K Number
K232928
Device Name
DeepContour (V1.0)
Date Cleared
2024-05-07

(230 days)

Product Code
Regulation Number
892.2050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. In addition, DeepCoutour is suitable for the following conditions: 1. Creation of contours using deep-learning algorithms , support quantitative analysis, organ HU distribution statistics, transfer contour files to TPS, and create management archives for patients. 2. Analvze the anatomical structure at different anatomical positions. 3. Rigid and elastic registration based on CT. 4. 3D reconstruction, editing and other visual tools based on organ contours
Device Description
DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. DeepContour contouring workflow supports CT input data and produces RTSTRUCT outputs. The organ segmentation can also be combined into templates, which can be customized by different hospitals according to their needs. DeepContour provides an interactive contouring application to edit and review the contours automatically generated by DeepContour.
More Information

Yes
The device description explicitly states "DeepContour is a deep learning based medical imaging software" and the intended use mentions "Creation of contours using deep-learning algorithms". The training and test set descriptions detail the use of deep learning models for auto-segmentation.

No
The device is described as a medical imaging software that processes CT images for contour creation, analysis of anatomical structures, registration, and 3D reconstruction. Its intended use focuses on providing tools for trained healthcare professionals to assist with tasks normally undertaken in medical imaging. It does not directly provide a therapeutic effect or intervene in the treatment of a condition. Therefore, it is not a therapeutic device.

No

The device is described as a medical imaging software to automatically process CT images for contour creation, quantitative analysis, and 3D reconstruction, among other visual tools. It aids in the workflow of trained healthcare professionals and does not provide a medical diagnosis or treatment decision.

Yes

The device is explicitly described as "deep learning based medical imaging software" and its function is to process CT images and produce RTSTRUCT outputs. There is no mention of any associated hardware component being part of the device itself.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for the diagnosis, treatment, or prevention of disease.
  • DeepContour's Function: DeepContour processes medical images (CT scans) to automatically generate contours of anatomical structures. It is a tool for trained healthcare professionals to assist in tasks like quantitative analysis, treatment planning (transferring contours to TPS), and patient management.
  • Lack of Specimen Analysis: DeepContour does not analyze biological specimens. Its input is image data, not samples from the human body.

While DeepContour is a medical device that provides information relevant to patient care, its function falls under the category of medical imaging software and image processing, not in vitro diagnostic testing.

No
The letter does not state that the FDA has reviewed and approved or cleared a PCCP for this specific device.

Intended Use / Indications for Use

DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. In addition, DeepCoutour is suitable for the following conditions:

  1. Creation of contours using deep-learning algorithms, support quantitative analysis, organ HU distribution statistics, transfer contour files to TPS, and create management archives for patients.
  2. Analyze the anatomical structure at different anatomical positions.
  3. Rigid and elastic registration based on CT.
  4. 3D reconstruction, editing and other visual tools based on organ contours

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

QKB

Device Description

DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. DeepContour contouring workflow supports CT input data and produces RTSTRUCT outputs. The organ segmentation can also be combined into templates, which can be customized by different hospitals according to their needs. DeepContour provides an interactive contouring application to edit and review the contours automatically generated by DeepContour.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Yes

Input Imaging Modality

CT Images

Anatomical Site

Head & Neck, Thorax, Abdomen & Pelvis (82 OARs)

Indicated Patient Age Range

DeepContour is designed for use only in adult populations.

Intended User / Care Setting

Trained healthcare professionals / professional environment

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

For DeepContour, the deep learning models were trained on a pool of training data that did not include any patients from the same institution as the test subjects. The data was collected from 35 hospitals across China over a period of about 3 years. The data collection time is random, including patients with different ages, races, size, et al. Data collected in a hospital tends to be a collection of consecutive cases. Due to the different time periods applicable to different hospitals, the time for collecting data varies among different hospitals. The specific patient subgroups were not the special consideration when collecting the patients' data.

