EXTRON Series are a mobile fluoroscopic X-ray system with high output capacity, high thermal capacity and high resolution image processing system, which provides X-ray images of the patient's anatomy during surgery or treatment. This device plays an important role in emergency injury treatment, orthopedic surgery, neurosurgery surgery, bone surgery, etc. This device has a function to save important a specific images as records, so you can easily search for the images and transmit it to the PACS system in the hospital to help the medical staff in diagnosis. Examples of a clinical application may include: Neurosurgery, Orthopedics, Anesthesiology, Urology, Gynecology, Internal Medicine (※ This device is not intended for mammography applications.)
Device Story
Mobile fluoroscopic X-ray system; C-arm main body and monitor cart. Inputs: X-ray beams directed at patient anatomy. Principle: X-ray photons converted to light, then to electrical signals via flat panel detector; signals digitized, processed, and displayed. Used in OR/clinical settings by physicians/surgeons/technicians for real-time imaging during surgery/treatment. Output: High-resolution X-ray images displayed on monitor; saved/transmitted to hospital PACS for diagnostic support. Benefits: Real-time visualization for surgical guidance; improved workflow via digital storage/transmission.
Clinical Evidence
No clinical trials; bench testing only. Clinical image quality evaluated by qualified experts comparing subject device images to predicate device images. Results confirmed equivalent image quality for indicated anatomies and populations.
Indicated for patients of all ages (neonates to adults) requiring X-ray radiography or fluoroscopy during surgery or treatment, including emergency injury, orthopedic, neurosurgery, bone surgery, anesthesiology, urology, gynecology, and internal medicine procedures. Not intended for mammography.
Regulatory Classification
Identification
An image-intensified fluoroscopic x-ray system is a device intended to visualize anatomical structures by converting a pattern of x-radiation into a visible image through electronic amplification. 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). An anthrogram tray or radiology dental tray intended for use with an image-intensified fluoroscopic x-ray 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. In addition, when intended as an accessory to the device described in paragraph (a) of this section, the fluoroscopic compression device 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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[LOGO]
FDA
U.S. FOOD & DRUG
ADMINISTRATION
August 19, 2026
Youngeun Lee
% DRTECH Corporation
Assistant Manager
Suite #1, 2 Floor /Suite # 2, 3 Floor, 29
Dunchon-Daero 541 Beon-Gil, Jungwon-Gu
SEONGNAM-SI, GYEONGGI 13216 3216
REPUBLIC OF KOREA
Re: K261413
Trade/Device Name: Extron 3; Extron 6
Regulation Number: 21 CFR 892.1650
Regulation Name: Image-Intensified Fluoroscopic X-Ray System
Regulatory Class: Class II
Product Code: OWB, OXO, JAA
Dated: April 10, 2026
Received: July 24, 2026
Dear Youngeun Lee:
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 (the 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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database available at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.
U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov
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K261413 - Youngeun Lee
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Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality Management System Regulation (QMSR) (21 CFR Part 820), which includes, but is not limited to, ISO 13485 clause 7.3 (Design controls), ISO 13485 clause 8.3 (Nonconforming product), ISO 13485 clause 8.5.2 (Corrective action), and ISO 13485 clause 8.5.3 (Preventative action). Please note that regardless of whether a change requires premarket review, the QMSR requires device manufacturers to review and approve changes to device design and production (ISO 13485 clause 7.3 and ISO 13485 clause 7.5) and document changes and approvals in the Medical Device File (ISO 13485 clause 4.2.3).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-products); good manufacturing practice requirements as set forth in the Quality Management System Regulation (QMSR) (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-devices/medical-device-safety/medical-device-reporting-mdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-
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K261413 - Youngeun Lee
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assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
for
Lu Jiang Ph.D.
