K Number
K170438
Device Name
MiroCam Capsule Endoscope System
Date Cleared
2018-01-30

(351 days)

Product Code
Regulation Number
876.1300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The MiroCam® Capsule Endoscope System is intended for visualization of the small bowel mucosa. - It may be used in the visualization and monitoring of lesions that may indicate Crohn's disease not detected by upper and lower endoscopy. - It may be used in the visualization and monitoring of lesions that may be a source of obscure bleeding (either overt or occult) not detected by upper and lower endoscopy. - It may be used in the visualization and monitoring of lesions that may be potential causes of iron deficiency anemia (IDA) not detected by upper and lower endoscopy. It may be used as a tool in the detection of abnormalities of the small bowel and this device is indicated for adults only. The Suspected GI Bleeding Indicator (SGIB) is intended to mark frames of the video suspected of containing blood or red areas.
Device Description
The MiroCam® Capsule Endoscope System is comprised of the following core components: - MiroCam® Capsule: MC2000-B - MiroCam® Receiver: MR2000 - Data Cable / Data Belt (Optional): MR1000-D / MR1000-D(S) or MR1000-D(M) or MR1000-D(L) - MiroView™ Software: MiroView™ U 4.0 The MiroCam® capsule captures images of the GI tract, which are sent via Human Body Communication to sensor pads which are affixed to the patient body. The sensor pads are connected to the receiver by the data cables. The image data is stored on the receiver for the duration of the patient procedure. After removing the receiver set from the patient body, the receiver is connected via USB to the Commercial PC and the image data is uploaded. Following upload, the physician (Gastroenterologist) reviews the patient image data for suspected abnormalities of the small bowel.
More Information

No
The document explicitly states "Mentions AI, DNN, or ML: Not Found" and the description of the device and its function does not mention any AI/ML components. The "Suspected GI Bleeding Indicator (SGIB)" is mentioned, but the description does not indicate it uses AI/ML for this function.

No

The device is intended for visualization and monitoring purposes, not for providing therapy or treatment. Its function is diagnostic, helping physicians detect abnormalities.

Yes

Explanation: The device is intended for "visualization of the small bowel mucosa" to "monitor lesions" that may indicate various conditions, and it is used as a "tool in the detection of abnormalities." Post-procedure, a physician "reviews the patient image data for suspected abnormalities." This process of identifying and evaluating potential medical conditions through visualization directly aligns with the definition of a diagnostic device.

No

The device description explicitly lists hardware components (MiroCam® Capsule, MiroCam® Receiver, Data Cable / Data Belt) in addition to the software (MiroView™ Software).

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information about a person's health. This testing is done outside of the body (in vitro).
  • MiroCam System Function: The MiroCam system works by capturing images inside the patient's body (in vivo) as the capsule travels through the small bowel. It visualizes the mucosa directly.
  • Intended Use: The intended use is for visualization and monitoring of lesions, not for analyzing specimens taken from the body.
  • Device Description: The description clearly outlines a system for capturing and transmitting images from within the GI tract.

While the system provides diagnostic information, it does so through direct visualization within the body, not through in vitro testing of specimens.

N/A

Intended Use / Indications for Use

The MiroCam® Capsule Endoscope System is intended for visualization of the small bowel mucosa.

  • It may be used in the visualization and monitoring of lesions that may indicate Crohn's disease not detected by upper and lower endoscopy.
  • It may be used in the visualization and monitoring of lesions that may be a source of obscure bleeding (either overt or occult) not detected by upper and lower endoscopy.
  • It may be used in the visualization and monitoring of lesions that may be potential causes of iron deficiency anemia (IDA) not detected by upper and lower endoscopy.

It may be used as a tool in the detection of abnormalities of the small bowel and this device is indicated for adults only.

The Suspected GI Bleeding Indicator (SGIB) is intended to mark frames of the video suspected of containing blood or red areas.

