EMS-9M1 and EMS-9M2 has additional LAN and WIFI, which makes the proposed device more convenient to use. Therefore, this difference will not affect the safety and effectiveness of the proposed device.
{8}------------------------------------------------
| ITEM | Proposed Device | | Predicate Device,<br>K173801 | Remark | |
|-----------------------------|--------------------------------------------|--------------------------------------------|----------------------------------|-----------------|------|
| | EMS-9M1 | EMS-9M2 | EMS-9F | | |
| Screen | NO | NO | No | Same | |
| Power supply mode | AC Power supply /<br>Internal Power supply | AC Power supply /<br>Internal Power supply | AC power supply | Difference | |
| External Nominal<br>Voltage | AC 100V-240V | AC 100V-240V | DC +12V, -12V,<br>+6V | Difference | |
| Nominal Frequency | 50Hz/60Hz | 50Hz/60Hz | / | Same | |
| Internal power supply | 14.4V 3000mAH | 14.4V 3000mAH | / | Difference | |
| Probe | 2 MHz PW probe<br>/ | 2 MHz PW probe<br>/ | 2 MHz PW probe<br>4 MHz CW probe | Same | |
| 2MHz<br>PW | Depth | not less 150 mm | not less 150 mm | not less 150 mm | Same |
| | Speed range | 10cm/s~300cm/s | 10cm/s~300cm/s | 10cm/s~300cm/s | Same |
| | Maximum<br>Error | ±15% | ±15% | ±15% | Same |
| Table 2 Specifications Comparison |
|-----------------------------------|
|-----------------------------------|
## Difference - Power supply mode
Compared with the predicate device, the proposed devices have one more power supply mode, powered by the built-in battery. The electrical safety testing of proposed device with built-in battery was conducted according to IEC 60601-1, and the test results of electrical safety testing demonstrate that the power supply of built-in battery is acceptable. Therefore, this difference will not affect the safety and effectiveness of the proposed device.
### Difference - Nominal Voltage
Although the external nominal voltage of proposed device are different with that of predicate device. The electrical safety testing of proposed device was conducted according to IEC 60601-1, and the test results of electrical safety testing demonstrate that the external nominal voltage of proposed device is acceptable. Therefore, this difference will not affect the safety and effectiveness of the proposed device.
### Difference - Internal power supply
Compared with the predicate device, the predicate device has no internal power supply, and the proposed device has an internal power supply. And the internal power supply provides battery test report and battery specification, this difference will not affect the safety and effectiveness of the proposed device.
{9}------------------------------------------------
#### 9. Conclusion
The conclusions drawn from the nonclinical tests demonstrate that the proposed devices are as safe, as effective, and perform as well as or better than the legally marketed predicate device K173801.
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1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
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Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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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.
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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.
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Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
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Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.