K Number
K051471
Device Name
CARDIODAY
Date Cleared
2005-06-29

(26 days)

Product Code
Regulation Number
870.1425
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

CardioDay" is a software package that allows a trained physician or health care professional knowledgeable in Holter interpretation, after having performed a long-term continuous electrocardiographic (ECG) recording on digital flash memory Holter recorder, to download and analyze the data from the recorder, review it and produce printed reports.

This device is available only upon the order of a physician or other licensed medical professional and not intended for any ambulatory or home applications.

Federal law restricts CardioDay® to use on order of a physician.

CardioDay is a Holter software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers.

WARNING:
CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.

Device Description

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values in graphical form. The physician will be able to review, edit, and print the data collected.

CardioDay® is a software package which is delivered on CD.

AI/ML Overview

The provided document is a 510(k) summary for CardioDay®, a Holter ECG software. The submission aims to establish substantial equivalence to a predicate device, Holter for Windows®. The document focuses on comparing the new device against the predicate in terms of various characteristics and functionality, rather than presenting a performance study with specific acceptance criteria and results.

Therefore, many of the requested details about acceptance criteria and a study proving their fulfillment are not explicitly available in the provided text. The document primarily makes a claim of substantial equivalence based on comparison rather than a standalone performance study with defined criteria.

Here's an analysis of the available information:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly state quantitative acceptance criteria or a formal table of device performance metrics against such criteria. Instead, equivalence is established through qualitative comparisons of features and functionalities with the predicate device. The performance is implied to be equivalent to the predicate.

Below is a summary of the comparative analysis, which serves as the basis for claiming "performance":

Feature CategoryPredicate Device (Holter for Windows®) Performance/CharacteristicNew Device (CardioDay®) Performance/CharacteristicEquivalence Claim
Intended UseHolter monitoring software for high-speed data analysis of continuous, long-term ECG, producing printed reports for physician review. Federal law restricts use to physician order.Software allows trained physician/healthcare professional to download, analyze, review, and produce printed reports from long-term continuous ECG recordings. Available only upon physician order and not for ambulatory/home use.Substantially Equivalent. The wording is slightly different but the core function and user restrictions are the same.
Indications for UseFor patients who benefit from long-term continuous ECG recording, including those with palpitations, syncope, chest pain, shortness of breath, or needing cardiac functionality monitoring (e.g., post-pacemaker).Same as predicate.Substantially Equivalent.
Device DescriptionDisplays ECG morphologies and associated calculated graphs; physician reviews, edits, and prints data.Displays ECG morphologies and associated calculated graphs (heart rate trends, RR variability, statistical values); physician reviews, edits, and prints data. Does not perform diagnosis itself.Substantially Equivalent. Both devices are analysis tools, not diagnostic.
Hardware SpecsPentium II, 32MB RAM, 200MB HDD, VGA 14" display, 1.4MB floppy, Windows 98, parallel port.Pentium III 500MHz+, 128MB RAM (256MB for XP), 5GB HDD (20GB for 12-lead), 17" CRT/15" TFT XGA display, no floppy required, Windows 98 SE/NT/2000/XP, parallel/USB ports.Not identical, but determined to have "No influence on safety and effectiveness" as CardioDay®'s requirements "correspond to the current state of the art."
Software FeaturesBroad range including patient data, analysis options (tachycardia, bradycardia thresholds, ST-analysis, pacemaker events), various event detections (VES, VTACH, Pause, etc.), and standard functionalities (start, read, analyze, print).Broad range including patient data, analysis options, event detections, and standard functionalities. Includes additional editing and printing options not available in the predicate (e.g., "Edit all Beat Labels in a Morphology Bin", more specific printout options).Substantially Equivalent. Specific differences in editing/printing options are noted but considered to have "No influence on safety and effectiveness." The core analysis modes are the same.
Supported RecordersRZ153+ Digital Recorder, CardioMem® CM 3000 (SMA).RZ153+ Digital Recorder, CardioMem® CM 3000 (SMA), CardioMem® CM 3000-12. Does not support RZ151 Analog Recorder.Not identical, but determined to have "No influence on safety and effectiveness." The additional recorder support is seen as an enhancement, and the lack of analog tape recorder support is due to outdated technology.
Regulatory StandardsComplies with 21 CFR 820, ISO 9001, IEC 60601-1-4, ANSI/AAMI EC38, IEC 60601-2-47, ISO 14971, EN 980, EN 1041, ISO 15223.Complies with 21 CFR 820, ISO 9001 / EN 46001 / ISO 13485:2003, IEC 60601-1-4 + A1, ANSI/AAMI EC38, IEC 60601-2-47, ISO 14971 +A1, EN 980, EN 1041, ISO 15223 + AMD1 + AMD2.Substantially Equivalent. Both devices comply with relevant standards for medical device quality management and safety.