The training data included 800 CT images (200 for each region of head and neck region, chest region, abdomen region and pelvic region) at various ages, no ethnicities or genders were excluded from training. Within 200 cases collected in each region, 160 cases were used for training and 40 cases were used for validation to establish the auto-segmentation models. The auto-segmentation process includes two steps: first step to distinguish the four different regions (head and neck region, chest region, abdomen region and pelvic region), second step to call the model of this region to realize auto-segmentation. The initial segmentations were then reviewed and corrected by two radiation oncologists for model training, with a third qualified internal staff member available to adjudicate if needed.

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

The performance of the DeepContour were verified by a total of 203 CT images with 2 datasets:
(1) clinical datasets retrospectively collected from multiple clinical regions across the Peking Union Medical College Hospital (N=100), consisting of four selected parts based on their location, 25 cases for head and neck, 25 cases for chest, 25 cases for abdomen and 25 cases for pelvic; These clinical datasets are not used in the training datasets at all.
(2) American public datasets (N=103);
(a)The 2017 lung CT segmentation challenge (LCTSC), which contains 60 thoracic CT scan patients with five segmented organs (left lung, right lung, heart, spinal cord, and esophagus),
(b) Pancreas-CT (PCT), which contains 43 abdominal contrast enhanced CT scan patients with seven segmented organs (the spleen, left kidney, esophagus, liver, stomach, pancreas, and duodenum). The American public datasets were annotated by the American doctors. The article was published in the journal (Medical Physics), doi: 10.1002/mp.14131. (Please refer to more information about the two publicly available datasets: https://wiki.cancerimagingarchive.net/pages/viewpage.action?pageId=24284539, https://wiki.cancerimagingarchive.net/display/Public/Pancreas-CT)

The auto-segmentation process is the same with what was applied to the training dataset with two steps: first step to distinguish the four different regions (head and neck region, chest region, abdomen region and pelvic region), second step to call the model of this region to realize auto-segmentation. The ground truth annotations for the 100 cases in China were established by two different radiation oncologists with more than 10 years of clinical practice (See Appendix 2 for their detailed CVs) following RTOG and clinical guidelines using manual annotation. A third qualified internal staff member is also available to adjudicate if needed. American public datasets (N=103) were annotated by the American doctors.

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

Study Type: Software verification and validation, performance comparison (Dice coefficients, MAE, RMSE, PSNR, SSIM, ASSD).
Sample Size: 100 clinical cases from Peking Union Medical College Hospital, 103 American public datasets (60 LCTSC, 43 Pancreas-CT).
Key Results:
The results of the subject device demonstrate equivalent or better performance compared to the predicate device when aggregate performance over all organs is considered with known limitations described in the labeling. Equivalence is defined such that the lower bound of 95th percentile confidence interval of the subject device segmentation is greater than 0.1 Dice lower than the mean of predicate device segmentation.

Rigid and deformable registration (rpCT-CBCT vs. dpCT1-CBCT vs. dpCT2-CBCT):

  • MAE(HU): 51.23±13.67 vs. 43.98±10.74 vs. 46.71±12.71
  • RMSE: 121.09±30.23 vs. 117.58±28.22 vs. 127.96±30.76
  • PSNR: 20.01±2.74 vs. 22.23±2.61 vs. 20.00±3.77
  • SSIM: 0.623±0.084 vs. 0.680±0.050 vs. 0.685±0.055

Segmentation Performance (Dice Coefficients):

  • Clinical performance comparison (Peking Union Medical College Hospital): Detailed Dice coefficients for 69 different anatomical structures (OARs) were provided, comparing DeepContour against AI-Rad CAI-Rad Companion Organs RT (K221305) and Contour ProtégéAI (K223774). DeepContour generally showed comparable or higher Dice coefficients across many structures.
  • Clinical performance comparison (LCTSC American public datasets): Dice coefficients for 5 anatomical structures were compared. DeepContour showed comparable or higher Dice coefficients for Spinal Cord, Lung L, Lung R, Heart, and Esophagus.
  • Clinical performance comparison (Pancreas-CT American public datasets): Dice coefficients for 7 anatomical structures were compared. DeepContour showed comparable or higher Dice coefficients for Spleen, Pancreas, Kidney_L, Esophagus, Liver, Stomach, and Duodenum.

