Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheters can be used for electrogram recording and cardiac stimulation during diagnostic electrophysiologic studies. The catheters are commonly placed in the high right atrium, right ventricular apex, and the HIS bundle.
Device Story
Reprocessed Abbott Inquiry Steerable Diagnostic Catheters; flexible, insulated thermoplastic elastomer construction with noble metal electrodes. Device features steerable tip manipulated via handle control mechanism. Used by clinicians in electrophysiology labs for electrogram recording and cardiac stimulation. Reprocessing involves validated cleaning, inspection, functional testing, packaging, and sterilization. Devices tracked to ensure maximum of two reprocessing cycles; units failing inspection are rejected. Output is electrical signal data for diagnostic interpretation. Benefits include clinical utility of diagnostic catheters with reprocessed sustainability model.
Clinical Evidence
Bench testing only. No clinical data presented. Functional performance evaluated via visual inspection, dimensional measurement, electrical safety, mechanical characteristics (continuity, isolation, resistance), and corrosion resistance. Validations performed for cleaning, biocompatibility, packaging, shelf life, sterilization, and product stability.
Technological Characteristics
Thermoplastic elastomer construction with noble metal electrodes. Steerable tip design with handle-based control. Available in various diameters (4-7 Fr), lengths, electrode counts, and curve configurations. Reprocessed via validated cleaning, inspection, and sterilization cycles (max 2 cycles).
Indications for Use
Indicated for electrogram recording and cardiac stimulation during diagnostic electrophysiologic studies in patients requiring such procedures. Catheters are placed in the high right atrium, right ventricular apex, and the HIS bundle.
Regulatory Classification
Identification
An electrode recording catheter or an electrode recording probe is a device used to detect an intracardiac electrocardiogram, or to detect cardiac output or left-to-right heart shunts. The device may be unipolar or multipolar for electrocardiogram detection, or may be a platinum-tipped catheter which senses the presence of a special indicator for cardiac output or left-to-right heart shunt determinations.
Predicate Devices
Modification of the IBI-1100 Steerable Electrophysiology Catheter System (K982232)
IBI-1100 Steerable Electrophysiology Catheter System (K961924)
Submission Summary (Full Text)
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November 29, 2024
Surgical Instrument Service and Savings Inc. (dba Medline ReNewal) Stephanie Boyle Mays Senior Regulatory Affairs Specialist, QA/RA 1500 NE Hemlock Ave. Redmond, Oregon 97756
Re: K242225
Trade/Device Name: Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheter Regulation Number: 21 CFR 870.1220 Regulation Name: Electrode Recording Catheter Or Electrode Recording Probe Regulatory Class: Class II Product Code: NLH Dated: November 1, 2024 Received: November 1, 2024
Dear Stephanie Boyle Mays:
We have reviewed your section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (the Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database available at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
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(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 OS 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 Rue"). 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-devices/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-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).