Assistant Director
Diagnostic X-Ray Systems Team
DHT8B: Division of Radiological Imaging
Devices and Electronic Products
OHT8: Office of Radiological Health
Office of Product Evaluation and Quality
Center for Devices and Radiological Health
Enclosure
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| Indications for Use | | |
| --- | --- | --- |
| Please type in the marketing application/submission number, if it is known. This textbox will be left blank for original applications/submissions. | | K261413 |
| Please provide the device trade name(s). | | ? |
| EXTRON 3; EXTRON 6 | | |
| Please provide your Indications for Use below. | | ? |
| EXTRON Series are a mobile fluoroscopic X-ray system with high output capacity, high thermal capacity and high resolution image processing system, which provides X-ray images of the patient's anatomy during surgery or treatment. This device plays an important role in emergency injury treatment, orthopedic surgery, neurosurgery surgery, bone surgery, etc. This device has a function to save important a specific images as records, so you can easily search for the images and transmit it to the PACS system in the hospital to help the medical staff in diagnosis. Examples of a clinical application may include: Neurosurgery, Orthopedics, Anesthesiology, Urology, Gynecology, Internal Medicine (※ This device is not intended for mammography applications.) | | |
| Please select the types of uses (select one or both, as applicable). | Prescription Use (21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C) | ? |
| Please select the age group(s) for which the device(s) is to be used. | Neonates/Newborns (Birth to < 29 days old)Infants (29 days old to < 2 years old)Children (2 years old to < 12 years old)Adolescents (12 years old to < 22 years old)Adults (22 years old and greater) | ? |
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K261413
DRTECH
# 510(k) Summary
[As required by 21 CFR 807.92]
This 510(k) summary of safety and effectiveness information is prepared in accordance with 21 CFR 807.92
# 1. Date Prepared [21 CFR 807.92(a) (1)]
August 19, 2026
# 2. Submitter's Information [21 CFR 807.92(a) (1)]
Name of Sponsor: DRTECH Corporation
Address: Suite No.1, 2 Floor / Suite No. 2, 3 Floor, 29, Dunchon-daero541 beon-gil, Jungwon-gu, Seongnam-si, Gyeonggi-do, 13216, Republic of Korea
Contact Name: Youngeun Lee
Telephone No.: +82-31-779-7705
Fax No.: +82-31-779-7790
Email Address: drtechra@drtech.com
Registration Number: 3005172103
Name of Manufacturer: Same as Sponsor
# 3. Trade Name, Common Name, Classification [21 CFR 807.92(a) (2)]
Trade Name: EXTRON 3, EXTRON 6
Common Name: Mobile Fluoroscopic X-ray System
Classification Name: Image-intensified fluoroscopic x-ray system
Classification Panel: Radiology
Classification Regulation: 21 CFR 892.1650
Product Code: OWB, OXO, JAA
Device Class: II
510(k) Summary
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DRTECH
# 4. Identification of Predicate Device(s) [21 CFR 807.92(a) (3)]
| | Predicate Device | Reference 1 | Reference 2 |
| --- | --- | --- | --- |
| 510(k) Number: | K250010 | K122234 | K142708 |
| Applicant: | DRTECH Corporation | GE HEALTHCARE SURGERY GE OEC MEDICAL SYSTEMS, INC | PHILIPS MEDICAL SYSTEMS NETHRLANDS BV |
| Trade Name: | EXTRON 3, EXTRON 5, EXTRON 7 | OEC 9900 ELITE | VERADIUS UNITY |
| Classification Name: | Image-intensified fluoroscopic x-ray system | | |
| Classification Panel: | Radiology | | |
| Classification Regulation: | 21 CFR 892.1650 | | |
| Product Code: | OWB, JAA, OXO | | |
| Device Class: | II | | |
# 5. Description of the Device [21 CFR 807.92(a) (4)]
EXTRON Series are mobile fluoroscopic X-ray systems with high output capacity, high thermal capacity, and high-resolution image processing systems that provide X-ray images of the patient's anatomical structures during surgery or treatment. This device plays an important role in emergency injury treatment, orthopedic surgery, neurosurgery surgery, bone surgery, etc. This device has a function to save important a specific images as records, so you can easily search for the images and transmit it to the PACS system in the hospital to help the medical staff in diagnosis.