2. Sample size used for the test set and the data provenance

The document mentions that "The impact of all parameters, especially those specified above, is evaluated with the help of the data bases from American Heart Association (AHA) and Massachusetts Institute of Technology (MIT) and performance evaluations." This indicates that public domain databases (AHA and MIT-BIH Arrhythmia Database are commonly used for Holter analysis algorithm validation) were used for performance evaluations. However, the specific sample size used from these databases for the test set, or details on data provenance (e.g., country of origin, retrospective/prospective) are not specified in this summary.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

The document does not provide details on the number or qualifications of experts used to establish ground truth for any test set derived from the AHA or MIT databases. These databases typically come with expert-verified annotations, but this fact is not explicitly stated in relation to this device's validation.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

The document does not describe any specific adjudication method used for a test set.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

The document does not mention any MRMC study or any study evaluating the improvement of human readers with or without AI assistance. The device is described as a software for trained professionals to review, edit, and print data, explicitly stating that it "does not perform any diagnosis of data by itself." This implies it's an analysis and presentation tool, not an AI-powered diagnostic aid designed to directly assist human readers in improving their diagnostic accuracy.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

The document notes that performance evaluations used "data bases from American Heart Association (AHA) and Massachusetts Institute of Technology (MIT)." This implies that the algorithms within CardioDay® were tested against these reference databases, which constitutes a form of standalone performance evaluation. However, specific metrics, methodology, and results are not provided in this summary. The output of the device (ECG morphologies, graphs, statistical values) is then reviewed and edited by human users.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

Given the mention of AHA and MIT databases, the ground truth for the algorithm evaluation would typically be expert annotations/consensus provided with these publicly available arrhythmia databases.

8. The sample size for the training set

The document does not provide any information about the sample size used for a training set. As a rule-based or conventional signal processing software (not explicitly stated as AI/machine learning), it might not have a "training set" in the modern sense. If it did employ machine learning, this detail is omitted.

9. How the ground truth for the training set was established

Not applicable, as no training set information is provided. If the algorithms were trained, the ground truth would likely be derived from expert annotations, similar to the test set ground truth.

{0}------------------------------------------------

JUN 29 2005

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D

1 510(k) - Summary

Submitted By:getemed Medizin- und Informationstechnik AGOderstr. 5914513 TeltowGermanyTel.: +49 3328 - 3942-70Fax: +49 3328 - 3942-99
Contact:Dr. Bert SchadowRegulatory Affairs Manager
Manufacturing Facility:getemed Medizin- und Informationstechnik AGOderstr. 5914513 TeltowGermany
Date of Preparation:2005-06-13
Trade Name:CardioDay®
Common Name:Holter ECG
Classification Name:Computer, Diagnostic, Programmable
Product Classification:21 CFR 870.1425, Class II
Product Code:DQK
Legally Marketed Devices:Holter for Windows® (K930564, NortheastMonitoring Inc.)

Reason for Submission

Premarket notification for CardioDay® (Version 1.9.5), a New Device, seeking authority to market the device under Section 510(k) as a device that is substantially equivalent to the Holter for Windows® evaluation software (K930564, Northeast Monitoring Inc.).

