K222304 · Gynesonics, Inc. · KNF · Nov 8, 2022 · Obstetrics/Gynecology
Device Facts
Record ID
K222304
Device Name
Sonata Transcervical Fibroid Ablation System 2.2
Applicant
Gynesonics, Inc.
Product Code
KNF · Obstetrics/Gynecology
Decision Date
Nov 8, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 884.4160
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Sonata® Transcervical Fibroid Ablation System 2.2 is intended for diagnostic intrauterine imaging and transcervical treatment of symptomatic uterine fibroids, including those associated with heavy menstrual bleeding.
Device Story
The Sonata System 2.2 is a transcervical, uterine-sparing device for treating symptomatic uterine fibroids. It integrates an Intrauterine Ultrasound (IUUS) probe for visualization and an RFA handpiece for radiofrequency ablation. The system includes an RF generator, a SMART tablet with graphical guidance software, and a system cart. The clinician uses the IUUS probe to localize fibroids and guide the placement of needle electrodes from the RFA handpiece into the target tissue. The system provides real-time ultrasound imaging and a graphical overlay (SMART Guide) to plan ablation zones and maintain a thermal safety border relative to the uterine serosa. RF energy is delivered to induce thermal fixation and coagulative necrosis. The device is used in a clinical setting by a physician. The output allows for precise, image-guided treatment of fibroids without incisions, potentially reducing patient recovery time and symptoms like heavy menstrual bleeding.
Clinical Evidence
No new clinical data was required for this submission. The device relies on clinical evidence from the original IDE study (G140114, NCT02228174), which involved 147 subjects across 22 centers in a single-arm cohort study.
Technological Characteristics
The system uses radiofrequency (RF) energy for ablation and B-mode ultrasound for imaging. Materials include glass fiber filled polyetherimide, glass reinforced vinyl ester, fluorocarbon rubber, silicone, Nitinol, and surgical grade stainless steel. The system is networked via internal data transfer (FireWire). It complies with ISO 10993 biocompatibility standards and electrical safety standards including ANSI/AAMI ES60601-1 and IEC 60601-2-37. The software includes a graphical user interface for treatment planning and automated RF energy control.
Indications for Use
Indicated for symptomatic uterine fibroids, including those associated with heavy menstrual bleeding, in patients requiring transcervical treatment and diagnostic intrauterine imaging.
Regulatory Classification
Identification
A unipolar endoscopic coagulator-cutter is a device designed to destroy tissue with high temperatures by directing a high frequency electrical current through the tissue between an energized probe and a grounding plate. It is used in female sterilization and in other operative procedures under endoscopic observation. This generic type of device may include the following accessories: an electrical generator, probes and electrical cables, and a patient grounding plate. This generic type of device does not include devices used to perform female sterilization under hysteroscopic observation.
Predicate Devices
Sonata Transcervical Fibroid Ablation System 2.2 (K211535)
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November 8, 2022
Gynesonics, Inc. Diane King VP, Global Regulatory Affairs & Healthcare Compliance 600 Chesapeake Drive Redwood City, CA 94063
Re: K222304
> Trade/Device Name: Sonata® Transcervical Fibroid Ablation System 2.2 Regulation Number: 21 CFR§ 884.4160 Regulation Name: Unipolar Endoscopic Coagulator-Cutter and Accessories Regulatory Class: II Product Code: KNF, ITX, IYO Dated: October 7, 2022 Received: October 11, 2022
Dear Diane King:
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.
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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 devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatoryinformation/postmarketing-safety-reporting-combination-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,
# Jason Roberts -S
Jason R. Roberts, Ph.D. Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices 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) K222304
Device Name
Sonata® Transcervical Fibroid Ablation System 2.2
Indications for Use (Describe)
The Sonata® Transcervical Fibroid Ablation System 2.2 is intended for diagnostic intrauterine imaging and transcervical treatment of symptomatic uterine fibroids, including those associated with heavy menstrual bleeding.
