ulricheasyINJECT Max 2M (XD 10140); ulricheasyINJECT Max 3 (XD 10150); ulricheasyINJECT Max 3 (XD 10180)
Applicant
Ulrich GmbH & Co. KG
Product Code
IZQ · Cardiovascular
Decision Date
Apr 19, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.1650
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
ulricheasyINJECT Max 2M (XD 10140) / 3 (XD 10150 / XD 10180) is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in magnetic resonance (MR) applications. ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is specifically indicated for use in MRI procedures for the delivery of Clariscan (Gadoterate Meglumine) Injection, - GE Healthcare Inc. contrast media as supplied in approved single dose bottles. Easy-Click-Cassette – flex Max 2M and Easy-Click-Cassette – flex Max 3 are used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast media container is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling. Spike for MRI disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure. ulricheasyINJECT Max is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravasular administration of contrast agent. The ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is not intended for injection of contrast media (CM) for highpressure angiography. ulricheasyINJECT Max 3 (XD 10180) is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in magnetic resonance (MR) applications. ulricheasyINJECT Max 3 (XD 10180) is specifically indicated for use in MRI procedures for the delivery of VUEWAY™ (gadopiclenol), - Bracco Diagnostics Inc, MultiHance (gadobenate dimeglumine) – Bracco Diagnostics, Inc, Clariscan™ (Gadoterate Meglumine) Injection, - GE Healthcare Inc., Dotarem® (gadoterate meglumine) Injection - Guerbet, LLC, and Gadavist™ (gadobutrol) Injection, - Bayer HealthCare Pharmaceuticals Inc., contrast media as supplied in approved single dose vials. Easy-Click-Cassette - flex Max 3 is used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling. Spike for MRI disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure. ulricheasylNJECT Max 3 (XD 10180) is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravascular administration of contrast agent. The ulricheasyINJECT Max 3 (XD 10180) is not intended for injection of contrast media (CM) for high-pressure angiography.
Device Story
Syringeless contrast media management system for MRI; consists of mobile injector base with battery, touch terminal, and disposable tubing system (spikes, Easy-Click-Cassette, patient tubing). Peristaltic pump transports media from single-dose bottles to patient. Operated by trained healthcare professionals in radiological suites. Provides controlled, automatic delivery of contrast and saline. Includes air detection (optical refraction sensor), pressure regulation (piezo-resistive sensor), and check valves to prevent backflow/contamination. Output displayed on touch terminal; assists clinicians in managing contrast administration during diagnostic imaging. Benefits include automated, precise delivery and reduced risk of contamination.
Clinical Evidence
Bench testing only. Includes software verification/validation, electrical safety (IEC 60601-1), sterilization validation (ISO 11135), chemical compatibility with specific contrast agents, microbial ingress/cross-contamination studies, biocompatibility (ISO 10993-1), and performance testing (ISO 8536-4). Human factors/usability assessments performed in simulated use environment.
Indicated for controlled, automatic venous administration of contrast media and saline to human subjects undergoing diagnostic MRI examinations. Used by trained healthcare professionals in licensed facilities. Not for high-pressure angiography.
Regulatory Classification
Special Controls
*Classification.* Class II (special controls). The device, when it is a non-patient contacting balloon inflation syringe intended only to inflate/deflate balloon catheters and monitor pressure within the balloon, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.
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April 19, 2024
ulrich GmbH & Co. KG % Rita King Chief Executive Officer MethodSense, Inc. 1 Copley Pkwy. Suite 130 Morrisville, North Carolina 27560
Re: K233737
Trade/Device Name: ulricheasyINJECT Max 2M (XD 10140); ulricheasyINJECT Max 3 (XD 10150); ulricheasyINJECT Max 3 (XD 10180) Regulation Number: 21 CFR 870.1650 Regulation Name: Angiographic injector and syringe Regulatory Class: Class II Product Code: IZQ Dated: November 21, 2023 Received: March 21, 2024
Dear Rita King:
We have reviewed your section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (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.
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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).
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).
