K Number
K183713
Device Name
Wireless Digital Flat Detector
Date Cleared
2019-01-09

(30 days)

Product Code
Regulation Number
892.1680
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Mars 17 17XF-CSI Wireless Digital Flat Panel Detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human anatomy. It is intended to replace radiographic film/screen systems in all general-purpose diagnostic procedures. This device is not intended for mammography or dental applications.
Device Description
Mars1717XF-CSI Wireless Digital Flat Panel Detector is a kind of wireless digital flat panel detector. It supports the single frame mode, with the key component of TFT (Thin Film Transistor)/PD (Photo Diode) image sensor flat panel of active area: 42.48cm×42.54cm. The sensor plate of Mars1717XF-CSI Wireless Digital Flat Panel Detector is direct-deposited with CsI scintillator to achieve the conversion from X-ray to visible photon. The visible photons are transformed to electron signals by diode capacitor array within TFT panel, which are composed and processed by connecting to scanning and readout electronics, consequently to form a panel image by transmitting to PC through the user interface. The major function of the Mars1717XF-CSI Wireless Digital Flat Panel Detector is to convert the X-ray to digital image, with the application of high resolution X-ray imaging. This detector is the key component of DR system, enables to complete the digitalization of the medical X-ray imaging with the DR system software.
More Information

Not Found

No
The description focuses on the hardware components and basic image processing steps (conversion, composition, transmission) without mentioning any AI/ML algorithms for image analysis, interpretation, or enhancement beyond standard digital radiography processing.

No.
This device is for diagnostic imaging (converting X-rays to digital images for general radiographic diagnosis), not for treating a disease or condition.

Yes

The device is indicated for "general radiographic diagnosis of human anatomy." This explicitly states its purpose is for diagnosis.

No

The device description explicitly details hardware components like a TFT/PD image sensor, CsI scintillator, diode capacitor array, scanning and readout electronics, and a wireless digital flat panel detector. It is a physical device that converts X-rays to digital images.

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

Here's why:

  • Intended Use: The intended use clearly states it's for "digital imaging solution designed for providing general radiographic diagnosis of human anatomy." This describes an imaging device used on the patient, not a device used to test samples from the patient (which is the core of IVD).
  • Device Description: The description details how the device converts X-rays into digital images of the human body. This aligns with medical imaging, not in vitro testing.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), reagents, or any other components typically associated with in vitro diagnostics.

Therefore, the Mars 17 17XF-CSI Wireless Digital Flat Panel Detector is a medical imaging device, not an IVD.

N/A

Intended Use / Indications for Use

Mars 17 17XF-CSI Wireless Digital Flat Panel Detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human anatomy. It is intended to replace radiographic film/screen systems in all general-purpose diagnostic procedures. This device is not intended for mammography or dental applications.

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

MQB

Device Description

Mars1717XF-CSI Wireless Digital Flat Panel Detector is a kind of wireless digital flat panel detector. It supports the single frame mode, with the key component of TFT (Thin Film Transistor)/PD (Photo Diode) image sensor flat panel of active area: 42.48cm×42.54cm.

The sensor plate of Mars1717XF-CSI Wireless Digital Flat Panel Detector is directdeposited with CsI scintillator to achieve the conversion from X-ray to visible photon. The visible photons are transformed to electron signals by diode capacitor array within TFT panel, which are composed and processed by connecting to scanning and readout electronics, consequently to form a panel image by transmitting to PC through the user interface.

The major function of the Mars1717XF-CSI Wireless Digital Flat Panel Detector is to convert the X-ray to digital image, with the application of high resolution X-ray imaging. This detector is the key component of DR system, enables to complete the digitalization of the medical X-ray imaging with the DR system software.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

human anatomy

Indicated Patient Age Range

The remaining notes depend on the DR system. Not intended for pediatric.

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

  • Electrical Safety and EMC testing: Electrical, mechanical, environmental safety and performance testing according to IEC/ES 60601-1 was performed, and EMC testing was also conducted in accordance with IEC/EN 60601-1-2. All test results are meet standard requirements.
  • Biological Evaluation: The materials of the detector which contact operators' skin have been evaluated with the ISO 10993-1. And the evaluation results and test result assured the safety the same as the predicate device.
  • Non-clinical Considerations: The only modification from the predicate device to Mars1717XF-CSI is the panel dimension, related to Amorphous Silicon (A-Si) panel size and structure size design. The non-clinical studies have been performed and the results have shown that sections of the non-clinical consideration mentioned in the 'Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices' are substantially equivalent to the non-consideration of predicate devices on the Market (Mars1417XF-CSI, K182551).
  • Clinical Consideration: The only modification from the predicate device to Mars1717XF-CSI is the panel dimension, related to Amorphous Silicon (a-Si) panel size and structure size design. Intended use, fundamental scientific technology, regulatory requirement, non-clinical performance, labeling, quality-assurance program and software keep the same with those of predicate device. Additionally, as mentioned in clinical considerations in 'Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices', clinical consideration may not necessary for changes in the dimensions of the image receptor with otherwise identical materials if non-clinical information is sufficient to support the substantial equivalence, which is described details in '009 Substantial Equivalence Discussion' in this submission.
    There was no significant difference between the images of the Mars1717XF-CSI and those of 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.