Product codes (comma separated list FDA assigned to the subject device)

NEZ

Device Description

The MiroCam® Capsule Endoscope System is comprised of the following core components:
-MiroCam® Capsule: MC2000-B

  • MiroCam® Receiver: MR2000 -
  • Data Cable / Data Belt (Optional): MR1000-D / MR1000-D(S) or MR1000-D(M) or MR1000-D(L)
  • MiroView™ Software: MiroView™ U 4.0 -

The general usage workflow of the MiroCam® system is as follows, the MiroCam® capsule captures images of the GI tract, which are sent via Human Body Communication to sensor pads which are affixed to the patient body. The sensor pads are connected to the receiver by the data cables. The image data is stored on the receiver for the duration of the patient procedure. After removing the receiver set from the patient body, the receiver is connected via USB to the Commercial PC and the image data is uploaded. Following upload, the physician (Gastroenterologist) reviews the patient image data for suspected abnormalities of the small bowel.

Mentions image processing

  • Functionally, the MiroCam® captures imaging via a CMOS imaging sensor for at least 12 hours at the rate of 6 images per second.
  • The MiroView™ U 4.0 helps the user to upload the image data from the Receiver and review the image data with displaying.
  • MiroView™ Client has functionalities: List Mode (Case Data Management), Review Mode (Video Display, Image Capture, Annotation Box, etc.), Report Mode (User Comment, Auto Disease Name Check, etc), Export Mode (JPG, AVI, MiroVlew™ file format)
  • The Suspected GI Bleeding Indicator (SGIB) is intended to mark frames of the video suspected of containing blood or red areas.
  • For the MC1200-B, Auto Exposure time is used to adjust the LED turn-on time depending on the target brightness, which applies equally to the MC2000-B.
  • Depending on the sensor's incident light intensity, the AE function optimally adjusts the exposure time, thus preventing the over-exposure and low exposure situations. Namely, it calculates an average brightness of the image and, after checking the present state of the exposure, adjusts the exposure doze to make sure that the current average brightness converges to target brightness value by means of P-control. ASPIN adjusts the exposure time by adjusting the pixel control timing as well as LED ON-time. The unit step of exposure time adjustment is 1 PCLOCK period.

Mentions AI, DNN, or ML

Not Found.

Input Imaging Modality

CMOS imaging sensor

Anatomical Site

Small bowel mucosa

Indicated Patient Age Range

Adults only

Intended User / Care Setting

Physician (Gastroenterologist) reviews the patient image data for suspected abnormalities of the small bowel.

Description of the training set, sample size, data source, and annotation protocol

Not Found.

Description of the test set, sample size, data source, and annotation protocol

Not Found.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The MiroCam® Capsule Endoscope System performance testing was done for the submission of predicate device but it was not included when Sensor Bench testing. MTF Measurement testing (including the predicate device, K143663), Minimum Distinguishable Contrast Value and Depth of Field testing (including the predicate device, K143663). Geometric distortion testing (including the predicate device. K143663). Field of View testing (including the predicate device, K143663), Color Reproduction testing (including the predicate device, K143663), Testing optical spectra of the light source at different time points during the battery life period (including the predicate device, K143663), Testing intensity change during the shelf life period (including the predicate device, K143663), Bite testing, Water proof testing, pH resistance testing, MR1100 (predicate device, K143663) and MR2000 (subject device) Equivalent Performance Comparison testing, and Shelf life testing (Operation time, Package integrity, pH resistance and Bite) was done. The results of this performance testing conclude that the material and technological characteristics have not diminished the safety and effectiveness of the IntroMedic Co., Ltd. MiroCam® Capsule Endoscope System device when compared to the predicate device.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found.

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K143663, K123864

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K123666

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found.

§ 876.1300 Ingestible telemetric gastrointestinal capsule imaging system.

(a)
Identification. An ingestible telemetric gastrointestinal capsule imaging system is used for visualization of the small bowel mucosa as an adjunctive tool in the detection of abnormalities of the small bowel. The device captures images of the small bowel with a wireless camera contained in a capsule. This device includes an ingestible capsule (containing a light source, camera, transmitter, and battery), an antenna array, a receiving/recording unit, a data storage device, computer software to process the images, and accessories.(b)
Classification. Class II (special controls). The special control is FDA's guidance, “Class II Special Controls Guidance Document: Ingestible Telemetric Gastrointestinal Capsule Imaging Systems; Final Guidance for Industry and FDA.”