Sincerelv.
Juliane C. Lessard -S
Juliane C. Lessard, Ph.D. Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors
{2}------------------------------------------------
OHT3: Office of Gastrorenal, ObGyn, General Hospital, and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{3}------------------------------------------------
# Indications for Use
510(k) Number (if known) K233737
Device Name ulricheasyINJECT Max 2M (XD 10140); ulricheasyINJECT Max 3 (XD 10150): ulricheasyINJECT Max 3 (XD 10180)
### Indications for Use (Describe)
Indications for Use - ulricheasyINJECT Max System (Max 2M (XD 10140) and Max 3 (XD 10150)) ulricheasylNJECT Max System Max 2M (XD 10140) and Max 3 (XD 10150) is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in magnetic resonance (MR) applications.
ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is specifically indicated for use in MRI procedures for the delivery of Clariscan (Gadoterate Meglumine) Injection, - GE Healthcare Inc. contrast media as supplied in approved single dose bottles.
Easy-Click-Cassette – flex Max 2M and Easy-Click-Cassette – flex Max 3 are used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast media container is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling.
Spike for MRI disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.
ulricheasyINJECT Max is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravasular administration of contrast agent.
The ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is not intended for injection of contrast media (CM) for highpressure angiography.
### Indications for Use - ulricheasyINJECT Max 3 (XD 10180)
ulricheasyINJECT Max 3 (XD 10180) is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in magnetic resonance (MR) applications.
ulricheasyINJECT Max 3 (XD 10180) is specifically indicated for use in MRI procedures for the delivery of VUEWAY™ (gadopiclenol), - Bracco Diagnostics Inc, MultiHance (gadobenate dimeglumine) – Bracco Diagnostics, Inc, Clariscan™ (Gadoterate Meglumine) Injection, - GE Healthcare Inc., Dotarem® (gadoterate meglumine) Injection - Guerbet, LLC, and Gadavist™ (gadobutrol) Injection, - Bayer HealthCare Pharmaceuticals Inc., contrast media as supplied in approved single dose vials.
Easy-Click-Cassette - flex Max 3 is used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling.
Spike for MRI disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.
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ulricheasylNJECT Max 3 (XD 10180) is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravascular administration of contrast agent.
The ulricheasyINJECT Max 3 (XD 10180) is not intended for injection of contrast media (CM) for high-pressure angiography.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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## Summary of 510(k)
### Ulrich GmbH & Co. KG K233737
This 510(k) Summary is in conformance with 21CFR 807.92
| Submitter: | ulrich GmbH & Co. KG<br>Buchbrunnenweg 12<br>89081 Ulm<br>Germany<br>Phone: +49 731 9654-1714<br>Fax: +49 731 9654-2807 |
|------------------|-------------------------------------------------------------------------------------------------------------------------|
| Primary Contact: | Rita King, CEO<br>MethodSense, Inc.<br>Email: ritaking@methodsense.com<br>Phone: 919-313-3961<br>Fax: 919-313-3979 |
| Company Contact: | Sven Erdmann<br>Vice President of Technology - Regulatory |
| Device Name and Classification | |
|--------------------------------|----------------------------------------------------|
| Trade Name: | ulricheasyINJECT Max |
| Common Name: | Contrast Media Management System |
| Classification: | Class II |
| Regulation Number: | 21 CFR 870.1650, Angiographic Injector and Syringe |
| Classification Panel: | Cardiovascular Panel |
| Product Code: | IZQ |
### Predicate Device:
| | Predicate |
|---------------------------|----------------------------------------------------|
| Trade Name | ulrichINJECT CT motion |
| Common Name | Contrast Media Management System |
| 510(k) Submitter / Holder | Class II |
| 510(k) Number | K192872 |
| Regulation Number | 21 CFR 870.1650, Angiographic Injector and Syringe |
| Classification Panel | Cardiovascular Panel |
| Product Code | IZQ |
The predicate device has not been subject to a design-related recall.
