iHealth® Early Pregnancy Test; iHealth® Early Pregnancy Test Strip
K241394 · Andon Health Co, Ltd. · LCX · Dec 20, 2024 · Clinical Chemistry
Device Facts
Record ID
K241394
Device Name
iHealth® Early Pregnancy Test; iHealth® Early Pregnancy Test Strip
Applicant
Andon Health Co, Ltd.
Product Code
LCX · Clinical Chemistry
Decision Date
Dec 20, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1155
Device Class
Class 2
Indications for Use
The iHealth® Early Pregnancy Test is an OTC in vitro diagnostic test used to assess early pregnancy by detecting the presence of the hCG (human chorionic gonadotropin) hormone in urine. The test device is intended for use as an aid in early detection of pregnancy, in some cases as early as six (6) days before the missed period, i.e., as early as five (5) days before the day of the expected period. The iHealth® Early Pregnancy Test Strip is an OTC in vitro diagnostic test used to assess early pregnancy by detecting the presence of the hCG (human chorionic gonadotropin) hormone in urine. The test device is intended for use as an aid in early detection of pregnancy, in some cases as early as six (6) days before the missed period, i.e., as early as five (5) days before the day of the expected period.
Device Story
Lateral flow immunoassay for qualitative hCG detection in urine; utilizes colloidal gold-labeled monoclonal antibodies. Device formats include test strip (dip) and test stick (dip or midstream). User applies urine sample to device; hCG binds to gold-conjugated antibody; complex migrates to test line coated with second hCG antibody; control line confirms test validity. Results displayed visually as two lines (pregnant) or one line (not pregnant) within 3-5 minutes. Used by lay users in home setting; provides rapid pregnancy status confirmation to aid clinical decision-making.
Clinical Evidence
Clinical performance supported by a study of 830 urine samples from women aged 18-55 across days +1 to -8 relative to expected period. Lay user study (n=204) demonstrated 100% agreement between lay-user and professional results. Specificity study (n=900) across pre-, peri-, and post-menopausal cohorts showed 0% false positive rate. Analytical studies confirmed 10 mIU/mL sensitivity, no high-dose hook effect up to 1,000,000 mIU/mL, and no interference from common substances, cross-reactants (LH, FSH, TSH), pH (4.0-9.0), or specific gravity (1.000-1.035).
Indicated for OTC use by individuals to assess early pregnancy by detecting hCG in urine. Intended as an aid in early pregnancy detection, potentially as early as 6 days before the missed period (5 days before the expected period).
Regulatory Classification
Identification
A human chorionic gonadotropin (HCG) test system is a device intended for the early detection of pregnancy is intended to measure HCG, a placental hormone, in plasma or urine. A human chorionic goadotropin (HCG) test system is a device intended for any uses other than early detection of pregnancy (such as an aid in the diagnosis, prognosis, and management of treatment of persons with certain tumors or carcinomas) is intended to measure HCG, a placental hormone, in plasma or urine.
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FDA
U.S. FOOD & DRUG
ADMINISTRATION
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
ASSAY ONLY
## I Background Information:
A 510(k) Number
K241394
B Applicant
Andon Health Co., Ltd.
C Proprietary and Established Names
iHealth® Early Pregnancy Test; iHealth® Early Pregnancy Test Strip
D Regulatory Information
| Product Code(s) | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| LCX | Class II | 21 CFR 862.1155 - Human Chorionic Gonadotropin (HCG) Test System | CH - Clinical Chemistry |
## II Submission/Device Overview:
A Purpose for Submission:
New Device
B Measurand:
Human Chorionic Gonadotropin (hCG)
C Type of Test:
Qualitative chromatographic immunoassay
## III Intended Use/Indications for Use:
A Intended Use(s):
Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
www.fda.gov
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See Indications for Use below.
## B Indication(s) for Use:
The iHealth® Early Pregnancy Test is an OTC in vitro diagnostic test used to assess early pregnancy by detecting the presence of the hCG (human chorionic gonadotropin) hormone in urine. The test device is intended for use as an aid in early detection of pregnancy, in some cases as early as six (6) days before the day of the missed period, i.e., as early as five (5) days before the day of the expected period.
