K Number
K180336
Device Name
syngo.MR Applications
Date Cleared
2018-04-19

(71 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
syngo.MR Applications is a syngo based post-acquisition image processing software for viewing, manipulating, evaluating, and analyzing MR, MR-PET, CT, PET, CT-PET images and MR spectra.
Device Description
Applications are syngo svnao.MR based post-processing The software/applications to be used for viewing and evaluating MR images provided by a magnetic resonance diagnostic device and enabling structured evaluation of MR images. The syngo.MR Applications is a combination of eight (8) former separately cleared medical devices which are now handled as features / functionalities within syngo.MR Applications. These functionalities are combined unchanged compared to their former cleared descriptions; of course some minor enhancements and improvements are made. The syngo.MR Applications are syngo.via based MR data viewing, processing and reading software allowing MR image evaluation in a structured way and supporting convenient reading and / or evaluation of MR images and data.
More Information

Not Found

No
The document describes post-acquisition image processing software and lists predicate devices that are also post-processing software. There is no mention of AI, ML, or related concepts like training/test sets or performance metrics typically associated with AI/ML algorithms.

No
The device is a post-acquisition image processing software for viewing and analyzing medical images. It does not exert any direct therapeutic action on the patient.

Yes

The "Intended Use / Indications for Use" states that the software is for "evaluating, and analyzing MR, MR-PET, CT, PET, CT-PET images and MR spectra," which are activities consistent with diagnostic purposes. Additionally, the "Device Description" mentions that the software is to be used for "viewing and evaluating MR images provided by a magnetic resonance diagnostic device and enabling structured evaluation of MR images."

Yes

The device description explicitly states it is "software/applications" for post-acquisition image processing and evaluation of medical images. It does not mention any accompanying hardware components.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The description clearly states that syngo.MR Applications is a post-acquisition image processing software for viewing, manipulating, evaluating, and analyzing medical images (MR, MR-PET, CT, PET, CT-PET) and MR spectra. It works with images already acquired from a diagnostic device.
  • No Mention of Biological Samples: There is no mention of the device analyzing biological samples from the human body. Its input is imaging data.

Therefore, while it's a medical device used in the diagnostic process, it does not fit the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

syngo.MR Applications is a syngo based post-acquisition image processing software for viewing, manipulating, evaluating, and analyzing MR, MR-PET, CT, PET, CT-PET images and MR spectra.

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

LLZ, LNH

Device Description

syngo.MR Applications are syngo based post-processing software/applications to be used for viewing and evaluating MR images provided by a magnetic resonance diagnostic device and enabling structured evaluation of MR images. The syngo.MR Applications is a combination of eight (8) former separately cleared medical devices which are now handled as features / functionalities within syngo.MR Applications. These functionalities are combined unchanged compared to their former cleared descriptions; of course some minor enhancements and improvements are made. The syngo.MR Applications are syngo.via based MR data viewing, processing and reading software allowing MR image evaluation in a structured way and supporting convenient reading and / or evaluation of MR images and data.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

MR, MR-PET, CT, PET, CT-PET

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Healthcare professionals

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)

Not Found

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.

K163294, K151353, K120315, K130749, K133401

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.

Not Found

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

§ 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).

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Siemens Medical Solutions USA, Inc. % Cordell L. Fields, Esq. Regulatory Affairs Technical Specialist 40 Liberty Boulevard, Mailcode 65-1A MALVERN PA 19355

April 19, 2018

Re: K180336

Trade/Device Name: syngo.MR Applications Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ LNH Dated: February 6, 2018 Received: February 7, 2018

Dear Mr. Fields:

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 (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

1

(1-800-638-2041 or 301-796-7100).

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

Sincerely,

Michael D. O'Hara For

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

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES

Indications for Use

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

510(k) Number (if known)K180336
Device Namesyngo.MR Applications
Indications for Use (Describe)syngo.MR Applications is a syngo based post-acquisition image processing software for viewing, manipulating, evaluating, and analyzing MR, MR-PET, CT, PET, CT-PET images and MR spectra.
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."

