Retrospective PMCF survey data from the predicate device was used to support the substantial equivalence of the subject device for specific endoscopic procedures.
Post Market Clinical Follow-up; Retrospective data; Endoscopy; Waste management
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Post Market Clinical Follow-up (PMCF) survey; Retrospective survey
Patients undergoing colonoscopies, EGDs, and bronchoscopies
Not applicable for this study
Success rate of waste fluid and debris removal; safety/adverse events
Indications for Use
The Neptune S Waste Management System is indicated for use in procedures where collecting and disposing of fluid waste and capturing suctioned tissue specimens is desired. It is intended to be used in operating rooms, pathology, surgical centers, procedure rooms, and for endoscopic procedures, such as colonoscopies, esophagogastroduodenoscopies (EGDs), and bronchoscopies.
Device Story
Mobile suction device (Neptune S Rover) connects to hospital AC power; uses integrated vacuum pump to suction fluid waste and tissue specimens from surgical sites via single-use, non-sterile V2 Manifolds. Rover features internal canister for waste collection, fluid volume measurement, lighted canister/specimen viewing, and lighted worksurface for specimen transfer. Used in ORs, pathology, surgical centers, and endoscopy suites by clinical staff. After procedures, Rover attaches to a docker (external to device) for automated canister emptying and cleaning. Output includes visual fluid volume measurements on control panels and physical collection of waste/specimens. Smaller footprint than predicate for use in space-constrained environments.
Clinical Evidence
Retrospective clinical data from Post Market Clinical Follow-up (PMCF) of predicate device (Neptune 3) in colonoscopies, EGDs, and bronchoscopies. Sample size not specified. Primary endpoints: waste fluid/debris removal success. Results: 98.3% success rate in waste/debris removal; 94.7% success rate without removing excess fluid/debris. No adverse events reported.
Technological Characteristics
Mobile suction rover with integrated vacuum pump. 120V, 60Hz, 6A power. 7" LCD touchscreen and membrane control panel. Non-sterile, single-use plastic manifolds. Conforms to IEC 60601-1, IEC 60601-1-6, IEC 60601-1-8, IEC 62366, and IEC 60601-1-2. RFID compatibility (125-134 kHz and 13.56 MHz).
Indications for Use
Indicated for patients undergoing surgical or nonsurgical procedures, including endoscopic procedures (colonoscopies, EGDs, bronchoscopies), where collection/disposal of fluid waste and capture of suctioned tissue specimens is required.
Regulatory Classification
Identification
A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.
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Image /page/0/Picture/0 description: The image contains two logos. The logo on the left is the Department of Health & Human Services - USA logo. The logo on the right is the FDA U.S. Food & Drug Administration logo. The FDA logo is in blue.
December 9, 2022
Stryker Instruments Tu Nguyen Staff Regulatory Affairs Specialist 1941 Stryker Way Portage, Michigan 49002
#### Re: K222552
Trade/Device Name: 120V Neptune S Rover (0711-001-000);V2 4-Port Manifold (0750-400-000);V2 Specimen Collection Manifold Kit (0750-200-000); V2 Specimen Collection Tray (0750-210-000) Regulation Number: 21 CFR 878.4780 Regulation Name: Powered suction pump Regulatory Class: Class II Product Code: JCX Dated: November 7, 2022 Received: November 9, 2022
Dear Tu Nguyen:
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,
Jessica Carr -S
for Long Chen, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.