Intended Use

CardioDay" is a software package that allows a trained physician or health care professional knowledgeable in Holter interpretation, after having performed a long-term continuous electrocardiographic (ECG) recording on digital flash memory Holter recorder, to download and analyze the data from the recorder, review it and produce printed reports.

This device is available only upon the order of a physician or other licensed medical professional and not intended for any ambulatory or home applications.

Federal law restricts CardioDay® to use on order of a physician.

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc CONFIDENTIAL AND PROPRIETARY

{1}------------------------------------------------

510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D

Indications for Use

CardioDay is a Holter software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers.

WARNING:

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.

Device Description

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values in graphical form. The physician will be able to review, edit, and print the data collected.

Description
Intended useHolter for Windows® is Holtermonitoring software, designed toperform high-speed data analysisof continuous, long-termelectrocardiograms saved in theform of direct recordings on acassette tape or flash memorycard. Holter for Windows® isintended for use as an analysistool and produces printed reportsto be reviewed by a personknowledgeable in Holterinterpretation.Federal law restricts Holter forWindows® to use on order of aphysician.CardioDay® is a software packagethat allows a trained physician orhealth care professionalknowledgeable in Holterinterpretation, after havingperformed a long-term continuouselectrocardiographic (ECG)recording on digital flash memoryHolter recorder, to download andanalyze the data from the recorder,review it and produce printedreports.This device is available only uponthe order of a physician or otherlicensed medical professional andnot intended for any ambulatory orhome applications.Federal law restricts CardioDay® touse on order of a physician.

Comparison to Legally Marketed Device

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc CONFIDENTIAL AND PROPRIETARY

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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
DescriptionFacility's CardioDay®Predicate Index
Indications for useSame as CardioDay®CardioDay® is a Holter softwarewhich is indicated for patients whomay benefit from a long-termcontinuous electrocardiographic(ECG) recording, including, but notlimited to, those with complaints ofpalpitations, syncope, chest pain,shortness of breath, or those thatneed to be monitored to judge theircurrent cardiac functionality such aspatients who have recently receivedpacemakers.WARNING:CardioDay® does not perform anydiagnosis of data by itself but onlydisplays ECG morphologies andassociated, calculated graphs suchas heart rate trends, RR variability,and other statistical values.
Device descriptionSame as CardioDay®CardioDay® does not perform anydiagnosis of data by itself but onlydisplays ECG morphologies andassociated, calculated graphs suchas heart rate trends, RR variability,and other statistical values ingraphical form. The physician will beable to review, edit, and print thedata collected.
Target populationSame as CardioDay®Patients who may benefit from along-term continuouselectrocardiographic (ECG)recording, including, but not limitedto, those with complaints ofpalpitations, syncope, chest pain,shortness of breath, or those thatneed to be monitored to judge theircurrent cardiac functionality such aspatients who have recently receivedpacemakers.
Design / materialsSame as CardioDay®CardioDay® is a software packagewhich is delivered on CD.
SterilityThis section does not apply.This section does not apply.
BiocompatibilityThis section does not apply.This section does not apply.
Mechanical safetyThis section does not apply.This section does not apply.
Chemical safetyThis section does not apply.This section does not apply.
Anatomical sitesThis section does not apply.This section does not apply.

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ાં ડા

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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
DescriptionHolter for Windows®
Human factorsSame as CardioDay®Human factors engineering:- device technology (seecomparison of technologycharacteristics),- the users (see targetpopulation),- environment in which thetechnology will be used (seeintended use),- how dangerous is the use of thedevice (see level of concern insection 2),- how critical is the device forpatient care (see productclassification and level ofconcern in section 2).
Energy used and/ordeliveredThis section does not apply.This section does not apply.
Compatibility withenvironment andother devicesSee comparison of technologycharacteristics and miscellaneousSee comparison of technologycharacteristics and miscellaneous
Where used:hospital, home,ambulance, etc.Holter for Windows® is availablefor sale only upon the order of aphysician or other related licensedmedical professional.CardioDay® is available for sale onlyupon the order of a physician orother related licensed medicalprofessional and not intended forany home use applications.
Electrical safetyThis section does not apply.This section does not apply.
Thermal safetyThis section does not apply.This section does not apply.
Radiation safetyThis section does not apply.This section does not apply.