Average Symmetric Surface Distance (ASSD):

  • Subject device (DeepContour) median ASSD: 0.95 (95% CI: [0.85, 1.13])
  • Predicate device (AI-Rad CAI-Rad Companion Organs RT (K221305)) median ASSD: 0.96 (95% CI: [0.84, 1.15])
  • Reference device (Contour ProtégéAI (K223774)) median ASSD: 0.95 (95% CI: [0.86, 1.17])

The subject device achieved a median ASSD of 0.95 in comparison to the predicate device achieving a median ASSD of 0.96 for existing organs.

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

Dice coefficients, mean absolute error (MAE), root mean square error (RMSE), peak signal-to-noise ratio (PSNR), structural similarity (SSIM), and median Average Symmetric Surface Distance (ASSD).

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.

K221305

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.

K223774

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).

0

May 7, 2024

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a seal with an abstract design and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA" arranged around it. To the right, there is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG" in blue, and "ADMINISTRATION" in a smaller font size below it.

Wisdom Technologies., Inc. % Wei Wang Regulatory Consultant 11 Longstreet IRVINE, CA 92620

Re: K232928

Trade/Device Name: DeepContour (V1.0) Regulation Number: 21 CFR 892.2050 Regulation Name: Medical Image Management And Processing System Regulatory Class: Class II Product Code: QKB Dated: April 5, 2024 Received: April 5, 2024

Dear Wei Wang:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming

1

product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Loran Werchner

Lora D. Weidner, Ph.D. Assistant Director Radiation Therapy Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

2

Indications for Use

Submission Number (if known)

K232928

Device Name

DeepContour (V1.0)

Indications for Use (Describe)

DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. In addition, DeepCoutour is suitable for the following conditions:

  1. Creation of contours using deep-learning algorithms , support quantitative analysis, organ HU distribution statistics, transfer contour files to TPS, and create management archives for patients.

  2. Analvze the anatomical structure at different anatomical positions.

  3. Rigid and elastic registration based on CT.

  4. 3D reconstruction, editing and other visual tools based on organ contours

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

Prescription Use (Part 21 CFR 801 Subpart D)

he-Counter Use (21 CFR 801 Subpart C)

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K232928

Image /page/3/Picture/1 description: The image shows a logo with a stylized human figure in the center, surrounded by radiating lines. The figure is placed within a blue, semi-circular shape. To the right of the figure, there are Chinese characters followed by the words "WISDOM TECH" in blue font. The logo appears to represent a technology company, possibly focused on human-centered solutions.

510(k) Summary

The following information is provided as required by 21 CFR 807.92

1. SUBMITTER

Name: Wisdom Technologies., Inc.

Address: 4th Floor, Building F2, Phase II, Innovation Industrial Park, Hefei, Anhui, China 230088

Phone: +86-0551-65116387

Email: registration(@wisdom-tech.online

Contact Person: Wei Wang, Consultant, Regulatory Affairs Phone: 949-7849283

Date Prepared: August 24, 2023

2. DEVICE

Subject Device Name: DeepContour v1.0 Common/Trade Name: DeepContour Product Code and Classification: Medical Image Management And Processing System 21 CFR 892.2050 | QKB | Class II

3. PREDICATE DEVICE

Primary: AI-Rad CAI-Rad Companion Organs RT (K221305) Siemens Reference: Contour ProtégéAI (K223774) MIM Software

4. DEVICE DESCRIPTION

DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. DeepContour contouring workflow supports CT input data and produces RTSTRUCT outputs. The organ segmentation can also be combined into templates, which can be customized by different hospitals according to their needs. DeepContour provides an interactive contouring application to edit and review the contours automatically generated by DeepContour.

5. INDICATIONS FOR USE

4

DeepContour is a deep learning based medical imaging software that allows trained healthcare professionals to use DeepContour as a tool to automatically process CT images. In addition, DeepCoutour is suitable for the following conditions:

1). Creation of contours using deep-learning algorithms , support quantitative analysis, organ HU distribution statistics, transfer contour files to TPS, and create management archives for patients.

