K122289 · Tomtec Imaging Systems GmbH · LLZ · Oct 24, 2012 · Radiology
Device Facts
Record ID
K122289
Device Name
IMAGE-COM 5.0
Applicant
Tomtec Imaging Systems GmbH
Product Code
LLZ · Radiology
Decision Date
Oct 24, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.2050
Device Class
Class 2
Attributes
Software as a Medical Device, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K122289 · Oct 24, 2012
IMAGE-COM 5.0
Tomtec Imaging Systems GmbH
Published clinical literature
A clinical evaluation based on a literature review was performed to assess the benefits and risks of the device, demonstrating that the device is as safe and effective as the predicate devices.
Literature review; Clinical evaluation; Risk-benefit assessment
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Clinical evaluation following the literature route; Literature review
Patients relevant to the intended use of the device
Not applicable for this study
Safety and performance of the device under normal conditions of use
Indications for Use
Image-Com software is intended for reviewing and measuring of digital medical data of different modalities. It can be driven by Image-Arena or other third party platforms and is intended to launch other commercially available analysis and quantification tools.
Device Story
Image-Com 5.0 is a clinical application software package for reviewing and measuring digital medical data. It functions as an integrated component of the Image-Arena platform or as a standalone integration within third-party PACS or CVIS environments. The device enables users to perform 2D, 3D, and 4D image analysis by combining functionalities previously separated in predicate software (2D analysis from Image-Com 4.5 and 3D/4D analysis from Cardio-View 2.x). Clinicians use the software to launch various analysis and quantification tools, facilitating more accurate assessments and reducing analysis time. The device is intended for professional clinical use to support diagnostic decision-making by providing quantitative measurements from medical images.
Clinical Evidence
No prospective clinical trials were conducted. Evidence consists of a clinical evaluation based on a literature review assessing the benefits of the device's measurement and analysis capabilities. The evaluation concluded that published data are relevant to the device's characteristics and intended medical procedures. Risk-benefit assessment indicates that benefits (improved accuracy and reduced analysis time) outweigh the low risks. Bench testing included software validation, functional testing, measurement verification, and multi-language testing, all of which passed without deviations.
Technological Characteristics
Clinical application software for 2D, 3D, and 4D medical image analysis. Operates as an integrated module within Image-Arena or third-party PACS/CVIS platforms. Software-based measurement and review tools. No specific hardware materials or energy sources; device is purely software-based.
Indications for Use
Indicated for the review and measurement of digital medical data across various modalities. No specific patient population, age, or gender restrictions are defined.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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K122289
Image /page/0/Picture/1 description: The image shows the logo for Tomtec Imaging Systems. The logo is in black and white, with the word "Tomtec" in large, bold letters. Below the word "Tomtec" is the phrase "Imaging Systems" in smaller letters. The logo is simple and modern, and it is likely used to represent the company's brand.
# Traditional 510(k) Summary
OCT 24 2012
Image-Com 5.0 .
# Owner's Name and Address
TomTec Imaging Systems GmbH Edisonstrasse 6 D-85716 Unterschleissheim
## Contact Person
B. Mumm COO Phone +49-89-32175-605 Fax +49-89-32175-750
#### Common, Classification & Proprietary Names
| Common Name: | Various Image Analysis System<br>Software | | |
|----------------------|---------------------------------------------|--|--|
| Classification Name: | Picture archiving and communications system | | |
Proprietary Name(s):
#### lmage-Com 5.0
## Predicate Devices
| Predicate Device 1 | K110667 | Image-Arena Platform 4.5, Echo-Com 4.5,<br>Image-Com 4.5 |
|--------------------|---------|--------------------------------------------------------------------------------|
| Predicate Device 2 | K071232 | Image-Arena Applications; Research-<br>Arena Applications : 4D Cardio-View 2.x |
Image /page/0/Picture/15 description: The image shows a series of black, angled lines arranged in a curved pattern. The lines are short and thick, and they are oriented at approximately 90-degree angles to each other. The overall arrangement of the lines creates a sense of movement or flow, as if they are following a curved path. The lines are closely spaced together, creating a dense and visually interesting pattern.
summary
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Image /page/1/Picture/0 description: The image shows the logo for TOMTEC Imaging Systems. The word "TOMTEC" is written in large, bold, black letters. Below the word "TOMTEC" is the phrase "IMAGING SYSTEMS" written in smaller, black letters.
# Device Description
Image-Com is a clinical application package software for reviewing and measuring of digital medical data. Image-Com is either embedded in Image-Arena™ platform or can be integrated into Third Party platforms, such as PACS or CVIS.
#### Indications for use and Intended use
Image-Com software is intended for reviewing and measuring of digital medical data of different modalities. It can be driven by Image-Arena or other third party platforms and is intended to launch other commercially available analysis and quantification tools.
#### Technological Characteristics Comparison
The Subject Device "Image-Com 5.0" is a CAP for analysis of medical studies containing 2D, 3D or 4D images.
