BVBLUE™ is an enzyme activity test for use in the detection of vaginal fluid specimens for sialidase activity, an enzyme produced by bacterial pathogens such as Gardnerella vaginalis, Bacteroides spp., Prevotella spp., and Mobiluncus spp. BVBLUE™ is indicated for use in women suspected of having Bacterial Vaginosis (BV) infection, e.g., women with vaginal discharge typical of BV and/or women with previous history of BV, as an aid in the diagnosis of BV infection. BVBLUE™ test results should be considered in conjunction with other clinical and patient information (see Limitations of the Procedure). For In Vitro Diagnostic Use Only. BVBLUE™ is indicated for professional use only and may be used at the point of care and/or in physician's offices. It is not intended for home use.
Device Story
BVBLUE is an in vitro diagnostic test for detecting sialidase enzyme activity in vaginal fluid, a marker for bacterial pathogens associated with Bacterial Vaginosis (BV). The device uses a chromogenic substrate (IBX-4041) in a testing vessel. A vaginal swab sample is incubated with the substrate for 10 minutes at 37°C. If sialidase is present, the substrate is hydrolyzed; adding a developer solution (sodium hydroxide) produces an intense blue color, while absence of the enzyme results in a yellow color. Used at the point of care or in physician offices by healthcare professionals. Results are interpreted visually by the clinician to aid in the diagnosis of BV in conjunction with other clinical information. The test provides a rapid, qualitative assessment of sialidase activity to assist in clinical decision-making for patients presenting with BV-like symptoms.
Clinical Evidence
Two clinical studies evaluated 502 and 118 women respectively. Compared against Amsel Criteria (Gold Standard), BVBLUE showed 85% sensitivity and 90% specificity in the first study. In the second study, reconciled comparisons against Amsel Criteria showed 97% sensitivity and 99% specificity; against Gram's stain, 97% sensitivity and 99% specificity. Additional comparisons against culture and morphotype identification were performed. Mean sialidase activity in BV-positive patients (12.34 U) was significantly higher than in healthy controls (2.70 U), Candidiasis (3.70 U), or Trichomoniasis (1.99 U).
Technological Characteristics
Chromogenic enzyme activity test. Components: Testing vessels with 0.25 mg IBX-4041 in aqueous potassium acetate buffer (pH 5.5-6.0) and developer solution (1.0 M sodium hydroxide, pH >11.0). Principle: Sialidase-mediated hydrolysis of chromogenic substrate followed by colorimetric detection. Manual, point-of-care diagnostic kit. No electronic components or software.
Indications for Use
Indicated for women suspected of having Bacterial Vaginosis (BV) infection, including those with typical vaginal discharge or a history of BV, as an aid in diagnosis. Professional use only; not for home use.
Regulatory Classification
Identification
A microorganism differentiation and identification device is a device intended for medical purposes that consists of one or more components, such as differential culture media, biochemical reagents, and paper discs or paper strips impregnated with test reagents, that are usually contained in individual compartments and used to differentiate and identify selected microorganisms. The device aids in the diagnosis of disease.
Predicate Devices
Affirm/VP Identification Test for Gardnerella vaginalis and Trichomonas vaginalis (K923133)
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# MAY 1 5 2000
EXTUBIT # I Page 1 of 8
## 510(K) SUMMARY
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
The assigned 510(k) number is:__K993732/S1
#### 1. Submitter's Identification:
Gryphus Diagnostics, L.L.C. 2800 Milan Court, Suite 235 Birmingham, AL 35211 Contact Person: Stephen C. Johnson, Ph.D.
Data Summary Prepared: October 20, 1999
#### Name of the Device: 2.
BVBLUETM
#### 3. Predicate Device Information:
- 1. Affirm/VP Identifiaction Test for Gardnerella vaginalis and Trichomonas vaginalis, K# 923133, Microprobe Inc.
- 2. Indicard® Test, K# 964015, Litmus Concepts, Inc.
- 3. FemExam® TestCard™ pH and Amines Tests, K# 962718, Litmus Concepts, Inc.
#### Device Description: র্বা
The BVBLUE™ Test contains a chromogenic substrate of sialidase enzyme, IBX-4041. The chromogenic substrate is provided in each of the BVBLUE™ Testing Vessels as a solution containing 0.25 mg IBX-4041 in 0.5 mL aqueous potassium acetate solution (49.0 mg/mL; 0.5 M, pH 5.5-6.0). When the solution containing the solubilized chromogenic substrate is exposed to sialidase enzyme, the substrate is hydrolyzed to yield sialic acid and IBX-4050. Upon the addition of one of more drops of the BVBLUE™ Developer Solution [an aqueous sodium hydroxide solution (40 mg/mL; 1.0 M; pH>11.0)], IBX-4050 exhibits an intense blue color. In the absence of sialidase enzyme, the chromogenic substrate is not hydrolyzed and exhibits a vellow color upon the addition of one or more drops of the BVBLUE'M Developer Solution.
