K232227 · Neuwave Medical, Inc. · JAK · Apr 4, 2024 · Radiology
Device Facts
Record ID
K232227
Device Name
ABLATE-IQ
Applicant
Neuwave Medical, Inc.
Product Code
JAK · Radiology
Decision Date
Apr 4, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1750
Device Class
Class 2
Indications for Use
ABLATE-IQ™ assists physicians in identifying ablation targets, assessing proper ablation probe placement and visualizing treatment zones when used with the NEUWAVE Microwave Ablation System (NEUWAVE System). The software is not intended for diagnosis, to predict ablation volume, or to predict ablation success.
Device Story
ABLATE-IQ is CT image processing software resident on the NEUWAVE Microwave Ablation System. It connects to hospital PACS and CT scanners via DICOM to receive/send CT, PET, and MR images. Operated by physicians via a dedicated monitor and USB mouse, it provides 2D/3D image manipulation, ROI segmentation, probe detection, and image registration. New features in v3.2.0 include probe insertion path planning, proposed ablation zone visualization (based on ex-vivo animal data), and electronic reporting. The device assists in procedural planning and technical assessment of ablation probe placement relative to targets. It does not control the ablation system or probe output. By providing visual feedback and registration of pre- and post-ablation scans, it aids physicians in determining technical success of the ablation procedure.
Clinical Evidence
Bench testing only. Verification and validation testing performed per 21 CFR 820.30, including unit, integration, system-level, regression, and information security testing. Software passed all pre-determined acceptance criteria. No clinical data presented.
Technological Characteristics
Software-only device resident on the NEUWAVE Microwave Ablation System. Connectivity via DICOM protocol for PACS/CT/PET/MR integration. Features include 2D/3D image processing, deformable registration, and semi-automated ROI/probe identification. Cybersecurity controls include whitelisting, shell lockdown, firewall rules, Bitlocker, and remote code removal. Operates on a dedicated monitor with independent user interface.
Indications for Use
Indicated for physicians to identify ablation targets, assess ablation probe placement, and visualize treatment zones during procedures using the NEUWAVE Microwave Ablation System. Not for diagnosis, predicting ablation volume, or predicting ablation success.
Regulatory Classification
Identification
A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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April 4, 2024
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NeuWave Medical, Inc. % Allison Francis Regulatory Affairs Specialist 3529 Anderson Street MADISON, WI 53704
#### Re: K232227
Trade/Device Name: ABLATE-IQTM Regulation Number: 21 CFR 892.1750 Regulation Name: Computed Tomography X-Ray System Regulatory Class: Class II Product Code: JAK Dated: March 4, 2024 Received: March 4, 2024
Dear Allison Francis:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,
Lu Jiang
Lu Jiang, Ph.D. Assistant Director Diagnostic X-Ray Systems Team DHT8B: Division of Radiological Imaging Devices and Electronic Products OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
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### Indications for Use
510(k) Number (if known) K232227
Device Name ABLATE-IOTM
Indications for Use (Describe)
ABLATE-IO™ assists physicians in identifying ablation targets, assessing proper ablation probe placement and visualizing treatment zones when used with the NEUWAVE Microwave Ablation System (NEUWAVE System). The software is not intended for diagnosis, to predict ablation volume, or to predict ablation success.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the text 'K232227'. The text is in a simple, sans-serif font. The letters and numbers are all the same size and are evenly spaced. The 'K' is the only letter, and the rest of the text is numbers.
Image /page/3/Picture/1 description: The image shows the logo for NeuWave Medical. The logo consists of a green sphere with a white wave design on the left, followed by the text "NeuWave Medical" in a simple, sans-serif font. Below the company name, in smaller letters, it says "PART OF THE ETHICON™ FAMILY OF COMPANIES".