| Type of Use (Select one or both, as applicable) |
|------------------------------------------------------------------------------------------------|
| <label><input checked="" type="checkbox"/> Remediation Use (Part 21 CFR 601 Subpart E)</label> |
| <label><input type="checkbox"/> For-Profit Control Use (21 CFR 601 Subpart E)</label> |
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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# gyn
# 510(k) Summary
| Sponsor: | Gynesonics, Inc.<br>600 Chesapeake Drive<br>Redwood City, CA 94063 |
|-----------------|----------------------------------------------------------------------------------------------------------------|
| Contact Person: | Diane King<br>VP Global Regulatory Affairs and Healthcare Compliance<br>dking@gynesonics.com<br>(650) 216-3883 |
| Date Prepared: | November 2, 2022 |
# Device Information
| Proprietary Name: | Sonata® Transcervical Fibroid Ablation System 2.2 | | |
|-----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|--|--|
| Common Name: | Sonography-Guided Transcervical Fibroid Ablation System | | |
| Class: | Class II | | |
| Regulation: | 21 CFR 884.4160<br>Unipolar endoscopic coagulator-cutter and accessories | | |
| Product Code: | KNF Coagulator-Cutter, Endoscopic, Unipolar (And Accessories<br>ITX Transducer, Ultrasonic, Diagnostic<br>IYO Ultrasonic pulsed echo imaging system | | |
| Classification Panel: | 85 – Obstetrical & Gynecological | | |
# Indications for Use
The Sonata® Transcervical Fibroid Ablation System 2.2 is intended for diagnostic intrauterine imaging and transcervical treatment of symptomatic uterine fibroids, including those associated with heavy menstrual bleeding.
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# Predicate Devices
The predicate device is listed in Table 1. The predicate device is the unmodified Sonata Transcervical Fibroid Ablation System 2.2.
The predicate device has not been the subject of any design-related recalls.
Table 1 Table of Predicate and Reference Device
| 510(k) | Product | 510(k) Holder | Clearance Date |
|---------|-----------------------------------------------------|---------------|----------------|
| K211535 | Sonata Transcervical Fibroid Ablation System<br>2.2 | Gynesonics | June 17, 2021 |
# Device Description:
The Sonata System 2.2 (Figure 1) provides radiofrequency (RF) ablation of uterine fibroids using a transcervical approach that is uterine sparing without incisions or material uterine distension. The system enables a clinician to deliver radiofrequency energy to fibroid tissue resulting in thermal fixation and coagulative necrosis of the tissue.
Image /page/4/Figure/9 description: The image shows the text "Figure 1 Sonata System 2.2". The text is in bold font. The figure number is 1, and the system version is 2.2.
Image /page/4/Figure/10 description: The image shows a medical device system and its components. On the left is a system cart with a SMART Tablet and RF Generator attached. On the right are the components: IUUS Probe, RFA Handpiece, RFA Handpiece Cable, and two Dispersive Electrodes. The reusability of each component is specified.
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The system combines two technologies - ultrasound for visualization, and radiofrequency energy for ablative therapy - in a single integrated handpiece (Figure 2).
Figure 2 Intrauterine Ultrasound (IUUS) Probe being connected to the Radiofrequency Ablation (RFA) Handpiece to form a single Treatment Device
Image /page/5/Picture/4 description: The image shows two medical instruments, labeled as "IUUS Probe" and "RFA Handpiece", being held by gloved hands. The IUUS probe is positioned above the RFA handpiece, both against a blue background. A second image shows the two instruments being held together.
The Sonata System is comprised of medical equipment (Figure 1), software, and various single-use and reusable instruments. Sonata System devices and accessories are summarized in Table 2. The devices that are changed or new with this submission are shown in bold purple.