### Materials Provided:
10 BVBLUE™ Units per Package:
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- Ten (10) BVBLUE™ Testing Vessels each containing 0.25 mg IBX-4041 . component in 0.5 mL of an aqueous potassium acetate buffer solution (49.0 mg/mL; 0.5 M; pH 5.5-6.0).
- One (1) BVBLUE™ Developer Solution Tube containing 0.5 mL of an . aqueous sodium hydroxide solution (40.0 mg/mL; 1.0 M; pH>11.0).
- Instructions for Use .
#### ર. Intended Use:
BVBLUE™ is an enzyme activity test for use in the detection of vaginal fluid specimens for sialidase activity, an enzyme produced by bacterial pathogens such as Gardnerella vaginalis, Bacteroides spp., Prevotella spp., and Mobiluncus spp.
BVBLUE™ is indicated for use in wornen suspected of having Bacterial Vaginosis (BV) infection, e.g., women with vaginal discharge typical of BV and/or women with previous history of BV, as an aid in the diagnosis of BV infection. BVBLUE™ test results should be considered in conjunction with other clinical and patient information (see Limitations of the Procedure).
For In Vitro Diagnostic Use Only. BVBLUE™ is indicated for professional use only and may be used at the point of care and/or in physician's offices. lt is not intended for home use.
#### 6. Comparisons to Predicate Devices:
Affirm/VP (manufactured by Becton Dickinson) evaluates patient vaginal fluid samples for the presence of Gardnerella vaginalis nucleic acid. Gardnerella vaginalis is a microorganism causative of bacterial vaginosis. Using this test, a patient vaginal fluid sample is obtained with a sterile cotton swab. A portion of the sample is transferred to a tube containing a lysis solution, thoroughly mixed, incubated at 85 °C for 10 minutes, and treated with a buffer solution. A portion of the resulting mixture is transferred to a Processor and then reacted for a period of 30 minutes to provide an identification of Gardnerella vaginalis nucleic acid. A positive indication for Gardnerella vaginalis nucleic acid is indicative of bacterial vaginosis in patients presenting bacterial vaginosis-like symptoms.
Indicard™ test (manufactured by Litmus Concepts, Inc.) evaluates patient vaginal fluid specimens for the presence of Gardnerella vaginalis proline imino peptidase enzyme activity. Gardnerella vaginalis is a microorganism
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causative of bacterial vaginosis. Using this test, a patient vaginal fluid sample is obtained with a sterile cotton swab. A portion of the sample is then transferred to the Indicard™ test to evaluate for the presence of Gardnerella vaginalis. A positive indication for Gardnerella vaginalis oroline imino peotidase enzyme activity is indicative of bacterial vaginosis in patients presenting bacterial vaginosis-like symptoms.
FemExam® TestCard™ (manufactured by Litmus Concepts, Inc.) evaluates patient vaginal fluid samples for elevated pH (i.e., pH >4.7) and for the presence of volatile amines in patient vaginal fluid samples. The pH and amine tests are two components of the Amsel Criteria, the Gold Standard method of clinically diagnosing patient vaginal fluid samples for bacterial vaginosis. Using this test, a patient vaginal fluid sample is obtained with a sterile cotton swab. A portion of the sample is first transferred to a section of the FemExam® TestCard™ to evaluate for elevated pH. A second portion of the sample is transferred to the card to evaluate for the presence of volatile amines. A positive indication in both the pH and amines tests is indicative of bacterial vaginosis in patients presenting bacterial vaginosis-like symptoms.
BVBLUE TM (manufactured by Gryphus Diagnostics, L.L.C.) evaluates patient vaginal fluid samples for sialidase activity, an enzyme produced by bacterial pathogens associated with Bacterial Vaginosis (BV) such as Gardnerella vaginalis, Bacteroides spp., Prevotella spp., and Mobiluncus spp. Using this test, a patient vaginal fluid sample is obtained with a sterile cotton swab. A portion of the sample is then transferred to the BVBLUE™ test and incubated for 10 minutes at 37 ℃ to provide identification of sialidase enzyme activity. A positive indication for sialdiase enzyme activity is indicative of bacterial vaginosis in patients presenting bacterial vaginosis-like symptoms.
