K Number
K172490
Device Name
eUnity
Date Cleared
2018-02-06

(173 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
eUnity is a software application that displays medical image data and associated clinical reports to aid in diagnosis for healthcare professionals. It performs operations relating to the transfer, storage, display, and measurement of image data. eUnity allows users to perform image manipulations, including window/level, rotation, measurement and markup. eUnity provides 2D display, Multi-Planar Reformating and 3D visualization of medical image data, and mobile access to images. eUnity displays both lossless and lossy compressed images. For lossy images, the medical professional user must determine if the level of loss is acceptable for their purposes. Display monitors or mobile devices used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance. For mobile diagnostic usage when a full workstation is not available. Mobile usage for mammography is for reference and referral only.
Device Description
Client Outlook has developed eUnity to load, display and manipulate medical (DICOM) images within a web-browser without installing client software. eUnity is a server-based software solution that extends common web-browsers on the most popular operating systems into medical review stations; removing a technical barrier that had long been a key contributor to poor medical image access. eUnity is an enterprise medical image viewer that provides access to full quality images from anywhere using nothing more than a standard web browser. Combined with a calibrated monitor, it can be used to make diagnostic decisions. Secure, fast, immediate access to information means less time spent searching for specialized workstations and supports greater efficiency for care, greater collaboration, and faster turnaround times. This device is the successor to eUnity predicate (K161515) and adds the following functionality: MIP/MPR/3D and Mobile Diagnostic Use.
More Information

No
The summary describes a medical image viewer with standard image manipulation and display features. There is no mention of AI, ML, or any functionality that would typically involve these technologies for image analysis or interpretation.

No
The device aids in diagnosis by displaying and manipulating medical images, it does not provide any treatment or therapy.

Yes

The "Intended Use / Indications for Use" section states that eUnity "aids in diagnosis for healthcare professionals." Additionally, the "Device Description" mentions that when combined with a calibrated monitor, it "can be used to make diagnostic decisions."

Yes

The device is described as a "software application" and a "server-based software solution" that operates within a web-browser. While it relies on external hardware (display monitors, mobile devices), the device itself is the software that performs the image processing, display, and manipulation functions. The description focuses solely on the software's capabilities and does not mention any accompanying hardware components provided by the manufacturer.

Based on the provided information, no, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that eUnity is a software application that displays medical image data and associated clinical reports to aid in diagnosis for healthcare professionals. It focuses on the display, manipulation, and access of medical images.
  • Device Description: The description reinforces this by stating it's an "enterprise medical image viewer" used to "load, display and manipulate medical (DICOM) images." It emphasizes providing access to images for diagnostic decisions when combined with a calibrated monitor.
  • Lack of Biological Sample Analysis: IVD devices are specifically designed to perform tests on biological samples (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. eUnity does not interact with or analyze biological samples. Its input is medical image data.

While eUnity is a medical device used in the diagnostic process, it falls under the category of medical image processing and display software, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

eUnity is a software application that displays medical image data and associated clinical reports to aid in diagnosis for healthcare professionals. It performs operations relating to the transfer, storage, display, and measurement of image data.

eUnity allows users to perform image manipulations, including window/level, rotation, measurement and markup. eUnity provides 2D display, Multi-Planar Reformating and 3D visualization of medical image data, and mobile access to images.

eUnity displays both lossless and lossy compressed images. For lossy images, the medical professional user must determine if the level of loss is acceptable for their purposes. Display monitors or mobile devices used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance. For mobile diagnostic usage when a full workstation is not available.

Mobile usage for mammography is for reference and referral only.

Product codes

LLZ

Device Description

Client Outlook has developed eUnity to load, display and manipulate medical (DICOM) images within a web-browser without installing client software. eUnity is a server-based software solution that extends common web-browsers on the most popular operating systems into medical review stations; removing a technical barrier that had long been a key contributor to poor medical image access.

eUnity is an enterprise medical image viewer that provides access to full quality images from anywhere using nothing more than a standard web browser. Combined with a calibrated monitor, it can be used to make diagnostic decisions. Secure, fast, immediate access to information means less time spent searching for specialized workstations and supports greater efficiency for care, greater collaboration, and faster turnaround times.

This device is the successor to eUnity predicate (K161515) and adds the following functionality: MIP/MPR/3D and Mobile Diagnostic Use.

The following devices are validated for use with eUnity for Mobile:

iPhone version 6 and higher versions, iPad Mini and higher versions, iPad pro and higher versions, Samsung Galaxy Note 5 and higher versions, and Samsung Galaxy Tab E and higher versions.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CR, CT, DX, ECG, MR, MG, NM, OP, PR, PT, RF, SC, SR, US, XA, VL

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

healthcare professionals/Diagnostic Quality

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)

Verification testing executed by multiple team members included functional, smoke and regression tests and was complimented by beta tests performed by Client Outlook partners and Validation in test systems at customer sites.