Submission Number (if known)
K222552
Device Name
120V Neptune S Rover (0711-001-000);
V2 4-Port Manifold (0750-400-000);
V2 Specimen Collection Manifold Kit (0750-200-000);
V2 Specimen Collection Tray (0750-210-000)
Indications for Use (Describe)
The Neptune S Waste Management System is indicated for use in procedures where collecting and disposing of fluid waste and capturing suctioned tissue specimens is desired. It is intended to be used in operating rooms, pathology, surgical centers, procedure rooms, and for endoscopic procedures, such as colonoscopies, esophagogastroduodenoscopies (EGDs), and bronchoscopies.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# 1.0 Applicant Information
# 1.1 Applicant Name and Address
Stryker Instruments 1941 Stryker Way Portage, MI 49002, USA
# 1.2 Contact Information
| Contact Name: | Tu Nguyen |
|-------------------|------------------------|
| Telephone Number: | (817) 932-4541 |
| Email: | tu.nguyen2@stryker.com |
# 2.0 Device Information
# 2.1 Device Name
| Trade Name | Neptune S Waste Management System |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common name | Portable suction device |
| Model Numbers | 0711-001-000 (120V Neptune S Rover)<br>0750-400-000 (V2 4-Port Manifold)<br>0750-200-000 (V2 Specimen Collection Manifold Kit)<br>0750-210-000 (V2 Specimen Collection Tray) |
| Classification | Class 2 |
| Classification Name | Powered suction pump |
| Regulation Number | 878.4780 |
| Product Code | JCX (Class 2) - Apparatus, Suction, Ward Use, Portable, Ac-<br>Powered |
### 2.2 Legally Marketed Predicate Devices
| Predicate Device Trade Name | 510(k) | Product Code | Manufacturer |
|--------------------------------------|---------|--------------|--------------------------------------------------------------|
| Neptune 3 Waste Management<br>System | K153407 | JCX | Stryker Instruments<br>1941 Stryker Way<br>Portage, MI 49002 |
| Neptune 2 Manifolds | K132671 | JCX | Stryker Instruments<br>1941 Stryker Way<br>Portage, MI 49002 |
### 2.3 Device Description
The Neptune S Waste Management System includes subject devices Neptune S Rover and V2 Manifolds, previously 510k cleared Neptune 2 Docker, and supporting accessories.
Neptune S Rover is a mobile device, plugged into a standard 15A hospital-grade AC power outlet and is used to suction and collect waste fluids during surgical or nonsurgical procedures. It can also be used to collect tissue specimens suctioned during these procedures. The Rover
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provides fluid waste management, fluid volume measurement and contains features designed to specifically aid with tissue specimen collection, including an array of lighting features and a flat worksurface. It was designed with a smaller footprint to accommodate smaller operating rooms or procedure rooms, particularly endoscopy suites.
The manifolds are non-sterile, single-use disposables, that act as an interface between the Rover canister and standard medical grade suction tubing. They facilitate the collection of surgical tissue and the removal of fluid waste.
# 2.4 Indication for Use
The Neptune S Waste Management System is indicated for use in procedures where collecting and disposing of fluid waste and capturing suctioned tissue specimens is desired. It is intended to be used in operating rooms, pathology, surgical centers, procedure rooms, and for endoscopic procedures, such as colonoscopies, esophagogastroduodenoscopies (EGDs), and bronchoscopies.
# 2.5 Indication for Use Comparison
The indication for capturing suctioned tissue specimen on Neptune S Waste Management System is not a new intended use or feature of the product as compared to the predicate device because indication for tissue specimen collection is already in scope of predicate device. It is simply being described more directly within the indications for use section of the Neptune S's product labeling.
The addition of use in endoscopic procedures such as colonoscopy,
esophagogastroduodenoscopy (EGD), and bronchoscopy is also not a new intended use of the product as compared to the predicate because these specific indications ordinarily fall within the general use of both the subject device and predicate device.
Substantial equivalence of the addition of these specific indications compared to the predicate IFU was additionally supported by the assessment of clinical evidence as described in Section 2.8 below.
In conclusion, the intended use of the Neptune S Waste Management System is the same as the predicate device.
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# 2.6 Technological Comparison
The technological comparison between the subject devices (Neptune S Rover and V2 Manifolds) and the predicate devices (Neptune 3 Rover and Neptune 2 Manifolds) is included in table below. The Neptune 3 Waste Management System was cleared under 510(k) number K153407. The Neptune 2 Manifolds, which is used in Neptune 3 Waste Management System, was cleared under 510(k) number K132671.