2). Analyze the anatomical structure at different anatomical positions.

  • 3). Rigid and elastic registration based on CT.
  • 4). 3D reconstruction, editing and other visual tools based on organ contours

6. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH PREDICATE DEVICE

The primary technological components of DeepContour and its predicate device are to achieve the deep learning based medical imaging software functions that allows trained healthcare professionals to automatically process CT images. Both are software devices that receive inputs related to radiological images; Both generate contours as output that may be used as input for radiation Treatment Planning Systems and interactive contouring applications to review and edit; Both are software devices for prescription use in a professional environment with no patient contact.

There are no known differences in technological characteristics between the subject device and the predicate device that raise any questions of safety or effectiveness. The technological characteristics of the subject device are believed to be substantially equivalent to the predicate device.

| Area of
Comparison | Subject Device-
DeepContour | Primary-AI-Rad CAI-
Rad Companion Organs
RT (K221305) Siemens | Reference-Contour
ProtégéAI(K223774)
MIM Software |
|------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Regulation
Number/code | 21 CFR 892.2050 QKB | 22 CFR 892.2050 QKB | 21 CFR 892.2050 QKB |
| Regulation Name | Medical Image Management
And Processing System | Medical Image Management
And Processing System | Medical Image
Management And
Processing System |
| Indications for
Use | DeepContour is a deep
learning based medical
imaging software that allows
trained healthcare
professionals to use
DeepContour as a tool to
automatically process CT
images. In addition,
DeepCoutour is suitable for
the following conditions:

  1. Creation of contours using
    deep-learning algorithms ,
    support quantitative analysis,
    organ HU distribution
    statistics, transfer contour files
    to TPS, and create
    management archives for
    patients.
  2. Analyze the anatomical
    structure at different
    anatomical positions.
  3. Rigid and elastic registration
    based on CT.
  4. 3D reconstruction, editing
    and other visual tools based on
    organ contours | AI-Rad Companion Organs
    RT is a post-processing
    software intended to
    automatically contour
    DICOM CT imaging data
    using deep-learning-based
    algorithms.
    Contours that are generated
    by AI-Rad Companion
    Organs RT may be used as
    input for clinical workflows
    including external beam
    radiation therapy treatment
    planning. AI-Rad
    Companion Organs RT must
    be used in conjunction with
    appropriate software such as
    Treatment Planning Systems
    and Interactive Contouring
    applications, to review, edit,
    and accept contours
    generated by AI-Rad
    Companion Organs RT.
    The output of AI-Rad
    Companion Organs RT in
    the format of RTSTRUCT
    objects are intended to be
    used by trained medical
    professionals.
    The software is not intended
    to automatically detect or
    contour lesions. Only
    DICOM images of adult
    patients are considered to be
    valid input. | Trained medical
    professionals use Contour
    ProtégéAI as a tool to
    assist in the automated
    processing of digital
    medical images of
    modalities CT and MR, as
    supported by ACR/NEMA
    DICOM 3.0. In addition,
    Contour ProtégéAI
    supports the following
    indications:
    • Creation of contours
    using machine-learning
    algorithms for applications
    including, but not limited
    to, quantitative
    analysis, aiding adaptive
    therapy, transferring
    contours to radiation
    therapy treatment planning
    systems, and archiving
    contours for patient
    follow-up and
    management.
    • Segmenting anatomical
    structures across a variety
    of CT anatomic locations.
    • And segmenting the
    prostate, the seminal
    vesicles, and the urethra
    within T2-weighted MR
    images.
    Appropriate image
    visualization software
    must be used to review
    and, if necessary, edit |
    | | | | results automatically
    generated by Contour
    ProtégéAI. |
    | Device
    description | DeepContour is a deep
    learning based medical
    imaging software that allows
    trained healthcare
    professionals to use
    DeepContour as a tool to
    automatically process CT
    images. DeepContour
    contouring workflow supports
    CT input data and produces
    RTSTRUCT outputs. The
    organ segmentation can also
    be combined into templates,
    which can be customized by
    different hospitals according to
    their needs.
    DeepContour provides an
    interactive contouring
    application to edit and review
    the contours automatically
    generated by DeepContour. | AI-Rad Companion Organs
    RT is a post-processing
    software used to
    automatically contour
    DICOM CT imaging data
    using deep-learning-based
    algorithms. AI-Rad
    Companion Organs RT
    contouring workflow
    supports CT input data and
    produces RTSTRUCT
    outputs. The
    configuration of the organ
    database and organ
    templates defining the
    organs and structures to be
    contoured based on the input
    DICOM data is managed via
    a configuration interface.
    Contours that are generated
    by AI-Rad Companion
    Organs RT may be used as
    input for clinical workflows
    including external beam
    radiation therapy treatment
    planning.
    The output of AI-Rad
    Companion Organs RT, in
    the form of RTSTRUCT
    objects, are intended to be
    used by trained medical
    professionals. The output of
    AI-Rad Companion Organs
    RT must be used in
    conjunction with appropriate
    software such as Treatment
    Planning Systems and
    Interactive Contouring
    applications, to review, edit,
    and accept contours
    generated by AI-Rad
    Companion Organs RT
    application.
    At a high-level, AI-Rad
    Companion Organs RT
    includes the following
    functionality: 1. Automated
    contouring of Organs at Risk
    (OAR) workflow
    a. Input -DICOM CT
    b. Output - DICOM | Contour ProtégéAI is an
    accessory to MIM
    software that automatically
    creates contours on
    medical images through
    the use of machine-
    learning algorithms. It is
    designed for use in the
    processing of medical
    images and operates on
    Windows, Mac, and Linux
    computer systems.
    Contour ProtégéAI is
    deployed on a remote
    server using the MIMcloud
    service for data
    management and transfer;
    or locally on the
    workstation or server
    running MIM software. |
    | | | RTSTRUCT
  5. Organ Templates
    configuration (incl. Organ
    Database)
  6. Web-based preview of
    contouring results to accept
    or reject the generated
    contours. | |
    | Algorithm | Deep Learning | Deep Learning | Machine-learning |
    | Segmentation of
    Organ at Risk in
    the Anatomic
    Regions | Head & Neck, Thorax,
    Abdomen & Pelvis
    (82 OARs) | Head & Neck, Thorax,
    Abdomen & Pelvis
    Head & Neck lymph
    nodes
    (108 OARs) | Head & Neck, Prostate,
    Thorax, Abdomen, Lungs
    & Liver, MRT structures
    (spleen, pelvic lymph
    nodes, descending
    aorta, bone) |
    | Compatible
    Modality | CT Images | CT Images | CT & MR |
    | Compatible
    Scanner Models | No Limitation on scanner
    model,
    DICOM compliance required. | No Limitation on scanner
    model,
    DICOM compliance
    required. | No Limitation on scanner
    model,
    DICOM compliance
    required. |
    | Compatible
    Treatment
    Planning System | No Limitation on TPS model,
    DICOM
    compliance required. | No Limitation on TPS
    model, DICOM
    compliance required. | No Limitation on TPS
    model, DICOM
    compliance required. |
    | Contraindications | Adult use only | Adult use only | Adult use only |
    | Target
    Population | DeepContour is designed for
    use only in adult populations
    for whom relevant modality
    scans , including head and
    neck, thorax, abdomen, and
    pelvis, are available . | AI-Rad Companion Organs
    RT is designed for use only
    in adult populations. AI-Rad
    Companion Organs RT is
    designed for any patient for
    whom relevant modality
    scans are available. More
    specifically, the software is
    validated on previously
    acquired CT DICOM
    volumes for radiation
    therapy treatment planning,
    including, head and neck, | No public record found |
    | Clinical condition
    the device is
    intended to
    diagnose, treat or
    manage | Limited to patients previously
    selected for Radiation
    Therapy. | Limited to patients
    previously selected for
    Radiation Therapy. | Limited to patients
    previously selected for
    Radiation Therapy. |
    | Software
    Architecture | Server-based application
    supporting
    Windows and Local
    deployment on Windows. | AI-Rad Companion
    (Engine) architecture
    enabling the deployment of
    AI Rad Companion Organs
    RT using Edge and in the
    Cloud. The UI is provided
    using a webbased interface. | Server-based application
    supporting
    Linux-based OS and Local
    deployment on Windows
    or Mac |
    | Deployment
    Feature | locally deployed or Cloud-
    based | Edge & Cloud Deployment | Cloud-based or locally
    deployed |
    | Organ Templates | Creating, editing and deletion
    of organ templates. Customize
    predefined structure database
    with mapping to international
    nomenclature schemes. | Creating, editing and
    deletion of organ templates.
    Customize predefined
    structure database with
    mapping to international
    nomenclature schemes. | No public record found |
    | Automated
    workflow | DeepContour automatically
    processes input image data and
    sends the results as DICOM-
    RT Structure Sets to a user-
    configurable target node. | AI-Rad Companion Organs
    RT automatically processes
    input image data and sends
    the results as DICOM-RT
    Structure Sets to a user-
    configurable target node. | Automatic contouring
    working using machine-
    learning |
    | Contour
    visualization and
    editing feature | DeepContour provides basic
    result preview of automatic
    segmentation results, and
    editing feature of the
    automatic segmented contour. | AI-Rad Companion Organs
    RT provides basic result
    preview of automatic
    segmentation results, and no
    editing feature of the
    automatic segmented
    contour. | No public record found |

