K223550 · Del Medical, Inc. · KPR · Apr 10, 2023 · Radiology
Device Facts
Record ID
K223550
Device Name
DMX
Applicant
Del Medical, Inc.
Product Code
KPR · Radiology
Decision Date
Apr 10, 2023
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 892.1680
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The DMX is a radiographic system used in hospitals, clinics, and medical practices. The DMX enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult, and bariatric patients. It can also be used for intravenous, small interventions (like biopsy, punctures, etc.) and emergency (trauma, critically ill) applications. Exposures may be taken with the patient sitting, standing, or in the prone position. The DMX is not meant for mammography. The DMX can use a mobile (wireless) digital detector (not provided with system) for generating diagnostic images by converting x-rays into electronic signals. The DMX is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes
Device Story
DMX is a stationary radiographic x-ray system for hospitals/clinics. Inputs: x-ray radiation; system components include tube support, x-ray tube, radiographic table, wall stand, and collimator. Operation: generates diagnostic images via user-supplied digital detector, film/screen, or CR cassettes. Features include autotracking tube crane (on specific models) and motorized receptor. Operated by healthcare professionals. Output: diagnostic x-ray images for radiologist evaluation to inform treatment plans. Benefits: enables general-purpose radiographic imaging across diverse patient populations and clinical settings.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, verification, and validation of software, and compliance with FDA-recognized consensus standards (AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-1-6, IEC 60601-2-54).
Indicated for radiographic imaging of whole body (skull, chest, abdomen, extremities) in pediatric, adult, and bariatric patients. Includes intravenous, small interventions (biopsy, punctures), and emergency/trauma applications. Contraindicated for mammography.
Regulatory Classification
Identification
A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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Del Medical, Inc. % Daniel Kamm, P.E. Principal Engineer Kamm & Associates 8870 Ravello Ct Naples, Florida 34114
Re: K223550
Trade/Device Name: DMX Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary X-Ray System Regulatory Class: Class II Product Code: KPR Dated: November 24, 2022 Received: November 25, 2022
Dear Daniel Kamm:
We have reviewed vour 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
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statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-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,
# Digitally signed by Gabriela M. Rodal -S
For
Lu Jiang, Ph.D. Assistant Director DHT8B: Division of Imaging Devices and Electronic Products OHT8: Office of Radiological Health Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K223550
Device Name DMX
#### Indications for Use (Describe)
The DMX is a radiographic system used in hospitals, clinics, and medical practices. The DMX enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult, and bariatric patients. It can also be used for intravenous, small interventions (like biopsy, punctures, etc.) and emergency (trauma, critically ill) applications. Exposures may be taken with the patient sitting, standing, or in the prone position. The DMX is not meant for mammography. The DMX can use a mobile (wireless) digital detector (not provided with system) for generating diagnostic images by converting x-rays into electronic signals. The DMX is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes
Type of Use (Select one or both, as applicable)
| <span> <input checked="true" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) </span> |
|-----------------------------------------------------------------------------------------------------------|
| <span> <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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# 510(k) Summary: Del Medical, Inc. DMX X-Ray System, K223550
| Company: | Del Medical, Inc.<br>241 Covington Dr.<br>Bloomingdale, IL 60108 |
|----------|------------------------------------------------------------------|
|----------|------------------------------------------------------------------|
March 25, 2023 Date Prepared:
This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR §807.92.
#### 1. General Information:
Establishment/Manufacturer/Location of Manufacturing Site: Del Medical, Inc. 241 Covington Dr. Bloomingdale, IL 60108 Establishment Registration Number: 1418964
#### 2. Contact Person:
Greg Geary Director of Quality and Regulatory c/o Del Medical, Inc. 241 Covington Dr. Bloomingdale, IL 60108 Phone: 847-288-7021
#### 3. Device Name and Classification
| Trade Name: | DMX |
|----------------------------|-------------------------|
| Classification Name: | Stationary X-Ray System |
| Classification Panel: | Radiology |
| Classification Regulation: | 21 CFR §892.1680 |
| Device Class: | Class II |
| Product Code: | KPR |
#### 4. Legally Marketed Predicate Device
| 510(k) Number: | K152767 (DEL Medical) |
|----------------------------|-------------------------|
| Trade Name: | OTC12D Auto |
| Regulation Name: | Stationary X-Ray System |
| Classification Panel: | Radiology |
| Classification Regulation: | 21 CFR §892.1680 |
| Device Class: | Class II |
| Product Code: | KPR |
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#### 5. Indications for Use
The DMX is a radiographic system used in hospitals, clinics, and medical practices. The DMX enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities and may be used on pediatric, adult, and bariatric patients. It can also be used for intravenous, small interventions (like biopsy, punctures, etc.) and emergency (trauma, critically ill) applications. Exposures may be taken with the patient sitting, standing, or in the prone position. The DMX is not meant for mammography. The DMX can use a mobile (wired) or portable (wireless) digital detector (not provided with system) for generating diagnostic images by converting x-rays into electronic signals. The DMX is also designed to be used with conventional film/screen or Computed Radiography (CR) cassettes
#### 6. Device Description
The DMX System is a permanently-installed diagnostic x-ray system for general purpose radiographic imaging for use in hospitals, clinics, and medical practices. It is intended to produce diagnostic x-ray images of human anatomy.
