K Number
K092039
Device Name
IDENTEVENT, VERSION 1.0G
Date Cleared
2009-10-16

(102 days)

Product Code
Regulation Number
882.1400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
IdentEvent ™ is a software-only product with an algorithm intended to analyze previously acquired, adult (≥18 years) scalp EEG signals and mark events that may correspond to electrographic seizures for the purpose of reviewing prolonged EEG traces. The marked events are reviewed, possibly deleted, and interpreted by qualified clinical practitioners who will exercise professional judgment in using the information. IdentEvent also includes the display of the quantitative EEG parameters Amplitude Variation and Maximum Frequency, which are intended to help the user analyze the EEG waveform after it has been collected. IdentEvent requires the use of EEGs recorded with at least a 16-channel scalp montage following the standard 10/20 electrode placement system. IdentEvent does not provide any diagnostic conclusion about the patient's condition to the user.
Device Description
Optima's IdentEvent™ analyzes digital scalp electroencephalograph (EEG) signals recorded from standard recording systems and displays information about brain electrical activity to the user. The application only analyzes and displays information from previously recorded digital EEG files. IdentEvent is designed for post-hoc EEG review of long-term EEG recordings, including the detection of seizure events. IdentEvent requires previously recorded, digitized scalp EEG recordings with electrodes placed according to the standard 10/20 system. The recording can then be automatically analyzed to detect seizures which are then marked for review by the user. IdentEvent includes the following features (outputs): * Display of raw & filtered EEG signals for review * Display of the following quantitative EEG (qEEG) measures: * Amplitude Variation * Maximum Frequency * Review (and possible deletion) of detected seizures * Entry, editing and display of user-entered comments * Graphical and text reports of detected seizures and comments.
More Information

Not Found

Unknown
The summary describes an algorithm for analyzing EEG signals to detect potential seizures but does not explicitly state whether this algorithm utilizes AI or ML techniques. While the task of identifying patterns in complex data like EEG is often addressed with AI/ML, the document does not provide enough detail about the algorithm's implementation to confirm its use.

No.
The device is described as a software product that analyzes EEG signals to mark events potentially corresponding to seizures for review by clinical practitioners. It does not provide any diagnostic conclusions or directly treat or mitigate any condition, which are characteristics of a therapeutic device.

No

The "Intended Use / Indications for Use" section explicitly states, "IdentEvent does not provide any diagnostic conclusion about the patient's condition to the user." It is intended to mark events for review by qualified practitioners who then exercise professional judgment.

Yes

The device description explicitly states "IdentEvent ™ is a software-only product" and describes its function as analyzing and displaying information from previously recorded digital EEG files. It does not mention any associated hardware components that are part of the device itself.

Based on the provided information, IdentEvent is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, tissue) to provide information for diagnostic purposes.
  • IdentEvent's Function: IdentEvent analyzes previously acquired EEG signals, which are electrical signals recorded from the scalp. It does not involve the collection or analysis of specimens taken from the body in the way that traditional IVDs do (e.g., analyzing blood for biomarkers).
  • Intended Use: The intended use is to analyze existing EEG signals and mark potential seizure events for review by qualified clinical practitioners. It explicitly states that it "does not provide any diagnostic conclusion about the patient's condition to the user." This further reinforces that it's a tool for analyzing existing data, not a diagnostic test performed on a specimen.

Therefore, IdentEvent falls outside the scope of an In Vitro Diagnostic device. It is a software tool for analyzing physiological signals.

N/A

Intended Use / Indications for Use

IdentEvent ™ is a software-only product with an algorithm intended to analyze previously acquired, adult (≥18 years) scalp EEG signals and mark events that may correspond to electrographic seizures for the purpose of reviewing prolonged EEG traces. The marked events are reviewed, possibly deleted, and interpreted by qualified clinical practitioners who will exercise professional judgment in using the information.

IdentEvent also includes the display of the quantitative EEG parameters Amplitude Variation and Maximum Frequency, which are intended to help the user analyze the EEG waveform after it has been collected.

IdentEvent requires the use of EEGs recorded with at least a 16-channel scalp montage following the standard 10/20 electrode placement system. IdentEvent does not provide any diagnostic conclusion about the patient's condition to the user.

