K Number
K180867
Device Name
AmCAD-UO
Date Cleared
2018-12-28

(270 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to support visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state.
Device Description
AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state. The generated information by AmCAD-UO software device must not be used alone for primary diagnostic interpretation.
More Information

Not Found

No
The summary describes image analysis software with manual or interactive tools for quantification, but does not mention AI, ML, or any related concepts like deep learning or neural networks. The performance studies focus on verification, validation against phantom images, and comparison to MRI measurements, without mentioning training or testing of an AI/ML model.

No.
This device is an image analysis software used for evaluation and monitoring; it does not directly treat or provide therapy.

No

The device description explicitly states: "The generated information by AmCAD-UO software device must not be used alone for primary diagnostic interpretation." This indicates it's intended to support, rather than independently diagnose.

Yes

The device is described as a "PC-based, self-contained, non-invasive image analysis software application" that processes images acquired from an FDA-cleared ultrasound system. It does not include the ultrasound hardware itself.

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

Here's why:

  • IVDs analyze specimens from the human body. The definition of an IVD involves examining specimens such as blood, urine, tissue, etc., outside of the body to provide information about a person's health.
  • AmCAD-UO analyzes medical images. The device processes and analyzes ultrasound images acquired directly from the patient's pharyngeal/upper airway. This is an in-vivo (within the living body) imaging modality, not an in-vitro (in glass/outside the body) analysis of a specimen.
  • The intended use is image analysis and visualization. The description clearly states the software is for "reviewing the pharyngeal/upper airway ultrasonic image," "support visualization and quantification of the airway sonographic characteristics," and "analysis of the airway in terms of its size, position and enhancement pattern." These are all related to interpreting medical images.

Therefore, AmCAD-UO falls under the category of medical image analysis software, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to support visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state.

Product codes

LLZ

Device Description

AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state. The generated information by AmCAD-UO software device must not be used alone for primary diagnostic interpretation.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

B-mode dynamic ultrasound image

Anatomical Site

pharyngeal/upper airway

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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

AmCad BioMed Corporation has conducted the software verification testing and performance validation testing to evaluate the safety and effectiveness of AmCAD-UO and to validate the performance of the AmCAD-UO for its intended use. The software verification testing, including software unit test, software integration test, and software system test, was performed to ensure that AmCAD-UO meets all functional and specifications for its indication for use. Phantom images were created to verify the accuracy of the region of interest (ROI) identification and the quantification of the airspace characteristics by the software under allowable ranges of parameter settings. AmCAD-UO performance was also validated through clinical assessment with a very limited sample size of human subjects. Comparison was performed against MRI measurements. It was found that the two measurement methods exhibit a significant correlation, i.e., a larger airway width measured in one method should be also observed larger in the other method. However, we are not able to conclude from the study, due to the small sample size and the systematic difference between the two imaging modalities, that the two measurement methods fully agree with each other.

Key Metrics

Not Found

Predicate Device(s)

K141745

Reference Device(s)

Not Found

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).

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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. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 28, 2018

AmCad BioMed Corporation % Chiu Lin President Lin & Associates, LLC 5614 Johnson Ave BETHESDA, MD 20817

Re: K180867

Trade/Device Name: AmCAD-UO Regulation Number: 21 CFR 892.2050 Regulation Name: Picture Archiving And Communications System Regulatory Class: Class II Product Code: LLZ Dated: November 23, 2018 Received: November 28, 2018

Dear Chiu Lin:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

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

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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,

Hole 2. Nils

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

510(k) Number (if known) K180867

Device Name AmCAD-UO

Indications for Use (Describe)

AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to support visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state.

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)
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Image /page/3/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "A" with a "C" inside. Below the logo is the company name in both Chinese and English. The address is listed as FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, and the telephone number is +886-2-27136227, while the fax number is +886-2-27152181.