Additional Clinical Validation testing based on typical clinical workflows was performed by trained radiologists in comparison with an existing device and on several different hardware devices. There was consensus among all the Radiologists that the same diagnosis would be made on the mobile device with eUnity as on the predicate device in various lighting conditions.

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

Not Found

Predicate Device(s)

K161515

Reference Device(s)

K161130, K151774

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.2050 Medical image management and processing system.

(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. Underneath the square are the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Client Outlook Inc. Christie Eby Director of Operations & Quality 103 Bauer Place. Suite #3 Waterloo, ON N2T 2V2 CANADA

February 6, 2018

Re: K172490

Trade/Device Name: eUnity Regulation Number: 21 CFR 892.2050 Regulation Name: Picture Archiving And Communications System Regulatory Class: Class II Product Code: LLZ Dated: January 2, 2018 Received: January 4, 2018

Dear Christie Eby:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting 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);

1

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,

Sincerely,

Michael D. O'Hara For

Robert A. Ochs. Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known) K172490

Device Name eUnity

Indications for Use (Describe)

eUnity is a software application that displays medical image data and associated clinical reports to aid in diagnosis for healthcare professionals. It performs operations relating to the transfer, storage, display, and measurement of image data.

eUnity allows users to perform image manipulations, including window/level, rotation, measurement and markup. eUnity provides 2D display, Multi-Planar Reformating and 3D visualization of medical image data, and mobile access to images.

eUnity displays both lossless and lossy compressed images. For lossy images, the medical professional user must determine if the level of loss is acceptable for their purposes. Display monitors or mobile devices used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance. For mobile diagnostic usage when a full workstation is not available.

Mobile usage for mammography is for reference and referral only.

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 needed and complete
and review the collection of information. Send comments regarding this burden estimate or any other aspect
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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This 510(k) summary is submitted in accordance with the requirements of 21 CFR Part 807.92(c)

Basis for the submission:Client Outlook hereby submits this traditional 510(k) submission for eUnity software which is substantially equivalent to the FDA cleared previous version of eUnity Software (K161515)
Submitter:Client Outlook Inc.
103 Bauer Place, Suite #3
Waterloo, Ontario
Canada N2L 6B5
Date:August 14, 2017
Establishment Registration:3009601121
Contact:Christie Eby, Director of Operations & Quality
Tel: 519-342-3049 x206
Fax: 519-725-2351
Trade Name:eUnity
Common Name:Medical Image Processing Software
Classification:Picture Archiving and Communications Software (PACS)
Product Code:LLZ
Device Class:Class II
Regulation #:21 CFR 892.2050
Device Panel:Radiology

Predicate Devices:

Trade Name510 (k) Submitter/ Manufacturer510 (k) number
eUnityClient Outlook Inc.K161515

Reference Predicate Devices:

Trade Name510 (k) Submitter/ Manufacturer510 (k) number
Resolution MDCalgary ScientificK161130
Vue MotionCarestreamK151774

Device Description:

Client Outlook has developed eUnity to load, display and manipulate medical (DICOM) images within a web-browser without installing client software. eUnity is a server-based software solution that extends common web-browsers on the most popular operating systems into medical review stations; removing a technical barrier that had long been a key contributor to poor medical image access.

eUnity is an enterprise medical image viewer that provides access to full quality images from anywhere using nothing more than a standard web browser. Combined with a calibrated monitor, it can be used to make diagnostic decisions. Secure, fast, immediate access to information means less time spent

4

searching for specialized workstations and supports greater efficiency for care, greater collaboration, and faster turnaround times.

This device is the successor to eUnity predicate (K161515) and adds the following functionality: MIP/MPR/3D and Mobile Diagnostic Use.

The following devices are validated for use with eUnity for Mobile:

iPhone version 6 and higher versions, iPad Mini and higher versions, iPad pro and higher versions, Samsung Galaxy Note 5 and higher versions, and Samsung Galaxy Tab E and higher versions.

Intended Use:

Client Outlook's eUnity enables health professionals to access, manipulate and collaborate real-time over full quality medical images using any web-browser without installing client software. eUnity is a server-based solution that connects to any PACS and displays DICOM images within the hospital, securely from remote locations, or as an integrated part of an EHR or portal. eUnity offers diagnostic quality images with the performance of installed PACS viewing software.

Indications for Use:

eUnity is a software application that displays medical image data and associated clinical reports to aid in diagnosis for healthcare professionals. It performs operations relating to the transfer, storage, display, and measurement of image data.

eUnity allows users to perform image manipulations, including window/level, rotation, measurement and markup.

eUnity provides 2D display, Multi-Planar Reformatting and 3D visualization of medical image data, and mobile access to images.

eUnity displays both lossless and lossy compressed images. For lossy images, the medical professional user must determine if the level of loss is acceptable for their purposes. Display monitors or mobile devices used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance. For Mobile diagnostic usage only when a full workstation is not available.

