Clinical Trials AI
U

Unlearn.AI

San Francisco company whose Digital Twin Generators are generative models trained on historical control and observational data to forecast how an individual trial participant would progress under control or standard of care. That forecast becomes a prognostic score used as a covariate in the trial analysis, a method the company calls PROCOVA, which reduces variance and can lower required sample size without introducing the confounding bias that external control arms carry. Occupies a regulatory position no other vendor in this index holds: PROCOVA received a positive qualification opinion from the European Medicines Agency in September 2022 as an acceptable statistical approach for primary analysis in Phase 2 and 3 trials with continuous endpoints, and FDA CDER subsequently commented that it concurs and that the method does not deviate from current guidance.

Last VerifiedJuly 21, 2026
Compare Unlearn.AI with other vendors
Founded
2017
Headquarters
San Francisco, California, United States
Website
www.unlearn.ai
Categories
clinical-trials-ai, diagnostics-and-genomics
Indexed Products
Digital Twin Generators, PROCOVA, PROCOVA-MMRM
Assessment

Capability Axes

AI Capability
AI Centrality
A
Peer-reviewed publication

The generative model is the product and also the intellectual property. Digital Twin Generators are trained on historical control and observational data to forecast individual disease progression, and the entire commercial offering is that forecast plus the statistical methodology for using it. Published work names the model class directly, including a conditional restricted Boltzmann machine trained on harmonized data from 6,736 subjects for the Alzheimer's generator. There is no services or platform layer to fall back on.

Autonomy and Oversight Model
A
Peer-reviewed publication

The most rigorous answer to the autonomy question in this index, because the company solved it by design rather than by policy. The team explicitly rejected the obvious application, using digital twins as external control arms in single arm trials, on the grounds that all non randomized designs with external controls are prone to bias from unknown confounders. Instead the twin only supplies a prognostic score adjusted for within a randomized controlled trial, which preserves randomization and bounds bias even when the model omits relevant variables. The AI never replaces a control patient or a human judgment; it improves the precision of an analysis that remains randomized. Constraining your own method to preserve statistical validity is a stronger safety posture than any oversight disclosure.

Model and Technology Transparency
A
Peer-reviewed publication

Method transparency here approaches the academic standard. The three step procedure is published and patented, the mathematical argument is public including a proof that adjusting for a prognostic score from a model trained to predict control outcomes yields the most efficient trial at a desired power, and extensions such as Bayesian PROCOVA are on arXiv with named authors. Model classes and training cohort sizes are disclosed in peer reviewed applications. A buyer or a regulator can audit the methodology from primary sources rather than a datasheet, which is why a regulator was able to qualify it.

Clinical and Operational Evidence
B
Peer-reviewed publication

Substantial published evidence, though it measures statistical efficiency rather than patient outcomes, which is the correct endpoint for this product. Applications include an Alzheimer's study using the AWARE trial of 453 subjects reporting positive partial correlations between twins and cognitive change scores of 0.30 to 0.39 at Week 96, consistent with validation across three independent trials at 0.30 to 0.46, and total residual variance reduced by roughly 9 to 15 percent. A separate simulation of the TRAILBLAZER-ALZ 2 donanemab trial quantified potential sample size reduction. Partnerships in ALS are underway. Note that several key demonstrations are simulations or retrospective applications rather than prospective use as the primary analysis of a completed registrational trial.

AI Safety and PHI Stewardship
Not rated

No specific PHI handling framework was located. The company works with harmonized historical trial and observational datasets rather than live patient care data, a different risk profile from clinical vendors, but data governance terms for sponsor datasets are not published.

Regulatory and Compliance
HIPAA and BAA Posture
Not rated

No HIPAA or BAA commitment was located. The customer is a trial sponsor rather than a provider organization, so contracting typically runs through sponsor data agreements, but the posture is not published.

Security Certifications and Trust Center
Not rated

No SOC 2, ISO 27001, or equivalent attestation and no trust center were located in the materials reviewed.