K180867

510(k) Summary of Safety and Effectiveness

This 510(k) summary of safety and effectiveness information is submitted as part of the Premarket Notification in compliance with requirements of CFR Part 807, Subpart E and Section 807.92

5.1 Identification of Submitter:

Submitter:AmCad BioMed Corporation
Address:FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, R.O.C.
Phone:886-2-2713-6227
Fax:886-2-2715-2181
Contact:Jack Yang
Title:Vice President
Phone:886-2-2713-6227 ext.2358
Fax:886-2-2715-2181
Email:jack.yang@amcad.com.tw
Manufacturer:AmCad BioMed Corporation
US Agent and Contact:Chiu S. Lin, Ph.D.
Lin & Associates, LLC
Address:5614 Johnson Avenue
Bethesda, MD 20817
Phone:(301) 591-3895
E-mail:cslin@lin-associates.com
Date prepared:March 28, 2018

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Image /page/4/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "A" with a white "C" inside. Below the logo is the company name in both Chinese and English. The contact information includes the address: FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, as well as the telephone number: +886-2-27136227 and fax number: +886-2-27152181.

5.2 Identification of Product

Device Trade Name:AmCAD-UO
Version number:1.0
Model number:UO-0102
Common and Usual Name:Picture Archiving and Communications System
Device Classification Name:Picture Archiving and Communications System
Regulation Number:21 CFR 892.2050
Classification Product Code:LLZ
Classification:Class II
Classification Panel:Radiology
Manufacturer:AmCad BioMed Corporation

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Image /page/5/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "C" shape. The text includes the company name in both Chinese and English, followed by the address: FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC. The telephone number is +886-2-27136227 and the fax number is +886-2-27152181.

5.3 Predicate Device

This subject software medical device is substantially equivalent to the devices listed below:

Primary Predicate Device Model: IQQA-Body Imaging Software Manufacturer: EDDA Technology, Inc. 510(k) Number: K141745

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Image /page/6/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "A" with a "C" inside. Below the logo is the company name in both Chinese and English. The address is listed as FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, and the telephone number is +886-2-27136227, while the fax number is +886-2-27152181.

5.4 Device Description

AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state. The generated information by AmCAD-UO software device must not be used alone for primary diagnostic interpretation.

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Image /page/7/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "C" inside a square shape. Below the logo is the company name in both Chinese and English, followed by the address: FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC. The telephone number is +886-2-27136227 and the fax number is +886-2-27152181.

5.5 Indications for Use

AmCAD-UO is a PC-based, self-contained, non-invasive image analysis software application for reviewing the pharyngeal/upper airway ultrasonic image acquired from an FDA-cleared ultrasound system. The software is designed to support visualization and quantification of the airway sonographic characteristics. The software also provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. This analysis provides information for physician's evaluation and monitoring of the airway state.

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Image /page/8/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "A" with a circle inside. Below the logo is the company name in both Chinese and English. The contact information includes the address: FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, as well as the telephone number: +886-2-27136227 and fax number: +886-2-27152181.

5.6 Comparison with Predicate Devices

The proposed device has different technological characteristics in software design and input images used for analysis, as compared to the predicate device. AmCAD-UO provides the function to review the pharyngeal/upper airway ultrasonic images and analyze the airway characterizes (i.e. size, position and enhancement pattern) based on the statistical pattern recognition and quantification methods. While, the predicate device, IQQA-Body Imaging Software, provides regional volumetric analysis for vascular/ductal/airway structure derived from CT and MR images. Although AmCAD-UO has the above described differences in technological characteristics, as compared to the predicate devices, it does not raise new types of safety or effectiveness questions.

This software, AmCAD-UO is substantially equivalent to the predicate device as described in table 5.6.1.

