K142517 · Delphinus Medical Technologies, Inc. · IYO · Oct 31, 2014 · Radiology
Device Facts
Record ID
K142517
Device Name
SoftVue
Applicant
Delphinus Medical Technologies, Inc.
Product Code
IYO · Radiology
Decision Date
Oct 31, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1560
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K142517 · Oct 31, 2014
SoftVue
Delphinus Medical Technologies, Inc.
Clinical study patient data (pre-IDE #I120143); Medical records/biopsy reports for lesion identification
Retrospective review of clinical images from 10 patients (13 masses) to qualitatively characterize tissue stiffness (stiff vs. soft) using the modified SoftVue system compared to known pathology.
Retrospective clinical data; Image characterization; Breast imaging; Clinical study cohort
Patients with suspicion or biopsy-proven breast lesions; Sample Size: 10 patients (13 imaged masses); Number of Sites: 1 (Karmanos Cancer Institute)
Not applicable for this study
Qualitative assessment of tissue stiffness (color relative stiffness images) compared to known pathology
Indications for Use
SoftVue™ is indicated for use as a B-mode ultrasonic imaging system for imaging of a patient's breast when used with an automatic scanning curvilinear array transducer. The device is not intended to be used as a replacement for screening mammography.
Device Story
SoftVue is an automated, table-top B-mode ultrasonic imaging system for breast examinations; patient lies prone with breast submerged in a warm water imaging chamber. System utilizes a curvilinear array transducer to acquire ultrasound data; reconstruction engine processes data into B-mode image slices and volumetric stacks. Modification adds colorized and grayscale relative stiffness imaging to help radiologists differentiate tissue stiffness (harder vs. softer) relative to surrounding tissue. Operator uses touchscreen or barcode reader to enter patient data; system integrates with DICOM modality worklists and PACS servers. Radiologists review output on workstations to aid clinical assessment of breast lesions. Benefits include non-compressive imaging and additional qualitative stiffness reference information.
Clinical Evidence
No clinical diagnostic claims made. Evidence includes phantom analysis and a small-scale clinical characterization study (10 patients, 13 masses: 4 cancers, 4 fibroadenomas, 5 cysts). Phantom testing confirmed color-coded stiffness correlation with known inclusions. Clinical study demonstrated qualitative ability to display relative stiffness (stiff vs. soft) in various breast densities and sizes; all 4 cancers were characterized as 'stiff'.
Indicated for B-mode ultrasonic imaging of the breast in patients. Not for use as a replacement for screening mammography.
Regulatory Classification
Identification
An ultrasonic pulsed echo imaging system is a device intended to project a pulsed sound beam into body tissue to determine the depth or location of the tissue interfaces and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A biopsy needle guide kit intended for use with an ultrasonic pulsed echo imaging system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 31, 2014
Delphinus Medical Technologies, Inc. % Ms. Andrea Wallen-Gerding Director of Quality & Regulatory Affairs 46701 Commerce Center Drive PLYMOUTH MI 48170
Re: K142517
Trade/Device Name: SoftVue Regulation Number: 21 CFR 892.1560 Regulation Name: Ultrasonic pulsed echo imaging system Regulatory Class: II Product Code: IYO, ITX Dated: September 10, 2014 Received: September 11, 2014
Dear Ms. Wallen-Gerding:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21. Parts 800 to 898. 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 Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Smh.7)
for
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)
K142517
Device Name SoftVue
Indications for Use (Describe)
SoftVue™ is indicated for use as a B-mode ultrasonic imaging of a patient's breast when used with an automatic scanning curvilinear array transducer. The device is not intended to be used as a replacement for screening mammography.