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Sincerely,
# Aneesh S. Deoras -S
Aneesh Deoras Assistant Director Division of Cardiac Electrophysiology, Diagnostics, and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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| OEM Model<br>No. | Diameter<br>(Fr) | Length<br>(cm) | Electrodes | | Curve |
|------------------|------------------|----------------|------------|-----------------|---------|
| | | | Qty. | Spacing<br>(mm) | |
| 81102 | 6 | 110 | 10 | 2-5-2 | M |
| 81104 | 6 | 110 | 10 | 2-5-2 | L |
| 81105 | 6 | 110 | 10 | 2-5-2 | XL |
| 81107 | 6 | 110 | 10 | 5 | L |
| 81171 | 5 | 110 | 10 | 2 | M |
| 81172 | 5 | 110 | 10 | 2-5-2 | M |
| 81174 | 5 | 110 | 10 | 2-5-2 | L |
| 81202 | 7 | 110 | 20 | 2-10-2 | XXL |
| 81207 | 7 | 110 | 20 | 5 | SL |
| 81209 | 7 | 110 | 20 | 2-5-2 | SL |
| 81223 | 5 | 110 | 10 | 2(50)3 | XL |
| 81224 | 5 | 110 | 10 | 2(30)3 | M |
| 81402 | 6 | 110 | 4 | 2-5-2 | M |
| 81403 | 6 | 110 | 4 | 5 | M |
| 81404 | 6 | 110 | 4 | 2-5-2 | L |
| 81405 | 6 | 110 | 4 | 5 | L |
| 81417 | 6 | 110 | 4 | 5 | XL |
| 81418 | 6 | 110 | 4 | 2-5-2 | XL |
| 81472 | 5 | 110 | 4 | 2-5-2 | M |
| 81473 | 5 | 110 | 4 | 5 | M |
| 81474 | 5 | 110 | 4 | 2-5-2 | L |
| 81483 | 5 | 110 | 4 | 5 | E(HIS) |
| 81504 | 6 | 110 | 10 | 5 | M |
| 81520 | 6 | 110 | 10 | 2 | XL |
| 81521 | 5 | 110 | 5 | 5(170) | M/L |
| 81524 | 6 | 110 | 10 | 2 | L |
| 81526 | 5 | 95 | 10 | 2-170-170 | C1(HIS) |
| 81530 | 4 | 110 | 10 | 2 | M |
| 81531 | 4 | 110 | 10 | 2-5-2 | M |
| 81532 | 4 | 110 | 10 | 2-5-2 | L |
| 81534 | 4 | 110 | 10 | 5 | L |
| 81537 | 4 | 60 | 10 | 2-5-2 | M(SC) |
| 81540 | 4 | 110 | 4 | 2-5-2 | M |
| 81542 | 4 | 110 | 4 | 5 | M |
| 81543 | 4 | 110 | 4 | 2-5-2 | L |
| 81557 | 5 | 110 | 10 | 3(170)50 | M |
| 81721 | 5 | 110 | 10 | 2-5-2 | M(SC) |
| 81730 | 5 | 110 | 10 | 2-8-2 | M/L |
| 81734 | 5 | 110 | 10 | 2-5-2 | L |
| 81735 | 5 | 110 | 10 | 5 | L |
| 81736 | 5 | 110 | 10 | 5(22)5 | M/L |
| 81801 | 6 | 110 | 8 | 2 | M |
| 81802 | 6 | 110 | 8 | 2-5-2 | M |
| 81807 | 6 | 110 | 8 | 2 | L |
| 81809 | 6 | 110 | 8 | 2-5-2 | L |
| 81871 | 5 | 110 | 8 | 2 | M |
| 81872 | 5 | 110 | 8 | 2-5-2 | M |
| 81945 | 6 | 110 | 10 | 2-5-2 | L |
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### Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.
Submission Number (if known)
K242225
Device Name
Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheter
Indications for Use (Describe)
Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheters can be used for electrogram recording and cardiac stimulation during diagnostic electrophysiologic studies. The catheters are commonly placed in the high right atrium, right ventricular apex, and the HIS bundle.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/5/Picture/0 description: The image contains the Medline Renewal logo. The Medline logo is on the left side of the image and consists of a blue square with a white star-like symbol and the word "MEDLINE" in white letters. To the right of the Medline logo is the word "Renewal" in green and blue letters. Below the word "Renewal" is the phrase "Full Circle Reprocessing" in smaller, blue letters.
Traditional 510(k) Notification Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheters
## 510(k) 242225 Summary
This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR § 807.92.