Product codes

OMB, OLT

Device Description

Optima's IdentEvent™ analyzes digital scalp electroencephalograph (EEG) signals recorded from standard recording systems and displays information about brain electrical activity to the user. The application only analyzes and displays information from previously recorded digital EEG files. IdentEvent is designed for post-hoc EEG review of long-term EEG recordings, including the detection of seizure events.
IdentEvent requires previously recorded, digitized scalp EEG recordings with electrodes placed according to the standard 10/20 system. The recording can then be automatically analyzed to detect seizures which are then marked for review by the user. IdentEvent includes the following features (outputs):

  • Display of raw & filtered EEG signals for review
  • Display of the following quantitative EEG (qEEG) measures:
    • Amplitude Variation
    • Maximum Frequency
  • Review (and possible deletion) of detected seizures
  • Entry, editing and display of user-entered comments
  • Graphical and text reports of detected seizures and comments.
    IdentEvent displays two measures for use in post-hoc analysis of EEG: Amplitude Variation and Maximum Frequency.
    Amplitude Variation is the calculation of standard deviation of one EEG signal within each calculation window, a statistical measure which increases with larger signal peaks (amplitude changes). The Amplitude Variation for one signal is calculated as follows: (Image /page/1/Figure/3 description: The image shows a mathematical formula. The formula is for calculating the standard deviation of a sample. It involves summing the squared differences between each data point and the sample mean, dividing by the sample size minus one, and then taking the square root. The formula is commonly used in statistics to measure the spread or dispersion of a set of data.)
    Maximum Frequency is the maximum number of one-directional (neqative to positive) zero crossings among 11 overlapping 1 second time windows within a given window defined by the sample period (5.12 seconds).
    Suppose that {x1, x2, x3, ..., x2048} represents a sample period of 5.12 second 400 Hz EEG epoch. Then 11 overlapping (600ms) 1 second windows can be constructed as:
    W1 = {x1, x2, ... , x400}, W2 = {x161, x162, ..., x560}, W3 = {x321, x322, ..., x720}, ..., W11= (x1601, x1602, ..., x2000)
    For each Wi, i=1, 2, ..., 11, frequency of one-directional (negative to positive) zero crossings is observed as fi, then the Frequency Maximum for this sample period is defined as:

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

scalp

Indicated Patient Age Range

adult (≥18 years)

Intended User / Care Setting

neurologists and EEG technicians

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

The seizure detection performance of IdentEvent's algorithm was evaluated on scalp EEG recordings from patients with medically refractory seizures. All patients 18 years of age or older with a history of intractable seizures admitted to multiple clinical sites for long term EEG-video recordings for diagnostic or pre-surgical evaluation were asked to participate.
A total of 436 EEG segments sampled from 55 long-term scalp EEG recordings were included in the test dataset. These 55 recordings (from 55 patients) represented the first 50 recordings with at least one seizure recorded and the first 5 without seizures recorded (based on initial clinical reports). Under the constraint that no more than 3% of the total seizures were included from one subject; detection performance was tested on 146 seizures in a total of 1,208.24 hours of scalp EEG recordings from these 55 patients. Otherwise, no additional inclusion/exclusion criteria were applied in the data selection process.
Reference Standard: Each of the 436 sampled EEG segments was reviewed by three independent, blinded EEG experts (all neurologists/epileptologists) to identify electrographic seizures. The end point of this independent review was to identify, if any, the seizure onset times in each of the sampled EEG segments. Due to the anticipated inter-rater variability among EEG experts, a majority rule (at least 2 out of 3) was applied to make the final determination of "true" electrographic seizure events.