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| Catalog Number | Product Description |
|---------------------|--------------------------------------------------------------------------|
| Durable Equipment | |
| SONATA2-110 | Sonata Transcervical Fibroid Ablation System, consisting of: |
| RFG2-110 | Sonata Radiofrequency Generator |
| USCON-2200 | Sonata SMART Tablet |
| ACCY-002 | Sonata System Cart |
| External components | Footswitch, mouse, cables |
| System Software | |
| SW-002 | Sonata System Software v2.1.2 |
| Reusable Devices | |
| IUSP-002 | Sonata Intrauterine Ultrasound (IUUS) Probe (Non-Sterile) (modified IFU) |
| IUSP-002S | Sonata Intrauterine Ultrasound (IUUS) Probe (Sterile) |
| ACCY-008 | Sonata RFA Handpiece Cable, Reusable |
| Single-Use Devices | |
| RFA-002 | Sonata Radiofrequency Ablation Handpiece (Sterile) |
| DE-001 | Sonata Dispersive Electrode (Non-sterile) |
| Accessories | |
| SHPR-001 | Sonata Intrauterine Ultrasound Probe Sterile Shipper Kit |
| RTN-001 | Sonata Intrauterine Ultrasound Probe Return Kit |
| ACCY-018 | Sonata IUUS Probe Connector Protector |
| OM-1000-GS | Sonata IUUS Probe Reprocessing Tray (Manufacturer: Summit Medical LLC) |
| 8EC4A | Endocavity Ultrasound Transducer (Manufacturer: Terason®) |
Table 2 Sonata System 2.2 Devices and Accessories
A single-use Radiofrequency Ablation (RFA) Handpiece attaches to a reusable Intrauterine Ultrasound (IUUS) Probe as shown in Figure 2 to provide sonography-guided RF ablation. Once connected, the combination is referred to as the "Treatment Device". The RFA Handpiece connects to the Sonata RF Generator and contains the Needle Electrodes that deliver radiofrequency energy to the target tissue. The IUUS Probe connects to the SMART Tablet and provides diagnostic ultrasound imaging and guidance. Ultrasound guidance is used to localize the fibroids from within the uterine cavity, guide placement of the RFA Handpiece Needle Electrodes into a target fibroid and ensure safety with respect to the serosa. When the Needle Electrodes are anchored within tissue, the physician is able to pivot the IUUS Probe transducer around the Needle Electrodes in order to confirm safety of the uterine serosa through multiple ultrasound planes.
The Sonata System allows for treatment planning through the use of a graphical interface and automated control of RF energy delivery.
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Sonata Graphical Guidance Software (GGS) includes the SMART Guide (Figure 3) and integrates treatment planning, targeting, and ablation of fibroids. The SMART Guide displays a real-time graphic overlay on the live ultrasound image for targeting and deployment of radiofrequency ablation.
Image /page/7/Figure/3 description: The image is a figure from the Sonata System SMART Guide. The figure shows two images, one ultrasound and one anatomical, with labels for the IUUS Probe Tip, Introducer Guide, Ablation Zone, and Thermal Safety Border. The text explains that the SMART Guide is a graphical overlay used for sizing and positioning of the Ablation Zone over the targeted fibroid, and that the Thermal Safety Border must be kept within the uterine serosa at all times.
#### Figure 3 Sonata SMART Guide
Two main elements of the SMART Guide are the Ablation Zone and the Thermal Safety Border.
- Ablation Zone (red inner ellipse) a two-dimensional representation of the outer . boundary of the average region of tissue ablation for the selected ablation size
- . Thermal Safety Border (green outer ellipse) - the distance at which tissue outside of the Ablation Zone is safe from the potential of thermal damage.
# Changes triggering this 510(k)
Table 3 summarizes the changes to the Sonata System 2.2 that are driving the need for a new 510(k).
