SONON Ultrasound Imaging System (Model: SONON 300C)
Applicant
Healcerion Co., Ltd.
Product Code
IYO · Radiology
Decision Date
Sep 10, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.1560
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The SONON Ultrasound Imaging System (Model: SONON 300C) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including obstetrics (OB), gynecology (GY) and general (abdominal) imaging.
Device Story
SONON 300C is a wireless, hand-held, battery-operated diagnostic ultrasound system. It uses a 3.5 MHz convex transducer to emit ultrasound pulses into the body; reflected echoes are converted into electrical signals by piezoelectric crystals. These signals are processed and transmitted wirelessly to a commercial off-the-shelf iOS or Android mobile device running the SONON app. The app provides a touch-based interface for real-time B-mode 2D imaging, cine/freeze-frame review, and measurements (linear/elliptical). Used by healthcare professionals in hospitals, clinics, and medical offices. Output allows clinicians to visualize and measure anatomical structures, aiding in diagnosis. Benefits include portability and wireless integration with mobile platforms for point-of-care imaging.
Clinical Evidence
No clinical or animal testing was conducted. Substantial equivalence is supported by bench testing, including acoustic output measurements (NEMA UD2-2004), phantom-based measurement accuracy testing, display performance verification, usability engineering, and software validation (IEC 62304).
Technological Characteristics
Wireless hand-held convex transducer (3.5 MHz). Piezoelectric sensing. Battery-powered. Connectivity via wireless to iOS/Android mobile devices. Biocompatible patient-contacting materials (ISO 10993-1). Standards: IEC 60601-1 (safety), IEC 60601-1-2 (EMC), IEC 60601-2-37 (ultrasound safety), IEC 62359 (thermal/mechanical indices).
Indications for Use
Indicated for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including obstetrics, gynecology, and abdominal imaging in all patients.
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.
Penrith Elettra Diagnostic Ultrasound System (K100598)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 10, 2015
Healcerion Co., Ltd. % Ms. Carmelina G. Allis The Allis Law Firm, PLLC 2437 Bav Area Blvd.. #30 HOUSTON TX 77058
Re: K151339
Trade/Device Name: SONON Ultrasound Imaging System (Model: SONON 300C) Regulation Number: 21 CFR 892.1560 Regulation Name: Ultrasonic pulsed echo imaging system Regulatory Class: II Product Code: IYO, ITX Dated: August 10, 2015 Received: August 14, 2015
Dear Ms. Allis:
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,
Robert Ocks
Robert Ochs. Ph.D. 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) K151339
#### Device Name
SONON Ultrasound Imaging System (Model: SONON 300C)
Indications for Use (Describe)
The SONON Ultrasound Imaging System (Model: SONON 300C) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including obstetrics (OB), gynecology (GY) and general (abdominal) imaging.
Type of Use (Select one or both, as applicable)
∑ Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
#### PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON A SEPARATE PAGE IF NEEDED.
#### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
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#### Diagnostic Ultrasound Indications for Use Form
510(k) Number: K151339 Device Name: SONON Ultrasound Imaging System (Model: SONON 300C) Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
| 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) |
| Fetal Imaging<br>& Other | Ophthalmic | | | | | | | |
| | Fetal | N | | | | | | |
| | Abdominal | N | | | | | | |
| | Intra-operative (Specify) | | | | | | | |
| | Intra-operative (Neuro) | | | | | | | |
| | Laparoscopic | | | | | | | |
| | Pediatric | | | | | | | |
| | Small Organ (Specify) | | | | | | | |
| | Neonatal Cephalic | | | | | | | |
| | Adult Cephalic | | | | | | | |
| | Trans-rectal | | | | | | | |
| | Trans-vaginal | | | | | | | |
| | Trans-urethral | | | | | | | |
| | Trans-esoph. (non-Card.) | | | | | | | |
| | Musculo-skeletal<br>(Conventional) | | | | | | | |
| | Musculo-skeletal (Superficial) | | | | | | | |
| | Intravascular | | | | | | | |
| | Other (Gynecology) | N | | | | | | |
| | | | | | | | | |
| Cardiac | Cardiac Adult | | | | | | | |
| | Cardiac Pediatric | | | | | | | |
| | Intravascular (Cardiac) | | | | | | | |
| | Trans-esoph. (Cardiac) | | | | | | | |
| | Intra-cardiac | | | | | | | |
| | Other (Specify) | | | | | | | |
| Peripheral<br>Vessel | Peripheral vessel | | | | | | | |
| | Other (Specify) | | | | | | | |
N = new indication; P = previously cleared by FDA; E = added under this appendix
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of Center for Devices and Radiological Health, Office of In Vitro Diagnostics and Radiological Health