Traditional 510(k) Premarket Notification for: syngo.MR Applications VB30

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Section 5 510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of Safe Medical Device Act 1990 and 21 CFR § 807.92.

Date of Summary Preparation: February 06, 2018

I. General Information

| Importer / Distributor: | Siemens Medical Solutions USA, Inc.
40 Liberty Boulevard
Mailcode: 65-1A
Malvern, PA 19355 |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Registration Number: | 2240869 |
| Manufacturer: | Siemens Healthcare GmbH
Henkestr. 127
D-91052 Erlangen, Germany |
| Registration Number: | 3002808157 |
| Contact Person: | Cordell L. Fields, Esq.
Regulatory Affairs Technical Specialist
Siemens Medical Solutions USA, Inc.
65 Valley Stream Pkwy
Mail Code 65-1A
Malvern, PA 19355, USA
Phone: (610) 448-6469
Fax: (610) 427-3465
Email: cordell.fields@siemens-healthineers.com |

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Device Name and Classification

DataDetails
Trade name /
Device
Proprietary
Name:syngo.MR Applications
It covers single and engine applications:
• syngo.MR General
○ syngo.MR Reading
○ syngo.MR General Routine
○ syngo.MR Cardiac Reader
○ syngo.MR Composing
○ syngo.MR General Engine2
• syngo.MR Cardiology
○ syngo.MR Cardiac 4D Ventricular
Function
○ syngo.MR Cardiac Flow
○ syngo.MR Cardio Engine
• syngo.MR Neurology
○ syngo.MR Neuro Perfusion
○ syngo.MR Neuro Perfusion Mismatch
○ syngo.MR Neuro fMRI
○ syngo.MR Tractography
○ syngo.MR Neuro Perfusion Engine
○ syngo.MR Neuro 3D Engine
• syngo.MR Oncology
○ syngo.MR Onco
○ syngo.MR 3D Lesion Segmentation
○ syngo.MR Tissue4D
○ syngo.MR Onco Engine
○ syngo.MR Onco Engine Pro
○ syngo.MR OncoCare
• syngo.BreVis
• syngo.mMR General
• syngo.MR Spectroscopy
○ syngo.MR Spectro SVS
○ syngo.MR Spectro CSI
○ syngo.MR Spectro Extension
• syngo.MR Vascular
○ syngo.MR Vascular Analysis
Classification
Name:Regulation Description:
Picture Archiving and Communication System (PACS)

2 syngo.MR General Engine is the precondition for all other, advanced MR post-processing applications and engines

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DataDetails
Classification
Panel:Radiology
Device
Classification:Class II devices
Regulation
number:21 CFR § 892.2050
Product Code:Primary: LLZ, Secondary: LNH
DataDetails
Trade name /
Device
Proprietary
Name:syngo.MR Applications
It covers single and engine applications:
syngo.MR General syngo.MR Reading syngo.MR General Routine syngo.MR Cardiac Reader syngo.MR Composing syngo.MR General Engine syngo.MR Cardiology syngo.MR Cardiac 4D Ventricular Function syngo.MR Cardiac Flow syngo.MR Cardio Engine syngo.MR Neurology syngo.MR Neuro Perfusion syngo.MR Neuro Perfusion Mismatch syngo.MR Neuro fMRI syngo.MR Tractography syngo.MR Neuro Perfusion Engine syngo.MR Neuro 3D Engine syngo.MR Oncology syngo.MR Onco syngo.MR 3D Lesion Segmentation syngo.MR Tissue4D syngo.MR Onco Engine syngo.MR Onco Engine Pro syngo.MR OncoCare syngo.BreVis syngo.mMR General syngo.MR Spectroscopy

