K Number
K013848
Manufacturer
Date Cleared
2002-04-08

(139 days)

Product Code
Regulation Number
892.1550
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The modified U-2000 is indicated for acquisition of related sets of 2D ultrasound images and 3 dimensional reconstruction of diagnostic ultrasound images. It is intended to acquire, analyze, store, and retrieve digital ultrasound images for computerized 3 dimensional image processing.

Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows: Abdominal, Small Organ (breast, thyroid, testes), Peripheral Vascular, Musculo-skeletal Conventional.

Device Description

The modified U-2000 software provides the capability for the acquisition, analysis, storage and retrieval of digital 3D ultrasound image data sets and multiplaner reformatting capabilities.

AI/ML Overview

The U-Systems Inc. 510(k) Notification for the U-2000 Ultrasound System with modified software (K013848) does not contain detailed acceptance criteria or a specific study proving the device meets quantitative performance metrics. Instead, the submission focuses on demonstrating substantial equivalence to a predicate device, the Echotech 3D Freescan, and adherence to internal software quality assurance procedures.

Therefore, many of the requested fields cannot be directly extracted from the provided text.

Here's an analysis based on the available information:

1. Table of Acceptance Criteria and Reported Device Performance

No specific, measurable acceptance criteria (e.g., minimum accuracy, sensitivity, or specificity values) or numerical performance metrics for the modified software are provided in the document. The document primarily attests to functional capabilities and intended use.

Acceptance CriteriaReported Device Performance
Not specifiedNot specified

2. Sample size used for the test set and the data provenance

No information is provided regarding a specific "test set" for performance evaluation, its sample size, or data provenance (e.g., country of origin, retrospective or prospective). The validation mentioned is related to software quality assurance procedures.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

No information is provided regarding experts, ground truth establishment, or their qualifications, as no specific performance study with a test set is detailed.

4. Adjudication method for the test set

Not applicable, as no specific test set or adjudication process is described.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

Not applicable. This device is a diagnostic ultrasound system with modified software for 3D reconstruction and analysis, not an AI-assisted diagnostic tool as understood in the context of MRMC studies for AI.

6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done

This is a diagnostic ultrasound system. While it has software for image acquisition, analysis, storage, and retrieval, the primary performance would inherently involve a human operator and interpretation. No "standalone algorithm" performance is described in the context of diagnostic accuracy. The "standalone" performance here refers to the software's ability to perform its specified functions (acquisition, reconstruction, analysis, storage, retrieval) which are implicitly covered by the software validation.

7. The type of ground truth used

No specific ground truth (expert consensus, pathology, outcomes data) is mentioned as a benchmark for evaluating the modified software's performance, as the submission focuses on functional equivalence and software validation rather than a diagnostic accuracy study.

8. The sample size for the training set

Not applicable. The document describes a software modification to an existing ultrasound system, not a machine learning or AI model that would require a "training set" in the conventional sense.

9. How the ground truth for the training set was established

Not applicable, as no training set is discussed.


Summary of the Study Discussed in the Document:

The provided documents indicate that the "study" for the modified U-2000 software primarily consisted of software validation according to the company's software quality assurance procedures, as certified in the original 510(k) Notification. This validation ensures that the software correctly performs its intended functions (acquisition, analysis, storage, and retrieval of digital 3D ultrasound image data sets and multiplaner reformatting capabilities).

The basis for regulatory clearance (510(k)) is substantial equivalence to an existing legally marketed predicate device (Echotech 3D Freescan) regarding features, specifications, and intended use, rather than a de novo performance study against explicit effectiveness criteria. The FDA's letter confirms this substantial equivalence determination based on the provided information. The new indications listed for the USI-2000 system and its transducers (7.5 MHz and 10 MHz) relate to expanded clinical applications for various modes of operation (B, M, PWD, Color Doppler, Amplitude Doppler, and combined modes) in areas like Abdominal, Small Organ, Peripheral Vascular, and Musculoskeletal imaging.

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K013848

CONFIDENTIAL U-Systems Inc.510(k) Notification evice Modification

APR = 8 2002

2.4 510(k) Summary

510(k) Summary U-Systems Ultrasound System U-Systems INC. Prepared November 15, 2001

Product Name:U-2000 Ultrasound System
Manufacturer:U-Systems Inc.
Generic NameDiagnostic Ultrasound System
Classification Name:Ultrasound Imaging System and Transducers (Class II); Classificationcodes:IYO 892.1560 System, Imaging Pulsed Echo, UltrasonicIYN 892.1550 System, Imaging, Pulsed Doppler, UltrasonicITX 892.1570 Transducer, Ultrasonic, Diagnostic
Contact Person:Sheila W. Pickering Ph.D.2081 Longden CircleLos Altos, California 94024Telephone/Fax 650 969 6114

A. Legally Marketed Predicate Device

The modification to the U-2000 software is substantially equivalent to the Echotech 3D Freescan with regard to features, specifications, and intended use.

e-mail: swpraqa@aol.com

B. Device Description

The modified U-2000 software provides the capability for the acquisition, analysis, storage and retrieval of digital 3D ultrasound image data sets and multiplaner reformatting capabilities.

C. Intended Use

The modified U-2000 is indicated for acquisition of related sets of 2D ultrasound images and 3 dimensional reconstruction of diagnostic ultrasound images. It is intended to acquire, analyze, store, and retrieve digital ultrasound images for computerized 3 dimensional image processing.

D. Substantial Equivalence

The U-2000 is substantially equivalent to the Echotech 3D Freescan, which is currently in commercial distribution.