The EXTRON Series are composed of a C-arm main body and a monitor cart. The C-arm main body is composed of an X-ray tube, a flat panel detector, a collimator, a generator, a touch panel, foot switch, hand switch and an XConsoleOP program, while the monitor cart is composed of a monitor, a thermal transfer printer, a mouse, a keyboard and an XConsole program.
The operating principle of the device is designed to expose the patient to X-ray beams. The range of X-ray irradiation are adjusted by the collimator.
X-rays can penetrate into the human body through a two-step conversion process.
X-ray photons are converted into light. The light is then converted into electrical signals through the sensor. The electrical charges are transmitted as the sensor output and converted into signals. These signals are digitized and captured by memory. The captured images are processed and displayed on the monitor. The displayed images can be saved or transmitted to an external storage device, such as a network printer.
# 6. Indications for Use [21 CFR 807.92(a)(5)]
EXTRON Series are a mobile fluoroscopic X-ray system with high output capacity, high thermal capacity and high resolution image processing system, which provides X-ray images of the patient's anatomy during surgery or treatment. This device plays an important role in emergency injury treatment, orthopedic surgery, neurosurgery surgery, bone surgery, etc. This device has a function to save important a specific images as records, so you can easily search for the images and transmit it to the PACS system in the hospital to help the medical staff in diagnosis.
Examples of a clinical application may include: Neurosurgery, Orthopedics, Anesthesiology, Urology, Gynecology, Internal Medicine
(※ This device is not intended for mammography applications.)
510(k) Summary
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# 7. Summary of Technological Characteristics of the Subject Device as Compared with the Predicate Device [21 CFR 807.92(a)(6), 21 CFR 807.92(b)]
The EXTRON Series are designed as a combination of components, including a C-arm, X-ray tube and housing, flat panel detector, digital imaging system, collimator, generator, and monitor cart. Its purpose is to provide X-ray images of a patient's anatomy during surgery or treatment.
The subject device has the same fundamental scientific technologies as the predicate devices. The technological comparison table below demonstrates the comparability of the technological characteristics of the new device and the currently cleared predicate devices. The Technological differences do not affect the intended use of the device.
The table 1 below compares the main performance data of the subject device with the predicate devices to substantiate equivalence of the subject device and predicates.
Table 1. Comparison of the Subject Device (EXTRON 3/6) with Predicate and Reference Devices
| Parameter | Subject Device | Predicate Device | Reference 1 | Reference 2 | Discussion |
| --- | --- | --- | --- | --- | --- |
| 510(K) Number | K261413 | K250010 | K122234 | K142708 | - |
| Manufacturer | DRTECH Corporation | DRTECH Corporation | GE HEALTHCARE SURGERY GE OEC MEDICAL SYSTEMS, INC | Philips Medical Systems Nederland B.V. | - |
| Model Name | EXTRON 3, EXTRON 6 | EXTRON 3, EXTRON 5, EXTRON 7 | OEC 9900 ELITE | Veradius Unity | - |
| Classification Name | Image-intensified fluoroscopic x-ray system | Image-intensified fluoroscopic x-ray system | Image-intensified fluoroscopic x-ray system | Image-intensified fluoroscopic x-ray system | Equivalent |
