Validation dataset of EEG recordings from 191 adult patients (181 with seizures, 10 controls) across three independent medical institutions
3 (EEG trained neurologists)
Spike Detection
Deep learning-based algorithm
Upper limit of 95% CI for difference in sensitivity < 15%; lower limit of 95% CI for difference in FDR > -1.5 per minute
Sensitivity: 72.18% [66.81, 77.54]; FDR: 3.24 [2.15, 4.33] per minute
—
—
Validation dataset of EEG recordings from 149 adult patients across three independent medical institutions
3 (EEG trained neurologists)
Indications for Use
LVIS NeuroMatch Software is intended for the review, monitoring and analysis of electroencephalogram (EEG) recordings made by EEG devices using scalp electrodes and to aid neurologists in the assessment of EEG. The device is intended to be used by qualified medical practitioners who will exercise professional judgement in using the information. The Seizure Detection component of LVIS NeuroMatch is intended to mark previously acquired sections of adult EEG recordings from patients greater than or equal to 18 years old that may correspond to electrographic seizures, in order to assist qualified medical practitioners in the assessment of EEG traces. EEG recordings should be obtained with a full scalp montage according to the electrodes from the International Standard 10-20 placement. The Spike Detection component of LVIS NeuroMatch is intended to mark previously acquired sections of adult EEG recordings from patients >18 years old that may correspond to spikes, in order to assist qualified medical practitioners in the assessment of EEG traces. LVIS NeuroMatch Spike Detection performance has not been assessed for intracranial recordings. LVIS NeuroMatch includes the calculation and display of a set of quantitative measures intended to monitor and analyze EEG waveforms. These include Artifact Strength, Asymmetry Spectrogram, and Fast Fourier Transform (FFT) Spectrogram. These quantitative EEG measures should always be interpreted in conjunction with review of the original EEG waveforms. LVIS NeuroMatch displays physiological signals such as electrocardiogram (ECG/EKG) if it is provided in the EEG recording. The aEEG functionality included in LVIS NeuroMatch is intended to monitor the state of the brain. LVIS NeuroMatch Artifact Reduction (AR) is intended to reduce muscle and eye movements, in EEG signals from the International Standard 10-20 placement. AR does not remove the entire artifact signal and is not effective for other types of artifacts. AR may modify portions of waveforms representing cerebral activity. Waveforms must still be read by a qualified medical practitioner trained in recognizing artifacts, and any interpretation or diagnosis must be made with reference to the original waveforms. This device does not provide any diagnostic conclusion about the patient's condition to the user.
Device Story
NeuroMatch is a cloud-based SaMD for reviewing, monitoring, and analyzing previously acquired or near real-time EEG data. Input consists of EEG recordings (10-20 scalp montage) and optional ECG signals. The device uses deep learning algorithms to perform artifact reduction, seizure detection, and spike detection, and calculates quantitative measures (FFT, spectrograms, aEEG). Output is displayed to neurologists/qualified practitioners as annotated EEG traces and quantitative metrics. The device does not provide diagnostic conclusions; clinicians must interpret outputs in conjunction with original waveforms. It assists in identifying potential electrographic seizures and spikes, potentially improving clinical efficiency in EEG review and patient monitoring.
Clinical Evidence
Clinical validation used independent datasets from three institutions. Seizure detection (N=191 subjects, 1059.4 hours) showed 75.01% sensitivity and 3.74 FDR/24hr, meeting non-inferiority criteria against Persyst 14. Spike detection (N=149 subjects, 45.9 hours) showed 72.18% sensitivity and 3.24 FDR/min, meeting non-inferiority criteria. Reference standards were established by a panel of three neurologists using a 2/3 majority rule. Testing confirmed non-inferiority in both sensitivity and false detection rates.
Technological Characteristics
Cloud-based SaMD; utilizes deep learning-based algorithms for event detection. Compatible with standard 10-20 scalp EEG electrode placement. Provides quantitative EEG measures (FFT, spectrograms, artifact strength) and artifact reduction. Operates on previously acquired or near real-time EEG data. No hardware components; software-only.