0

Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo, which features a stylized human figure. To the right of that is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

January 30, 2018

Intromedic Co., Ltd. Jinyoung Lee General Manager Suite 1105, 1106, E&C Venture Dream Tower 6-Cha Guro-dong, Guro-gu Seoul. 08375 Korea

Re: K170438 Trade/Device Name: MiroCam® Capsule Endoscope System Regulation Number: 21 CFR§ 876.1300 Regulation Name: Ingestible Telemetric Gastrointestinal Capsule Imaging System Regulatory Class: II Product Code: NEZ Dated: December 7, 2017 Received: December 14, 2017

Dear Jinyoung 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 (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.

1

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 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.

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.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Image /page/1/Picture/6 description: The image shows the name "Benjamin R. Fisher -S" in a large, bold, sans-serif font. The text is black and appears to be the main subject of the image. The background is plain and does not distract from the text.

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K170438

Device Name

MiroCam® Capsule Endoscope System

Indications for Use (Describe)

The MiroCam® Capsule Endoscope System is intended for visualization of the small bowel mucosa.

  • It may be used in the visualization and monitoring of lesions that may indicate Crohn's disease not detected by upper and lower endoscopy.
  • It may be used in the visualization and monitoring of lesions that may be a source of obscure bleeding (either overt or occult) not detected by upper and lower endoscopy.
  • It may be used in the visualization and monitoring of lesions that may be potential causes of iron deficiency anemia (IDA) not detected by upper and lower endoscopy.

It may be used as a tool in the detection of abnormalities of the small bowel and this device is indicated for adults only.

The Suspected GI Bleeding Indicator (SGIB) is intended to mark frames of the video suspected of containing blood or red areas.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data nepoled annound the and review the collection of information. Send comments regarding this burden estimate or any other onspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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5. 510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of 21 CFR Part 807.92.

1. Company and Correspondent making the submission

NameIntroMedic Co., Ltd.
AddressSuite 1105, 1106, E&C Venture Dream Tower 6-Cha
197-28 Guro-dong, Guro-gu, Seoul, 08375, Korea
Telephone+82-2-801-9300
Fax+82-2-801-9330
ContactJinyoung Lee
Internethttp://www.intromedic.com

2. Device

Proprietary NameMiroCam® Capsule Endoscope System
Common NameCapsule Imaging System
Classification Name21 CFR 876.1300 (Product Code NEZ)
Ingestible telemetric gastrointestinal capsule imaging system

3. Predicate Device

ManufacturerIntroMedic Co., Ltd.
DeviceMiroCam® Capsule Endoscope System
510(K) NumberK143663
ManufacturerGiven Imaging Ltd.
DeviceGiven PillCam SB3 Capsule endoscopy system
510(K) NumberK123864
ManufacturerGiven Imaging Ltd.
DeviceGiven PillCam COLON 2 Capsule endoscopy system
510(K) NumberK123666 (Reference device)

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4. Description

The MiroCam® Capsule Endoscope System is comprised of the following core components:

  • -MiroCam® Capsule: MC2000-B
  • MiroCam® Receiver: MR2000 -
  • Data Cable / Data Belt (Optional): MR1000-D / MR1000-D(S) or MR1000-D(M) or MR1000--D(L)
  • MiroView™ Software: MiroView™ U 4.0 -

The general usage workflow of the MiroCam® system is as follows, the MiroCam® capsule captures images of the GI tract, which are sent via Human Body Communication to sensor pads which are affixed to the patient body. The sensor pads are connected to the receiver by the data cables. The image data is stored on the receiver for the duration of the patient procedure. After removing the receiver set from the patient body, the receiver is connected via USB to the Commercial PC and the image data is uploaded. Following upload, the physician (Gastroenterologist) reviews the patient image data for suspected abnormalities of the small bowel. The key system components are explained in detail below.

MiroCam® Capsule

Functionally, the MiroCam® captures imaging via a CMOS imaging sensor for at least 12 hours at the rate of 6 images per second. Twelve white LEDs flash in concert with the imaging sensor. A sensor PCB links the imaging sensor to the two gold electrodes of the capsule, from which a weak current is emitted containing the image data via Human Body Communication technology. The weak current is then passed through the bodily tissue and fluid to be picked up by the sensor pads. Human Body Communications is uni-directional from the capsule to the sensor pads.

Physically, the capsule is 30.1mm in length, and 10.8mm in diameter. The exterior of the capsule is composed of biocompatible materials, capable of withstanding potential bite forces and exposure to fluids in the GI tract.