Summary of Performance Studies

Study type: Non-Clinical and Clinical Testing, Statistical Analysis (Inter-Rater Variability, Detection Performance)
Sample size: 55 patients (146 seizures in 1,208.24 hours of scalp EEG recordings)
AUC: Not Found
MRMC: Not Found
Standalone performance:
Positive % Agreement (95% C. I.): 79.5% (70%, 87%)
Negative Disagreement Rate (95% C. I.): 2/24h (1.3, 3.3)/24h
Key results:
The overall seizure detection positive percent agreement of IdentEvent was 79.5% (bootstrap 95% Cl = [70%, 87%]) with a negative disagreement rate of 2 per 24 hours (bootstrap 95% Cl = [1.3, 3.3]).
Inter-rater variability: The pair-wise kappa statistics among pairs of experts range from 0.641 to 0.790. with a weighted average of 0.680. Based on the interpretation of kappa statistic by Landis and Koch (Biometrics 33: 159-174, 1997), the kappa statistics for all pairs of EEG reviewers indicated "substantial agreement" (0.61 ~ 0.80).
Statistical comparisons to the predicate device were based on a type I error of .05 and a .10 non-inferiority margin. A Wilcoxon signed rank test and bootstrap estimates to generate 95% confidence intervals were calculated.
IdentEvent has similar positive percent agreement to the predicate while the negative percent agreement is significantly higher suggesting the false detection rate is lower with IdentEvent.

Key Metrics

Positive % Agreement: 79.5% (95% CI: 70%, 87%)
Negative Disagreement Rate: 2/24h (95% CI: 1.3, 3.3)/24h

Predicate Device(s)

Persyst Reveal® (K011397), NeuroGuide Analysis System (K041263)

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.1400 Electroencephalograph.

(a)
Identification. An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.(b)
Classification. Class II (performance standards).

0

SECTION 5 510(K) SUMMARY

.

510(k) Notification (21 CFR 807.90(e))

Traditional Premarket 510(k) Submission

OCT 1 6 2009

ldentEvent™

Date:July 2, 2009
Submitted by:Optima Neuroscience, Inc.
13400 Progress Boulevard
Alachua, FL 32615
Representative:Ryan T. Kern, MD
President
Phone:352-371-8281
FAX:386-462-0606
Proprietary Name:IdentEvent ™
Regulation Number:21 CFR 882.1400
Classification Name:Electroencephalograph, Electroencephalogram (EEG) signal spectrum analyzer
Classification Code:OMB, OLT
Regulatory Class:II
Predicate Devices:Persyst Reveal® (K011397)
NeuroGuide Analysis System (K041263)
Description:Optima's IdentEvent™ analyzes digital scalp electroencephalograph (EEG) signals recorded from standard recording systems and displays information about brain electrical activity to the user. The application only analyzes and displays information from previously recorded digital EEG files. IdentEvent is designed for post-hoc EEG review of long-term EEG recordings, including the detection of seizure events.
IdentEvent requires previously recorded, digitized scalp EEG recordings with electrodes placed according to the standard 10/20 system. The recording can then be automatically analyzed to detect seizures which are then marked for review by the user. IdentEvent includes the following features (outputs):
Display of raw & filtered EEG signals for reviewDisplay of the following quantitative EEG (qEEG) measures: Amplitude VariationMaximum FrequencyReview (and possible deletion) of detected seizuresEntry, editing and display of user-entered comments
  • Entry, editing and display of user-entered comments
    Graphical and text reports of detected seizures and comments .
    1

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:

:

:

1

IdentEvent displays two measures for use in post-hoc analysis of EEG: Amplitude Variation and Maximum Frequency.

Amplitude Variation is the calculation of standard deviation of one EEG signal within each calculation window, a statistical measure which increases with larger signal peaks (amplitude changes). The Amplitude Variation for one signal is calculated as follows:

Image /page/1/Figure/3 description: The image shows a mathematical formula. The formula is for calculating the standard deviation of a sample. It involves summing the squared differences between each data point and the sample mean, dividing by the sample size minus one, and then taking the square root. The formula is commonly used in statistics to measure the spread or dispersion of a set of data.

Maximum Frequency is the maximum number of one-directional (neqative to positive) zero crossings among 11 overlapping 1 second time windows within a given window defined by the sample period (5.12 seconds).

Suppose that {x1, x2, x3, ..., x2048} represents a sample period of 5.12 second 400 Hz EEG epoch. Then 11 overlapping (600ms) 1 second windows can be constructed as:

W1 = {x1, x2, ... , x400}, W2 = {x161, x162, ..., x560}, W3 = {x321, x322, ..., x720}, ..., W11= (x1601, x1602, ..., x2000)

For each Wi, i=1, 2, ..., 11, frequency of one-directional (negative to positive) žero crossings is observed as fi, then the Frequency Maximum for this sample period is defined as:

The application will be used only by neurologists and EEG technicians who are trained in the interpretation of EEGs. The graphical user interface will be designed to be intuitive and easy to setup and use without the need for extensive user training.