Indications for Use
Indicated for review, monitoring, and analysis of EEG recordings in adults (≥18 years) using scalp electrodes (10-20 system). Includes seizure and spike detection, quantitative EEG measures (Artifact Strength, Spectrograms, FFT), aEEG, and artifact reduction. Intended for use by qualified medical practitioners to aid in EEG assessment. Not for intracranial recordings.
Regulatory Classification
Identification
An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.
Predicate Devices
Persyst 14, EEG Review and Analysis Software (K182181)
Submission Summary (Full Text)
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a symbol representing the Department of Health & Human Services - USA. To the right of this symbol, there is the FDA logo in blue, with the words "U.S. FOOD & DRUG" stacked on top of the word "ADMINISTRATION".
November 26, 2024
LVIS Corporation % Devjani Saha, PhD Director, Neurology Regulatory Affairs MCRA, Llc 803 7th St NW. 3rd Floor Washington, District of Columbia 20001
Re: K241390
Trade/Device Name: NeuroMatch Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: Class II Product Code: OMB, OLT, OMA Dated: October 24, 2024 Received: October 25, 2024
Dear Devjani Saha:
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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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 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-regulatory
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assistance/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,
Patrick Antkowiak -S
for Jay Gupta Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional, and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K241390
Device Name NeuroMatch
### Indications for Use (Describe)
1. LVIS NeuroMatch Software is intended for the review, monitoring and analysis of electroencephalogram (EEG) recordings made by EEG devices using scalp electrodes and to aid neurologists in the assessment of EEG. The device is intended to be used by qualified medical practitioners who will exercise professional judgement in using the information.
2. The Seizure Detection component of LVIS NeuroMatch is intended to mark previously acquired sections of adult EEG recordings from patients greater than or equal to 18 years old that may correspond to electrographic seizures, in order to assist qualified medical practitioners in the assessment of EEG traces. EEG recordings should be obtained with a full scalp montage according to the electrodes from the International Standard 10-20 placement.
3. The Spike Detection component of LVIS NeuroMatch is intended to mark previously acquired sections of adult EEG recordings from patients >18 years old that may correspond to spikes, in order to assist qualified medical practitioners in the assessment of EEG traces. LVIS NeuroMatch Spike Detection performance has not been assessed for intracranial recordings.
4. LVIS NeuroMatch includes the calculation and display of a set of quantitative measures intended to monitor and analyze EEG waveforms. These include Artifact Strength, Asymmetry Spectrogram, and Fast Fourier Transform (FFT) Spectrogram. These quantitative EEG measures should always be interpreted in conjunction with review of the original EEG waveforms.
5. LVIS NeuroMatch displays physiological signals such as electrocardiogram (ECG/EKG) if it is provided in the EEG recording.
6. The aEEG functionality included in LVIS NeuroMatch is intended to monitor the state of the brain.
7. LVIS NeuroMatch Artifact Reduction (AR) is intended to reduce muscle and eye movements, in EEG signals from the International Standard 10-20 placement. AR does not remove the entire artifact signal and is not effective for other types of artifacts. AR may modify portions of waveforms representing cerebral activity. Waveforms must still be read by a qualified medical practitioner trained in recognizing artifacts, and any interpretation or diagnosis must be made with reference to the original waveforms.
