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IM007

Implicity, Inc. • Cardiovascular • 11/03/2021

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The IM007 system is a software medical device utilizing a proprietary machine learning algorithm to analyze ECG data from Insertable Cardiac Monitors for the detection and classification of various cardiac arrhythmias. It functions as an API-driven, server-side service that integrates with remote monitoring platforms to provide healthcare professionals with adjunctive diagnostic information.

Summary

IM007 is a software medical device designed for qualified healthcare professionals to aid in the assessment of arrhythmias by analyzing electrocardiogram (ECG) data obtained from Insertable Cardiac Monitors (ICMs). The system, developed by Implicity Inc., initially supports ECG data from Medtronic ICMs and is intended to be electronically interfaced with other computer systems, specifically remote monitoring platforms. These platforms supply the ECG data to IM007 and receive its analysis for viewing by healthcare professionals. IM007 itself does not include a user interface for viewing ECG data or a database to store results, as these functionalities are expected to be part of the interfacing 'client' application. The core of IM007 is a proprietary machine learning algorithm that processes ECG signals to detect and classify various cardiac events, including asystole, bradycardia, atrial tachycardia or atrial fibrillation, ventricular tachycardia, normal rhythm, and artifact. The system operates as a server-side service with an Application Programming Interface (API) consisting of input and output messaging queues. It receives ECG files and device parameters from the remote monitoring platform, the algorithm analyzes the data, and the output (formatted as a sequence of waveform labels with start and end times) is sent back. The interpretation results from IM007 are intended for advisory use only, to be considered by physicians in conjunction with their clinical knowledge and other diagnostic information, and it is not for use in life-supporting or sustaining systems. Non-clinical performance testing using ANSI/AAMI EC57:2012 standard databases and proprietary databases confirmed its ability to perform as intended.

AI Regulatory Concerns

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Keywords

IM007ECG AnalysisInsertable Cardiac Monitor (ICM)Arrhythmia DetectionMachine Learning AlgorithmRemote Monitoring PlatformAsystoleAtrial FibrillationVentricular TachycardiaSoftware Medical Device

Device Metadata

Submission Number
K210543
Company
Implicity, Inc.
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
detection/diagnosis

Relevant Clinical Questions

  • Q1. What are the specific performance metrics (sensitivity, specificity, positive predictive value, negative predictive value) of the IM007 algorithm for each type of arrhythmia it detects (asystole, bradycardia, AT/AF, VT) when benchmarked against standardized annotated ECG databases from ICMs?; How does the IM007 algorithm differentiate between true cardiac events and artifacts, particularly those specific to subcutaneous ECG signals from ICMs, and what is its false positive rate for critical arrhythmias like VT or asystole?; What are the technical requirements and data exchange protocols for integrating the IM007 API with various remote monitoring platforms beyond the initially supported Medtronic ICMs?; Could you elaborate on the types of ECG patterns or signal characteristics that would lead to an 'Unspecified abnormality' classification, and what is the recommended clinical workflow when such a classification is provided?; Given that IM007 relies on a 'client' application for ECG data viewing, what are the minimum data visualization and annotation capabilities recommended or required for the interfacing remote monitoring platform to ensure effective clinical use of IM007's analysis results?

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 Score25/100
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, algorithm, annotation)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(server, remote, platform)
✓ Detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not 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 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, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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IM007 - Implicity, Inc. | ESL FDA AI Device Intelligence