Traditional 510(k) Premarket Notification for: syngo.MR Applications VB30

February 06, 2018

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DataDetails
syngo.MR Spectro SVS syngo.MR Spectro CSI syngo.MR Spectro Extension syngo.MR Vascular syngo.MR Vascular Analysis
Single functionalities
and enginesDescription
syngo.MR General
syngo.MR ReadingEnables reading of 2D, 3D, and 4D MR data.
Includes:
• Basic workflow
• Workflow customization
• Follow-up support
• Rescan handling
Context-specific reporting
syngo.MR General
RoutineIt extends syngo.via by adding dedicated worflows and tools for routine
and advanced reading of MR examinations. Several workflows are
provided like MR Neurology, MR Prostate Reading, MR Breast
Reading, and MR Cardio-Vascular Reading workflows.
syngo.MR General Routine provides several MR Evaluation tools:
Subtraction, MeanCurve, Image Filter, 2D/3D Distortion Correction.
ADC and b-value tool (for extrapolated b-values), Multiplication,
Division, Addition, Elastic Motion Correction.Workflow optimized report
templates.
syngo.MR Cardiac
ReaderWith syngo.MR Cardiac Reader the Cardiac Reading step within the
Cardiac Analysis Workflow is provided. The Cardiac Reading enables
viewing and evaluating different kinds of cardiac images using the
common tools.
syngo.MR Composingsyngo.MR Composing is a dedicated offline application for creation of
full-format images from overlapping MR volume data sets acquired at
multiple stages. It can be used to compose images in any of the other
workflows.
syngo.MR General
Engine4syngo.MR General Engine contains:
• syngo.MR General Routine
• syngo.MR Cardiac Reader
syngo.MR General Engine is the precondition for all other, advanced
MR post-processing applications and Engines.
syngo.MR Cardiology
syngo.MR Cardiac 4D
Ventricular Functionsyngo.MR Cardiac 4D Ventricular Function processes MR cine images
of the heart which enables users to generates quantitative results for
physicians in the diagnostic process. The MR cardiac interactive
reporting template is included.
Single functionalities
and enginesDescription
syngo.MR Cardiac
FlowProcesses velocity-encoded MR images to evaluate blood flow
dynamics e.g. in the heart and the great vessels. The application
generates quantitative results for physicians in the diagnostic process.
The MR cardiac interactive reporting template is included.
syngo.MR Cardio
Enginesyngo.MR Cardio Engine contains:
syngo.MR Cardiac 4D Ventricular Function syngo.MR Cardiac Flow
syngo.MR Neurology
syngo.MR Neuro
Perfusion5Extends the MR Neurology workflow with advanced processing tools
for the analysis of brain perfusion datasets and allows the
assessment and evaluation of various spots of cerebral lesions.
syngo.MR Neuro
Perfusion MismatchExtends the assessment of brain perfusion datasets with calculation of
mismatch area and mismatch ratio between two different contrasts (for
example diffusion and perfusion) to support therapy decisions.
syngo.MR Neuro fMRIA workflow oriented visualization package for BOLD fMRI. It enables
the visualization of task-related areas of activation overlayed onto 2D
or 3D anatomical datasets, providing the spatial correspondence of
BOLD results with cortical landmarks or brain lesions. Image-based
registration and multi-contrast evaluation are also available. Functional
and anatomical image data can be exported for surgical planning as
DICOM datasets.
syngo.MR
TractographyEnables the representation of diffusion paths of the human brain
based on diffusion tensor imaging. syngo.MR Tractography supports
surgery planning and is suitable for neurophysiological research in
relation to cortical networking and pathologies of the white matter.
syngo.MR Neuro
Perfusion Enginesyngo.MR Neuro Perfusion Engine contains:
syngo.MR Neuro Perfusion syngo.MR Neuro Perfusion Mismatch
syngo.MR Neuro 3D
Enginesyngo.MR Neuro 3D Engine contains:
syngo.MR Neuro fMRI syngo.MR Tractography
syngo.MR Oncology
syngo.MR OncoAn image viewing, processing and reading software that allows for
oncological MR image evaluation in a structured way.
Single functionalities
and enginesDescription
syngo.MR 3D Lesion
SegmentationProvides convenient volumetric evaluation of lesions and/or other
structure of interest as well as particularly useful tools for oncology
applications.
syngo.MR Tissue4DA post-processing workflow which supports the physician in reading of
dynamic contrast-enhanced MR data sets.
syngo.MR OncoCareEnables the physician to evaluate signal intensities in segmented
regions of interest with the help of histograms and color maps as well
as evaluation the change of time in typical lesion parameters like
diameter or volume (trending).
syngo.MR Onco
Enginesyngo.MR Onco Engine contains:
• syngo.MR Onco
• syngo.MR 3D Lesion Segmentation
syngo.MR Onco
Engine Prosyngo.MR Onco Engine Pro contains:
• syngo.MR Onco Engine
• syngo.MR OncoCare
syngo.MR BreVisA software package intended for use in viewing and analyzing
magnetic resonance imaging (MRI) studies.
syngo.mMR GeneralA syngo based post-processing software for viewing, manipulating and
evaluating MR, PET and MR-PET images.
syngo.MR Spectroscopy
syngo.MR Spectro
SVSProvides evaluation of MR Single Voxel Spectroscopy (SVS) data with
comprehensive workflow guidance.
syngo.MR Spectro CSIProvides evaluation of MR Chemical Shift Imaging (CSI) data with
comprehensive workflow guidance. syngo.MR Spectro CSI includes
the possibility of an integrated reading of MR images and CSI
spectroscopy data for prostate exams.
syngo.MR Spectro
ExtensionProvides access to advanced parameters, which allow the advanced
user to configure the post processing and display of spectro results
according to his / her personal needs. Both Single Voxel Spectroscopy
(SVS) and Chemical Shift Imaging (CSI) data are supported.
syngo.MR Vascular
syngo.MR Vascular
AnalysisEnables assessment / quantification of general vascular pathologies.

