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510(k) Data Aggregation

    K Number
    K163694
    Manufacturer
    Date Cleared
    2017-11-07

    (314 days)

    Product Code
    Regulation Number
    870.2910
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Rooti Rx ECG Event Recorder, Rooti Link APP Software

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    • The intended use of the Rooti Rx System is to allow a patient at home or in the workplace to record single-lead electrocardiography (ECG) data for post-analysis by medical professionals. The Rooti Rx device stores the ECG data, and the recorded data is transmitted to a medical professional's iOS device via Wi-Fi at a later time.
    • The device is not intended to be used on critical care patients. The Rooti Rx System is indicated for use on general care patients and on patients who are 21 years of age or older.
    Device Description

    Rooti Rx System is a wearable single lead ECG recording device, composed by Rooti Rx, patch, charging dock and Rooti Link. When operating Rooti Rx System, medical professionals should use disposable, off the shelf, standard ECG electrodes which are not claimed in the system.

    AI/ML Overview

    The provided text describes the Rooti Rx System, an ECG event recorder, and its comparison to a predicate device (Zephyr Technology, BIOMODULE 3-M1) to demonstrate substantial equivalence for FDA 510(k) clearance. However, the document does not contain specific acceptance criteria, a detailed study proving device performance against those criteria, or information on several of the requested points.

    Here's a breakdown of what can be extracted and what information is missing based on the provided text:

    Missing Information:

    The document primarily focuses on demonstrating substantial equivalence to a predicate device. It does not explicitly state specific acceptance criteria for the Rooti Rx System's performance in terms of diagnostic accuracy or clinical utility. Consequently, it also does not detail a study proving device performance against such criteria.

    Specifically, the following requested information is not available in the provided text:

    • A table of acceptance criteria and the reported device performance.
    • Sample size used for the test set and data provenance.
    • Number of experts used to establish the ground truth for the test set and their qualifications.
    • Adjudication method for the test set.
    • If a multi-reader, multi-case (MRMC) comparative effectiveness study was done, or the effect size of human readers with/without AI assistance.
    • If a standalone (algorithm only) performance study was done.
    • The type of ground truth used (e.g., expert consensus, pathology, outcomes data) for the test set.
    • Sample size for the training set.
    • How the ground truth for the training set was established.

    Information Extracted from the Document:

    Therefore, I can only provide limited details based on the available text:

    1. A table of acceptance criteria and the reported device performance:

      • Acceptance Criteria for Substantial Equivalence: The primary "acceptance criteria" discussed in this document relate to demonstrating substantial equivalence to a predicate device (Zephyr Technology, BIOMODULE 3-M1) based on intended use, indications for use, and technological characteristics. The document implies that the device meets these criteria if the differences are "incidental and not significant which do not raise any new issues of safety or efficacy."
      • Reported Device Performance (Comparative Information): The document provides a comparison table between the Rooti Rx System and the predicate device. This is not "reported device performance" against explicit acceptance criteria in the typical sense of a clinical or performance study outcome, but rather a comparison of specifications.
      FeaturePredicate Device (BIOMODULE 3-M1)Rooti Rx SystemComparison
      Intended UseGeneral Ward Monitoring (detecting, storing, transmitting physiological data)Record single-lead ECG data for post-analysis by medical professionalsSimilar
      Indication For UseMonitoring ambulatory patients in alternate care settings; general patient monitorRecord single-lead ECG data for post-analysis; for general care patients ≥21 years oldSimilar
      Data Storage Capacity140 hrs7 daysRooti Rx System has more capacity
      Method Of ApplicationOff the shelf adhesive electrodeOff the shelf adhesive electrodeSame
      Number of ECG leads11Same
      ECG resolution1224Rooti Rx (implies higher resolution)
      ECG sampling rate (Hz)1000500Both are more than double the highest useful frequency component (40Hz).
      Water resistantYesYesSame
      Data transmissionWirelessWirelessSame
      Power sourceRechargeable batteryRechargeable batterySame
      Weight (g)3314Rooti Rx System is lighter
      Dimensions (mm)88 x 48 x 862 x 22.5 x 8.45Rooti Rx System is smaller
    2. Sample size used for the test set and the data provenance:

      • Not specified. The document does not describe a clinical test set or its sample size or provenance for direct performance evaluation. The "performance testing results" mentioned in the Conclusion likely refer to bench testing or engineering verification against electrical and physical standards, rather than clinical performance for ECG interpretation accuracy.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable / Not specified. No such information is provided as there's no described clinical test with expert-established ground truth.
    4. Adjudication method for the test set:

      • Not applicable / Not specified. No adjudication method is described.
    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:

      • No MRMC study described. The device is an ECG event recorder for post-analysis by medical professionals, implying that the device records the data for human interpretation, rather than providing AI-assisted diagnostic recommendations in a way that would alter human reader performance. The document focuses on the recording and transmission capabilities, not automated ECG interpretation.
    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • No standalone algorithm performance described. The device's function is to record ECG data for post-analysis by medical professionals. It does not claim to perform automated diagnosis or interpretation independently.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • Not applicable / Not specified for a clinical test set. The substantial equivalence argument relies on the device acquiring and transmitting ECG data similarly to a predicate, not on a ground truth for diagnostic accuracy derived from a clinical population.
    8. The sample size for the training set:

      • Not applicable / Not specified. There is no mention of an AI algorithm or a training set for machine learning.
    9. How the ground truth for the training set was established:

      • Not applicable / Not specified. There is no mention of an AI algorithm or a training set for machine learning.

    Summary from the provided text:

    The information primarily indicates that the Rooti Rx System is a single-lead ECG event recorder designed for home or workplace use, allowing patients to record ECG data for later review by medical professionals. The filing aims to demonstrate its substantial equivalence to an existing predicate device (BIOMODULE 3-M1) by comparing its intended use, indications for use, and technological characteristics. The document asserts that any differences are not significant and do not raise new safety or efficacy concerns. It does not provide details on specific performance studies against clinical diagnostic accuracy acceptance criteria, nor does it describe any AI components or their validation.

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