MiroCam® Receiver

The image data from the capsule is saved to the MiroCam® Receiver via the sensor pads and data cables. The sensor pads are standard ECG type sensor pads (3M Red Dot), which are affixed to the patient's abdomen according to the location guide. The 9 sensor pads are attached to the 9 leads of the data cable, and the data cable is subsequently attached to the Receiver sits in a shoulder pouch, which is put on the patient for the duration of the procedure. A waist pouch is used to organize the data cables.

5

The Receiver can store images for up to 12 hours. Using LCD display it shows icons that indicate the state of receiver, real time image view and preview. User can capture image for the real time images are displayed. Three LEDs also represent the receiver state by switching its power. And MiroCam® receiver play some sounds for notifying to user. To reduce the battery consumption of MiroCam® receiver backlight brightness is controlled. User can control MiroCam® receiver by using three buttons.

The dimensions of the receiver are 145mm in height, 82.5mm in width, and 29.8mm in length. The units weight 330 grams, which is data cable. The battery is lithium ion, and is unique to the Receiver. The battery is rechargeable, and can be charged by placing in the battery charger provided with the Receiver. The receiver uses a storage flash for storing the images.

MiroView™ U 4.0

The MiroView™ U 4.0 helps the user to upload the image data from the Receiver and review the image data with displaying.

MiroView™ U 4.0 will be deployed as three types of software: MiroView™M Server, MiroView™M Operator and MiroView™ Client.

Server PC includes two types of S/W: MiroView™ Server and Operator.

MiroView™ Server and MiroView™ Operator will be deployed on a Server PC. MiroView™ Client S/W will be deployed on reviewer's PCs. 10 Client S/Ws will be able to connect to one Server PC via Network (LAN) at a time.

MiroView™ Server has functionalities: Data Storage, PACS connectivity.

MiroView™ Operator has functionalities: Receiver Management and Account Management.

MiroView™ Client has functionalities: List Mode (Case Data Management), Review Mode (Video Display, Image Capture, Annotation Box, etc.), Report Mode (User Comment, Auto Disease Name Check, etc), Export Mode (JPG, AVI, MiroVlew™ file format)

MiroView™ U 4.0 provides some kinds of Modes and Views to help the user review patient video data quickly and conveniently; however, IntroMedic, Co., Ltd. recommends that the doctor review the patient video in the Normal Mode / Single View to prevent from a wrong diagnosis.

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MiroView™ U 4.0 is a new version of MiroView™ U 3.0, which has new updated features from the MiroView™M U 3.0. The features are described below:

  • Compatibility with New Receiver MR2000: MiroView™ U Operator 4.0 -
  • UI Function for Reviewing Patient Data of Dual Tip Capsule: MiroView™ U Client 4.0 -
  • Support of H.264 Codec: MiroView™ U Common 4.0 -
  • Express Play ver 3.0: MiroView™ U Client 4.0 -
  • Supplementary Play: MiroView™ U Client 4.0 -

5. Indications for Use

Capsule Endoscope System is intended for visualization of the small The MiroCam® bowel mucosa.

  • It may be used in the visualization and monitoring of lesions that may indicate Crohn's disease not detected by upper and lower endoscopy.
  • -It may be used in the visualization and monitoring of lesions that mav be a source of obscure bleeding (either overt or occult) not detected by upper and lower endoscopy.
  • -It may be used in the visualization and monitoring of lesions that may be potential causes of iron deficiency anemia (IDA) not detected by upper and lower endoscopy.

It may be used as a tool in the detection of abnormalities of the small bowel and this device is indicated for adults only.

The Suspected GI Bleeding Indicator (SGIB) is intended to mark frames of the video suspected of containing blood or red areas.