II. Safety and Effectiveness Information Supporting Substantial Equivalence

Intended Use

"syngo.MR Applications is a syngo based post-acquisition image processing software for viewing, manipulating, evaluating, and analyzing MR, MR-PET, CT, PET, CT-PET images and MR spectra."

Device Description

Applications are syngo svnao.MR based post-processing The software/applications to be used for viewing and evaluating MR images provided by a magnetic resonance diagnostic device and enabling structured evaluation of MR images.

The syngo.MR Applications is a combination of eight (8) former separately cleared medical devices which are now handled as features / functionalities within syngo.MR Applications.

These functionalities are combined unchanged compared to their former cleared descriptions; of course some minor enhancements and improvements are made. The syngo.MR Applications are syngo.via based MR data viewing, processing and reading software allowing MR image evaluation in a structured way and supporting convenient reading and / or evaluation of MR images and data.

3 While viewing (i.e. assessing) of images from other vendors is always possible; for advanced post-processing applications, some of the post-processing steps may depend on information contained in private DICOM tags ,therefore evaluation and processing of images can't be guaranteed for other vendors.

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The table below shows the functionalities of the syngo.MR Applications:

4 syngo.MR General Engine is the precondition for all other, advanced MR post-processing applications and engines

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§ The application syngo.MR Neuro Dynamics described in K151353 (and cleared August 07, 2015) is only available within syngo.MR Neuro Perfusion (neurospecific Mean Curve Tool), but no longer as single application. The syngo.MR Neuro Perfusion Engine Pro, described in K151353 (and cleared August 07, 2015), is therefore obsolete within SMRVB20, as all applications are already part of syngo.MR Neuro Perfusion Engine.

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Traditional 510(k) Premarket Notification for: syngo.MR Applications VB30

February 06, 2018

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Except for the new product composition, there are some minor improvements and enhancements of the existing functionalities within the syngo.MR Applications.