Indications for Use:

IdentEvent ™ is a software-only product with an algorithm intended to analyze previously acquired, adult (≥18 vears) scalp EEG signals and mark events that may correspond to electrographic seizures for the purpose of reviewing prolonged EEG traces. The marked events are reviewed, possibly deleted, and interpreted by qualified clinical practitioners who will exercise professional judgment in using the information.

IdentEvent also includes the display of the quantitative EEG parameters Amplitude Variation and Maximum Frequency, which are intended to help the user analyze the EEG waveform after it has been collected.

IdentEvent requires the use of EEGs recorded with at least a 16-channel scalp montage following the standard 10/20 electrode placement system. IdentEvent does not provide any diagnostic conclusion about the patient's condition to the user.

2

.

Technological Characteristics:

Optima's IdentEvent marks events that may correspond to electrographic seizures for the purpose of reviewing prolonged EEG traces and displays quantitative EEG parameters to help the user analyze the EEG waveform after it has been collected. These characteristics may be viewed in comparison with the technological characteristics of the identified predicate devices in Table 5.1.

Table 5.1 Comparison of Device Characteristics

| Optima Neuroscience
IdentEvent Software
(K092039/A02) | Persyst Reveal
(K011397)
Appendix A-01 | Neuroguide
Analysis System
(K041263)
Appendix A-02 | |
|-------------------------------------------------------------|------------------------------------------------------|-------------------------------------------------------------|-------------------------------------------------------|
| Identifies spikes | No | Yes | No |
| Identifies seizures | Yes | Yes | No |
| Displays calculated
EEG measures | Yes | No | Yes |
| Calculated EEG
measures
displayed: | Amplitude Variation &
Maximum Frequency | None | Power, Coherence &
Fast Fourier
Transform (FFT) |
| User-adjustable
seizure detection | No | Yes | No |
| Users can
add/delete events | Yes | Yes | No |
| Number of EEG
channels | 21 channels (standard
10/20 scalp EEG
montage) | Unknown | Unknown |
| Type of EEG
recording supported | Scalp EEG only | Unknown | Unknown |
| Type of EEG
analysis | Post-hoc only | Post-hoc only | Post-hoc only |
| Population age | Adults (age > 18) | Unknown | Unknown |
| Product Code | OMB, OLT | GWS | GWQ, GWS |
| Indications for Use | See Section 4 | See Section 12 | See Section 12 |

3

Non-Clinical and Clinical Testing

Non-Clinical: The IdentEvent seizure detection algorithm relies upon underlying mathematical analyses, including signal regularity, maximum frequency, and amplitude variation. Each mathematical analysis was independently calculated and verified against results generated from published methods.

Clinical: Optima conducted an extensive clinical test to: 1) Evaluate the positive percent agreement (i.e., detection sensitivity based on independent EEG review panel) and negative percent agreement (i.e., false detection rate based on independent EEG review panel) of Optima's IdentEvent on long-term scalp EEG recordings; and, 2) Demonstrate the seizure detection performance, in terms of positive percent agreement and negative percent agreement, of Optima's IdentEvent is equal to or better than those of Persyst Reveal.

Subiect Population and Test Dataset

The seizure detection performance of IdentEvent's algorithm was evaluated on scalp EEG recordings from patients with medically refractory seizures. All patients 18 years of age or older with a history of intractable seizures admitted to multiple clinical sites for long term EEG-video recordings for diagnostic or pre-surgical evaluation were asked to participate.

A total of 436 EEG segments sampled from 55 long-term scalp EEG recordings were included in the test dataset. These 55 recordings (from 55 patients) represented the first 50 recordings with at least one seizure recorded and the first 5 without seizures recorded (based on initial clinical reports). Under the constraint that no more than 3% of the total seizures were included from one subject; detection performance was tested on 146 seizures in a total of 1,208.24 hours of scalp EEG recordings from these 55 patients. Otherwise, no additional inclusion/exclusion criteria were applied in the data selection process. The number of seizures for all the test subjects is shown in Graph 5.1 and the number of hours for each of the samples may be viewed in Graph 5.2.

