K Number
K131699
Device Name
EMOTION ECG MOBILE
Date Cleared
2013-11-26

(168 days)

Product Code
Regulation Number
870.2920
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The eMotion ECG sensor is a wearable, portable, externally applied, electrocardiograph recorder and transmitter for the purpose of health monitoring, biofeedback and scientific research. The eMotion ECG Mobile is intended for use in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug-in devices such as ECG sensors, Weight Scales, Blood Pressure Meters and Pulse Oximeters. The eMotion ECG Mobile does not provide any automatic analysis or diagnosis.
Device Description
The eMotion ECG Mobile is a mobile device, PC and Internet based telemetry solution for the ambulant monitoring of the plug-in device data of chronic patients via a mobile network. Plug-in devices can be ECG devices, blood pressure monitors, weighing scales, etc. The device reads data from the plug-in device via a Bluetooth connection. The application in the mobile device sends the data to a server (Health Gateway) over mobile networks using the secured connection. Data can be viewed from the Health Gateway server using the Web Monitor. Monitoring is performed using PC application that reads data from the server over the internet using the secured connection.
More Information

Not Found

No
The summary explicitly states "The eMotion ECG Mobile does not provide any automatic analysis or diagnosis" and there are no mentions of AI, DNN, or ML in the document.

No.

The device is described as a "recorder and transmitter for the purpose of health monitoring, biofeedback and scientific research" and "does not provide any automatic analysis or diagnosis," indicating it collects and transmits data rather than providing treatment or therapy.

No

The "Intended Use / Indications for Use" section explicitly states, "The eMotion ECG Mobile does not provide any automatic analysis or diagnosis." This indicates it is a data collection and transmission device, not one that performs diagnostic analysis.

No

The device description explicitly states it is a "mobile device, PC and Internet based telemetry solution" and reads data from "external plug-in devices" via Bluetooth. While software is a key component, it relies on and interacts with external hardware (mobile device, PC, plug-in devices) for its function.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to diagnose, monitor, or screen for health issues.
  • Device Function: The eMotion ECG sensor and Mobile system collects and transmits physiological data (like ECG, weight, blood pressure, pulse oximetry) from external, commercially available devices. It does not perform any analysis or diagnosis on samples taken from the body.
  • Intended Use: The intended use is for health monitoring, biofeedback, scientific research, and collecting/transmitting health parameters to healthcare professionals for monitoring and evaluation. This aligns with a medical device that measures physiological signals, not an IVD that analyzes biological samples.
  • Device Description: The description focuses on the telemetry system for transmitting data from plug-in devices, not on analyzing biological samples.

The device is clearly a medical device that collects and transmits physiological data, but it does not fit the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The eMotion ECG sensor is a wearable, portable, externally applied, electrocardiograph recorder and transmitter for the purpose of health monitoring, biofeedback and scientific research.
The eMotion ECG Mobile is intended for use in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug-in devices such as ECG sensors, Weight Scales, Blood Pressure Meters and Pulse Oximeters.
The eMotion ECG Mobile does not provide any automatic analysis or diagnosis.

Product codes (comma separated list FDA assigned to the subject device)

DXH

Device Description

The eMotion ECG Mobile is a mobile device, PC and Internet based telemetry solution for the ambulant monitoring of the plug-in device data of chronic patients via a mobile network. Plug-in devices can be ECG devices, blood pressure monitors, weighing scales, etc. The device reads data from the plug-in device via a Bluetooth connection. The application in the mobile device sends the data to a server (Health Gateway) over mobile networks using the secured connection.
Data can be viewed from the Health Gateway server using the Web Monitor. Monitoring is performed using PC application that reads data from the server over the internet using the secured connection.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

clinical and non-clinical settings

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

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The eMotion ECG Mobile has been fully verified and validated following written test protocols to demonstrate that the design meets the requirements and performs as intended. The test results including pass/fail determination are documented in the corresponding test reports.
The device was also tested against the recognized consensus standard EN 60601-2-25:1999 Basic Safety and Essential Performance of Electrocardiographs.
The proper functioning of the applicable plug in devices was also verified.
The device and the applicable plug-in's passed all tests successfully.
All the specified performance tests have been passed successfully.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