The DMX System enables radiographic exposures of the whole body including: skull, chest, abdomen, and extremities, and may be used on pediatric, adult, and bariatric patients. Exposures may be taken with the patient sitting, standing, or in the prone position. The resultant images are evaluated by a radiologist within the diagnostic process prior to the development of a treatment plan. It is not intended for fluoroscopy, angiography, or mammography.
The DMX System typically includes a tube support, x-ray tube, radiographic table, radiographic wall stand, and collimator. Systems that include the overhead tube crane provide autotracking of the tube crane based on the position of the radiographic table or wall stand.
Below are the specific components in various configurations to form a radiographic system used for general purpose radiographic imaging (see Table 1). Note that the customer supplies their own digital x-ray panel. We do not supply it.
| DMX Part # | Description |
|------------|-------------------------------------------------------------|
| DM-OTC18S | Automatic stitching and tracking overhead tube crane system |
| DM-OTC18T | Automatic tracking overhead tube crane system |
| DM-OTC18M | Overhead tube crane system |
| DM-FMT18T | Automatic tracking floor mounted tube stand system |
| DM-FMT18M | Floor mounted tube stand system |
| DM-FMT | Basic floor mounted tube stand system |
| DM-FWFC | Basic floor to wall / floor to ceiling tube stand system |
| DM-SARM | Straight arm system |
#### Available System Variations
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| Structure Component | DM-OTC18S | DM-OTC18T | DM-OTC18M | DM-FMT18T | DM-FMT18M | DM-FMT | DM-FWFC | DM-SARM |
|------------------------------------------------|-----------|-----------|-----------|-----------|-----------|--------|---------|---------|
| OTC18S automatic stitching tube crane | X | | | | | | | |
| OTC18T automatic tracking tube crane | | X | | | | | | |
| OTC18M tube crane | | | X | | | | | |
| FMT18T automatic tracking tube stand | | | | X | | | | |
| FMT18M tube stand | | | | | X | | | |
| FMT basic tube stand | | | | | | X | | |
| FWFC floor-wall/ceiling basic tube stand | | | | | | | X | |
| Straight arm | | | | | | | | X |
| EV800T elevating table with motorized receptor | X | | | | | | | |
| EV800 elevating table | | X | X | X | X | X | X | |
| RT100 fixed height table | | | | | | X | X | |
| MT500 mobile table | | | X | | X | X | X | X |
| No table | | X | X | X | X | X | X | X |
| VT300T tilting wall stand with motor | X | | | | | | | |
| VT300 tilting wall stand | | X | X | X | X | X | X | |
| VS300 vertical wall stand | | | X | X | X | X | X | |
| VS100 basic vertical wall stand | | | | | | X | X | |
| No wall stand | | X | X | X | X | X | X | X |
### Tube Supports, Radiographic Tables, and Wall Stands Compatibility
#### Generator Availability
| Del Model | OEM | OEM Model |
|-------------|------------------------------------------|-----------------------------------------|
| CM Series | Communications and Power Industries Inc. | CMP200, 32, 40, 50 kW |
| CMDR Series | Communications and Power Industries Inc. | CMP200DR 40, 50, 65, 80 kW |
| AN Series | Del Medical | Anthem: 30, 32, 40, 50 kW |
| RF Series | Siemens | Polydoros / Polydoros ESU 55, 65, 80 kW |
#### 6. Substantial Equivalence
The DMX radiographic x-ray system is substantially equivalent to the commercially available OTC12D Auto (K152767) radiographic x-ray system with identical. indications for use. The OTC12D Auto was described in premarket notification K152767 which received FDA Clearance on December 14, 2015 (See Table below).