DeviceProposed DevicePredicate Device
AmCAD-UOIQQA-Body Imaging Software
ManufacturerAmCad BioMed Corp.EDDA Technology, Inc.
510(k) NumberK180867K141745
Device Common NamePicture archiving and
communications systemSame
Regulation Number21 CFR 892.2050 - Class IISame
Regulation NamePicture archiving and
communications systemSame
Product CodeLLZSame
Indications for UseAmCAD-UO is a PC-based,
self-contained, non-invasive image
analysis software application for
reviewing the pharyngeal/upper
airway ultrasonic image acquired
from an FDA-cleared ultrasound
system. The software is designed to
support visualization andIQQA-BodyImaging Software is a
PC-based, self-contained,
non-invasive image analysis software
application for reviewing body
imaging studies (including thoracic,
abdominal, and pelvic) derived from
CT and MR scanners. Combining
image viewing, processing and
reporting tools, the software is
designed to support the visualization,
DeviceProposed DevicePredicate Device
AmCAD-UOIQQA-Body Imaging Software
quantification of the airway
sonographic characteristics. The
software also provides tools for
manual or interactive selection of
Region of Interest to allow for
analysis of the airway in terms of its
size, position and enhancement
pattern. This analysis provides
information for physician's evaluation
and monitoring of the airway state.evaluation and reporting of body
imaging studies and
physician-identified lesions.
The software supports a workflow
based on automated image
registration for viewing and analyzing
multiphase and multiple time-point
volume datasets. It includes tools for
interactive segmentation and labeling
of organ segments and
vascular/ductal/airway structures.
The software provides functionalities
for manual or interactive
segmentation of physician-identified
lesions, interactive definition of
virtual resection plane and virtual
needle path, and allows for regional
volumetric analysis of such lesions in
terms of size, position, margin, and
enhancement pattern, providing
information for physician's evaluation
and treatment planning, monitoring,
and follow-up.
The software is designed for use by
trained professionals, including
physicians and technicians. Image
source: DICOM.
Functional CapabilityThe software is designed to support
visualization and quantification of the
airway sonographic characteristics.
The software also provides tools for
manual or interactive selection of
Region of Interest to allow for
analysis of the airway in terms of its
size, position and enhancement
pattern. This analysis provides
information for physician's evaluation
and monitoring of the airway state.Combining image viewing, processing
and reporting tools, the software is
designed to support the visualization,
evaluation and reporting of body
imaging studies and
physician-identified lesions.
The software supports a workflow
based on automated image
registration for viewing and analyzing
multiphase and multiple time-point
volume datasets. It includes tools for
interactive segmentation and labeling
of organ segments and

Table 5.6.1 - The substantial equivalence comparison table

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Image /page/9/Picture/4 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a blue stylized "A" with a "C" inside. Below the logo is the company name in both Chinese and English. The address is listed as FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, and the telephone number is +886-2-27136227, while the fax number is +886-2-27152181.

Tel: +886-2-27136227 Fax: +886-2-27152181

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© 安克生醫股份有限公司
----------------

AmCad BioMed Corporation

Tel: +886-2-27136227 Fax: +886-2-2715218

DeviceProposed DevicePredicate Device
AmCAD-UOIQQA-Body Imaging Software
vascular/ductal/airway structures.
The software provides functionalities
for manual or interactive
segmentation of physician-identified
lesions, interactive definition of
virtual resection plane and virtual
needle path, and allows for regionalvolumetric analysis of such lesions in
terms of size, position, margin, and
enhancement pattern, providing
information for physician's evaluation
and treatment planning, monitoring,
and follow-up.
The software is designed for use by
trained professionals, including
physicians and technicians. Image
source: DICOM.
Input (format)B-mode dynamic ultrasound imageDigital CT and MR Image data
Output (format)The software can provide analysis
information of the airway in terms of
its size, position and enhancement
pattern to physicians in evaluating
and monitoring the airway state.The software provides functionalities
for manual or interactive
segmentation of physician-identified
lesions, interactive definition of
virtual resection plane and virtual
needle path, and allows for regional
volumetric analysis of
physician-identified lesions or organ
segments and vascular/ductal/airway
structures in terms of size, position,
margin, and enhancement pattern,
providing information for physician's
evaluation and treatment planning,
DeviceProposed DevicePredicate Device
AmCAD-UOIQQA-Body Imaging Software
ExampleImage: AmCAD-UOImage: IQQA-Body Imaging Software
Tools provided by the
deviceThe software also provides tools for
manual or interactive selection of
Region of Interest to allow for
analysis of the airway in terms of its
size, position and enhancement
pattern with ultrasound images.The software also provides tools for
interactive segmentation and labeling
of organ segments and
vascular/ductal/airway structures
with CT/MR images.
Software DesignBased on Statistical Pattern
Recognition and Quantification
method of airway.Based on regional volumetric analysis
of such lesions and organs
Operating SystemStandard PC operating systemSame

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Image /page/11/Picture/0 description: The image contains the logo of Anke BioMedical Co., Ltd. The logo consists of a blue circular shape with a white "C" inside, followed by the company's name in traditional Chinese characters. The text reads "安克生醫股份有限公司", which translates to "Anke BioMedical Co., Ltd."