### 510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
Submission Sponsor: NeuWave Medical Inc. 3529 Anderson Street Madison, WI 53704
April 3, 2024
FDA Establishment# 3008769756
Date:
Submission Contact: Allison Francis Regulatory Affairs Specialist Phone: 508-728-7585 Email: afranc52@its.jnj.com
> Mohamed Shariff Director of Regulatory Affairs Phone: 856-449-9609 Email: msharif3@its.jnj.com
#### Device Identification
| Device Trade Name: | ABLATE-IQ TM |
|----------------------|-------------------------------------|
| Common Name: | System, X-Ray, Tomography, Computed |
| Classification Name: | Computed tomography x-ray system |
| Device Class: | Class II |
| Product Code: | JAK |
| CFR Section: | 21 CFR 892.1750 |
#### Predicate Device
ABLATE-IQ™ is substantially equivalent to the following currently marketed device: Predicate Device - Ablation Confirmation (K192427) NeuWave Medical, Inc.
#### Indications for Use
ABLATE-IQ™ assists physicians in identifying ablation targets, assessing proper ablation probe placement and visualizing treatment zones when used with the NEUWAVE Microwave Ablation System (NEUWA VE System). The software is not intended for diagnosis, to predict ablation volume, or to predict ablation success.
ABLATE-IQTM 510(k) Summary Page 1 of 10
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### Device Description
ABLATE-IQ™ formally known as Ablation Confirmation, is a Computed Tomography (CT) image processing software package available as an optional feature for use with the NEUWAVE System. ABLATE-IQ™ is resident on the NEUWAVE Microwave Ablation System and is accessible to the physicians via a second, dedicated monitor with its own user interface separate from the ablation user interface. ABLATE-IO™ functions are controlled via a USB connected mouse. ABLATE-IQ™ connects to a facility PACS system and CT scanner and receives and sends CT, fused PET and MR images via the DICOM protocol over the hospital network. DICOM enables the integration of scanners, servers, workstations, printers, and network hardware from multiple manufacturers into an electronic PACS.
ABLATE-IQTM contains a wide range of image processing tools, including:
- · 2D image manipulation
- · 3D image generation (from 2D images)
- · 3D image manipulation
- · Region of interest (ROI)/target identification, segmentation, and measurement
- · Image-based detection of ablation probes manually placed by the user (physician)
- · Registration of multiple images into a single view
### Modifications
This 510(k) was submitted to update the Ablation Confirmation software with the following modifications:
- · Planning (New Premium Feature that is optionally licensed for 3.2.0): Probe Insertion Path Planning is an optional feature that allows the user to pre-plan the location and trajectory of the probe(s) relative to a pre-defined target(s). Proposed Ablation Zone Display allows the user to try different combinations of time and power derived from ex-vivo animal tissue data to help users visualize proposed ablation zones with targets and does not provide a clinical representation of tissue to be ablated.
- · Reporting (New Premium Feature that is optionally licensed for 3.2.0): Generation of an electronic report containing procedural information (e.g., ablation time and power used), data related to the target, and the treatment zone dimensions is also a new optional software feature available. The resulting report can be stored to the Hospital PACS.
- · Workflow Updates (page combinations): Prior to 3.2.0, the software had ten steps the user was required to step through. In 3.2.0, the ABLATE-IQ™ navigation groups similar workflow steps together under 3 major workflow pages.
- · Profiles: The system can apply default settings for procedure selectable features and recall those in a procedure selectable way. The default settings do not control the NEUWAVE system nor probe output in any way.
- · Cybersecurity: New cybersecurity features were added for additional protection and compliance
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#### Comparison of Subject Device and Predicate Device
ABLATE-IQ™ software version 3.2.0 has the same or similar technological characteristics as the predicate device and therefore is substantially equivalent to the predicate device.