The iHealth® Early Pregnancy Test Strip is an OTC in vitro diagnostic test used to assess early pregnancy by detecting the presence of the hCG (human chorionic gonadotropin) hormone in urine. The test device is intended for use as an aid in early detection of pregnancy, in some cases as early as six (6) days before the day of the missed period, i.e., as early as five (5) days before the day of the expected period.
## C Special Conditions for Use Statement(s):
OTC - Over The Counter
## D Special Instrument Requirements:
Not applicable
## IV Device/System Characteristics:
### A Device Description:
The tests are available in two formats: 1) The iHealth Early Pregnancy Test, which consists of a single test strip assembled in a plastic card, with an absorbent tip, designed to be tested in dip or midstream sampling mode; and 2) the iHealth Early Pregnancy Test Strip which consists of a single test strip, designed to be used by dipping the strip into a urine sample collected into the provided collection cup.
### B Principle of Operation:
The tests are lateral flow immunoassays for the in vitro detection of human chorionic gonadotropin (hCG) in urine. Testing is conducted by immersing the absorbent tip in urine (dip mode) for 10 seconds or urinating on the absorbent tip (midstream mode) for 2-3 seconds and obtaining the result from the colored lines. After application of the urine specimen, the test result is shown in the result window and read visually after 3-5 minutes of urine application. The hCG present in the urine sample, it is bound by an hCG-2 antibody colloidal gold conjugate present at the front of the test strip forming a complex. This conjugate complex is captured by hCG-1 antibody in the detection zone forming a colored line in the test line region. Concurrently, a line will appear in the quality control zone. If the sample is negative, meaning it lacks hCG or the hCG concentration is below the detection limit, only a line appears in the quality control area. The test result is shown in the result window and read visually 3-5 minutes after urine application. Two distinct colored lines, one line in the control line region and another in the test
K241394 - Page 2 of 11
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line region, indicate a positive test result (pregnant). Absence of a colored line in the test line region and only a colored line in the control line region indicates a negative test result (not pregnant). Absence of a colored line in the control line region, even in the presence of a colored line in the test line region, indicates an invalid test result.
V Substantial Equivalence Information:
A Predicate Device Name(s):
Clearblue ® Early Pregnancy Test
B Predicate 510(k) Number(s):
K213379
C Comparison with Predicate(s):
| Device & Predicate Device(s): | K241394 | K213379 |
| --- | --- | --- |
| Device Trade Name | iHealth® Early Pregnancy Test
iHealth® Early Pregnancy Test Strip | Clearblue Early Pregnancy Test |
| General Device Characteristic Similarities | | |
| Intended Use/Indications For Use | Qualitative detection of human hCG for an aid in early detection of pregnancy. | Same |
| Early Detection Claim | Pregnancy can be detected in some cases as early as six (6) days before the day of the missed period, i.e. as early as five (5) days before the day of the expected period. | Same |
| hCG Sensitivity | 10 mIU/mL | Same |
| General Device Characteristic Differences | | |
| Time to Result | 3-5 minutes | 5 minutes |
| Traceability | World Health Organization (WHO) 5^{th} International Standard (IS) for hCG | World Health Organization (WHO) 4^{th} International Standard (IS) for hCG |
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VI Standards/Guidance Documents Referenced:
None referenced
VII Performance Characteristics (if/when applicable):
A Analytical Performance:
1. Precision/Reproducibility:
A precision study was performed using negative female urine samples spiked with hCG (traceable to the 5th World Health Organization International Standard (WHO IS)) to obtain samples with hCG concentrations of 0, 3, 5, 7.5, 10, 12.5, 15 and 25 mIU/mL. Each sample was tested using three lots of iHealth® Early Pregnancy Test Strip using dip sampling mode and the iHealth® Early Pregnancy Test using both dip and midstream sampling modes. The tests were performed over the course of five non-consecutive days, at three sites, by nine different operators. A total of 405 replicates were performed per sampling mode per hCG concentration. The results are summarized in the tables below:
iHealth® Early Pregnancy Test Strip (dip sampling mode)