| Submitter/<br>Owner | Surgical Instrument Service and Savings Inc. (dba Medline ReNewal)<br>1500 NE Hemlock Ave., Redmond, OR 97756 | |
|----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------|
| Contact/<br>Prepared by | Stephanie Boyle Mays<br>Senior Regulatory Affairs Specialist, Regulatory Affairs<br>P: 541-516-4205 • F: 541-923-3375 • smays@medline.com | |
| Date Prepared | July 26, 2024 | |
| Device Name<br>and<br>Classification | Proprietary/Trade Name: | Medline ReNewal Reprocessed Abbott Inquiry<br>Steerable Diagnostic Catheter |
| | Common or Usual Name | Catheter, recording, electrode, reprocessed |
| | Regulatory Name/Reference | Electrode recording catheter or electrode recording<br>probe/21 CFR § 870.1220 |
| | Regulatory Class | 2 |
| | Product Code | NLH |
| | Panel | Cardiovascular |
| Predicates<br>selection | Rationale | The predicate models in K982232 and K961924<br>include the subject device models of this submission. |
| | 510(k) Number | K982232 |
| Predicate<br>Device (1) | Proprietary or<br>Trade Name | Modification of the IBI-1100 Steerable<br>Electrophysiology Catheter System |
| | Common or Usual<br>Name | Catheter, recording, or probe electrode recording |
| | Regulatory<br>Name/Reference | Electrode recording catheter or electrode recording<br>probe/21 CFR § 870.1220 |
| | Regulatory Class | 2 |
| | Product Code | DRF |
| | Panel | Cardiovascular |
| | 510(k) applicant | Irvine BioMedical, Inc.,<br>2146-A Michelson Dr., Irvine, CA 92612 |
| | 510(k) Number | K961924 |
| Predicate<br>Device (2) | Proprietary or<br>Trade Name | IBI-1100 Steerable Electrophysiology Catheter<br>System |
| | Common or Usual<br>Name | Catheter, recording, or probe electrode recording |
| | Regulatory<br>Name/Reference | Electrode recording catheter or electrode recording<br>probe/21 CFR § 870.1220 |
| | Regulatory Class | 2 |
| Product Code | NLH | |
| Panel | Cardiovascular | |
| 510(k) applicant | Irvine BioMedical, Inc.,<br>2146-A Michelson Dr., Irvine, CA 92612 | |
| Device<br>Description/<br>Intended Use | The Medline ReNewal Reprocessed Inquiry Steerable Diagnostic<br>Electrophysiology Catheters are flexible, insulated catheters constructed of<br>thermoplastic elastomer material and noble metal electrodes. The tip of the<br>steerable catheters may be manipulated with the control mechanism<br>located in the handle of the proximal end of the catheter. | |
| Indications for<br>Use | Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic<br>catheters can be used for electrogram recording and cardiac stimulation<br>during diagnostic electrophysiologic studies. The catheters are commonly<br>placed in the high right atrium, right ventricular apex, and the HIS bundle. | |
| Technological<br>Characteristics | The technological characteristics, materials, and the fundamental scientific<br>technology of the subject device is equivalent to the predicate and<br>reference devices. The proposed devices are reprocessed versions of the<br>predicate devices. Each device undergoes a validated process that includes<br>cleaning, inspections and functional tests, packaging and sterilization.<br>Devices are tracked to ensure they do not exceed the number of validated<br>reprocessing cycles (2). Devices that have reached the maximum number<br>of cycles or do not meet inspection criteria are rejected and disposed of<br>appropriately. The predicate devices were used to support intended use,<br>technological characteristics, and functional performance specifications. | |
| Non-clinical<br>Testing<br>Summary | The functional characteristics of the subject device have been evaluated<br>and found to be substantially equivalent to the predicate device based on<br>the following tests:<br>Functional performance studies: visual inspection; dimensional measurement; electrical safety; mechancial characteristics continuity, isolation, resistance; and corrosion resistance. Cleaning validation Biocompatibility Packaging and shelf life validation Sterilization validation Product stability | |
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Image /page/6/Picture/0 description: The image contains the Medline Renewal Full Circle Reprocessing logo. The Medline logo is on the left side of the image and consists of a blue square with a white star-like symbol and the word "MEDLINE" in white letters. To the right of the Medline logo is the word "Renewal" in green and blue letters, with the words "Full Circle Reprocessing" in blue letters below it. The TM symbol is in the upper right corner of the word "Renewal".