8. This device does not provide any diagnostic conclusion about the patient's condition to the user.
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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# 510(k) Summary
### Applicant Information:
LVIS Corporation 2600 E. Bayshore Rd., Palo Alto, CA 94303
### Contact Person:
Sweta Srivastava Head of Regulatory Affairs Email: ssrivastava@lviscorp.com Phone: 415-997-7337
### Device Information:
| Trade Name: | NeuroMatch |
|----------------------|---------------------------------------------------------------------------|
| Common Name: | Automatic Event Detection Software For Full-Montage Electroencephalograph |
| Classification Name: | Electroencephalograph (21CFR 882.1400) |
| Device Class: | II |
| Product Code: | OMB, OLT, OMA |
### Predicate Device:
Persyst 14, EEG Review and Analysis Software, K182181
### Date Prepared:
November 25, 2024
### Device Description:
NeuroMatch is a cloud-based software as a medical device (SaMD) intended to review, monitor, display, and analyze previously acquired and/or near real-time electroencephalogram (EEG) data from patients 18 years old or older. The device is not intended to substitute for real-time monitoring of EEG. The software includes advanced algorithms that perform artifact reduction, seizure detection, and spike detection.
The subject device is identical to the NeuroMatch device cleared under K222450, with exception of the following additional features:
- 1. Spike detection;
- 2. Seizure detection;
Seizure and spike detection are substantially equivalent to the Persyst 14 device (K182181: Predicate). Apart from the proposed additional software changes and associated changes to the Indications for Use and labeling, there are no changes to the intended use or to the software features that were previously cleared. Below is a description of the software functions that will be added to the cleared NeuroMatch Device.
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# 1. Spike Detection
NeuroMatch Spike Detection identifies both spike waves and sharp waves. The NeuroMatch Spike Detection feature uses a deep learning-based algorithm that detects potential epileptiform spikes and annotates each detected potential spike with a unique identification. The detection of spikes in the EEG data is automatically triggered when an EEG file is uploaded by the user. The NeuroMatch Spike Detection feature identifies spikes and displays the spikes based upon the order (time) when the spike occurred.
## 2. Seizure Detection
The NeuroMatch Seizure Detection feature uses a deep learning-based algorithm to identify potential seizure events and annotates each detected potential seizure with a unique identification. Each annotation includes the start and end positions of the potential identified seizures.
## Indications for Use:
- 1. LVIS NeuroMatch Software is intended for the review, monitoring and analysis of electroencephalogram (EEG) recordings made by EEG devices using scalp electrodes and to aid neurologists in the assessment of EEG. The device is intended to be used by qualified medical practitioners who will exercise professional judgement in using the information.
- 2. The Seizure Detection component of LVIS NeuroMatch is intended to mark previously acquired sections of adult EEG recordings from patients greater than or equal to 18 years old that may correspond to electrographic seizures, in order to assist qualified medical practitioners in the assessment of EEG traces. EEG recordings should be obtained with a full scalp montage according to the electrodes from the International Standard 10-20 placement.
- 3. The Spike Detection component of LVIS NeuroMatch is intended to mark previously acquired sections of adult EEG recordings from patients ≥18 years old that may correspond to spikes, in order to assist qualified medical practitioners in the assessment of EEG traces. LVIS NeuroMatch Spike Detection performance has not been assessed for intracranial recordings.
- 4. LVIS NeuroMatch includes the calculation and display of a set of quantitative measures intended to monitor and analyze EEG waveforms. These include Artifact Strength, Asymmetry Spectrogram, Autocorrelation Spectrogram, and Fast Fourier Transform (FFT) Spectrogram. These quantitative EEG measures should always be interpreted in conjunction with review of the original EEG waveforms.
- 5. LVIS NeuroMatch displays physiological signals such as electrocardiogram (ECG/EKG) if it is provided in the EEG recording.
- 6. The aEEG functionality included in LVIS NeuroMatch is intended to monitor the state of the brain.
- 7. I VIS NeuroMatch Artifact Reduction (AR) is intended to reduce muscle and eye movements, in EEG signals from the International Standard 10-20 placement. AR does not remove the entire artifact signal and is not effective for other types of artifacts. AR may modify portions of waveforms representing cerebral activity. Waveforms must still be read by a qualified medical practitioner trained in recognizing artifacts, and any interpretationor diagnosis must be made with reference to the original waveforms.