XX Prescription Use -- Yes (Part 21 CFR 801 Subpart D)
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#### 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
#### 1) Submitter's name, address, telephone number; Contact person
| Submitter: | Jaeyeob Jung<br>RA Manager<br>HEALCERION Co., Ltd.<br>(Guro-dong, Changup Jiwon<br>Center)<br>72, Digital-ro 26-gil, Guro-gu<br>Seoul, South Korea<br>Ph: +82 70-7569-6326<br>Email: onair0816@healcerion.com | Contact Person: | Carmelina G. Allis<br>The Allis Law Firm, PLLC<br>2437 Bay Area Blvd., #30<br>Houston, TX 77058<br>Ph: 281-819-0216<br>Email: CAllis@TheAllisLawFirm.com |
|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|
|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|
August 10, 2015 Date prepared:
#### 2) Name of the device, including the trade or proprietary name, if applicable, the common or usual name, and the classification name, if known
| Device Common/Usual Name: | Diagnostic Ultrasound System and Transducer |
|---------------------------|----------------------------------------------------|
| Device Proprietary Name: | SONON Ultrasound Imaging System, Model: SONON 300C |
| Device Classification: | Class II |
| 21 C.F.R. Section | Classification Name | Product Code |
|-------------------|------------------------------------------|--------------|
| 892.1560 | System, Imaging, Pulsed Echo, Ultrasonic | 90-IYO |
| 892.1570 | Transducer, Ultrasonic, Diagnostic | 90-ITX |
#### 3) Substantially Equivalent Devices
| Device Name | 510(k) Number |
|--------------------------------------------------------------|---------------|
| MobiUS Ultrasound Imaging System (Mobisante, Inc.) | K102153 |
| Penrith Elettra Diagnostic Ultrasound System (Penrith Corp.) | K100598 |
Healcerion is not aware of any design-related recalls regarding the predicate devices. No reference devices were used in this submission.
# 4) Device Description
The SONON Ultrasound Imaging System, Model: SONON 300C, is a wireless ultrasound system that uses pulsed-echo technology (frequency: 3.5 MHz; module: convex) to transmit ultrasound images via wireless communication to a mobile device that utilizes the iOS or Android operating system.
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# 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
The minimum requirements for the mobile devices that utilize the iOS or Android operating system for use with the SONON Ultrasound Imaging System. Model: SONON 300C are as follows:
| Item | Minimum requirements |
|-------------------|-------------------------------------------------|
| | iPhone 5 / 5S / 6 / 6 plus |
| | iPad 3rd / 4th Generation / Air / Mini or later |
| Target Device | Galaxy S3 / S4 / S5 / Note 3, Note 4 |
| | Galaxy Note Tablet 10.1 2013 version or later |
| | Galaxy Tab Pro 8.4 2014 version or later |
| Mobile OS Version | iOS 7.0 or later |
| | Android 4.3 or later |
The SONON Ultrasound Imaging System is a portable, general-purpose, software-controlled, hand-held diagnostic ultrasound system that consists of (i) a commercial off-the-shelf iOS or Android mobile device. (ii) the SONON Ultrasound Imaging System software that runs as an app on the mobile device, (iii) the battery-operated, hand-held SONON Ultrasound Imaging System transducer that communicates wirelessly with iOS or Android mobile devices, and (iv) the instructions for use manual, battery, charger, and power cords.
The SONON software can be downloaded to an iOS or Android mobile device and utilizes an icon touch-based user interface. The software enables ultrasound image capture and review. controls for time gain, dynamic range, display of mirror image, focal length, brightness, contrast, linear/elliptical measurement, and image annotation, as well as storage and email transmission of images and videos. The SONON Ultrasound Imaging System allows the user to image in real time and review cine or freeze-frame images on the screen in a B-Mode. 2dimensional scan format. All images and data collected are stored in the mobile app. If the app is removed and reinstalled, all stored information is lost and cannot be recovered.
The SONON Ultrasound Imaging System utilizes pulsed-echo technology to determine the depth and location of tissue interfaces, and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. Ultrasound waves are emitted from the transducer, propagate through tissues, and return to the transducer as reflected echoes. The returned echoes are then converted into electrical impulses by transducer crystals and further processed in order to form the ultrasound image presented on the screen.
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# 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
The device components are not supplied sterile and do not require sterilization prior to use.