Comparison of Technology Characteristics Compared to Legally Marketed Device:

Specifications
TypeIBM PC AT compatibleIBM PC AT compatible
CPUPentium II ProcessorPentium III, 500MHz or greater
RAM32 Mbytes minimum128 Mbytes minimum,256 Mbytes minimum for XP
Free hard diskspace200 MB minimum5 GB minimum20 GB for 12-lead recordings
DisplayVGA, 14", 1024 x 768 pixel, 256colors17" CRT or 15" TFT, 1024 x 768pixel (XGA), 256 colors
Disc drive / floppydrive1.4 MbytesNot required

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510(k) NotificationCardioDay®o getemed
Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
SpecificationsHotter for Win
CD-ROM driveFor installation onlyFor installation only.Needs to be replaced by a CD-ROMwriter or DVD writer if archive optionimplemented
Operating systemWindows 98Windows 98 SE, NT (SP6a), 2000or XP
PortsOne free parallel port1 parallel port sufficient; if USBdevices used for printing, softwarekey or card reader, thencorresponding USB ports required
PrinterPrinter as any Windows ™compatiblePrinter as any Windows ™compatible, 300 dpi
KeyboardStandard deviceStandard device
MouseStandard, 2-button deviceStandard, 2 or 3-button device
Installation media(1) CD(1) CD
Further peripheryCompact Flash card readerCompactFlash (Type I) memorycard reader

Comparison of Software Characteristics:

Patient ScreenFORM DESIGNATIONSection Windows
Patient Identification NumberYesYes
Patient Name, Address, TelephoneYesYes
Patient Personal Data (Age, Gender, Date of Birth,etc.)YesYes
MedicationYesYes
IndicationYesYes
Physician's NameYesYes
Date of RecordingYesYes
Analysis Options
Analysis DurationYesYes
Primary Channel SelectionYesYes
Sensitivity / Signal QualityYesYes
Tachycardia Threshold [bpm]YesYes
Bradycardia Threshold [bpm]YesYes
Pause Duration [ms]YesYes
SV Prematurity [%]YesYes
V Prematurity [%]YesYes
R on T [ms]YesYes
Pacemaker TypeYesYes
Minimum Pulse Rate [bpm]YesYes
Maximum Pulse Rate [bpm]YesYes
Superimposition / QuickScanYesYes

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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Analysis OptionsHolter for WindowsNew DeviceCardioDay
12-Lead ECG ModuleYesYes
Holter Data TransferYesYes
Events DetectedHolter for WindowsNew DeviceCardioDay
BurstYesYes
VES / VPB (Extrasystole)YesYes
SVES / SVPB (Supraventricular Extrasystole)YesYes
Couplet / VPB PairYesYes
TripletYesYes
VTACH / VTAC (Ventricular Tachycardia)YesYes
BigeminyYesYes
R on TYesYes
ST-AnalysisYesYes
SVTACH / SVT (Supraventricular Tachycardia)YesYes
Arrhythmia / Irregular R-RYesYes
BradycardiaYesYes
VTACH (with 4 Beats) / BurstYesYes
V. STIM / V. PacedYesYes
A. STIM / A. PacedYesYes
AV. STIM / AV PacedYesYes
Undersense / Sense FailureYesYes
Exitblock / Capture FailureYesYes
Oversense / InhibitionYesYes
Pause / ArrestYesYes
Event MarkerYesYes
HR StripesYesYes
ArtifactYesYes
NormalYesYes
Functionality Available
The comparison between the legally marketed de-vice and the NEW DEVICE is based on their func-tions only and not on their names.
StartYesYes
Read TapeYesYes
Read Digital RecorderYesYes
ImportYesYes
Analyze NewYesYes
OpenYesYes
Edit Patient DataYesYes
Print PreviewYesYes
PrintYesYes
Close RecordingYesYes
CloseYesYes