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| Sonata System 2.2<br>Component/Accessory | Description of Change | Reason for change | Impact of Change |
|----------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Sonata Intrauterine<br>Ultrasound (IUUS) Probe<br>IUSP-002 | Labeling change: Addition<br>of validated instructions for<br>sterilization of the IUUS<br>Probe by the following<br>liquid chemical sterilant<br>processing systems:<br>STERIS System 1E®<br>(available in the US only)<br>STERIS System 1®<br>EXPRESS<br>(available only OUS). | Expand options for<br>sterilization of reusable<br>device. | Sterilization validation<br>and verification of device<br>compatibility required. |
| Addition of unclassified<br>accessory:<br>ACCY-018 Sonata IUUS<br>Probe Connector Protector<br>Referenced within Sonata<br>IUUS Probe IUSP-002 IFU | New accessory supports<br>reprocessing of the IUUS<br>Probe | Provides a water-tight<br>cover for the IUUS<br>Probe electrical<br>connector during liquid<br>reprocessing<br>procedures. | Design controls were<br>followed for the new<br>accessory. See Table 5<br>for summary of design<br>controls and test results<br>relevant to use of the<br>new accessories for<br>reprocessing of the<br>IUUS Probe. |
### Table 3 Summary of Device Changes Triggering New 510(k)
# Comparison to Predicate Device
Table 4 contains a detailed comparison of the modified Sonata System 2.2 to its predicate, the unmodified Sonata System 2.2. The modified Sonata Transcervical Fibroid Ablation System 2.2 employs the same fundamental scientific technology as the currently marketed predicate Sonata Transcervical Fibroid Ablation System 2.2 (K211535). The modifications in the subject device do not raise any new questions of safety and effectiveness.
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| | Modified Sonata System 2.2<br>(this submission) | Predicate Sonata System 2.2<br>(K211535) | Comparison Discussion |
|-----------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|
| Characteristics | Intended Use/Indications for Use | | |
| Intended Use | Ablation of uterine fibroids with diagnostic<br>ultrasound imaging. | Ablation of uterine fibroids with diagnostic<br>ultrasound imaging. | Same |
| Indications for Use | The Sonata System is intended for diagnostic<br>intrauterine imaging and transcervical<br>treatment of symptomatic uterine fibroids,<br>including those associated with heavy<br>menstrual bleeding. | The Sonata System is intended for diagnostic<br>intrauterine imaging and transcervical<br>treatment of symptomatic uterine fibroids,<br>including those associated with heavy<br>menstrual bleeding. | Same |
| Regulation Number | §884.4160 Unipolar endoscopic coagulator-<br>cutter and accessories | §884.4160 Unipolar endoscopic coagulator-<br>cutter and accessories | Same |
| Product Code | KNF<br>Coagulator-Cutter, Endoscopic, Unipolar (And<br>Accessories)<br><br>ITX<br>Transducer,<br>Ultrasonic, Diagnostic<br><br>IYO<br>Ultrasonic pulsed echo imaging system | KNF<br>Coagulator-Cutter, Endoscopic, Unipolar (And<br>Accessories)<br><br>ITX<br>Transducer,<br>Ultrasonic, Diagnostic<br><br>IYO<br>Ultrasonic pulsed echo imaging system | Same |
| System Functional/ Operational Features | | | |
| Principal Mode of Operation | Radiofrequency ablation of fibroid tissue<br>resulting in thermal fixation and coagulative<br>necrosis.<br>B Mode ultrasound imaging | Radiofrequency ablation of fibroid tissue<br>resulting in thermal fixation and coagulative<br>necrosis.<br>B Mode ultrasound imaging | Same |
| Primary user interface | Graphical user interface | Graphical user interface | Same |
| Characteristics | Modified Sonata System 2.2<br>(this submission) | Predicate Sonata System 2.2<br>(K211535) | Comparison Discussion |
| Treatment<br>Planning | Integrated SMART Guide in software | Integrated SMART Guide in software | Same |
| Treatment<br>Approach | In situ delivery and control of RF energy through deployable array needle electrodes with impedance and temperature feedback under visual control. | In situ delivery and control of RF energy through deployable array needle electrodes with impedance and temperature feedback under visual control. | Same |
