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LINQ II Insertable Cardiac Monitor, Zelda AI ECG Classification System

Medtronic, Inc. • Cardiovascular • 06/11/2021

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The LINQ II Insertable Cardiac Monitor system, now enhanced with the Zelda AI ECG Classification System, aims to provide continuous, long-term subcutaneous ECG monitoring for arrhythmia detection in adult patients. The core innovation lies in the Zelda AI's use of deep-learning neural networks to improve the accuracy of detecting Atrial Fibrillation and Pause episodes by significantly reducing false alerts while maintaining true event capture, with future algorithm updates managed by a structured Predetermined Change Control Plan.

Summary

The LINQ II Insertable Cardiac Monitor (ICM) Model LNQ22 is a programmable, implantable device designed for continuous subcutaneous ECG monitoring in patients at risk of cardiac arrhythmias or experiencing transient symptoms suggestive of such conditions, like dizziness, palpitations, syncope, or chest pain. It automatically records cardiac events and allows patient-initiated recordings via a mobile app or a dedicated patient assistant. The system classifies arrhythmias into categories such as tachyarrhythmia, bradyarrhythmia, pause, atrial tachyarrhythmia, and atrial fibrillation. The core LINQ II ICM hardware, constructed with materials like sapphire and titanium for a hermetic enclosure and reliable sensing, remains technologically unchanged from its predicate device. The key enhancement detailed is the introduction of the Zelda AI ECG Classification System (Models ZA400, ZA410, ZA420), which integrates with the LINQ II ICM. The Zelda AI system employs deep-learning neural architectures, specifically residual convolutional neural networks and ensemble models, to improve the detection of Atrial Fibrillation (AF) and Pause episodes. The primary scientific purpose of the Zelda AI is to significantly reduce false alerts generated by the ICM for these specific arrhythmia events, while ensuring the retention of true alerts. Performance validation testing confirmed its effectiveness in meeting these criteria. Future algorithm improvements for the Zelda AI system are governed by a Predetermined Change Control Plan (PCCP), allowing for modifications such as threshold adjustments and algorithm re-training under strict protocols, with any changes locked before deployment and aimed at achieving superior, validated performance.

AI Regulatory Concerns

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Keywords

Insertable Cardiac Monitor (ICM)ECG MonitoringArrhythmia DetectionAtrial Fibrillation (AF)Pause DetectionArtificial Intelligence (AI)Deep LearningFalse Alert ReductionSubcutaneous ECGPredetermined Change Control Plan (PCCP)

Device Metadata

Submission Number
K210484
Company
Medtronic, Inc.
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
detection

Relevant Clinical Questions

  • Q1. What specific performance metrics (e.g., sensitivity, specificity, positive predictive value) were achieved by the Zelda AI ECG Classification System in reducing false alerts for AF and Pause episodes compared to the predicate LINQ II ICM without Zelda AI?; How does the Zelda AI algorithm differentiate between true cardiac events and noise or artifacts that commonly lead to false alerts in ICMs?; What are the defined thresholds and data characteristics used for re-training and pre-training the Zelda AI algorithm under the Predetermined Change Control Plan, and how is "superior performance" quantified for these updates?; Given the LINQ II ICM is not tested for pediatric use, are there plans to validate the Zelda AI system's performance in pediatric populations or specific subpopulations with unique arrhythmia profiles?; What is the computational overhead of the Zelda AI ECG Classification System, and does its operation impact the battery life or data storage capacity of the LINQ II ICM?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score35/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan✓ Detected in Summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(machine learning, deep learning, neural network, algorithm, model validation)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(network)
✓ Detected
HBOMHardware Bill of Materials(hardware, sensor)
✓ Detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials(deployment)
✓ Detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM, HBOM, OBOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Not detected in AI-generated device summary: SBOM, CBOM, VDR/VEX. These may be present in the full FDA submission.

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LINQ II Insertable Cardiac Monitor, Zelda AI ECG Classification System - Medtronic, Inc. | ESL FDA AI Device Intelligence