| Classification Panel | Radiology | | | | Radiology |
| Classification Regulation | 21 CFR 892.1650 | 21 CFR 892.1650 | 21 CFR 892.1650 | 21 CFR 892.1650 | Equivalent |
| Product Code | OWB, OXO, JAA | OWB, OXO, JAA | OWB, JAA, OXO | OWB, OXO, JAA | Equivalent |
| Device Class | Class II | Class II | Class II | Class II | Equivalent |
| Indications for Use | EXTRON Series are a mobile fluoroscopic X-ray system with high output capacity, high thermal capacity and high resolution image processing system, which provides X-ray images of the patient's anatomy during surgery or | EXTRON Series are a mobile fluoroscopic X-ray system with high output capacity, high thermal capacity and high resolution image processing system, which provides X-ray images of the patient's anatomy during surgery or | The OEC® 9900 Elite Mobile Fluoroscopy System is designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures. Examples of | The proposed Veradius Unity device is intended to be used and operated by: adequately trained, qualified, and authorized health care professionals such as physicians, surgeons, cardiologists, radiologists, and | Equivalent |
510(k) Summary
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# DRTECH
| Parameter | Subject Device | Predicate Device | Reference 1 | Reference 2 | Discussion |
| --- | --- | --- | --- | --- | --- |
| | treatment. This device plays an important role in emergency injury treatment, orthopedic surgery, neurosurgery surgery, bone surgery, etc. This device has a function to save important a specific images as records, so you can easily search for the images and transmit it to the PACS system in the hospital to help the medical staff in diagnosis. Examples of a clinical application may include: Neurosurgery, Orthopedics, Anesthesiology, Urology, Gynecology, Internal Medicine (※ This device is not intended for mammography applications.) | treatment. This device plays an important role in emergency injury treatment, orthopedic surgery, neurosurgery surgery, bone surgery, etc. This device has a function to save important a specific images as records, so you can easily search for the images and transmit it to the PACS system in the hospital to help the medical staff in diagnosis. Examples of a clinical application may include: Neurosurgery, Orthopedics, Anesthesiology, Urology, Gynecology, Internal Medicine (※ This device is not intended for mammography applications.) | clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, cardiac, critical care and emergency room procedures. | radiographers, who have full understanding of the safety information and emergency procedures as well as the capabilities and functions of the device. The device is used for radiological guidance and visualization during diagnostic, interventional, and surgical procedures on all patients except neonates (birth to one month), within the limits of the device. The device is to be used in healthcare facilities both inside and outside the operating room, in sterile as well as non-sterile environments, in a variety of procedures. Applications • Orthopedic • Neuro • Abdominal • Vascular • Thoracic • Cardiac | |
| Target population | Patients who need X-ray radiography or fluoroscopy images Adults and Pediatrics | Patients who need X-ray radiography or fluoroscopy images Adults and Pediatrics | Patients who need fluoroscopic and spot-film images | Patients who need diagnostic, interventional and surgical procedures, except neonates (birth to one month) | Equivalent |