K182551

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

§ 892.1680 Stationary x-ray system.

(a)
Identification. A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

0

Image /page/0/Picture/0 description: The image shows 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.

iRay Technology Taicang Ltd. % Meng Li Registration & Regulation Affairs Engineer No. 33 Xinggang Rd., Taicang Port Economic & Technological Development Zone Taicang, Jiangsu 215434 CHINA

Re: K183713

Trade/Device Name: Wireless Digital Flat Panel Detector Regulation Number: 21 CFR 892.1680 Regulation Name: Stationary x-ray system Regulatory Class: Class II Product Code: MQB Dated: November 1, 2018 Received: December 10, 2018

Dear Meng Li:

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 mav, 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 avare 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.

January 9, 2019

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.html; 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.

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 Food and Drug Administration

Indications for Use

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

510(k) Number (if known)

K183713

Device Name Wireless Digital Flat Panel Detector

Indications for Use (Describe)

Mars 17 17XF-CSI Wireless Digital Flat Panel Detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human anatomy. It is intended to replace radiographic film/screen systems in all general-purpose diagnostic procedures. This device is not intended for mammography or dental applications.

We understand the Agency has become aware of situations where solid state detectors inserted into radiographic systems adversely impacted device performance due to improper integration (reference:http://www.fda.gov/downloads/ MedicalDevices/ResourcesforYou/Industry/UCM385149.pdf ).

Below is a summary of the information from the Mars1717XF-CSI user manuals covering key electromechanical and computer requirements needed for X-ray system interface and integration.

  1. Mechanical interface requirements.

  2. Computer requirements

  3. Data communication interface requirements

  4. Electrical power requirements

  5. X-ray trigger interface requirements

Neither the Mars 1717XF-CSI detector nor its software act as an X-ray generator controller, and therefore, the device is not subject to Electronic Product Radiation Control (EPRC) performance standards and reporting requirements.

Type of Use (Select one or both, as applicable)

[X] 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."

FORM FDA 3881 (7/17)

3

510 (k) SUMMARY OF SAFETY AND EFFECTIVENESS

(As Required by 21 CFR 807.92)

1. Date Prepared [21 CFR 807.92(a)(1)]

November 1st, 2018

2. Submitter's Information [21 CFR 807.92(a)(1)]

Company Name:iRay Technology Taicang Ltd.
Company Address:No.33 Xinggang Road, Taicang Port Economic and
Technological Development Zone, Jiangsu, China 215434
Contact Person:Meng Li
Phone:0512-53690872
Fax:0512-53690872
Email:meng.li@iraygroup.com

3. Trade Name, Common Name, Classification [21 CFR 807.92(a)(2)]

510(k) Number:K183713
Trade Name:Wireless Digital Flat Panel Detector
Common Name:Solid State X-Ray Imager
Model Name:Mars1717XF-CSI
Classification Name:Stationary X-Ray System
Product Code:MQB
Regulation Number:21 CFR 892.1680
Device Class:Class II

SECTION 6 - 2 of 12

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4. Identification of Predicate Devices(s) [21 CFR 807.92(a)(3)[

The identification predicates within this submission are as follows:

Manufacturer:iRay Technology Taicang Ltd.
Trade Name:Wireless Digital Flat Panel Detector
Model Name:Mars1417XF-CSI
Product Code:MQB
Classification Name:Stationary X-Ray System
FDA 510 (k) #:K182551

5. Description of the Device [21 CFR 807.92(a)(4)]

Mars1717XF-CSI Wireless Digital Flat Panel Detector is a kind of wireless digital flat panel detector. It supports the single frame mode, with the key component of TFT (Thin Film Transistor)/PD (Photo Diode) image sensor flat panel of active area: 42.48cm×42.54cm.

The sensor plate of Mars1717XF-CSI Wireless Digital Flat Panel Detector is directdeposited with CsI scintillator to achieve the conversion from X-ray to visible photon. The visible photons are transformed to electron signals by diode capacitor array within TFT panel, which are composed and processed by connecting to scanning and readout electronics, consequently to form a panel image by transmitting to PC through the user interface.

The major function of the Mars1717XF-CSI Wireless Digital Flat Panel Detector is to convert the X-ray to digital image, with the application of high resolution X-ray imaging. This detector is the key component of DR system, enables to complete the digitalization of the medical X-ray imaging with the DR system software.