# 5) Indications for Use
The SONON Ultrasound Imaging System (Model: SONON 300C) is intended for diagnostic ultrasound echo imaging, measurement, and analysis of the human body for general clinical applications including obstetrics (OB), gynecology (GY) and general (abdominal) imaging.
# 6) Technological Comparison to Predicate Devices
The SONON Ultrasound Imaging System and its predicate devices, the MobiUS and Penrith Elettra, are Track 3 systems that employ the same basic scientific technology for the acquisition and display of ultrasound images. They all operate in the same manner in that piezoelectric material in the transducer is used as a source to transmit sound waves into the body. Sound waves are reflected back to the transducer and converted to electrical signals that are processed and displayed as 2-dimensional images. The SONON Ultrasound Imaging System and the predicate devices allow for the visualization and measurement of body structures. All devices are intended to be used in clinical environments, including hospitals, clinics, and medical office settings, for the diagnosis of patients.
All devices are compact, portable, general-purpose, software-controlled diagnostic ultrasound imaging systems with hand-held probes. Both the SONON Ultrasound Imaging System and the Penrith Elettra devices utilize wireless network connectivity to run software and display images. Both the MobiUS and the SONON Ultrasound Imaging System are available in a 3.5 MHz ultrasound probe.
The patient-contacting surfaces of the subject and predicate devices have been found to be biocompatible for their intended application. The SONON Ultrasound Imaging System is manufactured and designed to the same electrical and safety standards as the predicate devices.
The SONON Ultrasound Imaging System display ranges from 4 to 10 inches depending on whether a mobile phone or tablet is used. This is similar to the range of display options available for the MobiUS and Penrith Elettra predicate devices.
| Characteristic | Healcerion Co., Ltd.<br>SONON Ultrasound Imaging<br>System | Predicate Device<br>Mobisante, Inc.<br>MobiUS Ultrasound Imaging System<br>K102153 | Predicate Device<br>Penrith Corporation<br>Penrith Elettra Diagnostic<br>Ultrasound System<br>K100598 |
|-------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended<br>Use/Indications for<br>Use | The SONON Ultrasound Imaging<br>System (Model: SONON 300C) is<br>intended for diagnostic ultrasound<br>echo imaging, measurement, and<br>analysis of the human body for<br>general clinical applications | Indicated for ultrasound imaging,<br>measurement, and analysis of the human<br>body for the following clinical<br>applications: fetal/OB, abdominal,<br>cardiac, pelvic, pediatric,<br>musculoskeletal, and peripheral vessel | Intended for diagnostic imaging<br>or fluid flow analysis of the<br>human body including: fetal,<br>abdominal, intraoperative,<br>intraoperative neurological,<br>pediatric, small organ, neonatal |
| | Healcerion Co., Ltd. | Predicate Device | Predicate Device |
| Characteristic | SONON Ultrasound Imaging<br>System | Mobisante, Inc.<br>MobiUS Ultrasound Imaging System<br>K102153 | Penrith Corporation<br>Penrith Elettra Diagnostic<br>Ultrasound System<br>K100598 |
| | including obstetrics (OB),<br>gynecology (GY) and general<br>(abdominal) imaging. | imaging. Its compact size, portability,<br>and user interface enable it for use in<br>primary care and special care areas. | cephalic, cardiac, peripheral<br>vessel, musculoskeletal<br>(conventional), musculoskeletal<br>(superficial). |
| Environment of Use | Hospital, clinic, and medical office<br>settings | Hospital, clinic, and medical office<br>settings | Hospital, clinic, and medical<br>office settings |
| Acoustic Output<br>Levels | Below Track 3 FDA limits in<br>accordance with Sept. 2008<br>ultrasound systems guidance<br>document | Below Track 3 FDA limits in<br>accordance with Sept. 2008 ultrasound<br>systems guidance document | Below Track 3 FDA limits in<br>accordance with Sept. 2008<br>ultrasound systems guidance<br>document |
| Imaging Capabilities | pulsed-echo ultrasound<br>•<br>Mode B (2D) scan | pulsed-echo ultrasound<br>•<br>Mode B (2D) scan | pulsed-echo and Doppler<br>•<br>ultrasound<br>Mode B (2D), Color,<br>•<br>Amplitude Doppler |
| Patient Population | For use in all patients | For use in all patients | For use in all patients |