Type of Use (Select one or both, as applicable)
2 Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# Diagnostic Ultrasound Indications for Use
# System: SoftVue
| Clinical Application | | Mode of Operation | | | | | | |
|---------------------------|---------------------------------|-------------------|---|-----|-----|------------------|-----------------------|---------------------|
| General<br>(Track 1 Only) | Specific<br>(Tracks 1 & 3) | B | M | PWD | CWD | Color<br>Doppler | Combined<br>(Specify) | Other*<br>(Specify) |
| Ophthalmic | Ophthalmic | | | | | | | |
| Fetal Imaging &<br>Other | Fetal | | | | | | | |
| | Abdominal | | | | | | | |
| | Intra-operative (Specify) | | | | | | | |
| | Intra-operative (Neuro) | | | | | | | |
| | Laparoscopic | | | | | | | |
| | Pediatric | | | | | | | |
| | Small Organ (Breast) | | P | | | | | |
| | Neonatal Cephalic | | | | | | | |
| | Adult Cephalic | | | | | | | |
| | Trans-rectal | | | | | | | |
| | Trans-vaginal | | | | | | | |
| | Trans-urethral | | | | | | | |
| | Trans-esoph. (non-Card.) | | | | | | | |
| | Musculo-skeletal (Conventional) | | | | | | | |
| | Musculo-skeletal (Superficial) | | | | | | | |
| | Intravascular | | | | | | | |
| | Other (Specify) | | | | | | | |
| Cardiac | Cardiac Adult | | | | | | | |
| | Cardiac Pediatric | | | | | | | |
| | Intravascular (Cardiac) | | | | | | | |
| | Trans-esoph. (Cardiac) | | | | | | | |
| | Intra-cardiac | | | | | | | |
| | Other (Specify) | | | | | | | |
| Peripheral<br>Vessel | Peripheral vessel | | | | | | | |
| | Other (Specify) | | | | | | | |
Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
N = new indication; P = previously cleared by FDA; E = added under this appendix
Additional Comments: SoftVue is intended for ultrasonic breast examinations
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#### 1.0 Submitter Information
- 1.1 This Premarket Notification is submitted by:
Delphinus Medical Technologies, Inc. 46701 commerce Center Drive Plymouth, Michigan 48170
- 1.2 Contact Information:
Contact Name: Andrea N. Wallen-Gerding 734-233-3984 Office Telephone: Fax: 734-207-3165 E-mail: awallen@delphinusmt.com
- 1.3 Date: September 5, 2014
#### 2.0 Device Name
- Trade/ Proprietary Name: SoftVue 2.1
- 2.2 Common Name:
- System, Imaging, Pulsed Echo Ultrasonic A
- A Transducer, Ultrasonic, Diagnostic
- Classification Name: 2.3
- 21 CFR § 892.1560: Ultrasonic pulsed echo imaging system A
- 21 CFR § 892-1570: Diagnostic ultrasonic transducer A
#### 3.0 Predicate Device
The predicate device is identified as SoftVue™ manufactured by Delphinus Medical Technologies. SoftVue™ received market clearance under 510(k) number K123209.
The Toshiba Aplio 500 (K133761) was used as a secondary predicate device for elastography image comparison.
#### 4.0 Device Description
SoftVue™ is indicated for use as a B-mode ultrasonic imaging system for imaging of a patient's breast using a curvilinear array transducer that completely surrounds the breast. The modification of SoftVue™ will allow the system to generate colorized and grayscale relative stiffness ultrasound images in addition to the grayscale B-mode images generated by the unmodified SoftVue™ system. This new feature will allow the user to be able to determine
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whether a region of interest is harder or softer than the surrounding tissue. No clinical diagnostic claims are being made.
SoftVue™ is comprised of the following subsystems: the Transducer, Table/Housing Assembly, Water Conditioning System, Computer Control System, Image Reconstruction System, Power System, and the Data Acquisition System.
Soft Vue™ has a built-in curvilinear transducer that is used to acquire ultrasound data. Data are acquired from a patient lying prone on the table with their breast submerged in an imaging chamber filled with warm (body temperature) water. The breast is positioned in the center of the transducer. A camera, located at the bottom of the imaging chamber provides a live video feed to the system operator to aid in positioning the patient's breast. Once the scan is initiated, the transducer collects data that are processed to produce a series of B-mode ultrasound image slices that can be stacked to yield a volumetric ultrasound image of the breast. Soft Vue™ also outputs colorized and grayscale relative stiffness image stacks that provide the radiologist with additional reference information.