Cardiac / Angio improvements:

  • Improved functional analysis in the MR Cardiac Analysis workflow: ●
    • o Mode for manual segmentation of the LV and RV
    • o Pen tool for improved editing of LV and RV contours
    • o Result values can be exported as text file
    • o LV and RV contours can be saved and restored
  • The workflows MR Angio SingleStation, MultiStation, TWIST and . TimCT are consolidated into the new workflow MR Angiography

Additional minor improvements:

  • 4D Navigation Toolbar ●
    • o Mini-Toolbar for 4D navigation
    • o Display of clinical phase labels
    • o Easy navigation in mulit-phase data
  • Freehand ROI for seed selection in Tractography ●
  • Series Navigator: series numbers now displayed ●
  • ADC / computed b-values: now as pre-processing ●
  • Tissue4D Maps: color-bar added to image segment ●
  • Median added to histogram statistics ●
  • Relative frequency added to histogram ●
  • Color-bar added to image segment (LUT) .
  • Wild card for series description ●
  • Organ specific workflow .

General Safety and Effectiveness Concerns

The device labeling contains instructions for use and any necessary cautions and warnings, to provide for safe and effective use of the device.

Risk Management is ensured via a Risk Analysis in compliance with ISO 14971:2007 to identify and provide mitigation to potential hazards in a Risk Analysis beginning early in the design phase and continuing throughout the development of the product. These risks are controlled via measures realized in software development. SW testing and product labeling. To minimize risks, Siemens adheres to recognized and established industry practices and standards. Furthermore, the operators are healthcare professionals familiar with and responsible for the evaluating and post-processing of MR images.

syngo.MR Applications conform to the applicable FDA recognized and international IEC, ISO and NEMA standards with regards to performance and safety as recommended by the respective MR FDA Guidance Document.

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Rec.- No.Product AreaTitle of StandardRef.- No. & DateStandards Development Organization
5-96GeneralMedical devices -
Application of usability
engineering to medical
devices62366-1:2015AAMI ANSI
IEC
5-40GeneralMedical devices - application of
risk management to medical
devices14971:2007ISO
13-32SoftwareMedical device software -
Software life cycle
processes62304:2006AAMI ANSI
IEC
12-300RadiologyDigital Imaging and
Communications in
Medicine (DICOM) Set PS
3.1-3.20 (2011)PS 3.1 -
3.20 (2016)NEMA

The standards conformed to are the following:

Substantial Equivalence

The syngo.MR Applications VB30 has a different Intended Use as compared to the predicate devices. This is the result of the new product setup of combining the former eight (8) medical devices into one (1) device. However, the main functionalities of the former separate medical devices are used unchanged for syngo.MR Applications VB30, except for the aforementioned minor enhancements and improvements. The conclusions from the non-clinical data suggest that the additional features bear an equivalent safety and performance profile as that of the predicate devices and also does not affect the Indications for use of it. Therefore syngo.MR Applications are considered to be substantially equivalent to their primary predicate devices, which are current legally marketed devices.

Table 1: Predicate devices for syngo.MR Applications
--------------------------------------------------------
Predicate DeviceFDA ClearanceProduct Code
syngo.MR Post-Processing
Software Version SMRVB20AK163294
cleared February 6, 2017LLZ, LNH
syngo.MR Post-Processing
Software Version SMRVB10AK151353
cleared August 1, 2015LLZ,LNH
syngo.MR SpectroscopyK120315
cleared April 13, 2012LLZ
syngo.MR Post-Processing
Software Version SMRVA16AK130749
cleared August 20, 2013LLZ,LNH
syngo.MR Post-Processing
Software Version SMRVA16BK133401
cleared March 11, 2014LLZ,LNH

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Conclusion as to Substantial Equivalence

The syngo.MR Applications are intended for similar indications as cleared in their according primary predicate devices.

In summary, Siemens is of the opinion that the syngo.MR Applications do not raise new questions of safety or effectiveness and are substantially equivalent to the currently marketed primary predicate devices as shown in Table 1.

Resulting from the new product setup of combining the eight (8) formerly cleared separate medical devices to one (1) medical device, the Intended Use changed. However, the main functionalities of the former devices will remain unchanged except for minor improvements and enhancements to give the device greater capabilities.

Therefore, Siemens believes that the subject device, the syngo.MR Applications is substantially equivalent to their primary predicate devices listed above in Table 1.