FDA and Regulatory Status
A
Regulatory Filing

A distinct and arguably harder regulatory achievement than a device clearance, and unique in this index. In September 2022 the EMA issued a positive qualification opinion through its novel methodologies programme, qualifying PROCOVA as an acceptable statistical approach for the primary analysis of Phase 2 and 3 trials with continuous outcomes. Unlike a 510(k), which establishes substantial equivalence to a predicate, a qualification opinion is a regulator endorsing a novel method as fit for evidence generation. FDA CDER subsequently stated it concurs with EMA and that PROCOVA does not deviate from current guidance. Two important limits a buyer should hold: the qualification is narrow, covering continuous endpoints under specific assumptions, and FDA has issued no parallel qualification opinion, with applicability to oncology endpoints and long term survival outcomes unsettled.

AI Governance and Bias Disclosure
B
Peer-reviewed publication

Stronger than most, expressed as statistical rigor rather than a governance programme. The method is specifically constructed so that bias is controlled even in the presence of unknown confounders, and the company engaged FDA through a Critical Path Innovation Meeting to confirm that controlling bias and type I error was the operative concern for pivotal trials. Validation reports correlation consistency across independent trials, which tests generalization. What is absent is subgroup or demographic performance analysis of the twin generators, which matters because a prognostic model trained on historical trial populations inherits the well documented underrepresentation of those populations. Independent commentary notes the validation question for digital twins is itself unsettled science.

Integration and Deployment
EHR and Interoperability Depth
Not rated

Not applicable in the usual sense and not claimed. The product operates on trial datasets within sponsor statistical workflows rather than integrating with provider systems, so EHR connectivity is outside its scope. No integration detail with clinical data capture or statistical computing environments was located.

Deployment Model and Data Residency
Not rated

No hosting, tenancy, or data residency terms were located. Engagements appear to run as sponsor collaborations on trial data rather than as deployed software, but the terms are not published.

Commercial
Commercial Transparency
C
Vendor Published

No pricing is published. The value case is nonetheless quantifiable from published evidence in a way most vendors cannot match, since reduced sample size and shortened enrollment translate directly into trial cost, and the studies report variance reduction figures a sponsor can model against their own trial economics. Named partnerships indicate a sponsor collaboration model rather than a licensed product, and terms are not disclosed.

Setting and Specialty Coverage
C
Peer-reviewed publication

Coverage is bounded by which Digital Twin Generators exist, and generators are disease specific, trained on historical data for a given condition. Published work centers on neurodegenerative disease, with Alzheimer's most developed and ALS partnerships underway. The EMA qualification is further limited to continuous endpoints, which excludes the binary and time to event endpoints common in oncology and cardiovascular trials. Deep where a generator exists, unavailable where one does not.

Commercial

Pricing

Vendor-published figures are labeled as such. Figures labeled “Estimated” are derived from third-party sources and have not been confirmed by the vendor.

Entry Price Pricing Basis BAA Tier Implementation Source
Sponsor engagement; terms not published
Undisclosed. Sponsor partnership model rather than licensed product; named partnerships exist but terms are not published. Not disclosed. The customer is a trial sponsor rather than a provider organization, so terms typically run through sponsor data agreements. Not applicable in the software sense. Engagements run as sponsor collaborations applying the methodology to trial design and analysis rather than as deployed software. Vendor Published

No pricing is published, but the value case is more quantifiable from public evidence than almost any vendor in this index, because the published studies report the mechanism of return directly. Reported variance reduction of roughly 9 to 15 percent and demonstrated sample size reduction translate into fewer enrolled participants and shorter enrollment, which a sponsor can price against their own per patient trial costs. Two limits shape whether that return is available: the EMA qualification covers continuous endpoints only, and a Digital Twin Generator must exist for the disease in question.

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Index Status
Last index update
July 21, 2026
The AI Health Index is an editorial reference, not a regulatory body. Vendor data is verified against published sources and public regulatory filings. Figures labeled “Estimated” have not been confirmed by the vendor. See the Methodology page for evaluation standards and limitations.
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