The actual submission combines the advantages of the FDA cleared software products:
| Predicate Device 1 | K110667 | Image-Arena Platform 4.5, Echo-Com 4.5, Image-Com 4.5 |
|--------------------|---------|-------------------------------------------------------------------------------|
| Predicate Device 2 | K071232 | Image-Arena Applications; Research-<br>Arena Applications: 4D Cardio-View 2.x |
The Subject Device includes the main functionalities as provided from Predicate Device 1 (Image-Com 4.6, TomTec Imaging Systems GmbH). The underlying technology of the Subject Device is identical to the predicate devices. It is a combined version of the Predicate Device 1 (Image-Com 4.5, TomTec Imaging Systems GmbH, for 2D analysis) and Predicate Device 2 (Cardio-View 2.x, TomTec Imaging Systems GmbH, for 3D/4D analysis) allowing the users to perform 2D, 3D and 4D image analysis within one software package.
#### Discussion according non-clinical performance data testing
Testing was performed according to internal company procedures. Software testing and validation were done at the module and system level according to written test protocols established before testing was conducted.
The test procedure was performed according to the Project Quality Plan. Test results were reviewed by designated technical professionals before software proceeded to release.
All requirements have been verified by tests or other appropriate methods.
summary
page 2 of 4
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Image /page/2/Picture/0 description: The image shows the logo for Tomtec Imaging Systems. The logo is in black and white, with the word "Tomtec" in large, bold letters. Below the word "Tomtec" is the phrase "Imaging Systems" in smaller letters. The logo is simple and modern, and it is likely used to represent the company's brand.
The incorporated OTS Software is considered validated either by particular tests or implied by the absence of OTS SW related abnormalities during all other V&V activities.
The summary conclusions state that:
- all automated tests were reviewed and passed
- feature complete test completed without deviations
- functional tests are completed -
- . measurement verification is completed without deviations
- multilanquage tests are completed without deviations -
- all non-verified bugs have been evaluated and are rated as minor deviations. They are deferred to the next release
#### Discussion according clinical performance data testing
The overall product concept was clinically accepted and the clinical test results support the conclusion that the device is as safe as effective, and performs as well as or better than the predicate devices.
A clinical evaluation following the literature route based on the assessment of benefits, associated with the use of the device, was performed. The clinical evaluation shows that the published data are relevant and applicable to the relevant characteristics of the device under assessment and the medical procedure for which the device is intended.
Risk analysis aspects were treated in the risk management report. Based on this document the existing applied methods in the literature and the newly described techniques of the product (which are considered in the risk analysis) were evaluated.
No further risks were identified.
#### Conclusion from the analysis of the literature review
- The Risk-Benefit Assessment that the Benefit is superior to the Risk. . Whereas the Risk is low. The benefit of the product is improving the accuracy of assessment and analyze-time. The product Image-Com is therefore harmless for patient and user and the advantages overbalance the probable risks of injury or illness for the patient.
- The data are sufficient to demonstrate compliance with the essential . requirements covering safety and performance of the device in question under normal conditions of use.
- . The claims made in the device labeling are substantiated by the clinical data.
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Image /page/3/Picture/0 description: The image shows the logo for TOMTEC IMAGING SYSTEMS. The word "TOMTEC" is in large, bold, black letters. Below the word "TOMTEC" is the phrase "IMAGING SYSTEMS" in smaller, black letters. The logo is simple and professional.
# Test Conclusions of non-clinical and clinical performance data
Test results support the conclusion, that the device is as safe as effective, and performs as well as or better than the predicate devices.
No reportable events or problems for the predicate devices exist. The overall product concept was clinically accepted and the test results support the conclusion that the subject device is as safe as effective and performs as well as the predicate devices.
July 23, 2012
L. Ulli-
B. Mumm COO
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Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or a stylized human figure with outstretched arms.
#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room - WO66-G609 Silver Spring, MD 20993-0002
OCT
24
2012
Mr. Bernhard MUMM COO TomTech Imaging Systems GmbH Edisonstrasse 6 Unterschleissheim, Bavaria D-85716 GERMANY
Re: K122289
Trade/Device Name: Image-Com 5.0 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ Dated: July 23, 2012 Received: July 30, 2012
#### Dear Mr. MUMM:
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.
If your device is classified (see above) into class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies 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 Parts 801 and 809); medical device reporting (reporting of
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medical device-related adverse events) (21 CFR 803); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Parts 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. 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/cdrh/industry/support/index.html.
Sincerely Yours,
Janine M. Morris
Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known): K122289
Device Name: Image-Com 5.0
Indications For Use:
Image-Com software is intended for reviewing and measuring of digital medical data of different modalities. It can be driven by Image-Arena or other third party platforms and is intended to launch other commercially available analysis and quantification tools.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of In Vitro Diagnostics and Radiological Health (OIR)
Michael D O'Hara
Page 1 of ____________________________________________________________________________________________________________________________________________________________________
(Division Sign Off) Division of Radiological Hea
Office of in Vitro Diagnostics and Ri
510/k
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.