| hCG concentration (mIU/mL) | Lot 1 | | Lot 2 | | Lot 3 | | Total result | | % Negative | % Positive |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | - | + | - | + | - | + | - | + | | |
| 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0 | 0 | 0 |
| 3 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0 | 0 | 0 |
| 5 | 58 | 77 | 53 | 82 | 59 | 76 | 170 | 235 | 42.0% | 58.0% |
| 7.5 | 41 | 94 | 43 | 92 | 35 | 100 | 119 | 286 | 29.4% | 70.6% |
| 10 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 12.5 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 15 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 25 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
iHealth® Early Pregnancy Test (dip sampling mode)
| hCG concentration (mIU/mL) | Lot 1 | | Lot 2 | | Lot 3 | | Total result | | % Negative | % Positive |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | - | + | - | + | - | + | - | + | | |
| 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0 | 0 | 0 |
| 3 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0 | 0 | 0 |
| 5 | 62 | 73 | 58 | 77 | 68 | 67 | 188 | 217 | 46.4% | 53.6% |
| 7.5 | 48 | 87 | 37 | 98 | 43 | 92 | 128 | 277 | 31.6% | 68.4% |
| 10 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 12.5 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 15 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 25 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
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iHealth® Early Pregnancy Test (midstream sampling mode)
| hCG concentration (mIU/mL) | Lot 1 | | Lot 2 | | Lot 3 | | Total result | | % Negative | % Positive |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | - | + | - | + | - | + | - | + | | |
| 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0 | 0 | 0 |
| 3 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0 | 0 | 0 |
| 5 | 67 | 68 | 63 | 72 | 66 | 69 | 196 | 209 | 48.4% | 51.6% |
| 7.5 | 44 | 91 | 48 | 87 | 49 | 86 | 141 | 264 | 34.8% | 65.2% |
| 10 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 12.5 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 15 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
| 25 | 0 | 135 | 0 | 135 | 0 | 135 | 0 | 405 | 0% | 100% |
2. Linearity:
Linearity is not applicable since this is a qualitative test.
3. Analytical Specificity/Interference:
Interference from exogenous and endogenous substances
A study was performed to evaluate potential interference from certain exogenous and endogenous substances for the iHealth® Early Pregnancy Test and the iHealth® Early Pregnancy Test Strip devices. Negative, female, human urine samples were used to make samples containing 0 and 10 mIU/mL hCG, which were then spiked with potentially interfering substances at the concentrations listed in the table below. Samples were tested in replicates of five, using three lots of the candidate device. No interference was observed at the concentrations shown in the table below:
| Substance | Highest concentration tested that demonstrated no interference |
| --- | --- |
| Acetaminophen | 20 mg/dL |
| Acetoacetic Acid | 500 mg/dL |
| Acetylsalicylic Acid | 20 mg/dL |
| Albumin | 2000 mg/dL |
| Ampicillin | 20 mg/dL |
| Ascorbic Acid | 20 mg/dL |
| Atropine | 20 mg/dL |
| Benzoylecgonine | 10 mg/dL |
| B-hydroxybutyrate | 1000 mg/dL |
| Bilirubin | 2 mg/dL |
| Caffeine | 20 mg/dL |
| Cannabinol | 10 mg/dL |
| Codeine | 6 μg/dL |
| EDTA | 80 mg/dL |
| Estriol-17-beta | 1400 μg/dL |
| Ethanol | 1.00% |
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| Substance | Highest concentration tested that demonstrated no interference |
| --- | --- |
| Gentisic Acid | 20 mg/dL |
| Glucose | 2000 mg/dL |
| Hemoglobin | 500 mg/dL |
| Ketone | 20 mg/dL |
| Methanol | 10% |
| Phenothiazine | 20 mg/dL |
| Phenylpropanolamine | 20 mg/dL |
| Pregnanediol | 1500 μg/dL |
| Salicylic Acid | 20 mg/dL |
| Tetracycline | 20 mg/dL |
| Thiophene | 20 mg/dL |
## Cross-reactivity of structurally-related compounds
A study was performed to evaluate the potential cross-reactivity from luteinizing hormone (LH), follicle-stimulating hormone (FSH), and thyroid-stimulating hormone (TSH) on the iHealth® Early Pregnancy Test and the iHealth® Early Pregnancy Test Strip devices. Negative, female, human urine sample were used to make samples containing 0 and 10 mIU/mL hCG, which were then spiked with the potential cross-reactants: 500 mIU/mL LH, 1000 mIU/mL FSH, and 1 mIU/mL TSH. Samples were tested in replicates of five with each of three lots of the candidate devices. The results demonstrated no cross-reactivity from potential cross-reactants was observed at the tested concentrations.