### 7. Discussion of Non-Clinical Tests Performed for Determination of Substantial Equilivance are as follows:
BVBLUE™ was evaluated using analytical samples of sialidase enzyme (Sigma Chemical Co.). The BVBLUE™ Test produces a positive result when the vaginal fluid contains ≥0.25 µg sialidase enzyme [i.e., ≥ 7.64 U (units of enzyme activity)]. This performance was defined in laboratory studies employing coded sialidase solutions containing varying levels of sialidase activity. A total of 207 replicates were evaluated.
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Of the 207 replicates, a total of 69/207 contained sialidase enzyme levels ≥0.25 ug (33%): and 138/207 contained sialidase enzyme levels <0.25 µg (67%).
BVBLUE™ properly identified 69/69 (100%) of confirmed positives for sialidase enzyme levels ≥0.25 µg from analytical samples. BVBLUE™ properly identified 138/138 (100%) of confirmed negatives for sialidase enzyme levels <0.25 ug from analytical samples.
Inter-operator reproducibility studies were conducted with BVBLUE 1M by three individuals in a blinded study employing coded sialidase solutions of varying levels of sialidase activity. A total of 30 replicates were performed by each individual, for a total of 90 replicates.
Of the 90 replicates, a total of 18/90 contained sialidase enzyme levels of 20.30 µg (20%); and 72/90 contained sialidase enzyme levels of <0.30 µg (80%).
BVBLUE™ properly identified 18/18 (100%) of confirmed positives for sialidase enzyme levels ≥0.30 µg from analytical samples. BVBLUE™ properly identified 69/72 (96%) of confirmed negatives for sialidase enzyme levels <0.30 µg from analytical samples.
Real-time and accelerated stability studies were conducted with BVBLUE™. Accelerated studies conducted at 56 °C established a stability of 41 days at 56 °C. Real-time studies conducted at ambient temperature established a stability of 241 days and continuing. These real-time stability studies are continuing.
#### 8. Discussion of Clinical Tests Performed:
BVBLUE™ was evaluated in two separate clinical studies.
The first clinical study was conducted by 18 site personnel and 2 company employees at 5 separate clinical sites. A total of 502 women were evaluated. The objective of this study was to define correlations between a diagnosis of bacterial vaginosis based on Amsel Criteria, the Gold Standard Method of clinically diagnosing bacterial vaginosis as recommended by the CDC, and BVBLUE™. A second objective was to determine the reproducibility of BVBLUE™ in patients with and without bacterial vaginosis. Two vaginal fluid samples were obtained from all women by contacting a sterile cotton swab with the vaginal wall (lower one-third). One swab sample was used in an evaluation for bacterial vaginosis based on Amsel Criteria and the second was used in an evaluation of BVBLUE™. A total of three vaginal fluid samples were
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obtained from a subset of women attending one clinical site. The third
swab sample was used to perform an independent BVBLUE™ Test. The results of the two tests were compared. Women were excluded from the study if they had used an antibiotic or antifungal agent within three days of testing. One production lot of the BVBLUE™ Test Kit was used in the clinical study.
Of the 502 clinical samples evaluated, a total of 86/502 (17%) exhibited bacterial vaginosis based on Amsel Criteria. Of these 86 samples, 73 (85%) exhibited a positive BVBLUE™ test result. Of the 502 clinical samples evaluated, a total of 416/502 (83%) did not exhibit bacterial vaginosis based on Amsel Criteria. Of these 416 samples, 375 (90%) exhibited a negative BVBLUE™ test result.
The first clinical study did not provide for the evaluation of discordant samples via a second reference method of diagnosing for bacterial vaginosis. This issue, among others, was addressed in a second clinical study.
There was a 100% correlation of results during the reproducibility testing of BVBLUE™. The reproducibility of the BVBLUE Test was conducted on a total of 50 vaginal fluid samples obtained from a total of 25 women.