Table 1. Substantial Equivalence Comparison

5

6

7

8

9

| Segmentation
Performance | The target performance was
validated using 100 cases. The
mean and standard deviation
Dice coefficients, along with
the lower 95th percentile
confidence bound were
calculated. | The target performance was
validated using 113 cases
distributed to two cohorts.
Cohort A is clinical routine
treatment planning CT and it
is split into two sub-cohort
and Cohort B is PET-CT
data. To objectively evaluate
the target performance, the
DICE coefficient, the
absolute symmetric surface
distance (ASSD) and the fail
rate was evaluated. The
segmentation performance
of the subject and reference
device were equivalent as
well as the overall
performance compared to
the predicate device. | 739 CT Images from 12
clinical sites were used for
testing. The mean and
standard deviation Dice
coefficients, along with the
lower 95th percentile
confidence bound were
calculated. |
|-------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| User Interface -
Results Preview
(Confirmation) | Basic visualization
functionality of original data
and generated contours | Basic visualization
functionality of original data
and generated contours | Basic visualization
functionality of original
data and generated
contours |
| User Interface
Configuration | Configuration UI | Configuration UI | Configuration UI |
| Automated
Workflow to TPS | Results send to Confirmation
UI & Optional bypassing of
Confirmation UI to TPS | Results send to
Confirmation UI & Optional
bypassing of Confirmation
UI to TPS | Results send to
Confirmation UI &
Optional bypassing of
Confirmation UI to TPS |
| Human Factors | Design to be used by
trained clinicians. | Design to be used by
trained clinicians. | Design to be used by
trained clinicians. |
| Patient Contact | None | None | None |

7. PERFORMANCE AND NONCLINICAL TESTS

Software verification and validation were conducted, and the process was documented per FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."

Verification test results demonstrate conformance to applicable requirements and specifications. Testing against the predicate device demonstrates good agreement, proving that tested device can be used as equivalent contouring software for clinical purposes. No animal studies or clinical tests were required for validation of the software.

10

7.1 Training Datasets

For DeepContour, the deep learning models were trained on a pool of training data that did not include any patients from the same institution as the test subjects. The data was collected from 35 hospitals across China over a period of about 3 years. The data collection time is random, including patients with different ages, races, size, et al. Data collected in a hospital tends to be a collection of consecutive cases. Due to the different time periods applicable to different hospitals, the time for collecting data varies among different hospitals. The specific patient subgroups were not the special consideration when collecting the patients' data.