The Water Control System is used to de-gas and warm the water that is used as the image acquisition medium. The Computer Control System controls all of the functionality of the other subsystems. The reconstruction engine processes the image data acquired by the transducer ring into B-mode ultrasound images.
The system includes a barcode reader and a touchscreen display (user interface). The touchscreen display allows the user to perform an imaging procedure. Patient information is entered into the system using either the QWERTY keyboard on the touchscreen display, using the barcode reader, or the user can import the patient information from a DICOM modality worklist on an externally networked RIS server. Device errors and warnings are displayed on the touchscreen display.
SoftVue™ outputs the images to an externally networked PACS server which allows the images to be stored until they are reviewed on a workstation.
#### Intended Use 5.0
SoftVue™ is indicated for use as a B-mode ultrasonic imaging system for imaging of a patient's breast when used with an automatic scanning curvilinear array transducer. The device is not intended to be used as a replacement for screening mammography.
#### Predicate Device Comparison 6.0
Delphinus Medical Technologies claims that the SoftVue device is substantially equivalent to the SoftVue system cleared by the FDA in K123209. Delphinus Medical Technologies claims substantial equivalence because the proposed device has an equivalent intended use, manufacturing materials, operating principles, physical and operational specifications as compared to the predicate device.
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The SoftVue device and the predicate device utilize B-mode grayscale ultrasound images to achieve their intended use. Both the modified SoftVue device and the unmodified predicate SoftVue device are table-top systems that have automatic scanning transducers to image breast tissue.
The specific details regarding similarities and differences between the modified SoftVue device and the unmodified SoftVue device have been identified and explained in the Comparison Table section provided in Section 10 of this submission. A brief summary of the similarities and differences between the modified SoftVue device and the unmodified SoftVue device is included below. The differences noted between the modified SoftVue device and the unmodified SoftVue device do not present any new issues related to safety and effectiveness.
# Similarities:
- The modified and unmodified SoftVue devices use an automated transducer to acquire A 2D images of a patient's breast.
- A The modified and unmodified SoftVue devices use broadband transducers.
- A The modified and unmodified SoftVue devices have a single operating frequency of 3 MHz.
- A Both systems acquire and process B-mode grayscale images of a patient's breast.
- Both systems position the patient in a prone position lying on their examination table A with the patient's in a pendulous position within an imaging chamber.
- A Both systems position the patient's breast in a fluid environment to eliminate the need for breast compression and facilitate the transmission of ultrasound waves.
# Differences:
- A The differences between the modified and unmodified Soft Vue systems are listed in Table 1 below.
| Item # | Modification | Reason for Change |
|--------|---------------------------------------------------------------------------|---------------------------------------------------------------------------|
| 1 | Added mesh to the spillage chamber. | Prevent debris from entering/ getting trapped and<br>degrading valves. |
| 2 | Added a second membrane module<br>to degasser | Improve degassing efficiency and maintain the<br>same flow rate of water. |
| 3 | Replaced transmit power supplies<br>with medical grade power supplies | Conform to 60601-1:2005 |
| 4 | Replaced in-line filter with medical<br>grade version | Conform to 60601-1:2005 |
| 5 | Added Ethernet opto-isolator | Conform to 60601-1:2005 |
| 6 | Replaced vacuum pump circuit<br>breaker with lower amp circuit<br>breaker | Conform to 60601-1:2005 |
| 7 | Added thermistor interface board | Better match reservoir and imaging chamber |
## Table 1: Changes made to Modified SoftVue System
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| Item # | Modification | Reason for Change |
|--------|-----------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 8 | Added cleaning tools | temperature sensors to more practical values |
| 9 | Parallelized user login and system initialization | Allows the user to view the status of the initialization process. |
| 10 | Added ability to query external RIS server | Allows user to upload patient information for an exam. |
| 11 | Updated GUI | Updated to accommodate other changes made such as allowing research users to select between running a research or clinical exam, RIS query, and initialization status. |
| 12 | Added acquisition PCBA temperature monitoring | Safety feature |
| 13 | Transferred full control of motors to control computer | Streamline system operation |
| 14 | Added ability to generate and output color and grayscale relative stiffness images | Additional reference information for radiologists |
| 15 | Improved image quality by updating pre-processing of attenuation image (not displayed) and updating sound speed image parameters. | Improve image quality.<br>• Updates to the pre-processing of the attenuation image result in better gain correction and equivalent contrast for the B-mode image.<br>• Updates to the sound speed image parameters results in better delay correction and equivalent contrast for the B-mode image. |
| 16 | Fixed a bug in firmware on the digital image processing board | Improve acquisition reliability |
| 17 | Updated the Master Clock and PCIe Interface (MCP) Board to make clock signals more reliable | Improve initialization reliability |
#### 7.0 Summary of Non-Clinical Testing
- 7.1 The function and performance of the modified SoftVue device has been evaluated through non-clinical design verification and validation testing. Testing includes system performance and simulated use tests. The results of the evaluation tests demonstrate that the modified SoftVue device successfully meets the requirements of its intended use.