6. Intended Use [21 CFR 807.92(a)(5)]

6.1. Intended Use

Mars1717XF-CSI Wireless Digital Flat Panel Detector is indicated for digital imaging solution designed for providing general radiographic diagnosis of human

SECTION 6 - 3 of 12

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anatomy. It is intended to replace radiographic film/screen systems in all generalpurpose diagnostic procedures. This device is not intended for mammography, dental applications, pediatric, pregnant women and fluoroscopy.

6.2. Suitable patient

It is suitable for providing digital X-ray imaging for DR system conventional photography but not intended for mammography or dental applications. The remaining notes depend on the DR system.

6.3. Processing of input and output

When flat panel detector works continuously, it can automatically distinguish Xray and output an imaging for diagnosis of disease, injury, or of any applicable health problem.

| Item | Predicate Device:
Wireless Digital Flat Panel
Detector | Proposed
Device:
Wireless
Digital Flat
Panel Detector | |
|---------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | 510(K)
Number | K182551 | To be assigned |
| | | Intended Use | The Mars1417XF-CSI Wireless
Digital Flat Panel Detector is
indicated for digital imaging
solution designed for providing
general radiographic system in
all general purpose diagnostic
procedures. |
| | Item | Predicate Device:
Wireless Digital Flat Panel
Detector | Proposed
Device:
Wireless
Digital Flat
Panel Detector |
| Indications for Use | Mars1417XF-CSI Wireless
Digital Flat Panel Detector is
indicated for digital imaging
solution designed for providing
general radiographic diagnosis
of human anatomy. It is intended
to replace radiographic
film/screen systems in all
general-purpose diagnostic
procedures. This device is not
intended for mammography or
dental applications.
We understand the Agency has
become aware of situations
where solid state detectors
inserted into radiographic | , dental
applications,
pediatric,
pregnant
women and
fluoroscopy.
Same with
Mars1417XF-
CSI,
additionally, In
the
consideration
of patient size
(i.e., height,
weight, body
part thickness)
and usable
dose range, the
detector could
be used for
general X ray
diagnosis of | |
| | systems adversely impacted
device performance due to | usual body part
for adult. | |
| Item | Predicate Device:
Wireless Digital Flat Panel
Detector | Proposed
Device:
Wireless
Digital Flat
Panel Detector | |
| | improper integration
(reference:http://www.fda.gov/d
ownloads/MedicalDevices/Reso
urcesforYou/Industry/UCM3851
49.pdf).

Below is a summary of the
information from the
Mars1417XF-CSI user manuals
covering key electromechanical
and computer requirements
needed for X-ray system
interface and integration.

  1. Mechanical interface
    requirements.
  2. Computer requirements
  3. Data communication interface
    requirements
  4. Electrical power requirements
  5. X-ray trigger interface
    requirements

Neither the Mars1417XF-CSI
detector nor its software act as
an X-ray generator controller,
and therefore, the | | |
| Item | Predicate Device: | Proposed Device: | |
| | Wireless Digital Flat Panel
Detector | Wireless
Digital Flat
Panel Detector | |
| | device is not subject to
Electronic Product Radiation
Control (EPRC) performance
standards and reporting
requirements. | | |
| Classification
Name | Stationary X-ray system | Same | |
| Product Code | MQB | Same | |
| Regulation Number | 21 CFR 892.1680 | Same | |
| Panel: | Radiology | Same | |
| Classification: | II | Same | |
| X-Ray Absorber
(Scintillator): | CsI | Same | |
| Installation Type: | Wireless, Portable | Same | |
| Readout Mechanism: | Thin Film Transistor | Same | |
| Image Matrix Size: | 2336 × 2836 pixels | 2832× 2836 pixels | |
| Pixel Pitch: | 150μm | Same | |
| ADC Digitization | 16 bit | Same | |
| Effective Imaging Area: | 350.4 mm × 425.4 mm | 424.8 mm × 425.4 mm | |
| Spatial Resolution: | Min. 3.3lp/mm | Same | |
| Modulation
Transfer
Function | 0.5 at 1 lp/mm | 0.49 at 1 lp/mm | |
| Item
(MTF) | Predicate Device:
Wireless Digital Flat Panel
Detector | Proposed
Device:
Wireless
Digital Flat
Panel Detector | |
| Detective
Quantum
Efficiency
(DQE)
(RQA5, 2.5µGy) | 0.37 at 1 lp/mm | 0.40 at 1
lp/mm | |
| Power Consumption: | Max. 19W | Max. 20W | |
| Communications:
(Wireless functionality) | Wireless: IEEE 802.11a/b/g/n
(2.4 GHz / 5 GHz) | Same | |
| Imaging protect Plate: | Carbon Fiber Plate | Same | |
| Cooling: | Air cooling | Same | |
| Dimensions: | 384 mm × 460 mm × 15 mm | 460 mm × 460 mm × 15 mm | |
| Operation: | Temperature: +5 ~ +30°C
Humidity: 10 ~ 80%
(Non-Condensing)
Atmospheric pressure: 70 ~ 106 kPa
Altitude: Max. 3000 meters | Same | |
| Storage and
Transportation:
( detector ) | Temperature: -20 ~ +50°C
Humidity: 10 ~ 90%
(Non-Condensing)
Atmospheric pressure: 70 ~ 106 kPa | Same | |
| Item | Predicate Device:
Wireless Digital Flat Panel
Detector | Proposed
Device:
Wireless
Digital Flat
Panel Detector | |
| Software | Altitude: Max. 3000 meters
iRay SDK(include iDetector) is
intend to supply API interface
for DR system manufacturers.
DR system manufacturer control
the detector by SDK interface.
SDK is not intend to use directly
by other users beside DR system
manufacturers. | Same | |
| | Utilized FDA guidance
documents | 1. Guidance for the Submission
of 510(k)'s for Solid State
X-ray Imaging Devices;
2. The 510(k) Program:
Evaluating Substantial
Equivalence in Premarket
Notifications[510(k)];
3. Content of Premarket
Submissions for
Management of
Cybersecurity in Medical
Devices;
4. Radio Frequency Wireless
Technology in Medical
Devices. | Same |