- This device does not provide any diagnostic conclusion about the patient's condition to the user. 8.
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# Comparison of Intended Use and Technological Characteristics with the Predicate Devices:
# TABLE 1: NEUROMATCH SUBSTANTIAL EQUIVALENCE TABLE
| Device | NeuroMatch<br>(Proposed Device)<br>K241390<br>LVIS | Persyst 14 EEG Review and<br>Analysis Software<br>(Predicate Device)<br>K182181<br>Persyst Development<br>Corporation | Rationale for<br>Substantial<br>Equivalence | |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|
| Classification | 21 CFR§882.1400,<br>Electroencephalograph | 21 CFR§882.1400,<br>Electroencephalograph | Same<br>classification as<br>the Predicate<br>device. | |
| Product Code | OMB, OLT, OMA | OMB, OLT, OMA | Same product<br>code as the<br>Predicate device. | |
| Indications for Use:<br>For the subject device new<br>indications are highlighted<br>in bold while previously<br>cleared indications are in<br>normal font. | 1. LVIS NeuroMatch<br>Software is intended for<br>the review, monitoring<br>and analysis of<br>electroencephalogram<br>(EEG) recordings made<br>by EEG devices using<br>scalp electrodes and to<br>aid neurologists in the<br>assessment of EEG. The<br>device is intended to be<br>used by qualified medical<br>practitioners who will<br>exercise professional<br>judgment in using the<br>information.<br><br>2. The Seizure Detection<br>component of LVIS<br>NeuroMatch is intended<br>to mark previously<br>acquired sections of<br>adult EEG recordings<br>from patients greater<br>than or equal to 18<br>years old that may<br>correspond to<br>electrographic seizures. | 1. Persyst 14 EEG Review<br>and Analysis Software is<br>intended for the review,<br>monitoring and analysis<br>of EEG recordings made<br>by electroencephalogram<br>(EEG) devices using<br>scalp electrodes and to<br>aid neurologists in the<br>assessment of EEG. The<br>device is intended to be<br>used by qualified medical<br>practitioners who will<br>exercise professional<br>judgment in using the<br>information.<br><br>2. The Seizure Detection<br>component of Persyst 14<br>is intended to mark<br>previously acquired<br>sections of adult (greater<br>than or equal to 18 years)<br>EEG recordings that may<br>correspond to<br>electrographic seizures, in<br>order to assist qualified<br>clinical practitioners in | The Proposed<br>Device and the<br>Predicate, have<br>similar<br>Indications for<br>Use. The<br>Proposed<br>Device's<br>Indications for<br>Use was<br>developed to<br>incorporate<br>wording from<br>the predicate<br>device. | |
| Device | NeuroMatch<br>(Proposed Device)<br>K241390<br>LVIS | Persyst 14 EEG Review and<br>Analysis Software<br>(Predicate Device)<br>K182181<br>Persyst Development<br>Corporation | Rationale for<br>Substantial<br>Equivalence | |
| | in order to assist<br>qualified medical<br>practitioners in the<br>assessment of EEG<br>traces. EEG recordings<br>should be obtained with<br>a full scalp montage<br>according to the<br>electrodes from the<br>International Standard<br>10-20 placement. | the assessment of EEG<br>traces. EEG recordings<br>should be obtained with a<br>full scalp montage<br>according to the standard<br>10/20 system. | | |
| | 3. The Spike Detection<br>component of LVIS<br>NeuroMatch is intended<br>to mark previously<br>acquired sections of<br>adult EEG recordings<br>from patients ≥18 years<br>old that may<br>correspond to spikes, in<br>order to assist qualified<br>medical practitioners in | 3. The Spike Detection<br>component of Persyst 14<br>is intended to mark<br>previously acquired<br>sections of the patient's<br>EEG recordings that may<br>correspond to spikes, in<br>order to assist qualified<br>clinical practitioners in<br>the assessment of EEG<br>traces. The Spike<br>Detection component is<br>intended to be used in<br>patients at least one<br>month old. Persyst 14<br>Spike Detection<br>performance has not been | | |