| Attribute | Subject Device<br>ABLATE-IQTM<br>K232227 | Predicate Device<br>Ablation Confirmation<br>K192427 | Comparison |
|--------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | NeuWave Medical | NeuWave Medical | Same |
| Product Code | JAK | JAK | Same |
| Regulation<br>Number | 892.1750 | 892.1750 | Same |
| Indications<br>for Use | ABLATE-IQTM assists<br>physicians in<br>identifying ablation<br>targets, assessing<br>proper ablation probe<br>placement and<br>visualizing treatment<br>zones when used with<br>the NEUWAVE<br>Microwave Ablation<br>System (NEUWAVE<br>System). The software<br>is not intended for<br>diagnosis, to predict<br>ablation volume, or to<br>predict ablation<br>success. | Ablation ConfirmationTM<br>(AC), is a Computed<br>Tomography (CT) image<br>processing software<br>package available as an<br>optional feature for use<br>with the NEUWAVE<br>Microwave Ablation<br>System. AC is controlled<br>by the user via an<br>independent user<br>interface on a second<br>monitor separate from<br>the NEUWAVE<br>Microwave Ablation<br>System user interface.<br>AC imports images from<br>CT scanners and facility<br>PACS systems for<br>display and processing<br>during ablation<br>procedures. AC assists<br>physicians in identifying<br>ablation targets,<br>assessing proper ablation<br>probe placement and<br>confirming ablation<br>zones. The software is<br>not intended for<br>diagnosis. | Same, the subject device<br>indications for use is the<br>same as the underlined text<br>from the predicate device.<br>The verbiage of the<br>Indications for Use of the<br>subject device is slightly<br>different than the declared<br>predicate as the text is<br>being reduced for clarity.<br>The change in verbiage<br>does not alter the intended<br>use of the device as<br>compared to the predicate<br>device. |
| Attribute | Subject Device<br>ABLATE-IQTM<br>K232227 | Predicate Device<br>Ablation Confirmation<br>K192427 | Comparison |
| Image<br>Acquisition | The system is capable<br>of retrieving CT image<br>data, conforming to the<br>DICOM standard.<br>Additionally, fused PET<br>images and MR images can<br>be imported for the<br>comparison scan feature. | The system is capable<br>of retrieving CT image<br>data, conforming to the<br>DICOM standard.<br>Additionally, fused PET<br>images and MR images can<br>be imported for the<br>comparison scan feature. | Same |
| 2D Image<br>Manipulation | The system provides tools<br>to manipulate the 2D<br>image data. The tool set<br>includes:<br>Window/LevelPan/ZoomImage ScrollingPoint<br>measurement<br>(HU and<br>coordinate)Distance<br>measurementRotation | The system provides tools<br>to manipulate the 2D<br>image data. The tool set<br>includes:<br>Window/LevelPan/ZoomImage ScrollingPoint<br>measurement<br>(HU and<br>coordinate)Distance<br>measurementRotation | Same |
| 3D Image<br>Generation | The system is able to<br>generate a 3D image<br>based upon the 2D<br>image series. | The system is able to<br>generate a 3D image<br>based upon the 2D<br>image series. | Same |
| 3D Image<br>Manipulation | The system provides tools<br>to manipulate the 3D<br>image rendering.<br>These tools include:<br>RotationPan/ZoomWindow/LevelDistance between tips<br>when multiple probes<br>are detected | The system provides tools<br>to manipulate the 3D<br>image rendering.<br>These tools include:<br>RotationPan/ZoomWindow/LevelDistance between tips<br>when multiple probes<br>are detected | Same |
| Attribute | Subject Device<br>ABLATE-IQTM | Predicate Device<br>Ablation Confirmation | Comparison |
| | K232227 | K192427 | |
| Region of<br>Interest (ROI)<br>Identification | The system allows the<br>user to semi-<br>automatically define<br>regions of interest on CT<br>images. A single- step<br>"undo" function was<br>added to this feature. | The system allows the<br>user to semi-<br>automatically define<br>regions of interest on CT<br>images. A single- step<br>"undo" function was<br>added to this feature. | Same |