| Anatomic<br>Structures/Clinical<br>applications | General clinical applications,<br>including fetal/obstetrics,<br>gynecology, abdominal | General clinical applications, including,<br>but not limited to fetal/obstetrics,<br>gynecology, abdominal, cardiac, pelvic,<br>pediatric, musculoskeletal, and<br>peripheral vessel imaging | General clinical applications,<br>including fetal, abdominal,<br>intraoperative, pediatric, small<br>organ, cephalic, cardiac,<br>peripheral vessel, and<br>musculoskeletal |
| Users | Healthcare professionals | Healthcare professionals | Healthcare professionals |
| Principle/Method of<br>Operation | Piezoelectric material in the<br>transducer is used as an ultrasound<br>source to transmit sound waves<br>into the body. Sound waves are<br>reflected back to the transducer and<br>converted to electrical signals that<br>are processed and displayed as<br>images of anatomic structures. | Piezoelectric material in the transducer<br>is used as an ultrasound source to<br>transmit sound waves into the body.<br>Sound waves are reflected back to the<br>transducer and converted to electrical<br>signals that are processed and displayed<br>as images of anatomic structures. | Piezoelectric material in the<br>transducer is used as an<br>ultrasound source to transmit<br>sound waves into the body. Sound<br>waves are reflected back to the<br>transducer and converted to<br>electrical signals that are<br>processed and displayed as<br>images of anatomic structures. |
| Image Display Unit | Mobile device (4 to 10 inches<br>approximately) | PC/Host computer (4.1 inches<br>approximately) | Video display (unknown size) |
| Probe Characteristics | Convex, 3.5 MHz frequency | Mechanic, 3.5 MHz to 12 MHz<br>frequency | L8-3 linear, L12-5 linear, and C5-<br>2 curvilinear |
| Probe Connection to<br>Display | Wireless | Wired (USB) | Wireless or wired |
| Off-the-shelf operating<br>system | iOS / Android | Win CE | Unknown |
| Software | Runs as an app on off-the-shelf<br>mobile device | Runs in host computer | Unknown |
| System Components | • Commercial off-the-shelf iOS<br>or Android mobile device,<br>• SONON Ultrasound Imaging<br>System software that runs as<br>an app on the mobile device,<br>• SONON Ultrasound Imaging<br>System battery-operated,<br>hand-held ultrasound<br>diagnostic transducer that<br>communicates wirelessly with | • Host computer,<br>• USB 2.0 interface, and<br>• Portable, handheld, compact<br>ultrasound probe | • System console housing<br>electronic circuitry<br>• Video display<br>• Power supply<br>• User controls<br>• Transducers (L8-3 linear,<br>L12-5 linear, C5-2<br>curvilinear) that<br>communicate wirelessly or<br>via wire with system console |
| Characteristic | Healcerion Co., Ltd.<br>SONON Ultrasound Imaging<br>System | Predicate Device<br>Mobisante, Inc.<br>MobiUS Ultrasound Imaging System<br>K102153 | Predicate Device<br>Penrith Corporation<br>Penrith Elettra Diagnostic<br>Ultrasound System<br>K100598 |
| | iOS or Android mobile<br>devices | | |
| Patient-Contacting<br>Materials | All materials with patient contact<br>are biocompatible and can be<br>disinfected | All materials with patient contact are<br>biocompatible and can be disinfected | All materials with patient contact<br>are biocompatible |
# Comparison of Technological Characteristics with Predicate Devices
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# 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
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#### 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
# 7) Determination of Substantial Equivalence
The SONON Ultrasound Imaging System is substantially equivalent to the predicate devices identified above with respect to intended use, principles of operation, and technological characteristics. As described below, the system has been evaluated for acoustic output. biocompatibility, cleaning and disinfection effectiveness, and thermal, electrical, and mechanical safety, and has been found to conform to applicable standards and product specifications that demonstrate that the SONON Ultrasound Imaging System is substantially equivalent to the predicate devices.
#### Non-clinical performance data
Non-clinical tests relied on this premarket notification submission for a determination of substantial equivalence include testing showing compliance with the following standards.