Traditional 510(k) Notification Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheters
Summary Table follows
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Image /page/7/Picture/0 description: The image contains the Medline Renewal logo. The Medline logo is on the left side of the image and consists of a blue square with a white cross inside. The word "MEDLINE" is written in white letters above the cross. To the right of the Medline logo is the word "Renewal" in large, bold letters, with "Re" in green and "Newal" in blue. Below the word "Renewal" is the phrase "Full Circle Reprocessing" in smaller, blue letters.
| Summary Table: Predicates and Proposed Device Comparison Chart | | | |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| PREDICATE 1<br>Modification of the<br>IB-1100 Steerable<br>Electrophysiology<br>Catheter System | PREDICATE 2<br>IBI-1100 Steerable<br>Electrophysiology<br>Catheter System | PROPOSED<br>Medline ReNewal<br>Reprocessed Abbott<br>Inquiry Steerable<br>Diagnostic Catheter | Comparison |
| 510(k) number | | | |
| K982232 | K961924 | TBD | N/A |
| Model number | | | |
| Not listed in K982232<br>Summary | Not listed in K961924<br>Summary | 81102, 81104, 81105,<br>81107, 81171, 81172,<br>81174, 81202, 81207,<br>81209, 81223, 81224,<br>81402, 81403, 81404,<br>81405, 81417, 81418,<br>81472, 81473, 81474,<br>81483, 81504, 81520,<br>81521, 81524, 81526,<br>81530, 81531, 81532,<br>81534, 81537, 81540,<br>81542, 81543, 81557,<br>81721, 81730, 81734,<br>81735, 81736, 81801,<br>81802, 81807, 81809,<br>81871, 81872, 81945,<br>81947 | As stated |
| Classification Name | | | |
| Catheter, electrode<br>recording, or probe<br>electrode recording | Catheter, electrode<br>recording, or probe<br>electrode recording | Catheter, recording,<br>electrode recording,<br>reprocessed | As stated |
| Regulation No. | | | |
| 21 CFR § 870.1220 | 21 CFR § 870.1220 | 21 CFR § 870.1220 | Same |
| Regulatory Class | | | |
| 2 | 2 | 2 | Same |
| Product Code | | | |
| DRF | DRF | NLH | As stated |
| Indications for Use | | | |
| Electrogram recording<br>and cardiac stimulation<br>during diagnostic<br>electrophysiologic<br>studies. The catheters<br>are commonly placed in<br>the high right atrium, right<br>ventricular apex, and the<br>HIS bundle | Electrogram recording<br>and cardiac stimulation<br>during diagnostic<br>electrophysiologic<br>studies. The catheters are<br>commonly placed in the<br>high right atrium, right<br>ventricular apex, and the<br>HIS bundle | Electrogram recording<br>and cardiac stimulation<br>during diagnostic<br>electrophysiologic<br>studies. The catheters are<br>commonly placed in the<br>high right atrium, right<br>ventricular apex, and the<br>HIS bundle | Same |
| Technological Characteristics | | | |
| The catheters contain<br>various numbers of<br>electrodes and electrode<br>spacings and a steerable<br>design with a tip that are<br>available in various<br>curves. | The catheters contain<br>various numbers of<br>electrodes and electrode<br>spacings and a steerable<br>design with a tip that are<br>available in various<br>curves. | The Medline ReNewal<br>Reprocessed Abbott<br>Inquiry Steerable<br>Diagnostic Catheters<br>contain various numbers<br>of electrodes and<br>electrode spacings and a<br>steerable design with a tip<br>that are available in<br>various curves. | Same |
| Reprocessing | | | |
| Each catheter is reprocessed no more than two times. Medline ReNewal does not reprocess the | | | |
| Inquiry Steerable Diagnostic Catheters of other reprocessors. | | | |
| Conclusion | | | |
| The predicates and proposed devices in this application have the same indications for use and<br>technological characteristics. Based on this and the non-clinical testing data presented in this<br>510(k) submission, the Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic<br>Catheters within the scope of this submission are substantially equivalent to the predicate<br>devices. | | | |
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Image /page/8/Picture/0 description: The image contains the Medline and Renewal logos. The Medline logo is on the left and consists of the word "MEDLINE" in white text inside of a blue square with a white star-like symbol. To the right of the Medline logo is the Renewal logo, which consists of the word "Renewal" in green and blue text, with the letters "Re" in green and the rest of the word in blue. Below the word "Renewal" is the phrase "Full Circle Reprocessing" in blue text.
Traditional 510(k) Notification Medline ReNewal Reprocessed Abbott Inquiry Steerable Diagnostic Catheters
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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.