- 7.2 Delphinus Medical Technologies conducted performance evaluations to verify that SoftVue's subsystems successfully meet predetermined specifications and product performance requirements. Results of the testing performed demonstrate that SoftVue's subsystems meet the system and performance requirements necessary for its intended use. A brief list of some of the testing performed is included below.
- 7.2.1 Software Unit and System Verification and Validation Testing - Software was tested at the unit and system level to ensure that it met the software's design and
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intended use requirements. All requirements were met and no new issues of safety or effectiveness were raised.
- 7.2.2 Sub-system Verification Testing - SoftVue subsystems that were modified from the original SoftVue system that received clearance to market underwent subsystem verification to ensure that they met their respective design requirements. All requirements were met and no new issues of safety or effectiveness were raised.
- 7.2.3 System Verification Testing - Since there were modifications made to the SoftVue system as a whole, system verification testing was conducted to ensure that the modified SoftVue system met the design requirements. All requirements were met and no new issues of safety or effectiveness were raised.
- 7.2.4 Human Factors/Usability Testing: Usability testing was conducted per the FDA Guidelines and ANSI/AAMI HE75:2009. All requirements were met and no new issues of safety or effectiveness were raised.
- 7.2.5 Design Validation Testing - Testing was conducted to ensure that the modified SoftVue device met the user needs and intended use requirements. All requirements were met and no new issues of safety or effectiveness were raised.
- 7.3 Soft Vue has undergone acoustic output testing per IEC 60601-2-37:2007. Testing was conducted by Acertara Acoustic Laboratories, an independent testing laboratory, located in Longmont, Colorado. SoftVue meets all Track 1 acoustic output requirements. The results of acoustic output testing are listed in Table 2 below. A copy of the test report can be found in Appendix 09-E of Section 9 (Declaration of Conformity) of this submission.
| Feature | Track 1 Exposure Level | SoftVue Level | Pass/Fail |
|-----------------------------------------|------------------------|---------------|-----------|
| Max. Mechanical Index<br>(MI) | 1.9 | 0.431 | Pass |
| Max. ISPTA.3 | 94 mW/cm2 | 15.1 mW/cm2 | Pass |
| Max. Soft Tissue Thermal<br>Index (TIS) | | 0.0006 | |
## Table 2: Global Maximum Acoustic Output Values
- 7.4 In addition to the tests listed above, the modified SoftVue device has also undergone testing to the safety standards listed in Table 3 below.