The second clinical study was conducted by 4 site personnel and 1 company employee at 2 separate clinical sites. A total of 118 women were evaluated. The objective of this study was to (1) define correlations between a diagnosis of bacterial vaginosis based on Amsel Criteria, the Gold Standard Method of clinically diagnosing bacterial vaginosis as recommended by the CDC, and BVBLUE™, (2) define correlations between a diagnosis of bacterial vaginosis based on Gram's stain, a second Gold Standard Method of clinically diagnosing bacterial vaginosis, and BVBLUE™: (3) define correlations between a diagnosis of bacterial vaginosis based on Amsel Criteria OR Gram's Stain and BVBLUE™: (4) define correlations between the semi-quantitative method of identifying Gardnerella vaginalis morphotypes, Prevotella spp. morphotypes, Bacteroides spp. morphotypes, and Mobiluncus spp. morphotypes and BVBLUE™; (5) define correlation between a genital culture for Gardnerella vaginalis, and anaerobic culture for microorganisms including Bacteroides spp. and Prevotella spp., and BVBLUETM; (6) define the quantitative sialidase enzyme activities in vaginal fluid specimens of women with bacterial vaginosis, candidiasis, trichomoniasis, and healthy controls; and (10) define the correlations between interfering substances including blood, semen, menses, contraceptive method, and vaginal signs and symptoms, and BVBLUE™ Three vaginal fluid samples were obtained from all women by contacting a sterile cotton swab with the vaginal wall (lower one-third). One swab sample was used in an evaluation of
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bacterial vaginosis based on Amsel Criteria; a second for an evaluation of bacterial vaginosis based on Gram's stain and the semi-quantitative identification of Gram's stain morphotypes; and a third for an evaluation of BVBLUE 100 and quantitative sialidase enzyme activity. A total of five vaginal fluid samples were obtained from a subset of women attending two clinical sites. The fourth swab sample was used in a genital culture. The fifth swab sample was used in an anaerobic culture. Women were excluded from the study if they had used an antibiotic or antifungal agent within three days of testing. Two production lots of the BVBLUE™ Test Kit was used in the clinical study.
In the reconciled comparison of BVBLUE™ vs. Amsel Criteria in all patients, of the 118 clinical samples evaluated, a total of 31/118 (26%) exhibited bacterial vaginosis. Of these 31 samples, 30 (97%) exhibited a positive BVBLUE™ test result. Of the 118 clinical samples evaluated, a total of 87/118 (74%) did not exhibit bacterial vaginosis. Of these 87 samples, 86 (99%) exhibited a negative BVBLUE™ test result.
In the reconciled comparison of BVBLUE™ vs. Gram's stain in all patients. of the 118 clinical samples evaluated, a total of 31/118 (26%) exhibited bacterial vaginosis. Of these 31 samples, 30 (97%) exhibited a positive BVBLUE™ test result. Of the 118 clinical samples evaluated, a total of 87/118 (74%) did not exhibit bacterial vaginosis. Of these 87 samples, 86 (99%) exhibited a negative BVBLUE™ test result.
In the comparison of BVBLUE™ vs. Amsel Criteria OR Gram's Stain in all patients, of the 118 clinical samples evaluated, a total of 34/118 (29%) exhibited bacterial vaginosis. Of these 34 samples, 26 (76%) exhibited a positive BVBLUE™ test result. Of the 118 clinical samples evaluated, a total of 84/118 (71%) did not exhibit bacterial vaginosis. Of these 84 samples, 82 (98%) exhibited a negative BVBLUE™ test result.
In the comparison of BVBLUE™ vs. Semi-Quantitative Identification of Morphotpyes Associates with Bacterial Vaginosis in all patients, of the 118 clinical samples evaluated, a total of 43/118 (36%) exhibited bacterial vaginosis. Of these 43 samples, 30 (70%) exhibited a positive BVBLUE™ test result. Of the 118 clinical samples evaluated, a total of 75/118 (64%) did not exhibit bacterial vaginosis. Of these 75 samples, 74 (99%) exhibited a negative BVBLUE™ test result.
In the comparison of BVBLUE™ vs. Clinically Significant Culture of Microorganisms Associated with Bacterial Vaginosis in all patients, of the 55 clinical samples evaluated, a total of 13/55 (24%) exhibited bacterial vaginosis. Of these 13 samples, 10 (77%) exhibited a positive BVBLUE™ test result. Of the 55 clinical samples evaluated, a total of 42/55 (76%) did
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not exhibit bacterial vaginosis. Of these 42 samples, 35 (83%) exhibited a negative BVBLUE™ test result.
In the comparison of BVBLUE™ vs. clinical diagnosis of bacterial vaginosis, Candidiasis, Trichomoniasis, herpes, gonorthea, and in healthy controls, of 255 clinical samples evaluated, a total of 50/255 (20%) exhibited bacterial vaginosis, 5/255 (2%) exhibited bacterial vaginosis and Candidiasis, and 2/255 (0.8%) exhibited bacterial vaginosis and Trichomoniasis. Of these samples, a total of 48/50 (96%) of those exhibiting bacterial vaginosis, 4/5 (80%) of those exhibiting bacterial vacinosis and Candidiasis, and 2/2 (100%) of those exhibiting bacterial vaginosis and Trichomoniasis exhibited a positive BVBLUE™ test result. Of the 255 clinical samples evaluated, a total of 1/255 (0,4%) exhibited gonorrhea. 1/255 (0.4%) exhibited herpes, 4/255 (1.6%) exhibited Trichomoniasis, 41/255 (16%) exhibited Candidiasis, and 151/255 (59%) were healthy controls. Of these samoles, 1/1 (100%) of those exhibiting gonorthea, 1/1 (100%) of those exhibiting herpes, 4/4 (100%) of those exhibiting Trichomoniasis. 41/41 (100%) of those exhibiting Candidiasis, and 142/151 (94%) of healthy controls exhibited a negative BVBLUE™ test result.