The training data included 800 CT images (200 for each region of head and neck region, chest region, abdomen region and pelvic region) at various ages, no ethnicities or genders were excluded from training. Within 200 cases collected in each region, 160 cases were used for training and 40 cases were used for validation to establish the auto-segmentation models. The auto-segmentation process includes two steps: first step to distinguish the four different regions (head and neck region, chest region, abdomen region and pelvic region), second step to call the model of this region to realize auto-segmentation. The initial segmentations were then reviewed and corrected by two radiation oncologists for model training, with a third qualified internal staff member available to adjudicate if needed.

# of Datasets800
Data Origin35 hospitals across China
SexMale:372
Female:428
Age70:70
Unknown:26 (unknown due to data minimization on customer site)
Body RegionHead and neck region: 200
chest region: 200
abdomen region: 200
pelvic region: 200
CT ScannerPhilips: 301
GE: 226
Simens: 128
Unknown:145 (unknown due to data minimization on customer site)

|--|

11

7.2 Verification datasets

The performance of the DeepContour were verified by a total of 203 CT images with 2 datasets:

(1) clinical datasets retrospectively collected from multiple clinical regions across the Peking Union Medical College Hospital (N=100), consisting of four selected parts based on their location, 25 cases for head and neck, 25 cases for chest, 25 cases for abdomen and 25 cases for pelvic; These clinical datasets are not used in the training datasets at all. (2) American public datasets (N=103);

(a)The 2017 lung CT segmentation challenge (LCTSC), which contains 60 thoracic CT scan patients with five segmented organs (left lung, right lung, heart, spinal cord, and esophagus), (b) Pancreas-CT (PCT), which contains 43 abdominal contrast enhanced CT scan patients with seven segmented organs (the spleen, left kidney, esophagus, liver, stomach, pancreas, and duodenum). The American public datasets were annotated by the American doctors. The article was published in the journal (Medical Physics), doi: 10.1002/mp.14131. (Please refer to more information about the two publicly available datasets: https://wiki.cancerimagingarchive.net/pages/viewpage.action?pageId=24284539, https://wiki.cancerimagingarchive.net/display/Public/Pancreas-CT)

The auto-segmentation process is the same with what was applied to the training dataset with two steps: first step to distinguish the four different regions (head and neck region, chest region, abdomen region and pelvic region), second step to call the model of this region to realize auto-segmentation. The ground truth annotations for the 100 cases in China were established by two different radiation oncologists with more than 10 years of clinical practice (See Appendix 2 for their detailed CVs) following RTOG and clinical guidelines using manual annotation. A third qualified internal staff member is also available to adjudicate if needed. American public datasets (N=103) were annotated by the American doctors.

The CT images in the 100 test cases were curated for suitability and to avoid bias through rich pre-processing and post-processing methods. Due to the differences between patients and the differences in CT machine image data, the data augmentation was used during training to simulate possible data situations in clinical practice, thereby increasing the model's generalization ability. The strategy of first localization and then segmentation is also used to improve the accuracy of the model.

# of Datasets100103
Data OriginPeking Union Medical
College HospitalThe 2017 lung CT segmentation
challenge (LCTSC): 60
Pancreas-CT (PCT): 43
SexMale: 43
Female: 57Unknow:103 (unknown due to data
minimization on customer site)

Table 3: Verification Data Information

12

| Age | 70: 23 | |
| Body Region | Head and neck region: 25 | 60 thoracic CT scan: 5 segmented
organs (left lung, right lung, heart, spinal
cord, and esophagus) |
| | chest region: 25 | |
| | abdomen region: 25 | 43 abdominal CT scan: 7 segmented
organs (the spleen, left kidney, esophagus,
liver, stomach, pancreas, and duodenum) |
| | pelvic region: 25 | |
| CT Scanner | Philips: 34 | Unknown 103 (unknown due to data
minimization on customer site) |
| | GE: 36 | |
| | Simens: 30 | |