| Table 3: Safety Testing Performed on SoftVue | | | | | | |
|----------------------------------------------|--|--|--|--|--|--|
|----------------------------------------------|--|--|--|--|--|--|
| Standard # and Date | Standard Title |
|--------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-1:2005; Corr.<br>1:2006; Corr. 2:2007 | Medical Electrical Equipment - Part 1: General Requirements for Safety, 1988;<br>Amendment 1, 1991-11, Amendment 2, 1995 |
| IEC 60601-1-2:2007 | Medical Electrical Equipment - Part 1-2: General Requirements for Safety -<br>Collateral standard: Electromagnetic Compatibility - Requirements and Tests<br>(Edition 2:2001 with Amendment 1:2004) |
| IEC 62304:2006 | Medical device software - Software life cycle processes |
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| Standard # and Date | Standard Title |
|---------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-2-37:2007 | Medical electrical equipment - Part 2-37: Particular requirements for the basic<br>safety and essential performance of ultrasonic medical diagnostic and<br>monitoring equipment. |
#### Summary of Clinical Testing 8.0
- 8.1 No clinical testing is required to be performed using SoftVue; however, image characterization testing using clinical data has been completed per study parameters suggested by the FDA during the Submission Issue Q-Sub Meeting (Q130909) held on August 23, 2013. The parameters are listed below.
- > 10 - 20 patients
- A Range of breast densities from Fatty to Dense Breasts
- Small to Large Breasts A
- Lesion sizes 5 mm to 15 mm or 20 mm A
- 8.2 The study was conducted in order to demonstrate SoftVue's ability to provide qualitative tissue stiffness information with the color relative stiffness images. The invivo comparisons are not meant to guide a statistical study, but are solely intended to provide an illustrative example of in-vivo stiffness imaging using the modified SoftVue System.
- 8.3 As part of the evaluation, a phantom analysis was also included in the test protocol to establish a baseline for the clinical image evaluations. An anthropomorphic breast phantom was chosen for this initial analysis because its characteristics are predetermined such that the stiffness properties of the entire phantom and its inclusions are accurately known. The phantom contains stiff and soft inclusions of varying sizes. Each of the masses in the phantom have known stiffness characteristics that have been used to demonstrate that the color of the masses within the color stiffness images output by Soft Vue correlate to the stiffness of the masses within the anthropomorphic breast phantom. The appearance of each mass was used to qualitatively characterize the mass stiffness based on relative color differences.
- 8.3.1 The phantom scan yielded images of 7 inclusions. Among the 7 phantom inclusions, 1 cancer and 3 fibroadenomas were found to be stiff (appearing red) compared to the background material while the 3 cysts were found to be soft (appearing blue) in complete concordance with the known properties of the phantom.
- 8.4 Delphinus Medical Technologies conducted a small scale clinical study to collect clinical images from the modified Soft Vue system. The images collected include Bmode images as well as color and grayscale relative stiffness images. Patient data were collected as part of the clinical study that Delphinus currently has in process under pre-IED # I120143. A modified SoftVue system has been installed at the Alexander J Walt Breast Center at the Karmanos Cancer Institute located in Detroit, Michigan.
- 8.5 The image evaluations were conducted per protocol 100-00745, SoftVue Color Stiffness Image Characterization Protocol (Appendix 20-A).
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- 8.6 The patient data were chosen from the clinical study on the basis of having a suspicion or a biopsy proven lesion such that the lesions in question could be identified by:
- 8.6.1 Appearance (echogenicity)
- 8.6.2 Size (dimensions)
- Location (clock position) 8.6.3
- All patient images from the SoftVue system were reviewed by board certified 8.7 radiologist, Dr. Peter Littrup. Previous biopsies and/or imaging were used to guide the identification of the lesions in the SoftVue images using clock position, appearance, size and location for guidance.
- 8.8 A set of 10 representative in-vivo comparisons of SoftVue's B-mode and color relative stiffness images was carried out to demonstrate SoftVue's ability to qualitatively measure tissue stiffness with clinical data, using the B-mode images for initial mass identification.
- A total of 10 SoftVue patient exams were used in the analysis. Some patients 8.8.1 had multiple lesions so that the final data set consisted of 13 imaged masses consisting of 4 cancers, 4 fibroadenomas, and 5 cysts.
- Breast cup size ranged from B to DDD with densities consisting of 5 scattered, 2 8.8.2 heterogeneous and 3 dense (one of which was extremely dense) indicating that a range of breast size and density was sampled.