| Treatment<br>Guidance | Must be used under ultrasound guidance that is integrated into the system. The Ultrasound Console (SMART Tablet) with IUUS Probe is indicated for intrauterine imaging and guidance for placement of the Needle Electrodes. | Must be used under ultrasound guidance that is integrated into the system. The Ultrasound Console (SMART Tablet) with IUUS Probe is indicated for intrauterine imaging and guidance for placement of the Needle Electrodes. | Same |
| Route of<br>Access | Transcervical | Transcervical | Same |
| System Components | | | |
| RF Generator | An RF Generator provides RF energy to the RFA Handpiece through the handpiece cable | An RF Generator provides RF energy to the RFA Handpiece through the handpiece cable | Same |
| Treatment<br>Device | Single-use RFA handpiece with trocar-pointed shaft and 7 deployable needle electrodes, with reusable Cable. Combines with the reusable Intrauterine Ultrasound Probe to form the "Treatment Device". | Single-use RFA handpiece with trocar-pointed shaft and 7 deployable needle electrodes, with single-use Cable. Combines with the reusable Intrauterine Ultrasound Probe to form the "Treatment Device". | Same |
| Dispersive<br>Electrodes | Dispersive Electrodes, quantity 2, with cables; provides return path for the RF energy delivered by the Handpiece | Dispersive Electrodes, quantity 2, with cables; provides return path for the RF energy delivered by the Handpiece | Same |
| Characteristics | Modified Sonata System 2.2 (this submission) | Predicate Sonata System 2.2 (K211535) | Comparison Discussion |
| Ultrasound Console | Incorporates the Terason uSmart3200T Ultrasound System (K150533) with addition of Sonata Graphical Guidance software. The uSmart3200T is a tablet with 11.6" LED backlit display, lithium-polymer battery. Uses a medical-grade power supply. Data transferred internally from the ultrasound engine to the laptop computer over a FireWire (aka IEEE 1394) | Incorporates the Terason uSmart3200T Ultrasound System (K150533) with addition of Sonata Graphical Guidance software. The uSmart3200T is a tablet with 11.6" LED backlit display, lithium-polymer battery. Uses a medical-grade power supply. Data transferred internally from the ultrasound engine to the laptop computer over a FireWire (aka IEEE 1394) | Same |
| Ultrasound Transducer | Gynesonics Sonata Intrauterine Ultrasound (IUUS) Probe | Gynesonics Sonata Intrauterine Ultrasound (IUUS) Probe | Same |
| Ultrasound Transducer | Claimed compatibility with commercially available Terason 8EC4A transducer | Claimed compatibility with commercially available Terason 8EC4A transducer | Same |
| Power cord | Power cord - A medical grade power cord that provides AC power to the power strip on the System Cart. The power strip in turn powers the RF Generator and the Ultrasound Console. | Power cord - A medical grade power cord that provides AC power to the power strip on the System Cart. The power strip in turn powers the RF Generator and the Ultrasound Console. | Same |
| Footswitch | Pneumatic footswitch with PVC tubing used to activate and terminate delivery of RF energy. | Pneumatic footswitch with PVC tubing used to activate and terminate delivery of RF energy. | Same |
| Optical Mouse | Optical Mouse | Optical Mouse | Same |
| System Cart | Cart, accommodates tablet | Cart, accommodates tablet | Same |
| Materials | | | |
| Materials - Patient Contact - IUUS Probe | Glass fiber filled polyetherimide, glass reinforced vinyl ester, fluorocarbon rubber, UV adhesive, Silicone | Glass fiber filled polyetherimide, glass reinforced vinyl ester, fluorocarbon rubber, UV adhesive, Silicone | Same |
| Patient Contact Materials - active electrode | Medical grade metal alloys and plastic polymers (i.e. Nitinol®, surgical grade stainless steel) | Medical grade metal alloys and plastic polymers (i.e. Nitinol®, surgical grade stainless steel) | Same |