| ROI<br>Measurements | The system allows the<br>user to assess the volume<br>of the defined ROIs. | The system allows the<br>user to assess the volume<br>of the defined ROIs. | Same |
| Desired Margin<br>Identification | The system allows the users<br>to draw on the ROI images<br>to visualize a user-<br>determined desired margin<br>for the ablation procedure. | The system allows the<br>users to draw on the ROI<br>images to visualize a user-<br>determined desired margin<br>for the ablation procedure. | Same |
| Registration | The system can perform<br>deformable registration on<br>two distinct CT images.<br>The user can manually<br>adjust the results of the<br>registration process.<br>Replaced 'Refine<br>Registration' capability<br>with a 'Manual<br>Registration' capability.<br>When using the manual<br>registration, the user has<br>the option of turning off<br>the deformations computed<br>by the deformable<br>registration. | The system can perform<br>deformable registration on<br>two distinct CT images.<br>The user can manually<br>adjust the results of the<br>registration process.<br>Replaced 'Refine<br>Registration' capability<br>with a 'Manual<br>Registration' capability.<br>When using the manual<br>registration, the user has<br>the option of turning off<br>the deformations computed<br>by the deformable<br>registration. | Same |
| Attribute | Subject Device<br>ABLATE-IQTM<br>K232227 | Predicate Device<br>Ablation Confirmation<br>K192427 | Comparison |
| Probe<br>Identification | The system can<br>automatically identify<br>ablation probes within the<br>scan. ABLATE-IQTM can<br>detect up to 3 probes.<br><br>The software also enables<br>the user to manually draw<br>probes. | The system can<br>automatically identify<br>ablation probes within the<br>scan. AC can detect up to<br>3 probes.<br><br>The software also enables<br>the user to manually draw<br>probes. | Same |
| Probe Placement<br>Assessment | The system, using the<br>deformable registration<br>process, can visualize the<br>position of the ablation<br>probe(s) in relation to the<br>ROI. | The system, using the<br>deformable registration<br>process, can visualize the<br>position of the ablation<br>probe(s) in relation to the<br>ROI. | Same |
| Ablation Zone<br>Assessment | Using the same process as<br>ROI identification, the<br>system allows the user to<br>semi- automatically<br>identify the ablation zone<br>following an ablation<br>procedure. | Using the same process as<br>ROI identification, the<br>system allows the user to<br>semi- automatically<br>identify the ablation zone<br>following an ablation<br>procedure. | Same |
| Allows User to<br>Account for<br>Tissue<br>Contraction | Yes | Yes | Same |
| Tissue<br>Contraction<br>Ranges - Liver | ABLATE-IQTM with<br>V3.2.0 SW allows users<br>to apply 0%, 10%, 15%,<br>20% or 30% tissue<br>contraction to identified<br>target during the<br>"Evaluate Ablation<br>Zone" step in the<br>workflow or<br>automatically based<br>upon default settings. | Ablation Confirmation<br>with V3.1.0 SW allows<br>users to apply 0%, 10%,<br>15%, 20% or 30%<br>tissue contraction to<br>identified target during<br>the "Evaluate Ablation<br>Zone" step in the<br>workflow or<br>automatically based<br>upon default settings. | Same |
| Attribute | Subject Device<br>ABLATE-IQTM<br>K232227 | Predicate Device<br>Ablation Confirmation<br>K192427 | Comparison |
| Tissue<br>Contraction<br>Ranges - Kidney | ABLATE-IQTM with<br>V3.2.0 SW allows users to<br>apply 0%, 10%, 15%,<br>20% or 30% tissue<br>contraction to identified<br>target during the<br>"Evaluate Ablation Zone"<br>step in the workflow or<br>automatically based upon<br>default settings. | Ablation Confirmation<br>with V3.1.0 SW allows<br>users to apply 0%, 10%,<br>15%, 20% or 30% tissue<br>contraction to identified<br>target during the<br>"Evaluate Ablation Zone"<br>step in the workflow or<br>automatically based upon<br>default settings. | Same |