6. Technological Characteristics and Substantial Equivalence

The characteristics of the IntroMedic Co., Ltd. MiroCam® Capsule Endoscope System are substantially equivalent to the following current legally marketed predicate devices based on indications for use, typical clinical use, and operational and fundamental technological characteristics

  • MiroCam® Capsule Endoscope System by IntroMedic Co., Ltd. K143663
  • Given® PillCam® SB3 Capsule endoscopy system by Given Imaging Ltd. K123864
  • Given PillCam® COLON 2 capsule endoscopy system by Given Imaging Ltd. K123666 (Reference device)

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Table 5-1. Side-by-Side Comparison of the MiroCam® Capsule Endoscope System

with the Predicate Device

| Type | Characteristics | MiroCam®
Endoscope System
Subject device | MiroCam®
Endoscope System
K143663 | Given® PillCam® SB3
Capsule system
K123864 | Given PillCam®
COLON 2 capsule
endoscopy system
K123666
(Reference device) |
|---------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------|
| Indications for Use | The MiroCam® Capsule
Endoscope System is
intended for visualization
of the small bowel
mucosa.

  • It may be used in the
    visualization and
    monitoring of
    lesions that may
    indicate Crohn's
    disease not detected
    by upper and lower
    endoscopy.
  • It may be used in the
    visualization and
    monitoring of
    lesions that may be a
    source of obscure
    bleeding (either
    overt or occult) not
    detected by upper
    and lower
    endoscopy.
  • It may be used in the
    visualization and
    monitoring of
    lesions that may be
    potential causes of
    iron deficiency
    anemia (IDA) not
    detected by upper
    and lower
    endoscopy.
  • It may be used as a tool in
    the detection of
    abnormalities of the small
    bowel and this device is
    indicated for adults only.
  • The Suspected GI
    Bleeding Indicator
    (SGIB) is intended to
    mark frames of the video
    suspected of containing
    blood or red areas. | MiroCam® Capsule
    Endoscope System is
    intended for visualization
    of the small bowel
    mucosa. It may be used as
    a tool in the detection of
    abnormalities of the small
    bowel in adults and
    children from two years
    of age.
  • The Suspected GI
    Bleeding Indicator
    (SGIB) is intended to
    mark frames of the video
    of suspected of containing
    blood or red areas. | The PillCam SB capsule
    is intended for
    visualization of the small
    bowel mucosa.
  • It may be used in the
    visualization and
    monitoring of
    lesions that may
    indicate Crohn's
    disease not detected
    by upper and lower
    endoscopy.
  • It may be used in the
    visualization and
    monitoring of
    lesions that may be
    a source of obscure
    bleeding (either
    overt or occult) not
    detected by upper
    and lower
    endoscopy.
  • It may be used in the
    visualization and
    monitoring of
    lesions that may be
    potential causes of
    iron deficiency
    anemia (IDA) not
    detected by upper
    and lower
    endoscopy.
  • The suspected Blood
    Indicator (SBI) feature is
    intended to mark frames
    of the video suspected of
    containing blood or red
    areas.
  • The PillCam SB capsule
    may be used as a tool in
    the detection of
    abnormalities of the small
    bowel and is intended for
    use in adults and children
    from two years of age. | The PillCam COLON 2
    System is indicated to
    provide visualization of
    the colon. It is intended to
    be used for detection of
    colon polyps in patients
    that may after an incomplete
    optical colonoscopy with
    adequate preparation, and
    a complete evaluation of
    the colon was not
    technically possible.
    (※The Indications for
    Use of the device do not
    apply to the subject
    device.) | |
    | Manufacturer | IntroMedic Co., Ltd.
    MC2000-B | IntroMedic Co., Ltd.
    MC1200-B | Given Imaging Ltd.
    PillCam SB3 | Given Imaging Ltd.
    PillCam COLON 2 | |
    | | | | | | |
    | ule | Size | Length: 30.1mm
    Diameter: 10.8mm | Length: 24.5mm
    Diameter: 10.8mm | Length: 26.2mm
    Diameter: 11.4mm | Length: 31.5mm
    Diameter: 11.6mm |
    | | Weight | $3.5g\pm0.1g$ | 3.25g | $3.0\pm0.1g$ | $2.9\pm0.03g$ |
    | | Material | Human Compliance
    Plastic | Human Compliance
    Plastic | Biocompatible plastic | Biocompatible plastic |
    | | Dome Material | COP (Cyclo Olefin
    Polymers) | COP (Cyclo Olefin
    Polymers) | Polycarbonate | Polycarbonate |
    | | Light | 12 White LEDs (each
    White LEDs) | 6 White LEDs | 4 White LEDs | 8 White LEDs (each
    White LEDs) |