Subject and Predicate Device Comparable Properties:
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| Comparable<br>Properties | Predicate OTC12D Auto K152767 | Subject Device DMX System | Comparison<br>Results |
|-----------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------|
| Indications for<br>use | The OTC12D Auto System is a<br>radiographic system used in hospitals,<br>clinics, and medical practices. The<br>OTC12D Auto System enables<br>radiographic exposures of the whole<br>body including: skull, chest, abdomen,<br>and extremities and may be used on<br>pediatric, adult, and bariatric patients.<br>It can also be used for intravenous,<br>small interventions (like biopsy,<br>punctures, etc.) and emergency<br>(trauma, critically ill) applications.<br>Exposures may be taken with the<br>patient sitting, standing, or in the prone<br>position. The OTC12D Auto System is<br>not meant for mammography. The<br>OTC12D Auto System can use a mobile<br>(wired) or portable (wireless) digital<br>detector (not provided with system) for<br>generating diagnostic images by<br>converting x-rays into electronic<br>signals. The OTC12D Auto System is<br>also designed to be used with<br>conventional film/screen or Computed<br>Radiography (CR) cassettes. | The DMX System is a radiographic<br>system used in hospitals, clinics, and<br>medical practices. The DMX System<br>enables radiographic exposures of the<br>whole body including: skull, chest,<br>abdomen, and extremities and may be<br>used on pediatric, adult, and bariatric<br>patients. It can also be used for<br>intravenous, small interventions (like<br>biopsy, punctures, etc.) and<br>emergency (trauma, critically ill)<br>applications. Exposures may be taken<br>with the patient sitting, standing, or in<br>the prone position. The DMX System is<br>not meant for mammography. The<br>DMX System can use a mobile (wired)<br>or portable (wireless) digital detector<br>(not provided with system) for<br>generating diagnostic images by<br>converting x-rays into electronic<br>signals. The DMX System is also<br>designed to be used with conventional<br>film/screen or Computed Radiography<br>(CR) cassettes. | SAME |
| Tube<br>crane/Tube<br>stand | Overhead tube crane with manual<br>or automated x-ray tube assembly<br>movement. | Overhead tube crane with manual<br>or automated x-ray tube assembly<br>movement. | SAME |
| Wall stand | Manual vertical movable wall stand,<br>non-tiltable tray. | Manual vertical movable wall<br>stand, tiltable tray. | Better<br>Functionality |
| Table | Free-floating and height-adjustable,<br>maximum patient weight 800 lbs., | Free-floating and height-adjustable,<br>maximum patient weight 800 lbs.,. | Same |
| Available X-<br>ray tubes | Canon, Varex, or Siemens | Canon, Varex, or Siemens | SAME |
| Collimator | R221 (Ralco) or ML03, AL02<br>(Siemens) | R221 (Ralco) or ML03, AL02<br>(Siemens) | SAME |
| Available<br>X-ray<br>Generators | 32, 40, 50, 65, 80, 100 kW | 30, 32, 40, 50, 55, 60, 80 kW | Similar<br>range of<br>sizes |
| Comparable<br>Properties | Predicate OTC12D Auto K152767 | Subject Device DMX System | Comparison<br>Results |
| Wireless<br>detector | Supports various sizes of wireless<br>detectors (not provided with<br>system):<br>7" x 9.5"; 9.5" x 9.5";<br>10" x 12"; 14" x 17";<br>12" x 12"; 10" x 8";<br>14" x 14"; 17" x 17";<br>7" x 17" | SAME | SAME |
| Fixed<br>detector | Supports various sizes of fixed<br>detectors (not provided with<br>system):<br>7" x 9.5"; 9.5" x 9.5";<br>10" x 12"; 14" x 17";<br>12" x 12"; 10" x 8";<br>14" x 14"; 17" x 17";<br>7" x 17" | SAME | SAME |
| Conventional<br>film/screen<br>systems or<br>CR cassettes | Film/Screen or CR Cassettes. | Film/Screen or CR Cassettes. | SAME |
| Operator<br>console | GUI-based | GUI-based | SAME |
| System<br>Appearance<br>(Photo) | Image: OTC12D Auto K152767 | Image: Subject Device DMX System | Very similar<br>appearance,<br>same<br>functionality |
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## 7. Summary of Technological Characteristics of the Subject Device as Compared with the Predicate Device
The DMX System uses similar or identical radiographic x-ray system components to the predicate device. The differences in the subject device, such as the x-ray generator, radiographic table, wall stand, tube crane, collimator, and x-ray tube, do not affect the safety or effectiveness of the device. The DMX System can use a wireless or fixed flat panel detector (not provided with system) same models as the predicate device, and the differences do not adversely affect the safety or effectiveness of the radiographic x-ray
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system. The properties of the subject device presented in the comparison table above and described throughout this submission do not differ significantly from the legally marketed predicate device with regards to fundamental scientific technology, nor do they reflect a significant change in the indications for use. The differences between the subject device and the legally marketed predicate device have been assessed using Risk Management and through third-party evaluation using FDA-recognized consensus standards. The results of these efforts demonstrate that the device is as safe and effective as the predicate device and does not raise different questions of safety and effectiveness than the predicate.