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E. Performance Data

The modified software has been validated according to the company's software quality assurance procedures, as certified in the original 510(k) Notification.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular emblem with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. Inside the circle is a stylized image of a caduceus, a symbol often associated with medicine and healthcare, featuring a staff with a serpent entwined around it.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Sheila W. Pickering, Ph.D. Regulatory Affairs Consultant U-Systems, Inc. 2081 Longden Circle LOS ALTOS CA 94024

Re: K013848

Trade Name: USI-2000 Diagnostic Ultrasound System, Modified Software Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic pulsed doppler imaging system Product Code: 90 IYN Regulation Number: 21 CFR 892.1560 Regulation Name: Ultrasonic pulsed echo imaging system Product Code: 90 IYO Regulation Number: 21 CFR 892.1570 Regulation Name: Diagnostic ultrasonic transducer Product Code: 90 ITX Regulatory Class: II Dated: February 27, 2002 Received: March 1, 2002

Dear Dr. Pickering:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and we 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). 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.

This determination of substantial equivalence applies to the following transducers intended for use with the USI-2000 Diagnostic Ultrasound System, as described in your premarket notification:

Transducer Model Number

7.5 MHz 10 MHz

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Page 2 - Dr. Pickering

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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); 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.

This letter will allow you to begin marketing your device as described in your premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus permits your device to proceed to market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801, please contact the Office of Compliance at (301) 594-4591. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97).

Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or at (301) 443-6597 or at its Internet address "http://www.fda.gov/cdrh/dsmamain.html".

If you have any questions regarding the content of this letter, please contact Rodrigo C. Perez at (301) 594-1212.

Sincerely yours.

Nancy C. Brogdon

Nancy C. Brogdon Director, Division of Reproductive, Abdominal and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure(s)

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CONFIDENTIAL U-Systems Inc.510(k) Notification USI-2000 Diagnostic Ultrasound System

Diagnostic Ultrasound Indications for Use

510(k) Number(s):

N/A

Device Name:

USI-2000 Diagnostic Ultrasound Pulsed Echo System Diagnostic Ultrasound Pulsed Doppler Imaging System

Intended Use:

Mode of Operation
Clinical ApplicationABMPWDCWDColorDopplerAmplitudeDopplerColorVelocityImagingCombined(specify)*Other(specify)
Ophthalmic
Fetal
AbdominalNNNNNNote 1
Intraoperative (specify)
Intraoperative Neurological
Pediatric
Small Organ (breast, thyroid,testes)NNNNNNote 1
Neonatal Cephalic
Adult Cephalic
Cardiac
Tranesophageal
Transrectal
Transvaginal
Transurethral
Intravascular
Laproscopic
Peripheral VascularNNNNNNote 1
Musculo-skeletalConventionalNNNNNNote 1
Musculo-skeletalSuperficial

Note 1: Combined includes: B/M; B/PWD; B/Color Doppler; B/Amplitude Doppler; B/Color Doppler/PWD and B/Amplitude Doppler/PWD

N = new indication

P = previously cleared by FDA

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)

Haneye Broadon

(Division Sign-Off)
Division of Reproductive, Abdominal,
and Radiological Dai

022

Prescription Use

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CONFIDENTIAL U-Systems Inc.510(k) Notification USI-2000 Diagnostic Ultrasound System

Diagnostic Ultrasound Indications for Use

510(k) Number:

N/A

Device Name:

7.5 MHz Transducer Diagnostic Ultrasound Transducer

Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:

Mode of Operation
Clinical ApplicationABMPWDCWDColorDopplerAmplitudeDopplerColorVelocityImagingCombined(specify)*Other(specify)
Ophthalmic
Fetal
AbdominalNNNNNNote 1
Intraoperative (specify)
Intraoperative Neurological
Pediatric
Small Organ (breast, thyroid,testes)NNNNNNote 1
Neonatal Cephalic
Adult Cephalic
Cardiac
Tranesophageal
Transrectal
Transvaginal
Transurethral
Intravascular
Laproscopic
Peripheral VascularNNNNNNote 1
Musculo-skeletalNNNNNNote 1
Conventional
Musculo-skeletalSuperficial

Note 1: Combined includes: BBM; B/PWD; B/Color Doppler; B/Amplitude Doppler; B/Color Doppler/PWD and B/Amplitude Doppler/PWD

N = new indication P = previously cleared by FDA

. (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)

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Prescription Use

Nancy C. Brogdon
(Division Sign-Off)
Division of Reproductive, Abdominal,
and Radiological Devices 023

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CONFIDENTIAL U-Systems Inc.510(k) Notification USI-2000 Diagnostic Ultrasound System

Diagnostic Ultrasound Indications for Use

510(k) Number:

N/A

Device Name:

10 MHz Transducer Diagnostic Ultrasound Transducer

Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:

Mode of Operation
Clinical ApplicationABMPWDCWDColorDopplerAmplitudeDopplerColorVelocityImagingCombined(specify)*Other(specify)
Ophthalmic
Fetal
AbdominalNNNNNNote 1
Intraoperative (specify)
Intraoperative Neurological
Pediatric
Small Organ (breast, thyroid,testes)NNNNNNote 1
Neonatal Cephalic
Adult Cephalic
Cardiac
Tranesophageal
Transrectal
Transvaginal
Transurethral
Intravascular
Laproscopic
Peripheral VascularNNNNNNote 1
Musculo-skeletalNNNNNNote 1
Conventional
Musculo-skeletalSuperficial

Note 1: Combined includes: B/M; B/PWD; B/Color Doppler; B/Amplitude Doppler; B/Color Doppler/PWD and B/Amplitude Doppler/PWD

N = new indication P = previously cleared by FDA

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)

Nancy C Brogdon 024

of Reproduct ive. Al diological De 15 510(k) Numb

Prescription Use

§ 892.1550 Ultrasonic pulsed doppler imaging system.

(a)
Identification. An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.