    | | LED Size | 2.0mm(L)1.25mm(W)
    0.8mm(H) | 2.0mm(L)1.25mm(W)
    0.8mm(H) | | |
    | | LED Viewing
    Angle | 130° | 130° | | |
    | | Exposure Time | 0.5 ~ 24 ms | 0.524 ms | | |
    | | Field of View | 170° | 170° | 156° | |
    | | Image Sensor | CMOS | CMOS | CMOS | CMOS |
    | | Depth of Field | Length: 3cm | Length: 3cm | Length: 3cm | Length: 3cm |
    | | Enlargement
    Ratio | 1:8 | 1:8 | | |
    | | Detectable
    Range | Under 0.1mm | Under 0.1mm | At least 0.07mm | |
    | | Sampling Ratio | 6 frames per second (each
    3 frames per head) | 3 frames per second | 2 or 2
    6 frames per
    second | Up to 35 Frames per
    Second per head |
    | | Pixel size of
    Sensor | $6.0 \mu m6.0 \mu m$ | $6.0 \mu m6.0 \mu m$ | | |
    | | Working Time | 12 Hours | 12 Hours | Over 8 Hours | 10 Hours |
    | | Chemical Safety | Safe in pH=2 ~ pH=8 | Safe in pH=2 ~ pH=8 | Safe in pH=2 ~ pH=8 | Safe in pH=2 ~ pH=8 |
    | | Battery Type | Silver Oxide Cell | Silver Oxide Cell | Silver Oxide Cell | Silver Oxide Cell |
    | | Optimum
    working
    distance | 0mm | 0mm | | |
    | | Direction of
    View | 0° | 0° | | |
    | | Resolution | 320x320 | 320x320 | | |
    | | Distortion (%) | -14.5 | -14.5 | | |
    | | Lens Uniformity
    (%) | 79.39 | 79.39 | | |
    | | Shelf life | 12 months from date
    manufacture | 18 months from date
    manufacture | | 12 months from date
    manufacture |
    | | Operation Temp. | 20 ~ 40 ℃ | 20 ~ 40 ℃ | 20 ~ 40℃ | 20 ~ 40 ℃ |
    | | Storage Temp. | 0 ~ 50 ℃ | 050℃ | 0 ~ 25℃ | 030℃ |
    | | Transmission
    Methods | HBC (Human
    Communication) | HBC (Human Body
    Communication) | RF | RF |
    | Rece
    iver | Model Name | MR2000 | MR1100 | DR3 | DR3 |
    | | Recording Time | 12 Hours | 12 Hours | Up to 15 hours at LCD off | Up to 15 hours at LCD off |
    | | Weight | 330g (Include Battery) | 350g (Include Battery) | 500g (Include Battery
    Pack) | 500g (Include Battery
    Pack) |
    | | Operation
    Voltage | 3.65Vdc, 0.45A | 3.7Vdc, 0.45A | 3.54.2Vdc, 0.150.5A | 3.54.2Vdc, 0.150.5A |
    | | Battery Type | Lithium Ion Battery,
    3.65V, 10,500mA | Lithium Ion Battery,
    3.7V, 10,400mA | Lithium Ion Battery,
    3.8V, 8,800mAh | Lithium Ion Battery,
    3.8V, 8,800mAh |
    | | Operation Temp. | 0 ~ 40 ℃ | 040℃ | 0 ~ 40℃ | 0 ~ 40 ℃ |
    | | Storage Temp. | 0
    55℃ | 0 ~ 55 ℃ | 0 ~ 55 ℃ | 0 ~ 55 ℃ |
    | | Category | Internal power supply,
    Type BF | Internal power supply,
    Type BF | Internal power supply,
    Type BF | Internal power supply,
    Type BF |
    | | Real Time View | LCD | USB, Wifi | LCD | LCD |
    | | Method of Data
    Communication | Data Cable or Data Belt
    (Optional) | Data Cable or Data Belt
    (Optional) | Sensor Array or Sensor
    Belt | Sensor Array or Sensor
    Belt |
    | | Characteristics | IntroMedic Co., Ltd. | IntroMedic Co., Ltd. | Given Imaging Ltd. | Given Imaging Ltd. |
    | Soft
    ware | Software | MiroView™ U 4.0 | MiroView™ U 3.0
    MiroView™ RTV (Real
    Time Viewer
    Application-only USB)
    MiroView™ RTV-I
    (Real Time Viewer
    Application-only Wifi) | RAPID 8.0 | |
    | | Language | English,
    Portuguese, | Spanish, English,
    Danish, Portuguese,
    Chinese, French, Italian, Korean, Dutch, Russian,
    Swedish | English, French, German,
    Italian, Spanish,
    Portuguese, Dutch,
    Swedish, Finish, Danish,
    Chinese-Mandarin,
    Korean, Russian, Greek | |
    | | Data Export | JPEG Image, AVI Video
    Clip, PDF Report Data,
    ODF (Open Data
    Format),
    (Exchangeable Medical
    Information Format) | JPEG Image, AVI Video
    Clip, PDF Report Data,
    ODF (Open Data
    EXMIF Format),
    (Exchangeable Medical
    Information Format) | JPEG Images, (MPEG)
    Video clips, grml (Given
    Data proprietary) files, PDF
    EXMIF Reports, generic XML-
    format, Capsule
    Endoscopy report data | |
    | | Data Display | Single and Multi Image,
    Time Bar, Diagnosis
    Data, Dual Bar | Single and Multi Image,
    Time Bar, Diagnosis Data | Single and Multi Image,
    Time Bar, Colorbar with
    region specific color and
    other diagnostic data | |
    | | Event Marker | Small Image with
    Explanation | Small Image with
    Explanation | Annotated thumbnails with | |
    | | Display Ratio | 310,000fps | 310,000fps | 5~80fps | |
    | | Display Mode | Single View, Dual View,
    Quad View, Range View,
    Map View | Single View, Dual View,
    Quad View, Range View,
    Map View | Single View, Dual View,
    Quad View, Mosaic
    View, Dual Head View | |
    | | Running Mode | Normal Mode, Express,
    SGIB | Normal Mode, Express,
    SGIB | Normal, Auto, Quick
    View. SBI | |