Tel: +886-2-27136227 Fax: +886-2-27152181

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Image /page/12/Picture/0 description: The image displays the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "A" with a "C" inside. Below the logo is the company name in both Chinese and English. The address is listed as FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, and the telephone number is +886-2-27136227, while the fax number is +886-2-27152181.

5.7 Performance Standards

No performance standards for PACS systems or components have been issued under the authority of Section 514.

5.8 General Safety and Effectiveness Concerns

Software development for the AmCAD-UO follows documented processes for software design, verification and validation testing. A risk assessment has been completed to identify potential design hazards that could cause an error or injurv based on the use of the quantification results. Appropriate steps have been taken to control all identified risks for this type of image viewing and quantification device. The device labeling contains operating instructions for use and necessary warnings and notes to provide the safe and effective use of the AmCAD-UO.

5.9 Summary of Performance Data to Support Substantial Equivalence

AmCad BioMed Corporation has conducted the software verification testing and performance validation testing to evaluate the safety and effectiveness of AmCAD-UO and to validate the performance of the AmCAD-UO for its intended use. The software verification testing, including software unit test, software integration test, and software system test, was performed to ensure that AmCAD-UO meets all functional and specifications for its indication for use. Phantom images were created to verify the accuracy of the region of interest (ROI) identification and the quantification of the airspace characteristics by the software under allowable ranges of parameter settings. AmCAD-UO performance was also validated through clinical assessment with a very limited sample size of human subjects. Comparison was performed against MRI measurements. It was found that the two measurement methods exhibit a significant correlation, i.e., a larger airway width measured in one method should be also observed larger in the other method. However, we are not able to conclude from the study, due to the small sample size and the systematic difference between the two imaging modalities, that the two measurement methods fully agree with each other.

13

Image /page/13/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "C" shape. Below the logo is the company name in both Chinese and English. The address is listed as FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, and the telephone number is +886-2-27136227, while the fax number is +886-2-27152181.

AmCAD-UO provides tools for manual or interactive selection of Region of Interest to allow for analysis of the airway in terms of its size, position and enhancement pattern. The results demonstrated that AmCAD-UO can be used to visualize and quantify the airway in terms of its size, position and enhancement pattern. The analyzed images displayed on AmCAD-UO must not be used alone for primary diagnostic interpretation.

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Image /page/14/Picture/0 description: The image shows the logo and contact information for AmCad BioMed Corporation. The logo features a stylized blue "A" with a "C" inside. Below the logo is the company name in both Chinese and English. The address is listed as FL.3, NO.167, Fu Hsing N. RD., Taipei 105, Taiwan, ROC, and the telephone number is +886-2-27136227, while the fax number is +886-2-27152181.

5.10 Conclusions

The software development for AmCAD-UO followed documented processes for software design, verification testing, and validation testing. A risk assessment has been completed to identify potential design hazards that could cause an error or injury based on the use of the quantification results. Appropriate steps have been taken to control all identified risks for the device. There is no known direct safety or health risk caused by, or related to, the use of the device. The safety and effectiveness of the device has been described in the verification and validation document.

The data presented in this 510(k) application demonstrates that the proposed device, AmCAD-UO, is as safe and effective as the predicate device. The intended use of AmCAD-UO is similar to the predicate device. The technological differences do not raise any new questions regarding the safety and effectiveness of the device. Thus, AmCAD-UO is substantially equivalent to the predicate device as a software device intended to view and analyze airway structures of ultrasound image. Both devices are classified as Picture Archiving and Communication Systems, 21 CFR 892.2050.