## Effect of urine pH
A study was performed to evaluate the effects of urine pH on the iHealth® Early Pregnancy Test and the iHealth® Early Pregnancy Test Strip devices. Negative, female, human urine sample were used to make samples containing 0 and 10 mIU/mL hCG, which were then adjusted to pH values from 4.0 to 9.0 and tested using the candidate devices. Samples were tested in replicates of five, using three lots of the candidate devices. The results demonstrated that samples within the pH range of 4.0 to 9.0 do not interfere with either positive or negative results from the device.
## Effect of urine Specific Gravity
A study was performed to evaluate the effects of urine specific gravity on the iHealth® Early Pregnancy Test and the iHealth® Early Pregnancy Test Strip devices. Negative, female, human urine sample were used to make samples containing 0 and 10 mIU/mL hCG, which were then adjusted to specific gravity values from 1.000 to 1.035 and tested using the candidate devices. Samples were tested in replicates of five, using three lots of the candidate device. The results demonstrated that samples within the specific gravity range of 1.000 to 1.035 do not interfere with either positive or negative results from the device.
## Effect of hCG β-core (hCGβcf) fragment
A study was performed to evaluate the effects hCGβcf on the iHealth® Early Pregnancy Test and the iHealth® Early Pregnancy Test Strip devices. Negative, female, human urine samples and were used to make samples containing 0 and 10 mIU/mL hCG, which were then spiked with hCG β-core fragment concentrations of 250,000 pmol/L, 500,000 pmol/L, and 1,000,000 pmol/L. Samples were tested in replicates of five, using three lots of the candidate
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devices. The results show that the performance of the candidate device is not affected by concentrations of hCGβcf up to 1,000,000 pmol/L.
## High dose hook effect study
A study was performed to evaluate the high dose hook effect on the iHealth® Early Pregnancy Test and the iHealth® Early Pregnancy Test Strip devices. Negative, female, human urine samples were spiked up to 1,000,000 mIU/mL hCG and tested using the candidate device. Samples were tested in replicates of five, using three lots of the candidate device. No hook effect was observed at concentrations of up to 1,000,000 mIU/mL hCG.
4. Assay Reportable Range:
Not applicable
5. Traceability, Stability, Expected Values (Controls, Calibrators, or Methods):
The tests are calibrated against the World Health Organization (WHO) International Standard (IS) 5th Edition, NIBSC code 07/364.
6. Detection Limit:
The detection limit was determined in the precision study (see Section VII.A.1. above).
7. Assay Cut-Off:
The device cutoff is 10 mIU/mL hCG. See Precision/Reproducibility (Section VII.A.1.) sections above.