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510(k) Notificationo getemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Functionality AvailableLegally Marketed DeviceHolter for WindowsPredicate DeviceCardioDay
Delete RecordingYesYes
ArchiveYesYes
DiagnosisYesYes
View ECGYesYes
Print PreviewYesYes
Screen Scale CalibrationYesYes
Screen: Colour SetupYesYes
FFT SetupYesYes
Report SetupYesYes
Classes DisplayYesYes
PM Events DisplayYesYes
Events DisplayYesYes
HR Min./Max. DisplayYesYes
Statistics DisplayYesYes
Diagnosis DisplayYesYes
Overview DisplayYesYes
Context sensitive HelpYesYes
Keyboard Shortcuts HelpYesYes
Menu Entries HelpYesYes
Help: AboutYesYes
Help: VersionYesYes
Icons/Buttons AvailableLegally Marketed Device (Hotar or Window)NEW DEVICE (Display)
The following comparison between the legallymarketed device and the NEW DEVICE is based ontheir functions only. The label and form of the icons/ buttons, however, are different. It might even takemore than one click to initiate a given action.
Start: Read Digital RecorderYesYes
Start: Read Tape RecorderYesYes
Start: Open Existing RecordYesYes
Digital RecorderYesYes
Tape RecorderYesYes
Open: List of PatientsYesYes
PrintYesYes
Rhythm AnalysisYesYes
Print Preview on ScreenYesYes
Options AvailableLegally Marketed Device (Note on Wind)New Device (Note on Wind)
The following comparison between the legally mar-keted device and the NEW DEVICE is based on theirfunctions only. The name of those options may vary.
ClassesYesYes
EventsYesYes
Heart Rate Min/MaxYesYes

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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Options AvailableLegally Marketed Device Holter for WindowsNew Device CardioDay
Average Heart RateYesYes
Statistics: FFT AnalysisYesYes
Statistics: ST DiagramsYesYes
ReportYesYes
OverviewYesYes
Heart Variability: RR DelayYesYes
Heart Rate Variability: RR FFTYesYes
Heart Rate Variability: 24h RR FFTYesYes
Heart Rate Variability: RR HistogramsYesYes
Graphics & Displays AvailableLegally Marketed Device:Holter for WindowsNew Device:CardioDay
The following comparison between the legally mar-keted device and the NEW DEVICE is based on theirfunctions only. The label and appearance of thosedisplays may vary.
Classified Beats Grouped into Morphology BinsYesYes
Zoomed Version of Selected BeatYesYes
Context of Selected BeatYesYes
EventsYesYes
Heart Rate Trend in Recording PeriodYesYes
Average RR IntervalYesYes
Y-T DistributionYesYes
RR > 50ms DistributionYesYes
FFT AnalysisYesYes
ST DiagramsYesYes
Overview 2 channels at Different Scaling FactorsYesYes
Printout OptionsLegally Marketed DeviceHoferator WindowNew DeviceCardioDay
The following comparison between the legally mar-keted device and the NEW DEVICE is based on their
functionality only. The commands to generate agiven printout as well as its appearance do vary.
Full Disclosure 2 Channels, 1 h/PageYesYes
Full Disclosure 2 Channels, 15 min./PageNoYes
Full Disclosure 2 Channels, 30 min./PageYesYes
Marked Events: 8 Events/PageYesYes
Marked Events: 32 Events/PageYesYes
Marked Events: Analysis Channel 25 mm/sYesYes
Marked Events: Analysis Channel 2.5 min +25mm/sNoYes
Selected Channels 25 mm/sYesYes
Selected Channels 1 min. + 25 mm/sYesYes
Selected Channels 2.5 min. + 25 mm/sNoYes
Selected Channels 10 min. + 25 mm/sNoYes
Event TableYesYes