| Mobile Platform | Yes | Yes | Yes | Yes | Equivalent |
510(k) Summary
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# DRTECH
| Parameter | Subject Device | Predicate Device | Reference 1 | Reference 2 | Discussion |
| --- | --- | --- | --- | --- | --- |
| X-ray tube | EXTRON 3 : Stationary Anode EXTRON 6: Rotating Anode | EXTRON 3 : Stationary Anode EXTRON 5 : Rotating Anode EXTRON 7: Rotating Anode | Rotating Anode | Rotating Anode | Equivalent |
| X-ray Generator Manufacturer / Model | EXTRON 3 : Powersite / MB-C5B EXTRON 6 : IMD / HF1 R/8 | EXTRON 3 : Powersite / MB-C5B EXTRON 5, EXTRON 7 : IMD / HF1 R/8 | - | - | Equivalent |
| X-ray Tube Manufacturer / Model | EXTRON 3 : RADII / KL188-0.6/1.2-125 EXTRON 6 : IAE / RTM 780 H | EXTRON 3 : EXTRON 3 : RADII / KL188-0.6/1.2-125 EXTRON 5, EXTRON 7 : IAE / RTM 780 H | - | - | Equivalent |
| Radiographic Mode | [Optional] kV Range : 40 to 120kV mA Range EXTRON 3 - Up to 100mA EXTRON 6 - Up to 100mA | kV Range : 40 to 120kV mA Range EXTRON 7 - Up to 150mA EXTRON 5 - N/A EXTRON 3 - Up to 100mA | kV Range : 40 to 120kV mA Range : Up to 150mA | kV Range : 40 to 120kV mA Range : Up to 125mA | Equivalent |
| Fluoroscopic Mode | kV Range : 40 to 120kV mA Range : EXTRON 3 - Up to 30mA EXTRON 6 - Up to 60mA | kV Range : 40 to 120kV mA Range : EXTRON 3 - Up to 30mA EXTRON 5 - Up to 40mA EXTRON 7 - Up to 60mA | kV Range : 40 to 120kV mA Range : - Normal : 0.2- 10 mA - High Level Fluoro : 1.0 - 40 mA | kV Range : 40 to 120kV mA Range : 1 to 60mA | Equivalent |
510(k) Summary
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# DRTECH
| Dimension | | Immersion Depth EXTRON 3 - 73cm EXTRON 6 - 74cm Free Space : 80cm Orbital movement EXTRON 3 - 165°, 180° EXTRON 6 - 165°, 180° | Immersion Depth EXTRON 3 - 73cm EXTRON 5 - 74cm EXTRON 7 - 74cm Free Space : 80cm Orbital movement : 165° | Immersion Depth : 84cm Free Space : 79cm Orbital movement : 145° | Immersion Depth : 73cm Free Space : 77cm Orbital movement : 145° | Equivalent : Alteration in the dimension does not give rise to any novel concerns regarding safety and effectiveness. Additionally, due to the greater scope of movement, the Subject device offers a higher degree of convenience compared to the Predicate device. |
| --- | --- | --- | --- | --- | --- | --- |
| Laser Guide | | Yes | Yes | Yes | Yes | Equivalent |
| Foot Switch | | Wired Foot Switch Wireless Foot Switch | Wired Foot Switch Wireless Foot Switch | Wired Foot Switch Wireless Foot Switch | Wired Foot Switch Wireless Foot Switch | Equivalent |
| Detector | Pixels | EXPD 2121PB : 1500 x 1500 pixels EXPD 2323PB:1536 x 1536 pixels | EXPD 2121P : 1500 x 1500 pixels EXPD 2323P : 1536 x 1536 pixels | 21 cm FPD : 1536 x 1496 pixels 31 cm FPD : 1548 x 1524 pixels | 1560 x 1420 pixels | Equivalent |
510(k) Summary
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# DRTECH
| Parameter | | Subject Device | Predicate Device | Reference 1 | Reference 2 | Discussion |
| --- | --- | --- | --- | --- | --- | --- |
| | | EXPD 3030P : 2048 x 2048 pixels | EXPD 2323PB:1536 x 1536 pixels EXPD 3030P : 2048 x 2048 pixels | | | |
| | DQE | 55% @1lp/mm | 55% @1lp/mm | 21 cm FPD : Typical 63% @0.5lp/mm 31 cm FPD : Typical 62% @0.5lp/mm | 70% @ 0p/mm | Equivalent |
| | MTF | 55% @1lp/mm | 55% @1lp/mm | - | 59% @ 1lp/mm | Equivalent |
510(k) Summary
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DRTECH
# **8. Summary of Non-Clinical Data [21 CFR 807.92(b)(1)]**
The EXTRON Series comply with the following international and FDA-recognized consensus standards list in Table 2.