  • System A/D Conversion: 14 bit (Passed)
  • Sampling rate: 1000 Hz (Passed)
  • IP Class: IP20 (Passed)
  • Signal frequency band (ECG): 1 Hz ... 30 Hz (Passed)
  • System sensitivity: 1µV / bit (peak to peak) or 0.2µV / bit (peak to peak) switchable ; ECG: 1.33 µV / bit (peak to peak) (Passed)
  • System noise: 1 µV RMS (Passed)
  • CMRR: 90 dB minimum ; 104 dB typical (type tested) (Passed)
  • Signal range: 14 bit: +/- 8192µV (peak to peak) (Passed)
  • Accelerometer: 10-bit +/- 8g mode, typical sensitivity 64 bits/g ; Output data rate: 250 Hz ; Accuracy: +/- 5% at 1g (Passed)
  • ECG Waveform shape: ECG Complex - Recognizable ; Ventricular Fibrillation - Recognizable ; 30, 60, 120, 180 and 240 BPM +/- 2 % ; Sine wave 10Hz and 40 Hz +/- 2 %, shape a clear sine wave (Passed)
  • Sensor power: Re-chargeable Li-Po or Li-ion 140mAh, 3.7V (Passed)
  • Battery life: 300 full re-charge cycles (80%) (Passed)
  • Operating time: Online with Bluetooth: ca. 4h (Passed)
  • Commercial OTS plug-ins: UA-767PBT Digital Blood Pressure Monitor (K043217), HEM-780N3 Automatic Blood Pressure Monitor (K061822), 3150 WristOX2 (K102350), UC-321 PBT C40 Weight Scale, HBF-206IT Weight Scale. All passed.

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K083535, K050940

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 870.2920 Telephone electrocardiograph transmitter and receiver.

(a)
Identification. A telephone electrocardiograph transmitter and receiver is a device used to condition an electrocardiograph signal so that it can be transmitted via a telephone line to another location. This device also includes a receiver that reconditions the received signal into its original format so that it can be displayed. The device includes devices used to transmit and receive pacemaker signals.(b)
Classification. Class II (performance standards).

0

EMERGO 9 GROUP

K131699 b 1/6

Section 5 - 510(k) Summary

1. Submission Sponsor

Mega Electronics Ltd Pioneerinkatu 6 KUOPIO FI-70800 Finland Phone: +358 17 581 7700 Fax: +358 17 580 0978 Contact: Aki Tiihonen, Operations Director Email: aki.tiihonen@megaemg.com

2. Submission Correspondent

Emergo Group 816 Congress Avenue, Suite 1400 Austin, TX 78701 Office Phone: (512) 327.9997 Fax: (512) 327.9998 Contact: André Kindsvater, Senior Consultant, QA/RA Email: project.management@emergogroup.com

3. Date Prepared

May 20th, 2013

4. Device Identification

Trade/Proprietary Name:eMotion ECG Mobile
Common/Usual Name:Digital Ambulatory Monitor
Classification Name:Transmitters And Receivers, Electrocardiograph, Telephone
Classification Regulation:21 CFR 870.2920
Product Code:DXH
Device Class:Class II
Classification Panel:Cardiovascular

5. Predicate Devices

Heartrak Smart ECAT, 510(k) Number: K083535 Card Guard PMP4 Medical Web Center, 510(k) Number: K050940

1

EMERGO GROUP

KI31699 P 2/6

Device Description 6.

The eMotion ECG Mobile is a mobile device, PC and Internet based telemetry solution for the ambulant monitoring of the plug-in device data of chronic patients via a mobile network. Plug-in devices can be ECG devices, blood pressure monitors, weighing scales, etc. The device reads data from the plug-in device via a Bluetooth connection. The application in the mobile device sends the data to a server (Health Gateway) over mobile networks using the secured connection.

Data can be viewed from the Health Gateway server using the Web Monitor. Monitoring is performed using PC application that reads data from the server over the internet using the secured connection.

Figure 5-1. eMotion ECG Mobile concept

7. Intended Use

The eMotion ECG sensor is a wearable, portable, externally applied, electrocardiograph recorder and transmitter for the purpose of health monitoring, biofeedback and scientific research.

The eMotion ECG Mobile is intended for use in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug-in devices such as ECG sensors, Weight Scales, Blood Pressure Meters and Pulse Oximeters.

2

·

EMERGO GEROUP

KI31699 b 3/6

The eMotion ECG Mobile does not provide any automatic analysis or diagnosis.