| | the assessment of EEG<br>traces. LVIS<br>NeuroMatch Spike<br>Detection performance<br>has not been assessed<br>for intracranial<br>recordings. | assessed for intracranial<br>recordings. | | |
| | 4. LVIS NeuroMatch<br>includes the calculation<br>and display of a set of<br>quantitative measures<br>intended to monitor and<br>analyze EEG waveforms.<br>These include Artifact | 4. Persyst 14 includes the<br>calculation and display of<br>a set of qualitative<br>measures intended to<br>monitor and analyze the<br>EEG waveform. These<br>include FFT,<br>Rhythmicity, Peak<br>Envelope, Artifact<br>Intensity, Amplitude,<br>Relative Symmetry and<br>Suppression Ratio.<br>Automatic event marking | | |
| Device | NeuroMatch<br>(Proposed Device)<br>K241390<br>LVIS | Persyst 14 EEG Review and<br>Analysis Software<br>(Predicate Device)<br>K182181<br>Persyst Development<br>Corporation | Rationale for<br>Substantial<br>Equivalence | |
| | Strength, Asymmetry<br>Spectrogram,<br>Autocorrelation<br>Spectrogram, and Fast<br>Fourier Transform (FFT)<br>Spectrogram. These<br>quantitative EEG<br>measures should always<br>be interpreted in<br>conjunction with review<br>of the original EEG<br>waveforms.<br><br>5. LVIS NeuroMatch<br>displays physiological<br>signals such as<br>electrocardiogram<br>(ECG/EKG) if it is<br>provided in the EEG<br>recording.<br><br>6. The aEEG functionality<br>included in LVIS<br>NeuroMatch is intended<br>to monitor the state of the<br>brain.<br><br>7. LVIS NeuroMatch<br>Artifact Reduction (AR)<br>is intended to reduce<br>muscle and eye<br>movements, in EEG<br>signals from the<br>International Standard<br>10-20 placement. AR<br>does not remove the<br>entire artifact signal and<br>is not effective for other<br>types of artifacts. AR<br>may modify portions of<br>waveforms representing | is not applicable to the<br>quantitative measures.<br>These quantitative EEG<br>measures should always<br>be interpreted in<br>conjunction with review<br>of the original EEG<br>waveforms.<br><br>5. Persyst 14 displays<br>physiological signals,<br>including the calculation<br>and display of a heart rate<br>measurement based on<br>the ECG channel in the<br>EEG recording, which are<br>intended to aid in the<br>analysis of an EEG.<br>Heart rate measurement<br>of Persyst 14 is not<br>applicable to patients with<br>pacemaker and/or active<br>implantable devices.<br><br>6. The aEEG functionality<br>included in Persyst 14 is<br>intended to monitor the<br>state of the brain. The<br>automated event marking<br>function of Persyst 14 is<br>not applicable to aEEG.<br><br>7. Persyst 14 provides<br>notifications for seizure<br>detection, quantitative<br>EEG and aEEG that can<br>be used when processing<br>a record during<br>acquisition. These<br>include an on screen<br>display and the optional | | |
| Device | NeuroMatch<br>(Proposed Device)<br>K241390<br>LVIS | Persyst 14 EEG Review and<br>Analysis Software<br>(Predicate Device)<br>K182181<br>Persyst Development<br>Corporation | Rationale for<br>Substantial<br>Equivalence | |