7. Technological Characteristic [21 CFR 807.92(a)(6)]

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7

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8

SECTION 6 - 7 of 12

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8. System requirements to operate with other radiographic system components

    1. Recommended Generator Specification:
      Energy range: 40~150kVp

mA range: 10~1000mA (depending on the generator power)

ms range: 106300ms to produce 0.11000mAs (depending on the generator power) Note: To our best knowledge, the detector is compatible with the X-ray generators with the specifications described above. If still having any questions regarding the compatibility issue for other generators, please contact the distributor or iRay's service office.

    1. Application Program Interface (API) for system integration manufacturer Peripheral hardware: Mars1717XF-CSI detector connected via wireless communication.
Operating System:Windows XP/7 32/64bit
CPU:Intel Core i5 3.6G
Memory:8G DDR3
Hard Disk:640 G
LAN Card:Intel Pro EXP9301CT PRO
Gigabit Network Adapter with PCIe interface

3) X-ray exposure mode

The AED trigger module is a unit can connect X-ray signal in the Mars1717XF-CSI. Once there is X-ray generator exposure exist, the inner trigger module will detect the X-ray radiation and output signal to the detector. Until the exposure finished, the detector will receive a signal which represent the end of exposure from the inner trigger module and begin to acquire the image.

9. Substantial Equivalence [21 CFR 807.92(b)(1) and 807.92(b)(2)]

  • Electrical Safety and EMC testing: 1)

SECTION 6 - 10 of 12

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iRay Technology Taicang Ltd.

Electrical, mechanical, environmental safety and performance testing according to IEC/ES 60601-1 was performed, and EMC testing was also conducted in accordance with IEC/EN 60601-1-2. All test results are meet standard requirements.

    1. Biological Evaluation:
      The materials of the detector which contact operators' skin have been evaluated with the ISO 10993-1. And the evaluation results and test result assured the safety the same as the predicate device.
    1. Non-clinical Considerations:
      The only modification from the predicate device to Mars1717XF-CSI is the panel dimension, related to Amorphous Silicon (A-Si) panel size and structure size design. The non-clinical studies have been performed and the results have shown that sections of the non-clinical consideration mentioned in the 'Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices' are substantially equivalent to the non-consideration of predicate devices on the Market (Mars1417XF-CSI, K182551).
    1. Clinical Consideration:
      The only modification from the predicate device to Mars1717XF-CSI is the panel dimension, related to Amorphous Silicon (a-Si) panel size and structure size design. Intended use, fundamental scientific technology, regulatory requirement, non-clinical performance, labeling, quality-assurance program and software keep the same with those of predicate device. Additionally, as mentioned in clinical considerations in 'Guidance for the Submission of 510(k)s for Solid State X-ray Imaging Devices', clinical consideration may not necessary for changes in the dimensions of the image receptor with otherwise identical materials if non-clinical information is sufficient to support the substantial equivalence, which is described details in '009 Substantial Equivalence Discussion' in this submission.

There was no significant difference between the images of the Mars1717XF-CSI and those of the predicate device.

    1. Conclusion [21 CFR 807.92(b)(3)]

SECTION 6 - 11 of 12

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In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this premarket notification, iRay Technology Taicang Ltd. concludes that iRay Mars1717XF-CSI Wireless Digital Flat Panel Detectors is substantially equivalent to predicate device with regards to safety and effectiveness.