| Item | Subject Device:<br>Neptune S Rover and V2<br>Manifolds | Predicate Device:<br>Neptune 3 Rover and Neptune 2<br>Manifolds |
|-----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Main System<br>Components | Neptune S Rover<br>V2 Manifolds: 4-port, specimen<br>collection | Neptune 3 Rover<br>Neptune 2 Manifolds: 1-port, 4-port,<br>4-port specimen collection |
| Operating<br>Principle | Fluid waste is suctioned from the<br>surgical site through suction tubes<br>connected to the inlet port(s) of a<br>disposable, nonsterile, single<br>patient use manifold installed in the<br>rover. Suction is created via an<br>integrated vacuum pump. The<br>manifold facilitates the collection<br>of surgical tissue and the removal of<br>fluid waste.<br><br>Once suctioned, the fluid waste is<br>collected in the internal canister of<br>the rover during a procedure. The<br>rover provides fluid waste<br>management, fluid volume<br>measurement, a lighted canister for<br>viewing of canister contents, a<br>specimen light for viewing captured<br>tissue specimen, and a lighted work<br>surface for specimen transfer. Fluid<br>volume measurements are shown<br>on the main control panel display<br>and the secondary control panel<br>display.<br><br>After use in a procedure, the rover is<br>relocated and attached to the docker,<br>which is typically installed in a<br>healthcare facility waste disposal<br>area. Once the rover is attached, the<br>docker empties the rover's canister of<br>fluid waste for subsequent disposal.<br>Cleaning of the interior of the | Fluid waste is suctioned from the<br>surgical site through suction tubes<br>connected to the inlet port(s) of a<br>disposable, nonsterile, single patient<br>use manifold installed in the rover.<br>Suction is created via an integrated<br>vacuum pump. The manifold<br>facilitates the collection of surgical<br>tissue and the removal of fluid<br>waste.<br><br>Once suctioned, the fluid waste is<br>collected in 2 internal canisters of<br>the rover during a procedure. The<br>rover provides fluid waste<br>management, fluid volume<br>measurement, a lighted canister for<br>viewing of canister contents, a<br>motorized IV pole, and a smoke<br>evacuation unit. Fluid volume<br>measurements are shown on the<br>main control panel display and the<br>top swivel display.<br><br>After use in a procedure, the rover is<br>relocated and attached to the docker,<br>which is typically installed in a<br>healthcare facility waste disposal<br>area. Once the rover is attached, the<br>docker empties the rover's canisters<br>of fluid waste for subsequent<br>disposal. Cleaning of the interior of |
| | | |
| | canister takes place immediately<br>after the removal of fluid waste. | the canister takes place immediately<br>after the removal of fluid waste. |
| Energy<br>Source | 120V, 60Hz, 6A | 120V, 60Hz, 12A |
| Intended Use<br>Environment | Operating rooms, pathology, surgical<br>centers, procedure rooms | Operating room, pathology, surgical<br>centers, and doctor's offices |
| User<br>Interface | 7" LCD touchscreen Membrane<br>Control Panel Suction Control Dial | 8.4" LCD touchscreen<br>7" Top Display Suction Control Dials |
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# 2.7 Non-Clinical Tests Summary & Conclusion
The function and performance of the subject devices (Neptune S Waste Management System) have been evaluated through non-clinical design verification testing. The results of the evaluation tests demonstrate that the subject devices successfully meet the requirements of their intended use. A summary of the testing and the results are included in the table below.
| Test Item | Summary of Testing |
|--------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use/ User Needs | The subject devices were validated with intended users in simulated use tests to ensure the user needs and intended use requirements were met. All requirements were met and no new issues of safety or effectiveness were raised. |
| Safety | Verified the effectiveness of all risk controls determined in the device risk analysis. No new issues of safety or effectiveness were raised. |
| General Requirements and Performance | Verified all components against their design specifications. All requirements were met and no new issues of safety or effectiveness were raised. |
| Software | Software verification and validation testing was conducted as required by IEC 62304 and FDA guidance on general principles of software validation, January 11, 2002. All requirements were met and no new issues of safety or effectiveness were raised. |
| Electrical, Mechanical, and Thermal Safety | Verified conformance to IEC 60601-1: 2012, IEC 60601-1-6: 2013, IEC 60601-1-8: 2012, IEC 62366:2014 |
| Electromagnetic Compatibility | Verified conformance to IEC 60601-1-2: 2020, CISPR 11 Group 1, Class A requirements as well as additional testing to verify compatibility with RFID devices operating in the 125 - 134 kHz and 13.56 MHz frequency band. |
| Shipping | The functionality of the devices after simulated shipping conditions was verified. No new issues of safety or effectiveness were raised. |
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# 2.8 Clinical Test Summary &Conclusion
The safety and effectiveness of the subject devices in proposed indications for use have been evaluated using retrospective clinical data collected through Post Market Clinical Follow-up (PMCF) survey of predicate device (Neptune 3 Waste Management System) in colonoscopies, EGDs and bronchoscopies procedures. The predicate device performed as expected with no adverse event observed. The data showed 98.3% success rate of all waste fluid and debris removed and 94.7% without removing excess waste fluid and debris than planned. Analysis and evaluation of PMCF data shows that no safety issues or adverse events related to the use of the devices in the clinical procedures as stated in the indications for use.
#### 2.9 Conclusion
The subject device, Neptune S Waste Management System, including the Neptune S Rover and the V2 Manifolds, perform as intended and are at least as safe and effective their respective predicate devices with regard to intended use, design, principles of operation, technology, materials, and performance. No new issues of safety or effectiveness have been raised.
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Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
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.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
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.