### Device Description
ulricheasyINJECT Max is a syringeless contrast media management system that is designed for the controlled, automatic venous administration of contrast media in conjunction with physiological saline solution to human subjects underqoing diagnostic examinations in Magnetic Resonance Imaging (MRI or PET MRI).
The ulricheasyINJECT Max device consists of a terminal, injector, and tubing system. The injector is a mobile pedestal device that consists of an injector base with rechargeable battery. The tubing system is the only component that comes in contact with the patient and has indirect contact with the blood path of a patient for a limited duration (few minutes). The tubing system consists of the following three components:
- . Spikes,
{6}------------------------------------------------
- . Easy-Click-Cassette - flex
- . Patient Tubing
The ulricheasyINJECT Max uses a peristaltic pump as part of the injector which is designed to transport the media fluid through the tubing system (spikes, cassette, and patient tubing), ulricheasylNJECT Max is intended to be used with the following components that are not supplied with the system:
- Saline containers,
- Single-dose contrast media bottles, and .
- . Cannula.
ulricheasylNJECT Max is equipped with multiple hardware and software controls that work together for the safe operation of the intended use of the system. Controls include air detect the presence of air in the tubing system without direct contact with the medium, pressure controls to manage and regulate pressure inside the tubing system, and check valves to prevent backflow of media and avoid retrograde contamination.
The ulricheasyINJECT Max is provided in three models:
- . ulricheasyINJECT Max 2M (XD 10140),
- . ulricheasyINJECT Max 3 (XD 10150), and
- . ulricheasyINJECT Max 3 (XD 10180).
The Max 3 models have 3 media connection points: 1 NaCl and 2 Contrast Media connections. The Max 2M has 2 media connection points: 1 NaCl and 1 Contrast Media connections. Max 2M and Max 3 are technically identical except the different available media connection points.
### Indications for Use
### Indications for Use – ulricheasyINJECT Max System (Max 2M (XD 10140) and Max 3 (XD 10150))
ulricheasyINJECT Max System Max 2M (XD 10140) and Max 3 (XD 10150) is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCI), to human subjects undergoing diagnostic examinations in magnetic resonance (MR) applications.
ulricheasylNJECT Max 2M / 3 (XD 10140 / XD 10150) is specifically indicated for use in MRI procedures for the delivery of Clariscan (Gadoterate Meglumine) Injection, - GE Healthcare Inc. contrast media as supplied in approved single dose bottles.
Easy-Click-Cassette - flex Max 2M and Easy-Click-Cassette - flex Max 3 are used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast media container is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling.
Spike for MRI disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.
ulricheasyINJECT Max is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravascular administration of contrast agent.
The ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is not intended for injection of contrast media (CM) for high-pressure angiography.
Indications for Use – ulricheasyINJECT Max 3 (XD 10180)
{7}------------------------------------------------
ulricheasylNJECT Max 3 (XD 10180) is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCI), to human subjects undergoing diagnostic examinations in magnetic resonance (MR) applications.
ulricheasylNJECT Max 3 (XD 10180) is specifically indicated for use in MRI procedures for the delivery of VUEWAY™ (qadopiclenol), - Bracco Diagnostics Inc. MultiHance (gadobenate dimeqlumine) - Bracco Diagnostics, Inc, Clariscan™ (Gadoterate Meglumine) Injection, - GE Healthcare Inc., Dotarem® (gadoterate meglumine) Injection – Guerbet, LLC, and Gadavist™ (gadobutrol) Injection, - Bayer HealthCare Pharmaceuticals Inc., contrast media as supplied in approved single dose vials.
Easy-Click-Cassette - flex Max 3 is used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast media container is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling.
Spike for MRI disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.
ulricheasyINJECT Max 3 (XD 10180) is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravascular administration of contrast agent.
The ulricheasyINJECT Max 3 (XD 10180) is not intended for injection of contrast media (CM) for highpressure angiography.
## Predicate Device Comparison
ulricheasyINJECT Max is substantially equivalent to the ulrichINJECT CT Motion (K192872) by ulrich GmbH & Co. KG that is currently on the market.