#### Electrical safety, EMC, and RF Wireless Capabilities
Electrical safety, electromagnetic compatibility, and RF wireless capabilities were evaluated per international standards and the device complies with the following standards:
- . IEC 60601-1: Medical Electrical Equipment - General Requirements for Basic Safety and Essential Performance
- . IEC 60601-1-2: Medical Electrical Equipment - Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Compatibility -Requirements and Tests
- IEC 60601-2-37: Medical electrical equipment Part 2-37: Particular requirements for . the basic safety and essential performance of ultrasonic medical diagnostic and monitoring equipment
- IEC 62359: Ultrasonics – Field Characterization – Test Methods for the Determination of Thermal and Mechanical Indices Related to Medical Diagnostic Ultrasonic Fields
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# 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
#### Acoustic Output Levels
The acoustic output exposure levels were measured and calculated following the NEMA UD2-2004 (R2009), Acoustic Output Measurement Standard for Diagnostic Ultrasound Equipment Revision 3. Acoustic Output Level Test Results are as follows:
| Transducer | Ispta.3 | TIS | MI | Ipa.3@MImax |
|-------------|---------------|--------|--------|----------------|
| Convex only | 0.0627[W/cm2] | 0.2535 | 0.7861 | 11.6369[W/cm2] |
# Clinical Measurement Range and Accuracies
Clinical Measurement Range and Accuracies were tested using a phantom with vertical, dead zone, horizontal and linear groups. The length and the vertical and horizontal resolutions were evaluated and results met performance criteria.
# Display Performance Testing
The SONON Ultrasound Imaging System (Model: SONON 300C) displays ranges from 4 to 10 inches depending on whether a mobile phone or tablet is used. This is similar to the range of display options available for the predicate devices. The display performance of the device was assessed using various mobile devices, and the test results demonstrate that the device meets performance specifications.
# Usability Report
The usability engineering process was conducted by Healcerion to assess and mitigate risks caused by usability problems associated with the correct use of the device as well as user errors. The test results demonstrate that the product has been found to be reasonably safe and effective for the intended users, intended uses, and intended use environments through usability engineering process.
# Failure Mode and Risk Analyses
Healcerion conducted a Failure Mode and Effects Analysis and a risk analysis in accordance with ISO 14971. The risk analysis of SONON 300C was performed by taking into account the risks of the device, such as design, production, storage, related international standards, state of art of risk management, and the foreseeable risks related to the intended use of the device. The hazards were identified, the risks were estimated, and procedures were implemented to control them. All identified hazards were reduced to acceptable levels.
# Biocompatibility
Biocompatibility testing was conducted in accordance with the international standard below. The patient-contacting surfaces of the device (probe nosepiece and lens) were evaluated for cytotoxicity, skin irritation and skin sensitization. Test results demonstrate that the patientcontacting surfaces of the probe are biocompatible in accordance with the following standard:
- . ISO 10993-1: Biological Evaluation of Medical Devices
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# 510(k) Summary of Safety and Effectiveness
# Healcerion Co., Ltd. SONON Ultrasound Imaging System, Model: SONON 300C
#### Software Evaluation and Cybersecurity Management
Furthermore, Healcerion conducted validation and verification activities on the SONON Ultrasound Imaging System software. Cybersecurity evaluation was also conducted. The software passed its performance requirements and met specifications per the following standard:
- IEC 62304: Medical Device Software - Software Life-Cycle Processes
# Additional Standards
Healcerion also relied on the following standards to ensure the substantial equivalence of the SONON Ultrasound Imaging System to predicate devices:
- ISO 14971: Application of Risk Management to Medical Devices
- ISO 15223-1: Symbols to be used with Medical Device Labels I
Healcerion applied quality assurance measures to the system design and development, including, but not limited to:
- Risk Analysis
- 트 Product Specifications
- 트 Design Reviews
- 트 Verification and Validation Activities
# Clinical tests and animal studies - not conducted
The Healcerion SONON Ultrasound Imaging System ultrasound system does not introduce new indications for use, modes, features, or technologies relative to the predicate devices that would require evaluation through clinical or animal testing. The clinical safety and effectiveness of ultrasound systems with characteristics similar to those of the SONON 300C are well accepted for the predicate and subject devices.
# 8) Conclusion
In conclusion, the tests conducted, as well as all verification and validation activities, demonstrate that the design specifications and technological characteristics of the SONON Ultrasound Imaging System (Model: SONON 300C) meet applicable requirements and standards for the safety and effectiveness of the device for its intended use. There are some differences in technological characteristics between the predicate and proposed devices, but those differences only indicate that the predicate devices may have secondary or added functionalities as compared to the SONON Ultrasound Imaging System, such as additional probe models or imaging capabilities as in the case of Doppler ultrasound. The testing and validation activities conducted demonstrate that any differences between the devices do not raise new or different questions of safety or effectiveness as compared to the predicate devices. Therefore, the SONON Ultrasound Imaging System (Model: SONON 300C) is substantially equivalent to the predicate devices.
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.