8. Comparison of Technological Characteristics

The following table compares the eMotion ECG Mobile to the predicate devices with respect to intended use, technological characteristics and principles of operation, providing more detailed information regarding the basis for the determination of substantial equivalence.

| Manufacturer | Mega Electronics Ltd | Universal Medical Inc. | CARD GUARD SCIENTIFIC
SURVIVAL, LTD |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | eMotion ECG | Heartrak Smart ECAT | Card Guard PMP4
Medical Web Center |
| 510(k) Number | TBD | K083535 | K050940 |
| Product Code | DXH | DXH | DXH |
| Regulation
Number | 21 CFR 870.2920 | 21 CFR 870.2920 | 21 CFR 870.2920 |
| Regulation
Name | Transmitters And
Receivers,
Electrocardiograph,
Telephone | Transmitters And
Receivers,
Electrocardiograph,
Telephone | Transmitters And
Receivers,
Electrocardiograph,
Telephone |
| Indications for
Use | The eMotion ECG sensor is
a wearable, portable,
externally applied,
electrocardiograph
recorder and transmitter
for the purpose of health
monitoring, biofeedback
and scientific research.
The eMotion ECG Mobile is
intended for use in clinical
and non-clinical settings to
collect and transmit health
parameters to healthcare
professionals for
monitoring and evaluation.
Health parameters are
collected from a variety of
commercially available,
external plug-in devices
such as ECG sensors,
Weight Scales, Blood | Heartrak Smart ECAT is a
wireless ambulatory,
multi-channel, continuous
ECG event recorder with
embedded arrhythmia
detection algorithms.
Heartrak Smart ECAT
registers symptomatic and
asymptomatic cardiac
event triggered by a
patient manually or auto-
triggered by embedded
arrhythmia detection
algorithms. Using wireless
technology, Heartrak
Smart ECAT, when placed
with range of a compatible
RF receiver, uploads
recorded ECG parameter
data to receiver. When
data upload is complete | The PMP4 Medical Web
Center is a Software
application intended for
supporting remote
monitoring of
Electrocardiographic
(ECG), Spirometric,
Fetal/Maternal, Blood
Pressure, Heart Rate,
Blood Glucose, Blood
Oxygen Saturation, Body
Weight and optionally
other patients' vital signs
and parameters.
The data is received from
transducers/monitors,
which are external to the
system. |

Table SA - Comparison of Characteristics

3

Mega Electronics LTD Traditional 510(k) Premarket Submission eMotion ECG Mobile

EMERGO GROUP

| Manufacturer | Mega Electronics Ltd | Universal Medical Inc. | CARD GUARD SCIENTIFIC
SURVIVAL, LTD |
|-----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------|----------------------------------------|
| Trade Name | eMotion ECG
Pressure Meters and Pulse
Oximeters.
The eMotion ECG Mobile
does not provide any
automatic analysis or
diagnosis. | Heartrak Smart ECAT
data can be reviewed and
analyzed at a physician's
office, clinic or monitoring
center. | Card Guard PMP4
Medical Web Center |
| Overall Design | PEMS and Software | PEMS | Software |
| Sterile | non-sterile | non-sterile | N/A |
| Single-Use | no | no | No |
| Battery
Operated | Re-chargeable 3.7 V Li-ion
battery | Internal Li-Ion
rechargeable battery 3.6V | N/A |
| Data
Transmission | Bluetooth & Mobile Net | Bluetooth & Mobile Net | N/A |
| Sampling rate | Selectable 100, 125, 250,
500 or 1000 Hz | 205 Hz | N/A |
| AC Powered | no | no | N/A |
| Patient Cable | 3-lead | 3-lead | N/A |
| Latex Free | yes | yes | N/A |
| Data
transmission | via mobile device | RF within 10 m | via PDA, Cellular Phone,
iTV, PC |
| Web-based
Medical Center
Platform | Yes | N/A | Yes |
| Complies with
ISO 10993-1 | Yes | Yes | N/A |
| Electrical Safety
Testing Passed | Yes | Yes | N/A |

9. Non-Clinical Performance Data

The eMotion ECG Mobile has been fully verified and validated following written test protocols to demonstrate that the design meets the requirements and performs as intended. The test results including pass/fail determination are documented in the corresponding test reports.

The device was also tested against the recognized consensus standard EN 60601-2-25:1999 Basic Safety and Essential Performance of Electrocardiographs.

The proper functioning of the applicable plug in devices was also verified.

The device and the applicable plug-in's passed all tests successfully.

4

EMERGO 9 GROUP

K131699 b 5/6

All required software testing was completed as part of the software verification and validation. Please refer to Section 016 Software.

Summary of Performance Testing Result

All the specified performance tests have been passed successfully.