{8}------------------------------------------------
# Comparative Analysis of the ulricheasyINJECT Max to the Predicate Device
| Characteristic | Subject Device<br>ulricheasyINJECT Max<br>(XD 10140 / XD 10150 / XD 10180)<br>(K233737) | Predicate Device<br>ulrichINJECT CT motion<br>(K192872) | Comparison |
|-------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | ulricheasyINJECT Max 2M (XD 10140) / 3 (XD<br>10150 / XD 10180) is a contrast media<br>management system that is indicated for the<br>controlled, automatic administration, on the<br>venous side, of contrast media and saline<br>(NaCl), to human subjects undergoing<br>diagnostic examinations | ulrichINJECT CT motion is a contrast media<br>management system that is intended for the<br>controlled, automatic administration, on the<br>venous side, of contrast media and saline<br>(NaCl), to human subjects undergoing<br>diagnostic examinations | Same |
| Indications for Use | ulricheasyINJECT Max 2M (XD 10140) / 3 (XD<br>10150)<br>ulricheasyINJECT Max 2M (XD 10140) / 3 (XD<br>10150) is a contrast media management<br>system that is indicated for the controlled,<br>automatic administration, on the venous side, of<br>contrast media and saline (NaCl), to human<br>subjects undergoing diagnostic examinations in<br>magnetic resonance (MR) applications.<br>ulricheasyINJECT Max 2M / 3 (XD 10140 / XD<br>10150) is specifically indicated for use in MRI<br>procedures for the delivery of Clariscan<br>(Gadoterate Meglumine) Injection, - GE<br>Healthcare Inc. contrast media as supplied in<br>approved single dose bottles.<br>Easy-Click-Cassette - flex Max 2M and Easy-<br>Click-Cassette – flex Max 3 are used for a<br>maximum time of twenty four (24) hours or a<br>maximum of 96 bottles of contrast media, or<br>whichever comes first. Use time expiration per<br>single dose contrast media container is a<br>maximum of four (4) hours per contrast media<br>container, unless otherwise stated by the<br>contrast media labeling.<br>Spike for MRI disposable is for single-bottle use<br>only and must be discarded with the media | ulrichINJECT CT motion is a contrast media<br>management system that is indicated for the<br>controlled, automatic administration, on the<br>venous side, of contrast media and saline<br>(NaCl), to human subjects undergoing<br>diagnostic examinations in computed<br>tomography (CT) applications.<br>ulrichINJECT CT motion is specifically<br>indicated for use in CT procedures for the<br>delivery of Omnipaque™ (Iohexol) Injection,<br>solution - GE Healthcare Inc. contrast media<br>as supplied in Imaging Bulk Packages (IBP),<br>Omnipaque™ (Iohexol) Injection, solution - GE<br>Healthcare Inc., and Visipaque™ (iodixanol)<br>Injection - GE Healthcare Inc. contrast media<br>as supplied in single dose bottles.<br>Pump tubing-flex is used for a maximum time<br>of twenty four (24) hours. When used with<br>Omnipaque™ IBP, Omnipaque™ single dose<br>bottles, or Visipaque™ single dose bottles, a<br>maximum of 19 bottles of contrast media can<br>be used or maximum time of twenty four (24)<br>hours of Pump tubing-flex, or whichever<br>comes first. Time per contrast media or saline<br>container depends on each contrast media's<br>or saline's use time expiration with a maximum | Different - This difference does not<br>change the intended use of the<br>device. The safety and effectiveness<br>of the ulricheasyINJECT Max has<br>been confirmed through MR<br>compatibility testing, chemical<br>compatibility testing, and Safety /<br>EMC testing. |
| Characteristic | Subject Device | Predicate Device | Comparison |
| | ulricheasyINJECT Max<br>(XD 10140 / XD 10150 / XD 10180) | ulrichINJECT CT motion<br>(K192872) | |
| | (K233737) | | |
| | container. The Patient tubing must be | of eight (8) hours per contrast media or saline | |
| | discarded after each patient procedure. | container. | |