## 8. Performance Testing
Del Medical claims conformance to a signed statement of performance standards. This submission contains performance data and test results to demonstrate conformance with special controls for medical devices containing software for a moderate level of concern per the FDA document Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, issued May 11, 2005. Testing for verification and validation of the device was found acceptable to support the claims of substantial equivalence.
The system was tested and certified to comply with the Radiation Safety Performance Standards of Title 21 of the CFR.
Cybersecurity controls have been implemented per the FDA Guidance: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices, Guidance for Industry and Food and Drug Administration Staff.
EMC, mechanical safety, and electrical safety were evaluated according to various FDA-recognized consensus standards (see Table below). In conclusion, the identified risk of EMC, mechanical, and electrical hazards was mitigated and is substantially equivalent to the predicate device in terms of safety and effectiveness. Clinical testing is not required for a determination of substantial equivalence.
Conformance to Consensus Standards: The Del Medical DMX radiographic x-ray system complies with the applicable portions of the following standards:
| Recognition<br>Number | Standard<br>Reference<br>Number | Standard Title and Edition |
|-----------------------|---------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 19-4 | AAMI<br>ES60601-1 | ANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and<br>A2:2010/(R)2012 (Consolidated Text) Medical electrical equipment - Part 1:<br>General requirements for basic safety and essential performance (IEC<br>60601-1:2005, MOD) |
| 19-8 | IEC<br>60601-1-2 | IEC60601-1-2 Edition 4.0 2014-02 Medical electrical equipment - Part 1-2:<br>General requirements for basic safety and essential performance -<br>Collateral Standard: Electromagnetic disturbances - Requirements and tests |
| 12-269 | IEC<br>60601-1-3 | IEC 60601-1-3 Edition 2.1 2013-04 Medical electrical equipment - Part 1-3:<br>General requirements for basic safety and essential performance -<br>Collateral Standard: Radiation protection in diagnostic X-ray equipment |
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| Recognition<br>Number | Standard<br>Reference<br>Number | Standard Title and Edition |
|-----------------------|---------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 5-89 | IEC<br>60601-1-6 | IEC 60601-1-6 Edition 3.1 2013-10 Medical electrical equipment - Part 1-6:<br>General requirements for basic safety and essential performance -<br>Collateral standard: Usability |
| 12-317 | IEC<br>60601-2-54 | IEC 60601-2-54 Edition 1.2 2018-06 CONSOLIDATED VERSION Medical<br>electrical equipment - Part 2-54: Particular requirements for the basic<br>safety and essential performance of X-ray equipment for radiography and<br>radioscopy |
## 9. General Safety and Effectiveness Concerns
Instructions for use are included within the device labeling, and the information provided will enable the user to operate the device in a safe and effective manner. Several safety features, including an emergency stop button, are incorporated into the system design. In addition, operation of the DMX System is continually monitored, and if an error occurs, the system functions will be blocked and an error message will be displayed. Furthermore, the intended operators of the DMX System are health care professionals familiar with and responsible for the x-ray examinations being performed. To minimize electrical, mechanical, and radiation hazards, Del Medical, Inc. adheres to recognized and established industry practice, and all equipment is subject to final performance testing.
#### 10. Conclusion as to Substantial Equivalence
The DMX System is intended for the same uses as the OTC12D Auto. It uses components similar to those cleared for the OTC12D Auto (e.g. tube crane/tube stand, table, x-ray tube, collimator, x-ray generator, operator console). It is Del Medical, Inc.'s opinion that the DMX System is substantially equivalent to the cleared predicate device, the OTC12D Auto.
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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.