Mobile usage for mammography is for reference and referral only.

Patient Interaction:

eUnity is a software device that handles medical images. It does not contact the patient, nor control any life sustaining devices. Prior to any medical decisions, a licensed medical practitioner reviews the output, providing ample opportunity for competent human intervention for the interpretation of images and information being displayed.

Client Outlook Inc. - eUnity 510(k) Summary - Section 5

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Comparison to predicate devices CHART:

System, Image Processing, Radiological
CategoryClient Outlook
'eUnity'A)Predicate
Client Outlook
'eUnity'B)Calgary
Scientific
ResolutionMD
MobileC)Carestream
Vue Motion
510KK161515K133508K151774
ClassClass IIClass IIClass IIClass II
Intended Use - for full descriptions - see appendices
Intended UseDiagnostic
QualityDiagnostic
QualityDiagnostic
QualityDiagnostic Quality
User Install
RequirementsThin Client - no
install, runs
within browserThin Client - no
install, runs
within browserThin Client - no
install, runs within
browserThin Client - no
install, runs within
browser
CommunicationsDICOM, IHE,
Non-DICOMDICOM, IHEDICOM, Non-
DICOMDICOM, Non-
DICOM
ModalitiesCR, CT, DX,
ECG, MR, MG,
NM, OP, PR,
PT, RF, SC,
SR, US, XA, VLCR, CT, DX,
ECG, MR, MG,
NM, OP, PR,
PT, RF, SC,
SR, US, XA, VLCT, MR, CR, DX,
ES, KO, NM, OP,
OT, PT, SC, US,
XA, IO, XC,
RTIMAGE, OPT,
SR, RFCR, DR, CT, MR,
NM, ECG, US
Tools
Window Level,
Rotate/Pan/Zoom,
Reset, Presets,
Invertyesyesyesyes
Multi-Study
viewing, Image
printing, Report
Printing, Image
Exportyesyesyesyes
Metadata
display/hideyesyesyesyes
Orientation
labels,
Keyboard
shortcuts,yesyesyesyes
Measurement
tools, Annotation
tools (Line,
Arrow, Polygon,
Freehand, Text)yesyesyesyes
Full-screen
mode,
Collaboration,
Multimonitor,
Linking Series,
Revert to
Original, Image
Sharing,
Triangulation,
Image scrolling,
Layouts, Linked
scrolling,
Reference lines,
Image flip and
rotate, Image
measurements,yesyesyesyes
Grayscale
softcopy
presentation
states (GSPS)yesyesyesyes
KINyesyesyesyes
Mag lensyesyesyesyes
MIP/MPR/3D Features:
Multi-Planar
reformat (MPR)yesnoyesyes
Maximum
Intensity
Projection (MPR)yesnoyesyes
Oblique and
double-oblique
reformat,
Triangulate,
Rotateyesnoyesyes
3D Volume,
orientation
widget,
Opacity preset,
Scalpel Tool,
Bone Removalyesnoyesyes
Mobile Specific Features:
Mobile
Luminance
Check(test to be
performed by
user to determine
lighting
conditions prior
to diagnosis)yesnoyesyes
Security
Data EncryptionHTTPSHTTPSHTTPSHTTPS
Data SecurityStored on
ServerStored on
ServerStored on ServerStored on Server
Access ControlCan either use
built in access
control or when
launched from
parent
application canCan either use
built in access
control or when
launched from
parent
application canCan either use
built in access
control or when
launched from
parent applicationCan either use
built in access
control or when
launched from
parent application
Client Outlook™
Inc.510(k) Summary Document – eUnity TMApproved
utilize its
access controlutilize its
access controlcan utilize its
access controlcan utilize its
access control

6

Approved

7

8

Summary of Testing and conclusion

As required by the Risk Analysis, designated individuals performed all verification and validation activities and results demonstrated that the device meets its design requirements and intended use, and that it is safe and effective. Verification testing executed by multiple team members included functional, smoke and regression tests and was complimented by beta tests performed by Client Outlook partners and Validation in test systems at customer sites.

Additional Clinical Validation testing based on typical clinical workflows was performed by trained radiologists in comparison with an existing device and on several different hardware devices. Refer to the Validation Summaries in Section 12 for additional information. There was consensus among all the Radiologists that the same diagnosis would be made on the mobile device with eUnity as on the predicate device in various lighting conditions.

Conclusion:

The Intended use and technological characteristics of the Client Outlook eUnity software are substantially equivalent, in our opinion, to those of the predicate device and reference devices and do not pose any new issues of safety and effectiveness. The device and the predicates are post-processing and provide the same or similar essential features of visualization of radiological data on mobile devices.

The modified eUnity device offers the same functionality as the K161515 eUnity device with the addition of the Mobile enhanced capabilities and 3D viewing capabilities that are found in the Reference Predicate device.