| | ulricheasyINJECT Max 2M / 3 (XD 10140 / XD<br>10150) is to be used only by and under quasi-<br>continuous supervision of trained healthcare<br>professionals in an appropriate licensed<br>healthcare facility, in a room designated for<br>radiological procedures that involve<br>intravascular administration of contrast agent.<br>The ulricheasyINJECT Max 2M / 3 (XD 10140 /<br>XD 10150) is not intended for injection of<br>contrast media (CM) for high-pressure<br>angiography. | Spike for CT disposable is for single-bottle use<br>only and must be discarded with the media<br>container. The Patient tubing must be<br>discarded after each patient procedure.<br>ulrichINJECT CT motion is to be used only by<br>and under quasi-continuous supervision of<br>trained healthcare professionals in an<br>appropriate licensed healthcare facility, in a<br>room designated for radiological procedures<br>that involve intravascular administration of<br>contrast agent. | |
| | ulricheasyINJECT Max 3 (XD 10180)<br>ulricheasyINJECT Max 3 (XD 10180) is a<br>contrast media management system that is<br>indicated for the controlled, automatic<br>administration, on the venous side, of contrast<br>media and saline (NaCl), to human subjects<br>undergoing diagnostic examinations in<br>magnetic resonance (MR) applications. | | |
| | ulricheasyINJECT Max 3 (XD 10180) is<br>specifically indicated for use in MRI procedures<br>for the delivery of VUEWAY™ (gadopiclenol)<br>Injection - Bracco Diagnostics, Inc., MultiHance<br>(gadobenate dimeglumine) - Bracco<br>Diagnostics, Inc, Clariscan™ (Gadoterate<br>Meglumine) Injection, - GE Healthcare Inc.,<br>Dotarem® (gadoterate meglumine) Injection -<br>Guerbet, LLC, and Gadavist™ (gadobutrol)<br>Injection, - Bayer HealthCare Pharmaceuticals<br>Inc., contrast media as supplied in approved<br>single dose vials. | | |
| | Easy-Click-Cassette - flex Max 3 is used for a<br>maximum time of twenty four (24) hours or a<br>maximum of 96 bottles of contrast media, or | | |
| Characteristic | Subject Device<br>ulricheasyINJECT Max<br>(XD 10140 / XD 10150 / XD 10180)<br>(K233737) | Predicate Device<br>ulrichINJECT CT motion<br>(K192872) | Comparison |
| | whichever comes first. Use time expiration per<br>single dose contrast media container is a<br>maximum of four (4) hours per contrast media<br>container, unless otherwise stated by the<br>contrast media labeling.<br>Spike for MRI disposable is for single-bottle use<br>only and must be discarded with the media<br>container. The Patient tubing must be<br>discarded after each patient procedure.<br>ulricheasyINJECT Max 3 (XD 10180) is to be<br>used only by and under quasi-continuous<br>supervision of trained healthcare professionals<br>in an appropriate licensed healthcare facility, in<br>a room designated for radiological procedures<br>that involve intravascular administration of<br>contrast agent. | | |
| | The ulricheasyINJECT Max 3 (XD 10180) is<br>not intended for injection of contrast media<br>(CM) for high-pressure angiography. | | |
| Product Codes | | | |
| Product Codes | IZQ<br>(21 CFR 870.1650) | IZQ<br>(21 CFR 870.1650) | Same |
| Device Use | | | |
| Environment of<br>Use | MR Environment | CT Environment | Different - This difference does not<br>change the intended use of the<br>device. The safety and effectiveness<br>of the ulricheasyINJECT Max has<br>been confirmed through MR<br>compatibility testing, chemical<br>compatibility testing, and Safety /<br>EMC testing. |
| Physical | | | |
| System | Injector Head<br>Touch Terminal | Injector Head<br>Touch Terminal | Same |
| Characteristic | Subject Device<br>ulricheasyINJECT Max<br>(XD 10140 / XD 10150 / XD 10180)<br>(K233737) | Predicate Device<br>ulrichINJECT CT motion<br>(K192872)…
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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.