Table 2. International and FDA-recognized consensus standards
| Standards development organization, reference number, and date | Standard name |
| --- | --- |
| ISO 14971 Third Edition 2019-12 | Medical devices - Application of risk management to medical devices |
| IEC 60601-1 Edition 3.2 2020-08 CONSOLIDATED VERSION | Medical electrical equipment - Part 1: General requirements for basic safety and essential performance - Note: This standard is recognized with relevant US national differences applied, see references #1 and #2 in the Relevant FDA Guidance and/or Supportive Publication section below. |
| ANSI AAMI ES60601-1:2005/(R)2012 & A1:2012, C1:2009/(R)2012 & A2:2010/(R)2012 (Cons. Text) [Incl. AMD2:2021] | Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD) [Including Amendment 2 (2021)] |
| IEC 60601-1-2 Edition 4.1 2020-09 CONSOLIDATED VERSION | Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests |
| IEC 60601-1-6 Edition 3.2 2020-07 CONSOLIDATED VERSION | Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability |
| IEC 62366-1 Edition 1.1 2020-06 CONSOLIDATED VERSION | Medical devices - Part 1: Application of usability engineering to medical devices |
| IEC 60601-1-3 Edition 2.2 2021-01 CONSOLIDATED VERSION | Medical electrical equipment - Part 1-3: General requirements for basic safety and essential performance - Collateral Standard: Radiation protection in diagnostic X-ray equipment |
| IEC 60601-2-28 Edition 3.0 2017-06 | Medical electrical equipment - Part 2-28: Particular requirements for the basic safety and essential performance of X-ray tube assemblies for medical diagnosis |
| IEC 60601-2-54 Edition 2.0 2022-09 | Medical electrical equipment - Part 2-54: Particular requirements for the basic safety and essential performance of X-ray equipment for radiography and radioscopy |
| IEC 60601-2-43 Edition 3.0 2022-12 | Medical electrical equipment - Part 2-43: Particular requirements for the safety and essential performance of X-ray equipment for interventional procedures |
| IEC 60601-2-43 Edition 2.2 2019-10 CONSOLIDATED VERSION | Medical electrical equipment - Part 2-43: Particular requirements for the safety and essential performance of X-ray equipment for interventional procedures |
| IEC 62304 Edition 1.1 2015-06 CONSOLIDATED VERSION | Medical device software - Software life cycle processes |
| ANSI UL 2900-1 First Edition 2017 | Standard for Safety, Standard for Software Cybersecurity Network-Connectable Products, Part 1: General Requirements |
510(k) Summary
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| IEC 81001-5-1 Edition 1.0 2021-12 | Health software and health IT systems safety, effectiveness and security - Part 5-1: Security - Activities in the product life cycle |
| --- | --- |
And EXTRON Series comply with the FDA guidance documents listed in Table 3.
Table 3. FDA Guidance Documents
| Title of Guidance Document | Issue Date |
| --- | --- |
| Guidance for Industry and Food and Drug Administration Staff: The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)] | July 28, 2014 |
| Guidance for Industry and FDA Staff: Content of Premarket Submissions for Device Software Functions | June 14, 2023 |
| Guidance for Industry and Food and Drug Administration Staff: Medical X-Ray Imaging Devices Conformance with IEC Standards | May 8, 2019 |
| Guidance for Industry and FDA Staff: Electromagnetic Compatibility (EMC) of Medical Devices | June 3, 2022 |
| Guidance for Industry and FDA Staff: Applying Human Factors and Usability Engineering to Medical Devices | February 3, 2016 |
| Guidance for Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions | September 27, 2023 |
Bench testing and related documentation performed in accordance with Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices
Sample clinical images representative of the indicated anatomies and populations have been taken for both the proposed devices (EXTRON 3, EXTRON 6) and the predicate devices (EXTRON 5/7/3(K250010)). These images have been reviewed and compared by qualified clinical experts. As a result of this evaluation, it has been confirmed that the EXTRON Series devices provide equivalent image quality to the predicate devices.
## 9. Summary of Clinical Data [21 CFR 807.92(b)(2)]
Clinical images were taken and reviewed by qualified clinicians to support SE (see Section 8 for more details).
## 10. Conclusion [21 CFR 807.92(b)(3)]
The EXTRON Series are substantially equivalent to the currently marketed predicate devices (EXTRON 5/7/3(K250010)) in terms of design, fundamental scientific technology, and indications for use, safety, and effectiveness.
Substantial equivalence for Mobile fluoroscopic X-ray System was demonstrated through the non-clinical performance in compliance with the requirements specified in the international and FDA recognized consensus standards, ANSI AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-54, IEC 60601-2-43, IEC 62304, ANSI UL 2900-1, and IEC 81001-5-1.
The comparison of technological characteristics, non-clinical performance data and safety testing demonstrate that the EXTRON Series are substantially equivalent to the predicate devices.
510(k) Summary
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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.