In the comparison of BVBLUE™ vs. the quantitative assessment of sialidase enzyme activity in patients with bacterial vaginosis. Candidiasis. Trichomoniasis, and in healthy controls, of 118 clinical samples evaluated. 27/118 (23%) exhibited bacterial vaginosis. The mean sialidase enzyme activity in these samples was 12.34 U. Of the 118 dinical samples, 59/118 (50%) were healthy controls. The mean sialidase enzyme activity in these samples was 2.70 U. Of the 118 clinical samples, 16/118 (14%) exhibited Candidiasis. The mean sialidase enzyme activity in these samples was 3.70 U. Of the 118 clinical samples, 3/118 (3%) exhibited Trichomoniasis. The mean sialidase enzyme activity in these samples was 1.99 U.
The cutoff precision of BVBLUE™, as determined using analytical samples of sialidase enzyme, was found to be 7.64 U. From the clinical studies, the 95% CI for patients with bacterial vaginosis (8.12-16.56 U) is significantly higher than the cutoff of BVBLUE™ The 95% CIs for patients with Candidiasis (2.57-4.83 U), Trichomoniasis (0.59-3.39 U), or in healthy controls (2.23-3.17 U) are significantly lower than the cutoff of BVBLUETM
The data from this clinical study demonstrated that blood, semen, menses, contraceptive methods, vulvo vaginal signs and symptoms, and the presence of other morphotypes and microorganisms did not adversely effect the performance of BVBLUE 10
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EXHIBIT # 1 Page 8 of 8
#### 9. Conclusions:
The BVBLUE™ device has similar intended uses and similar technological characteristics as the predicate devices. Moreover, bench testing contained in this submission and clinical testing supplied demonstrate that contaiffed in this cubeir sechnological characteristics do not raise any new any different of safety or effectiveness. Thus, the BVBLUE™ device is qubstantially equivalent to the predicate devices in the identification of bacterial vaginosis in patient vaginal fluid samples.
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Image /page/8/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized symbol of three human profiles facing right, stacked on top of each other, representing health and human services.
MAY 1 5 2000
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
Gryphus Diagnostics, L.L.C. c/o Mr. Thomas M. Tsakeris Devices and Diagnostics Consulting Group 16809 Briardale Road Rockville, Maryland 20855
Re: K993732
> Trade Name: BVBlue™ Regulatory Class: I Reserved Product Code: MXB Dated: March 7, 2000 Received: March 7, 2000
Dear Mr. Tsakeris:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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 (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
{9}------------------------------------------------
Page 2
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4588. Additionally, for questions on the promotion and advertising of your device. please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrl/dsma/dsmamain.html".
Sincerely yours,
Steven Butman
Steven I. Gutman, M.D., M.B.A. Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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EXHIBIT B Page 1 of 1
## 510(k) Number (if known): K993732
Device Name: BV BLUE™
### Indications for Use:
BV BLUEm is an enzyme activity test for use in the detection of vaginal fluid specimens for sialidase activity, an enzyme produced by bacterial pathogens such as Gardnerella vaginalis, Bacteroides spp., Prevotella spp., and Mobiluncus spp.
BV BLUE™ is indicated for use in women suspected of having Bacterial Vaginosis (BV) infection, e.g., women with vaginal discharge typical of BV and/or women with previous history of BV, as an aid in the diagnosis of BV infection. BV BLUE™ test results should be considered in conjunction with other clinical and patient information (see Limitations of the Procedure)
For In Vitro Diagnostic Use Only. BV9LUE™ is indicated for professional use only and may be used at the point of care and/or in physician's offices. It is not intended for home-use.
Cooper
(Division Sign-Off)
Division of Clinical Laboratory Devices
510(k) Number K993732
# (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
い OR Over-The-Counter Use Prescription Use Format 1-2-96) (Per 21 CFR 801.109)
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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.
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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.
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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.
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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.
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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
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Reading rule for every project: how many summaries do you read in full?
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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.
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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.
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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.
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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.