- 8.9 All 4 cancers were characterized as "stiff" by SoftVue's color stiffness images. Two fibroadenomas were found to be mixed (range of colors), 1 was stiff (red) and 1 was found to be soft (blue). Of the 5 cysts, 4 were found to be soft, while 1 was found to be mixed. A summary of the results are included in Table 4 below.
| Mass<br># | Case<br># | Study # | Breas<br>t Size | Breast<br>Density | Lesion<br>Pathology | Reported<br>Lesion<br>Position | Average<br>Lesion<br>Size (cm) | Soft Vue<br>Appearance | SoftVue<br>Stiffness<br>Assessment |
|-----------|-----------|-------------|-----------------|--------------------|---------------------|--------------------------------|--------------------------------|---------------------------------------------------------------------------|------------------------------------|
| 1 | 1 | SV021 | C | Dense | Cancer | 8:00 | 2.5 | Hypoechoic<br>Red / green (redder<br>than background on<br>average) | Stiff |
| 2 | 2 | SV022 | DD | Scattered | Fibroadenoma | 1:30 | 3.0 | Hypoechoic<br>Yellow / green<br>(redder than<br>background on<br>average) | Stiff |
| 3 | 3 | SV045 | C | Scattered | Cancer | 10:00 | 1.8 | Hypoechoic<br>Red (redder than<br>background on<br>average) | Stiff |
| 4 | 4 | SV077_<br>1 | B | Extremely<br>Dense | Cyst | 2:00 | 1.4 | Anechoic<br>Blue/green (bluer<br>than background on<br>average) | Soft |
| 5 | 4 | SV077_<br>2 | B | Extremely<br>Dense | Cyst | 12:00 | 1.9 | Anechoic<br>Blue/green (bluer<br>than background on<br>average) | Soft |
Table 4: Clinical Image Analysis Summary
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| Mass<br># | Case<br># | Study # | Breas<br>t Size | Breast<br>Density | Lesion<br>Pathology | Reported<br>Lesion<br>Position | Average<br>Lesion<br>Size (cm) | SoftVue<br>Appearance | SoftVue<br>Stiffness<br>Assessment |
|-----------|-----------|-------------|-----------------|--------------------|---------------------|--------------------------------|--------------------------------|------------------------------------------------------------------------|------------------------------------|
| 6 | 4 | SV077_<br>3 | B | Extremely<br>Dense | Cyst | 12:00 | 2.0 | Anechoic<br>Blue/green (bluer<br>than background on<br>average) | Soft |
| 7 | 5 | SV079 | C | Heterogene<br>ous | Cyst | 9:00 | 1.4 | Anechoic<br>Blue/green<br>(bluer than<br>background on<br>average) | Soft |
| 8 | 6 | SV089 | D | Scattered | Cancer | 9:30 | 1.7 | Hypoechoic<br>Red (redder than<br>background on<br>average) | Stiff |
| 9 | 7 | SV090 | DDD | 26yrs<br>(Hetero)* | Fibroadenoma | 10:00 | 4.3 | Hypoechoic<br>Blue/Green (range<br>of color, no<br>dominant color) | Mixed |
| 10 | 8 | SV113 | DD | Scattered | Cyst | 2:00 | 1.8 | Anechoic<br>Blue/green (range<br>of color, no<br>dominant color) | Mixed |
| 11 | 9 | SV114 | D | Scattered | Cancer | 10:00 RA | 1.2 | Hypoechoic<br>Red/green (redder<br>than background on<br>average) | Stiff |
| 12 | 10 | SV117_<br>1 | D | 21 yrs<br>(Dense)* | Fibroadenoma | 5:00 | 1.9 | Hypoechoic<br>Blue/green/red<br>(range of color, no<br>dominant color) | Mixed |
| 13 | 10 | SV117_<br>2 | D | 21 yrs<br>(Dense)* | Fibroadenoma | 8:00 | 2.6 | Hypoechoic<br>Blue (range of<br>color, no dominant<br>color) | Soft |
#### 9.0 Conclusion
The modified SoftVue device performs as intended and is substantially equivalent to the unmodified SoftVue device with respect to intended use, design, principles of operation, technology, materials, and performance. Any noted differences do not raise any new issues of safety and effectiveness.
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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.