8

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For the predicate device and the subject device, this has all the same performances except Receiver and Software.

[Capsule]

Subject device uses the same optical system as Capsule of Predicate device K143663. It means that this optical system uses the same parts as those of K143663 such as Sensor, LED, and Lens. However, the K143663 Capsule can only shoot in one direction, but the subject device can shoot in both directions. Two-way Capsule has the advantage of eliminating blind spots by two-way shooting because it has two identical optical systems compared to one-way Capsule. This is comparable to that of the Predicate device in terms of effectiveness. And this two-way Capsule endoscope system has the reference device, COLON 2, K123666. The COLON 2 is able to expand indications for use from diagnosis of colon to diagnosis of small bowel due to the advantages of bi-directional photography and increased frame number. The frame number of this submitted the subject device is smaller than that of the reference device and because it cannot prove the effectiveness of colon diagnosis, the reference device is limited to small bowel diagnosis. In addition, the subject device is smaller in size than the COLON 2 of the

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reference device K123666, which makes ease of ingestion easier.

And because two optical systems are used compared to K143663, Operating Time and Shelf Life can be different, and it is proved that there is no problem in operating time when using within the given period through Performance and Bench Test.

  • . Ease of device ingestion
    The size of MC2000-B is 30.1mm x Ø10.8mm. This is smaller than the 31.5mm x Ø11.6mm of the previously FDA clearance device COLON 2 (K123666). So ease of device ingestion of subject device is smaller than COLON 2 (K123666) and can be claimed to be easier to ingest.

The predicate device K143663 and the subject device are using the same sensor (ASPIN), LED and battery. However, the subject device has two image sensors in each head of the capsule and two sensors capture images alternately, so that the total current can be minimized. (See "Hand Shaking Mode for

Dual camera")

Hand Shaking Mode for Dual camera

ASPIN supports dual camera mode. One of the two chips is set to operate in Master mode by setting the SEL SAVE pin to "LOW" while another chip must be set to operate in Slave mode by setting the SEL SLAVE pin to "High". In Dual mode, the hand shaking operation is implemented using HAND1 pins. In Master mode, HAND0 operates as output and HAND1 operates as input. In slave mode the situation is opposite. Timing diagram is shown below.