TestPass / fail criteriaResults
1System A/D
Conversion14 bitPassed
2Sampling rate1000 HzPassed
3IP ClassIP20Passed
4Signal frequency
bandECG: 1 Hz ... 30 HzPassed
5System sensitivity1µV / bit (peak to peak) or 0.2µV / bit
(peak to peak) switchable
ECG: 1.33 µV / bit (peak to peak)Passed
6System noise1 µV RMSPassed
7CMRR90 dB minimum
104 dB typical (type tested)Passed
8Signal range14 bit: +/- 8192µV (peak to peak)Passed
9Accelerometer10-bit +/- 8g mode, typical sensitivity 64 bits/g
Output data rate: 250 Hz
Accuracy: +/- 5% at 1gPassed
10ECG Waveform
shapeECG Complex - Recognizable
Ventricular Fibrillation - Recognizable
30, 60, 120, 180 and 240 BPM +/- 2 %
Sine wave 10Hz and 40 Hz +/- 2 %, shape a
clear sine wavePassed
11Sensor powerRe-chargeable Li-Po or Li-ion 140mAh, 3.7VPassed
12Battery life300 full re-charge cycles (80%)Passed
13Operating timeOnline with Bluetooth: ca. 4hPassed

Table 5B – Performance Testing Summary - ECG Sensor

The performance of the commercial OTS plug-ins has been tested and all tests passed successfully.

5

Mega Electronics LTD Traditional 510(k) Premarket Submission eMotion ECG Mobile

EMERGO GROUP

K131699 P 6/6

K-NumberDeviceResults
K043217UA-767PBT Digital Blood Pressure MonitorPassed
K061822HEM-780N3 Automatic Blood Pressure MonitorPassed
K1023503150 WristOX2Passed
noneUC-321 PBT C40 Weight ScalePassed
noneHBF-206IT Weight ScalePassed

Table 5C - Performance Testing - OTS Plug-ins

The eMotion ECG Mobile meets all the requirements for overall design, biocompatibility, and electrical safety confirms that the output meets the design inputs and specifications. The eMotion ECG Mobile passed all testing and supports the claims of substantial equivalence and safe operation.

The eMotion ECG Mobile complicable voluntary standards for biocompatibility. The device passed all the testing in accordance with national and international standards.

10. Clinical Testing

There was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. These types of devices, including the predicate devices, have been on the market for many years with a proven safety and efficacy for the use of the device. The non-clinical testing detailed in this submission supports the substantial equivalence of the device.

11. Statement of Substantial Equivalence

By definition, a device is substantially equivalent to a predicate device when the device has the same intended use and the same technological characteristics as the previously cleared predicate device. Or the device has the same intended use and different technological characteristics that can be demonstrated that the device is substantially equivalent to the predicate device, and that the new device does not raise different questions regarding its safety and effectiveness as compared to the predicate device.

It has been shown in this 510(k) submission that the difference between the eMotion ECG Mobile and the predicate devices do not raise any questions regarding its safety and effectiveness. Performance testing and compliance with voluntary standards, demonstrate that the eMotion ECG Mobile is substantially equivalent to the relevant aspects of the predicate devices in terms of design, components, materials, principals of operation, sterilization, biocompatibility, performance characteristics, and intended use.

The eMotion ECG Mobile, as designed and manufactured, is determined to be substantially equivalent to the referenced predicate devices.

6

Image /page/6/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. In the center of the seal is a stylized representation of an eagle with its wings spread. The eagle is facing to the right and has three wavy lines emanating from its body.

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002

November 26, 2013

Mega Electronics Ltd. c/o Mr. Andre Kindsvater Senior Consultant QA/RA Prinsessegracht 20 2514 AP, The Hague Netherlands

Re: K 13 l 699

Trade/Device Name: Emotion ECG Mobile Regulation Number: 21 CFR 870.2920 Regulation Name: Telephone Electrocardiograph Transmitter & Receiver Regulatory Class: II (two) Product Code: DXH Dated: October 22, 2013 Received: October 24, 2013

Dear Mr. Andre Kindsvater:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

7

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complics 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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.goy/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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/MedicalDevices/Safety/ReportaProblem/default.htm_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 (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

OwenP.Faris -S

for

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

Enclosure

8

K131699

Indications for Use Statement

510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________

Device Name: eMotion ECG Mobile •

Indications for Use:

The eMotion ECG sensor is a wearable, portable, externally applied, electrocardiograph recorder and transmitter for the purpose of health monitoring, biofeedback and scientific research.

The eMotion ECG Mobile is intended for use in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug-in devices such as ECG sensors, Weight Scales, Blood Pressure Meters and Pulse Oximeters.

The eMotion ECG Mobile does not provide any automatic analysis or diagnosis.

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)

Digitally signed by
Owen P. Faris -S
Date: 2013.11.26
13:18:19-05'00'