Image /page/3/Figure/7 description: This image is a bar graph showing the adjusted number of seizures for 55 subjects. The y-axis represents the adjusted number of seizures, ranging from 0 to 8. The x-axis represents the subject number, ranging from 1 to 55. The graph also includes the range of seizures (0-5), the mean (2.65), the standard deviation (1.81), and the median (3).

Graph 5.1 Number of test electrographic seizures for all 55 test subjects

4

Image /page/4/Figure/1 description: The image is a bar graph titled "Graph 5.2 Number of sampled EEG hours for all 55 test subjects". The x-axis is labeled "Subject" and represents the 55 test subjects. The y-axis is labeled "Length of Test EEG Data (Hours)" and ranges from 0 to 30 hours. The range of the data is 14.25 to 30.51, the mean is 21.97, and the standard deviation is 4.49.

Reference Standard

Each of the 436 sampled EEG segments was reviewed by three independent, blinded EEG experts (all neurologists/epileptologists) to identify electrographic seizures. The end point of this independent review was to identify, if any, the seizure onset times in each of the sampled EEG segments.

Due to the anticipated inter-rater variability among EEG experts, a majority rule (at least 2 out of 3) was applied to make the final determination of "true" electrographic seizure events.

Statistical Analysis

1) Inter-Rater Variability

Inter-rater variability was assessed using Cohen's kappa statistic between any pair of EEG experts. The pair-wise kappa statistics among pairs of experts range from 0.641 to 0.790. with a weighted average of 0.680. Based on the interpretation of kappa statistic by Landis and Koch (Biometrics 33: 159-174, 1997), the kappa statistics for all pairs of EEG reviewers indicated "substantial agreement" (0.61 ~ 0.80).

2) Detection Performance

Based on the seizure samples determined by the independent EEG review panel, the positive percentage agreement (i.e., detection sensitivity based on the Reference Standard) and negative disagreement rate (i.e., false detection rate based on the Reference Standard) were estimated for both IdentEvent and the predicate device. Bootstrap method was applied to construct 95% confidence intervals for the estimated performance statistics, as well as to statistically compare positive percentage agreement between IdentEvent and the predicate device. In addition, Wilcoxon signed-rank test (non-parametric paired two-sample t-test) was applied to compare negative disagreement rates between the two detection devices.

5

Results - Summary

Table 5.2 provides a summary of the detection performance statistics for IdentEvent and Reveal.

IdentEventReveal (0.5)Reveal (0.8)Reveal (0.9)
Positive % Agreement
(95% C. I.)79.5%
(70%, 87%)80.8%
(72%, 88%)76.0%
(66%, 84%)74.0%
(64%, 83%)
Negative
Disagreement Rate
(95% C. I.)2/24h
(1.3, 3.3)/24h13/24h
(10.1, 17.1)/24h8/24h
(5.8, 10.5)/24h6/24h
(4.1, 7.8)/24h

Table 5.2 Summary of Detection Performance Statistics

Results - Detailed

The overall seizure detection positive percent agreement of IdentEvent was 79.5% (bootstrap 95% Cl = [70%, 87%]) with a negative disagreement rate of 2 per 24 hours (bootstrap 95% Cl = [1.3, 3.3]). The positive percent agreements of Reveal were 80.8%, 76%, and 74% (bootstrap 95% CIs = [72%, 88%], [66%, 84%], [64%, 83%1. respectively) using its three detection thresholds (perception score = 0.5 (default), 0.8 and 0.9), respectively. Reveal's negative disagreement rates were 13, 8, and 6 per 24 hour (bootstrap 95% CIs = [10.1, 17.1], [5.8, 10.5], [4.1, 7.8], respectively).

The statistical comparisons to the predicate device were based on a type I error of .05 and a .10 non-inferiority margin. A Wilcoxon signed rank test and bootstrap estimates to generate 95% confidence intervals were calculated. A plot of negative disagreement rate (on the X-axis) and positive percent agreement (on the Y-axis) is given in Graph 5.3. Confidence intervals for positive percent agreement and neqative disagreement rate are presented in Graphs 5.4 and 5.5. IdentEvent has similar positive percent agreement to the predicate while the negative percent agreement is significantly higher suggesting the false detection rate is lower with IdentEvent.