| | cerebral activity.<br>Waveforms must still be<br>read by a qualified<br>medical practitioner<br>trained in recognizing<br>artifacts, and any<br>interpretation or<br>diagnosis must be made<br>with reference to the<br>original waveforms.<br>8. This device does not<br>provide any diagnostic<br>conclusion about the<br>patient's condition to the<br>user. | sending of an email<br>message. Delays of up to<br>several minutes can occur<br>between the beginning of<br>a seizure and when the<br>Persyst 14 notifications<br>will be shown to a user.<br>Persyst 14 notifications<br>cannot be used as a<br>substitute for real time<br>monitoring of the<br>underlying EEG by a<br>trained expert.<br>8. Persyst AR (Artifact<br>Reduction) is intended to<br>reduce EMG, eye<br>movement, and electrode<br>artifacts in a standard 10-<br>20 EEG recording. AR<br>does not remove the<br>entire artifact signal, and<br>is not effective for other<br>types of artifacts. AR<br>may modify portions of<br>waveforms representing<br>cerebral activity.<br>Waveforms must still be<br>read by a qualified<br>medical practitioner<br>trained in recognizing<br>artifact, and any<br>interpretation or diagnosis<br>must be made with<br>reference to the original<br>waveforms.<br>9. This device does not<br>provide any diagnostic | | |
| Device | NeuroMatch<br>(Proposed Device)<br>K241390<br>LVIS | Persyst 14 EEG Review and<br>Analysis Software<br>(Predicate Device)<br>K182181<br>Persyst Development<br>Corporation | Rationale for<br>Substantial<br>Equivalence | |
| | | patient's condition to the<br>user. | | |
| Prescription/<br>Over-the-Counter | Rx | Rx | Same as the<br>Predicate device. | |
| Patient Population | Individuals ≥18 years<br>undergoing EEG assessment | Adults and pediatric patients<br>undergoing EEG assessment:<br>Seizure detection:<br>- Individuals ≥18 years<br>- Spike detection at<br>least one month old | Similar, the<br>Proposed Device<br>age group of at<br>least 18 years<br>old for seizure<br>detection is the<br>same as the<br>predicate device.<br>For spike<br>detection, the<br>subject device is<br>intended for a<br>subset of the<br>population that is<br>cleared for the<br>predicate device. | |
| Components | SaMD | SaMD | Same as the<br>Predicate device. | |
| EEG Data Source | | 10-20 system | 10-20 system (spike and<br>seizure detection)¹ up to 256<br>channels² | Similar, the<br>Proposed Device<br>and the Predicate<br>both use 10-20<br>system. |
| EEG<br>Functions | Review,<br>Monitor, and<br>Analyze<br>Recordings | Yes | Yes | Same as the<br>Predicate device. |
| | Annotation<br>List | Yes | Yes | Same as the<br>Predicate device. |
| Device | NeuroMatch<br>(Proposed Device)<br>K241390<br>LVIS | Persyst 14 EEG Review and<br>Analysis Software<br>(Predicate Device)<br>K182181<br>Persyst Development<br>Corporation | Rationale for<br>Substantial<br>Equivalence | |
| Measurements | Previously Cleared:<br>• FFT Spectrogram<br>• Artifact Strength<br>• aEEG<br>• Autocorrelation Spectrogram<br>• Asymmetry Spectrogram<br><br>Added in Current 510(k):<br>• Seizure Detection<br>• Spike Detection | • FFT<br>• Artifact Intensity<br>• Amplitude<br>• Rhythmicity<br>• Peak Envelope<br>• Relative Symmetry<br>• Suppression Ratio<br>• Artifact intensity<br>• FFT spectrogram<br>• FFT power<br>• FFT power ratio<br>• FFT spectral edge<br>• Relative asymmetry spectrogram<br>• Absolute asymmetry index<br>• Relative asymmetry index<br>• aEEG<br>• Rhythmicity spectrogram<br>• Spike detection<br>• Spike density<br>• Seizure detection<br>• Seizure probability<br>• Spike Perception Score<br>• VSBASLINE3 | The Proposed Device and the<br>Predicate both provide seizure<br>and spike detection. | |
| Seizure Detection | Yes, full montage | Yes, full montage | Same as the<br>Predicate device. | |
| Spike Detection | Yes | Yes | Same as the<br>Predicate device. | |
| Notifications | No…
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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.