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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
Printout OptionsLegally Marketed Device Holter for WindowNew Device CardioDay
Event HistogramYesYes
Heart Rate and ST DiagramsYesYes
HR diagram + Min/Max per MinuteNoYes
RR IntervalsYesYes
RR DelayNoYes
RR HistogramsNoYes
RR Interval SpectraNoYes
Pacemaker Event HistogramYesYes
Pacemaker Function AnalysisYesYes
ReportYesYes
Print to File (PDF)YesYes
Save as Default OptionYesYes
Editing & Reviewing OptionsLegally Marketed Device to WindowsNew Device CardioDay
The following comparison between the legally mar- keted device and the NEW DEVICE is based on their functions only. The label and appearance of those options may vary.
Scroll through all Beats in a Morphology BinYesYes
Edit all Beat Labels in a Morphology BinNoYes
Scroll through ECG and Edit Single Beat LabelsNoYes
Scroll through Events of the Same TypeYesYes
Edit Event MarkerYesYes
View Patient Event MarkersYesYes
Jump from any Statistics Diagram to the corresponding ECGNoYes
Jump from ECG Overview to the corresponding ECGYesYes
Select Tme Interval for Time Domain RR ParametersYesYes
Edit ReportYesYes
MiscellaneousLegally Marketed Device Holter for WindowsNew Device Cardiology
RZ153+ Digital Recorder Supported (K022540)YesYes
CardioMem® CM 3000 (SMA) SupportedYesYes
CardioMem® CM 3000-12 SupportedNoYes
CD Installation MediumYesYes
RZ151 Analog Recorder SupportedNoNo
CD Installation MediumYesYes

Standards Comparison

StandardDevice Master RecordDevice History RecordCardioDay
21 CFR 820 (FDA cGMP Good ManufacturingPractice)YesYes

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510(k) Notificationo getemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
StandardComply Marked DeviceHolter for WindowsNon-Device (C-Code Only)
ISO 9001:2000 / EN 46001 / ISO 13485:2003Quality Management SystemsYesYes
IEC 60601-1-4 + A1 Programmable ElectricalMedical SystemsYesYes
ANSI/AAMI EC38 Ambulatory ElectrocardiographsYesYes
IEC 60601-2-47 Particular Requirements for theSafety, including Essential Performance, ofAmbulatory Electrocardiographic SystemsYesYes
ISO 14971 +A1 Application of the RiskManagement to Medical DevicesYesYes
EN 980 Graphic Symbols for the Marking ofMedical DevicesYesYes
EN 1041 Supply of Information by the Manufacturerof a Medical DeviceYesYes
ISO 15223 + AMD1 + AMD2 Symbols to be Usedwith Medical DevicesYesYes

Differences between the Legally Marketed Device (Holter for Windows®) and the New Device (CardioDay®):

Where Used: Hospital, Home, Ambulance, etc.:

CardioDay® clearly excludes home use applications. This has no influence on safety and effectiveness.

Performance

CardioDay and Holter for Windows® have the following different technology specifications:

SpecificationsLegally Marketed DeviceHot for WindowsNew DeviceOrtotoBay
CPUPentium II ProcessorPentium III, 500MHz or greater
RAM32 Mbytes minimum128 Mbytes minimum,256 Mbytes minimum for XP
Free hard disk space200 MB minimum5 GB minimum20 GB for 12-lead recordings
DisplayVGA, 14", 1024 x 768 pixel,256 colors17" CRT or 15" TFT, 1024 x 768 pixel(XGA), 256 colors
Disc drive / floppy drive1.4 MbytesNot required
CD-ROM driveFor installation onlyFor installation only.Needs to be replaced by a CD-ROMwriter or DVD writer if archive optionimplemented
Operating systemWindows 98Windows 98 SE, NT (SP6a), 2000 or XP

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K051471/SI
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510(k) Notificationgetemed
CardioDay®Project ID: 0429S1
510(k) - SummarySection 1-0001-Rev D
PortsOne free parallel port1 parallel port sufficient; if USB devicesused for printing, software key or cardreader, then corresponding USB portsrequired

The minimum hardware requirements, such as CPU, RAM, free Hard disk space, display, CD-ROM drive and ports and supported operating system of CardioDay® correspond to the current state of the art. No influence on safety and effectiveness is expected.