    1. Master device EEPROM data read: time interval (1)
    1. Slave device EEPROM data read: time interval (2)
  • time interval (3) 3) Master dummy tx period:
    1. Slave dummy tx period:
  • time interval 4
  • time interval 5, 7 5) Master tx. Slave idle:
    1. Slave tx. Master idle: time interval 6, 8

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Image /page/11/Figure/1 description: The image shows a timing diagram with several signals, including HAND0, HAND1, SCL, SDA, LED0, SEL_SLAVE, TX, and pd. The diagram is divided into two sections, labeled "Master" and "Slave", each with its own set of signals. The HAND0 signal has numbered sections 1 through 8. The diagram illustrates the timing relationships between these signals in a master-slave communication scenario.

Figure 12-1_Hand Shaking Mode operation

Changing of battery voltage caused by LED connected with control resistance than entire battery voltage changes due to increase of LED resistance has no affect on image quality.

Image /page/11/Figure/4 description: The image shows two different LED module schematics. The first schematic is labeled "LED Module of MC1200-B" and shows a module with two current control resistors labeled R1 and R2, each with a value of 100. The second schematic is labeled "LED Module of MC2000-B" and shows two modules labeled "Master" and "Slave", each with two current control resistors labeled R2 and R3, each with a value of 150.

Figure 12-2_Comparison LED Module

For the MC1200-B, Auto Exposure time is used to adjust the LED turn-on time depending on the target brightness, which applies equally to the MC2000-B.

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AE (Auto Expose Control)

Depending on the sensor's incident light intensity, the AE function optimally adjusts the exposure time, thus preventing the over-exposure and low exposure situations. Namely, it calculates an average brightness of the image and, after checking the present state of the exposure, adjusts the exposure doze to make sure that the current average brightness converges to target brightness value by means of P-control. ASPIN adjusts the exposure time by adjusting the pixel control timing as well as LED ON-time. The unit step of exposure time adjustment is 1 PCLOCK period.

[Receiver]

The Human Body Communication (HBC) method is used on both Subject device and Predicate device (K143663). Even if. Subject device and Predicate device share same communication method, they have different way to display real time view (RTV). Predicate device displays RTV using another device such as laptop and tablet PC via USB or wifi connection, abd Subject device displays these RTV on LCD on the receiver, similar way to Predicate device (K123864).

Another difference, electro-mechanically can be found between K143663 and Subject device but we conducted Safety and EMC test to verifie both devices are safe.

[Software]

MiroView™ U 4.0 is a new version of MiroView U 3.0, which has new updated features from the MiroView™M U 3.0. The features are described below:

  • Compatibility with New Receiver MR2000: MiroView™ U 4.0 Operator -
  • UI Function for Receiving Patient Data of Dual Tip Capsule MC2000 Series: MiroView™ -U Client 4.0
  • -Support of H.264 Codec: MiroView™ U 4.0
  • Express Play 3.0: MiroView™ U Client 4.0 -
  • Supplementary Play: MiroView™ U Client 4.0 -

7. Performance Testing

The MiroCam® Capsule Endoscope System performance testing was done for the submission of predicate device but it was not included when Sensor Bench testing. MTF Measurement testing (including the predicate device, K143663), Minimum Distinguishable Contrast Value and Depth of Field testing (including the predicate device, K143663). Geometric distortion testing (including the predicate device. K143663). Field of View testing (including the predicate device, K143663), Color Reproduction testing (including the predicate device, K143663), Testing optical spectra of the light source at different

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time points during the battery life period (including the predicate device, K143663), Testing intensity change during the shelf life period (including the predicate device, K143663), Bite testing, Water proof testing, pH resistance testing, MR1100 (predicate device, K143663) and MR2000 (subject device) Equivalent Performance Comparison testing, and Shelf life testing (Operation time, Package integrity, pH resistance and Bite) was done. The results of this performance testing conclude that the material and technological characteristics have not diminished the safety and effectiveness of the IntroMedic Co., Ltd. MiroCam® Capsule Endoscope System device when compared to the predicate device.

8. Conclusion

Based on Indications for Use, Substantial Equivalence, Performance testing of the devices, IntroMedic Co., Ltd. believes that the MiroCam® Capsule Endoscope System and the predicate devices selected are substantially equivalent and do not raise new issues of safety or effectiveness.