| Tissue<br>Contraction<br>Ranges - Lung | ABLATE-IQTM with<br>V3.2.0 SW allows users to<br>apply 0%, 10%, 20%,<br>30%, 40% or 50%<br>tissue contraction to<br>identified target during<br>the "Evaluate Ablation<br>Zone" step in the<br>workflow or<br>automatically based<br>upon default settings | Ablation Confirmation<br>with V3.1.0 SW allows<br>users to apply 0%, 10%,<br>20%, 30%, 40% or 50%<br>tissue contraction to<br>identified target during<br>the "Evaluate Ablation<br>Zone" step in the<br>workflow or<br>automatically based<br>upon default settings. | Same |
| Assessing the<br>technical success<br>of the ablation<br>procedure | Using the same<br>deformable registration<br>process, image set with<br>ablation zone can be<br>overlaid onto the image<br>set with the initial ROI<br>segmentation to help<br>physicians determine the<br>technical success of an<br>ablation procedure.<br>Allow user to view the<br>Set Up scan next to the<br>Evaluate Ablation scan. | Using the same<br>deformable registration<br>process, image set with<br>ablation zone can be<br>overlaid onto the image<br>set with the initial ROI<br>segmentation to help<br>physicians determine the<br>technical success of an<br>ablation procedure.<br>Allow user to view the<br>Set Up scan next to the<br>Evaluate Ablation scan. | Same |
| Attribute | Subject Device<br>ABLATE-IQ™<br>K232227 | Predicate Device<br>Ablation Confirmation<br>K192427 | Comparison |
| Snapshots | User can take<br>snapshots of any view<br>and send to the facility<br>PACS for achieving, if<br>desired. | User can take snapshots<br>of any view and send to<br>the facility PACS for<br>achieving, if desired. | Same |
| Remote Viewing | No remote viewing<br>capability | No remote viewing<br>capability | Same |
| Orthogonal 2D<br>Viewing | Axial, Sagittal,<br>Coronal, "Needle" and<br>"Periscope"<br>presentation options. | Axial, Sagittal, Coronal,<br>"Needle" and<br>"Periscope" presentation<br>options. | Same |
| Workflow | 3 workflow pages<br>Prior to 3.2.0, the<br>software had ten steps<br>the user was required<br>to step through. In<br>3.2.0, the ABLATE-IQ™ navigation<br>groups similar<br>workflow steps<br>together under 3 major<br>workflow pages. | 10 workflow pages | Different |
| Reporting | New optional<br>reporting feature<br>added for version 3.2.0<br>software. | No reporting feature<br>available. | Different |
| Profiles | The system can apply<br>default settings for<br>procedure selectable<br>features and recall<br>those in a procedure<br>selectable way.<br>The default settings do<br>not control the<br>NEUWAVE system<br>nor probe output in<br>any way. | No profile feature<br>available. | Different |
| Planning | New optional feature<br>added for software<br>version 3.2.0. | No planning feature<br>available. | Different |
| Attribute | Subject Device<br>ABLATE-IQ™ | Predicate Device<br>Ablation Confirmation | Comparison |
| | K232227 | K192427 | |
| Cybersecurity | ABLATE-IQ™ V3.2.0<br>is a software only<br>device resident on the<br>NEUWAVE<br>Microwave Ablation<br>System. Cybersecurity<br>updates were made to<br>software V3.2.0 on the<br>NEUWAVE<br>Microwave Ablation<br>System. Cybersecurity<br>updates in V3.2.0<br>software on the<br>NEUWAVE<br>Microwave Ablation<br>System include:<br>● Whitelisting<br>Amendments<br>● Shell Lockdown<br>Amendments<br>● Firewall Rule<br>Amendments<br>● Bitlocker<br>● Remove Remote<br>Code<br>● Component<br>Removal<br>Cleanup | Ablation Confirmation<br>V3.1.0 is a software only<br>device resident on the<br>NEUWAVE Microwave<br>Ablation System.<br>Cybersecurity controls in<br>V3.1.0 software on the<br>NEUWAVE Microwave<br>Ablation System include:<br>● Whitelisting<br>● Shell Lockdown<br>● Firewall | Similar.<br>The NEUWAVE<br>Microwave Ablation<br>System software V3.2.0<br>includes new<br>cybersecurity features for<br>additional protection and<br>compliance. |
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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.