Software characteristics

The new device CardioDay offers a number of editing and printing options not available in the legally marketed device. No influence on safety and effectiveness is expected.

Miscellaneous

Holter for Windows® does not support the Holter recorder CardioMem® CM 3000-12. No influence on safety and effectiveness is expected.

CardioDay® does not support the RZ 151 analog tape recorder. This technology is no longer state of the art and therefore it is not supported. No influence on safety and effectiveness is expected.

Conclusion

CardioDay and Holter for Windows® software packages are both used in clinical applications to allow trained physicians or other health care providers to download, review and print electrocardiographic (ECG) data recorded on digital Holter recorders. Both are computerized programs which run under a computer operating system. Both perform a high-speed analysis of the recorded ECG data and use the computer operating system to access the displayed data. CardioDay® has the same analysis modes as Holter for Windows®. The impact of all parameters, especially those specified above, is evaluated with the help of the data bases from American Heart Association (AHA) and Massachusetts Institute of Technology (MIT) and performance evaluations.

WARNING:

CardioDay' does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends. RR variability, and other statistical values.

CardioDay conforms to Good Manufacturing Procedures outlined by the FDA GMP. This software is safe and effective for the application for which it is intended and has been tested to confirm the safety and efficacy of the software. CardioDay® is found to be substantially equivalent to the Holter for Windows® software.

0429S1-Sec01-0001-RevD-CardioDay-Executive_Summary.doc CONFIDENTIAL AND PROPRIETARY

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Image /page/11/Picture/1 description: The image shows the seal of the U.S. Department of Health and Human Services. The seal features a stylized eagle with three lines representing its wings and body. The eagle is encircled by the text "DEPARTMENT OF HEALTH AND HUMAN SERVICES, U.S.A."

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

JUN 2 9 2005

getemed Medizin-und Informationstechnik AG c/o Mr. Tamas Borsai Division Manager, Medical Division TUV Rheinland of North America 12 Commerce Road Newtown, CT 06470

Re: K051471 Trade Name: CardioDay® Regulation Number: 21 CFR 870.1425 Regulation Name: Diagnostic Programmable Computer Regulatory Class: Class II (two) Product Code: DOK Dated: June 16, 2005 Received: June 17, 2005

Dear Mr. Borsai:

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 (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. 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 (PMA), 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 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

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Page 2 - Mr. Tamas Borsai

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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. This letter will allow you to begin marketing your device as described in your Section 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), please contact the Office of Compliance at (240) 276-0295_ Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours.

Blummer for
R. D. Zuber, M.D.

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known):

CardioDay® Device Name:

Indications For Use:

CardioDay® is a Holter Software which is indicated for patients who may benefit from a long-term continuous electrocardiographic (ECG) recording, including, but not limited to, those with complaints of palpitations, syncope, chest pain, shortness of breath, or those that need to be monitored to judge their current cardiac functionality such as patients who have recently received pacemakers.

WARNING:

CardioDay® does not perform any diagnosis of data by itself but only displays ECG morphologies and associated, calculated graphs such as heart rate trends, RR variability, and other statistical values.

Prescription Use (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use _ (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Blommima

(Division Sign-Off) Division of Cardiovascular Devices 510(k) Number

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§ 870.1425 Programmable diagnostic computer.

(a)
Identification. A programmable diagnostic computer is a device that can be programmed to compute various physiologic or blood flow parameters based on the output from one or more electrodes, transducers, or measuring devices; this device includes any associated commercially supplied programs.(b)
Classification. Class II (performance standards).