Image /page/5/Figure/8 description: The image is a graph titled "Graph 5.3 Detection Performance". The graph plots "Positive Percentage Agreement (Detection Sensitivity)" on the y-axis and "Negative Disagreement Rate (False Detection Rate / 24 Hrs)" on the x-axis. There are data points for "IdentEvent" and "Reveal", with perception scores of 0.9, 0.8, and 0.5 indicated for the "Reveal" data points.

ર-૯

6

Image /page/6/Figure/1 description: The image is a graph that shows the positive percent agreement (detection sensitivity) and 95% confidence interval for different events. The x-axis ranges from 0.5 to 1.0, and the y-axis lists the events: IdentEvent, Reveal (0.5), Reveal (0.8), and Reveal (0.9). Each event has a horizontal line with a diamond in the middle, representing the confidence interval and the positive percent agreement, respectively. The graph shows that IdentEvent has the highest positive percent agreement, followed by Reveal (0.5), Reveal (0.8), and Reveal (0.9).

Graph 5.4 Positive Percent Agreement (Detection Sensitivity) and 95% Confidence Interval

Graph 5.5 Negative Disagreement Rate (False Detection Rate) and 95% Confidence Interval

Image /page/6/Figure/4 description: The image is a plot showing the negative disagreement rate (false detection rate per 24 hours) for different events. The events are IdentEvent, Reveal (0.5), Reveal (0.8), and Reveal (0.9). The negative disagreement rate for IdentEvent is between 1 and 2. The negative disagreement rate for Reveal (0.5) is between 11 and 17, for Reveal (0.8) it is between 6 and 11, and for Reveal (0.9) it is between 4 and 7.

7

Safety testing was performed during validation testing off all software requirements which included safety requirements. Safety requirements included proper handling of patient information, checking data integrity, and prompt notification of the user upon detection of abnormalities. Validation tests demonstrated that all safety requirements were met.

A copy of all study data may be found in Appendix A-05.

Conclusion

Compared to Persyst Reveal, Optima's IdentEvent is substantially equivalent in safety and performance, including sensitivity (positive percent agreement) and false positive rate (negative percent agreement).

8

Image /page/8/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an image of an eagle with its wings spread, symbolizing the department's mission to protect the health of all Americans. The eagle is a stylized design with three lines representing its wings and a simple head and body.

Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring, MD 20993-0002

Optima Neuroscience, Inc. c/o Ms. Paula Wilkerson RAC. CRA Actualized Science, LLC 12337 NW 9th Lane Newberry, FL 32669

OCT 1 6 2009

Re: K092039

Trade/Device Name: IdentEvent™ Version 1.0H Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: II Product Code: OMB, OLT Dated: July 2, 2009 Received: September 17, 2009

Dear Ms. Wilkerson:

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 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.

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 (reporting of medical device-related adverse events) (21 CFR 803); 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.

9

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/cdrh/mdr/ for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,
Kesia Alexander for

Malvina B. Eydelman, M.D Director Division of Ophthalmic, Neurological, and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

10

Indications for Use

510(k) Number (if known): K092039

Device Name: IdentEvent™ (Version 1.0H)

Indications For Use:

IdentEvent™ is a software-only product with an algorithm intended to analyze previously acquired, adult (≥18 years) scalp EEG signals and mark events that may correspond to electrographic seizures for the purpose of reviewing prolonged EEG traces. The marked events are reviewed, possibly deleted, and interpreted by qualified clinical practitioners who will exercise professional judgment in using the information.

IdentEvent also includes the display of the quantitative EEG parameters Amplitude Variation and Maximum Frequency, which are intended to help the user analyze the EEG waveform after it has been collected.

ldentEvent requires the use of EEGs recorded with at least a 16-channel scalp montage following the standard 10/20 electrode placement system. IdentEvent does not provide any diagnostic conclusion about the patient's condition to the user.

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)

Sara Doll

(Division Sign-Off) Division of Ophthalmic, Neurological and Ear. Nose and Throat Devices

510(k) Number K092039

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