## B Comparison Studies:
1. Method Comparison with Predicate Device:
A total of 204 urine samples were collected from women whose ages ranged from 18 to 45 years, who suspect they are in the early stages of pregnancy. Approximately half of the women were suspected to be pregnant and most of them were in the early stage of pregnancy (less than 5 weeks). The samples were masked and randomized prior to testing by professionals using the candidate device (iHealth® Early Pregnancy Test in dip mode and midstream mode and iHealth® Early Pregnancy Test Strip in dip mode) and the predicate device (Clearblue Early Pregnancy Test in dip mode). One hundred and three (103) samples were tested using the iHealth® Early Pregnancy Test Strip and 101 samples were tested using the iHealth® Early Pregnancy Test Stick. Summary results are presented in the tables below.
iHealth® Early Pregnancy Test Strip (dip mode)
| Candidate Device | Predicate device | | Total | |
| --- | --- | --- | --- | --- |
| | | Positive | | Negative |
| iHealth® Early Pregnancy Test Strip | Positive | 54 | 0 | 54 |
| | Negative | 0 | 49 | 49 |
| | Total | 54 | 49 | 103 |
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iHealth® Early Pregnancy Test Stick (dip and midstream mode)
| Candidate Device | Predicate device | | Total | |
| --- | --- | --- | --- | --- |
| | | Positive | | Negative |
| iHealth® Early Pregnancy Test Strip | Positive | 55 | 0 | 55 |
| | Negative | 0 | 46 | 46 |
| | Total | 55 | 46 | 101 |
The sponsor also provided a study of 502 women which additionally supported the accuracy of the device.
2. Matrix Comparison:
Not applicable. The device is intended for urine samples only.
C Clinical Studies:
1. Clinical Sensitivity:
Not applicable
2. Clinical Specificity:
Not applicable
3. Other Clinical Supportive Data (When 1. and 2. Are Not Applicable):
Detection of hCG in Early Pregnancy Clinical Samples:
A total of 830 urine samples from days +1 to -8 relative to the day of the expected menstrual period (EMP) were collected from women aged 18 to 55 years from the intended use population. Each sample was tested using both the iHealth® Early Pregnancy Test Strip (dip mode) and the iHealth® Early Pregnancy Test (dip mode and midstream modes) across three lots of each device format (stick and strip). The early pregnancy detection results are summarized in table below.
| Day relative to EMP | Sample (n) per sampling mode | iHealth® Early Pregnancy Test Strip (dip mode) | | iHealth® Early Pregnancy Test (dip mode) | | iHealth® Early Pregnancy Test (midstream mode) | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | Pregnant (n) | Pregnant (%) | Pregnant (n) | Pregnant (%) | Pregnant (n) | Pregnant (%) |
| -8 | 83 | 4 | 5 | 4 | 5 | 5 | 6 |
| -7 | 83 | 11 | 13 | 10 | 12 | 11 | 13 |
| -6 | 83 | 23 | 28 | 22 | 27 | 22 | 27 |
| -5 | 83 | 65 | 78 | 65 | 78 | 65 | 78 |
| -4 | 83 | 77 | 93 | 77 | 93 | 77 | 93 |
| -3 | 83 | 82 | 99 | 82 | 99 | 82 | 99 |
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| Day relative to EMP | Sample (n) per sampling mode | iHealth® Early Pregnancy Test Strip (dip mode) | | iHealth® Early Pregnancy Test (dip mode) | | iHealth® Early Pregnancy Test (midstream mode) | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | Pregnant (n) | Pregnant (%) | Pregnant (n) | Pregnant (%) | Pregnant (n) | Pregnant (%) |
| -2 | 83 | 82 | 99 | 82 | 99 | 82 | 99 |
| -1 | 83 | 83 | 100 | 83 | 100 | 83 | 100 |
| 0 | 83 | 83 | 100 | 83 | 100 | 83 | 100 |
| +1 | 83 | 83 | 100 | 83 | 100 | 83 | 100 |
## Lay user study
A lay user study was conducted with 204 volunteers with diverse educational and occupational backgrounds who were between the age of 18 and 45. This included 103 lay users using the iHealth® Early Pregnancy Test Strip and 101 lay users using the iHealth® Early Pregnancy Test. Lay users tested their own urine specimen. Each lay user also provided a sample for professional testing. Then the results of lay-user tests were compared to results reported by a laboratory professional. The data shows that the agreement between lay-user results and professional results was 100% (below):
iHealth® Early Pregnancy Test Strip (dip mode)
| Lay user | Professional | | |
| --- | --- | --- | --- |
| | Pregnant | Not Pregnant | Total |
| Positive | 54 | 0 | 54 |
| Negative | 0 | 49 | 49 |
| Total | 54 | 49 | 103 |
iHealth® Early Pregnancy Test (dip and midstream mode)
| Lay user | Professional | | |
| --- | --- | --- | --- |
| | Pregnant | Not Pregnant | Total |
| Positive | 55 | 0 | 55 |
| Negative | 0 | 46 | 46 |
| Total | 55 | 46 | 101 |
The sponsor also provided a study of 369 women which additionally supported the accuracy of the device.