| Characteristics | Modified Sonata System 2.2<br>(this submission) | Predicate Sonata System 2.2<br>(K211535) | Comparison Discussion |
| Patient Contact<br>Materials<br>- dispersive<br>electrode | Acrylate-polymer based hydrogel, polyester<br>fabric with poly film and medical grade acrylic<br>adhesive | Acrylate-polymer based hydrogel, polyester<br>fabric with poly film and medical grade acrylic<br>adhesive | Same |
| Biocompatibility | Is biocompatible with intended use in<br>compliance with<br>• ISO 10993-1 5th Ed. 2018-08<br>• ISO 10993-5 3rd ed. 2009-06-01<br>• ISO 10993-10 3rd ed. 2010-08-01<br>• ISO 10993-11 3rd ed. 2017-09 | Is biocompatible with intended use in<br>compliance with<br>• ISO 10993-1 5th Ed. 2018-08<br>• ISO 10993-5 3rd ed. 2009-06-01<br>• ISO 10993-10 3rd ed. 2010-08-01<br>• ISO 10993-11 3rd ed. 2017-09 | Same |
| Safety and Performance | | | |
| Electrical Safety<br>& EMC | ANSI/AAMI ES60601-1:2005/(R)2012 And A1:2012,<br>C1:2009 / (R)2012 And A2:2010/(R)2012<br>IEC 60601-1-2 Ed 4: 2014-02<br>IEC 60601-1-6 Ed 3.1 2013-10<br>ANSI AAMI IEC 62366-1:2015<br>IEC 60601-1-8: Edition 2.1 2012-11<br>ANSI/AAMI IEC 60601-2-2:2017<br>IEC 60601-2-37 Ed 2.1 2015<br>IEC 62304 Ed. 1.1 2015-06 | ANSI/AAMI ES60601-1:2005/(R)2012 And A1:2012,<br>C1:2009 / (R)2012 And A2:2010/(R)2012<br>IEC 60601-1-2 Ed 4: 2014-02<br>IEC 60601-1-6 Ed 3.1 2013-10<br>ANSI AAMI IEC 62366-1:2015<br>IEC 60601-1-8: Edition 2.1 2012-11<br>ANSI/AAMI IEC 60601-2-2:2017<br>IEC 60601-2-37 Ed 2.1 2015<br>IEC 62304 Ed. 1.1 2015-06 | Same |
| Performance<br>testing –<br>System level<br>(bench) | • Shelf-life / Service life<br>• Confirmatory verification to specifications,<br>standards, and guidance documents. | • Shelf-life / Service life<br>• Confirmatory verification to specifications,<br>standards and guidance documents. | Same including design<br>controls |
| Characteristics | Modified Sonata System 2.2<br>(this submission) | Predicate Sonata System 2.2<br>(K211535) | Comparison Discussion |
| Performance<br>testing –<br>Ablation | Ablation output RF Generator safety features Handpiece retention forces Ultrasound visibility of the handpiece Dispersive Electrode adhesion RF Generator software and hardware verification and validation, including GUI, alerts, communication between components, real-time feedback to user via device sensors, power control, and software/hardware interface Successfully demonstrated through early clinical and bench ablation testing that the system performs as intended and per specifications. Ablation capability was confirmed and the radiofrequency ablation provides a reproducible, discretely demarcated zone of tissue necrosis. | Ablation output RF Generator safety features Handpiece retention forces Ultrasound visibility of the handpiece Dispersive Electrode adhesion RF Generator software and hardware verification and validation, including GUI, alerts, communication between components, real-time feedback to user via device sensors, power control, and software/hardware interface Successfully demonstrated through early clinical and bench ablation testing that the system performs as intended and per specifications. Ablation capability was confirmed and the radiofrequency ablation provides a reproducible, discretely demarcated zone of tissue necrosis. | Same |
| Acoustic Output<br>Measurement<br>Standard | NEMA UD 2-2004 (R2009)<br>IEC 60601-2-37 Ed 2.1 2015 | NEMA UD 2-2004 (R2009)<br>IEC 60601-2-37 Ed 2.1 2015 | Same |
| Acoustic Output<br>Global<br>Maximum<br>B Mode: | ISPTA ≤ limit of 720 mW/cm²<br>Value: 162 mW/cm² | ISPTA ≤ limit of 720 mW/cm²<br>Value: 162 mW/cm² | Same |
| | MI ≤ limit of 1.9<br>Value: 1.7 | MI ≤ limit of 1.9<br>Value: 1.7 | |
| Characteristics | Modified Sonata System 2.2<br>(this submission) | Predicate Sonata System 2.2<br>(K211535) | Comparison Discussion |
| Usability and | IEC 60601-1-6 Ed 3.1 2013-10 | IEC 60601-1-6 Ed 3.1 2013-10…
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Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
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.