## Lay user spiked sample study
A second lay user study was conducted with a total of 100 women with diverse educational and professional backgrounds between the ages of 18 years to 55. Lay users performed the testing using samples spiked with 0, 2, 3, 5, 10 and 15 mIU/mL hCG using one lot each of the iHealth® Early Pregnancy Test Strip using dip mode and the iHealth® Early Pregnancy Test using both dip and simulated midstream modes. Results are summarized below.
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| hCG level (mIU/mL) | iHealth® Early Pregnancy Test Strip (dip mode) | iHealth® Early Pregnancy Test (dip mode) | iHealth® Early Pregnancy Test (simulated midstream mode) |
| --- | --- | --- | --- |
| | % Positive | % Positive | % Positive |
| 0 | 0% | 0% | 0% |
| 2 | 0% | 0% | 0% |
| 3 | 0% | 0% | 0% |
| 5 | 46% | 43% | 44% |
| 10 | 100% | 100% | 100% |
| 15 | 100% | 100% | 100% |
# Specificity Study to Determine False Positive Result Rate
A study was performed to determine the incidence of false positive test results from iHealth® Early Pregnancy Test and iHealth® Early Pregnancy Test Strip. Urine samples were collected from 300 women from each of three cohorts: non-pregnant pre-menopausal women aged 18-40 years, non-pregnant peri-menopausal women aged 41-55 years, and non-pregnant post-menopausal women $>55$ years of age. Samples were tested by trained technicians with three lots of the candidate device using both the iHealth® Early Pregnancy Test (dip mode) and the iHealth® Early Pregnancy Test Stick (dip mode and midstream mode). No false positive results were observed for any of the age groups. Results of the study are shown in the table below:
Summary of Specificity Testing
| Format | Cohort | # of Samples | Positive Results (%) |
| --- | --- | --- | --- |
| iHealth® Early Pregnancy Test Strip (dip mode) | Non-pregnant, pre-menopausal | 100 | 0/100 (0%) |
| | Non-pregnant, peri-menopausal | 100 | 0/100 (0%) |
| | Non-pregnant, post-menopausal | 100 | 0/100 (0%) |
| | All non-Pregnant | 300 | 0/100 (0%) |
| iHealth® Early Pregnancy Test Stick (dip mode) | Non-pregnant, pre-menopausal | 100 | 0/100 (0%) |
| | Non-pregnant, peri-menopausal | 100 | 0/100 (0%) |
| | Non-pregnant, post-menopausal | 100 | 0/100 (0%) |
| | All non-Pregnant | 300 | 0/100 (0%) |
| iHealth® Early Pregnancy Test Stick (midstream mode) | Non-pregnant, pre-menopausal | 100 | 0/100 (0%) |
| | Non-pregnant, peri-menopausal | 100 | 0/100 (0%) |
| | Non-pregnant, post-menopausal | 100 | 0/100 (0%) |
| | All non-Pregnant | 300 | 0/100 (0%) |
# A Clinical Cut-Off:
Not applicable
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B Expected Values/Reference Range:
Not applicable
VIII Proposed Labeling:
The labeling supports the finding of substantial equivalence for this device.
IX Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
K241394 - Page 11 of 11
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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.