7.3 Rigid and deformable registration

The rigid and deformable registration methods are mainly used for contour mapping in the delineation of target areas and organs at risk. The following Table showed the results between planning CT images (moving image) and CBCT images (Fixed images), rpCT represents rigid planning CT, dpCT1 represents deformed planning CT with our algorithms, and dpCT2 represents deformed planning CT with predicate device. The metrics include the mean absolute error (MAE), root mean square error (RMSE), peak signal-to-noise ratio (PSNR), and structural similarity (SSIM).

rpCT-CBCTdpCT1- CBCTdpCT2- CBCT
MAE(HU)51.23±13.6743.98±10.7446.71±12.71
RMSE121.09±30.23117.58±28.22127.96±30.76
PSNR20.01±2.7422.23±2.6120.00±3.77
SSIM0.623±0.0840.680±0.0500.685±0.055

Table 4: Rigid and deformable registration

7.4 Performance comparison

The mean and standard deviation of Dice coefficients was calculated for each organ in the subject device compared with the predicate device. The results of the subject device demonstrate equivalent or better performance compared to the predicate device when aggregate performance over all organs is considered with known limitations described in the labeling. Here equivalence is defined such that the lower bound of 95th percentile confidence interval of the subject device segmentation is greater than 0.1 Dice lower than the mean of predicate device segmentation.

13

Dice coefficients of 100 clinical datasets collected from multiple clinical regions across the Peking Union Medical College Hospital compared to the predicate device are presented here:

| Structure: | DeepContour | AI-Rad CAI-Rad
Companion Organs RT
(K221305) | Contour ProtégéAI
(K223774) |
|--------------------------|---------------------|----------------------------------------------------|--------------------------------|
| Brain | 0.98±0.01(0.97) | 0.93±0.11 | 0.98 ± 0.01 |
| BrainStem | 0.91±0.03(0.89) | 0.90±0.02 | 0.82 ± 0.09 |
| Cochlea_L | 0.86±0.03(0.84) | 0.84±0.03 | 0.27 ± 0.17 |
| Cochlea_R | 0.85±0.01(0.84) | 0.86±0.07 | 0.29 ± 0.18 |
| Eye_L | 0.89±0.02(0.88) | 0.81±0.06 | 0.87 ± 0.06 |
| Eye_R | 0.88±0.03(0.86) | 0.89±0.13 | 0.87 ± 0.06 |
| Lens_L | 0.89±0.02(0.88) | 0.85±0.05 | 0.61±0.17 |
| Lens_R | 0.88±0.02(0.85) | 0.81±0.12 | 0.63 ± 0.15 |
| Larynx | 0.88±0.03(0.83) | 0.84±0.08 | 0.50 ± 0.16 |
| Larynx_extend | 0.92±0.02(0.91) | 0.90±0.11 | None |
| Mandible | 0.95±0.02(0.91) | 0.91±0.07 | 0.85 ± 0.07 |
| Optic_Chiasm | 0.88±0.03(0.82) | 0.63±0.11 | 0.12±0.11 |
| OpticalNerve_L | 0.86±0.04(0.79) | 0.66±0.06 | 0.53 ± 0.13 |
| OpticalNerve_R | 0.89±0.02(0.81) | 0.59±0.10 | 0.52 ± 0.12 |
| OralCavity | 0.92±0.03(0.89) | 0.82±0.09 | 0.77 ± 0.12 |
| OralCavity_WithGum | 0.91±0.06(0.89) | 0.71±0.06 | None |
| Parotid_L | 0.88±0.05(0.82) | 0.80±0.15 | 0.80 ± 0.10 |
| Parotid_R | 0.86±0.03(0.81) | 0.81±0.04 | 0.80 ± 0.06 |
| Pituitary | 0.78±0.04(0.69) | 0.68±0.14 | 0.49±0.15 |
| Temporal_Lobe_L | 0.92±0.02(0.90) | 0.82±0.09 | 0.68 ± 0.17 |
| Temporal_Lobe_R | 0.91±0.11(0.86) | 0.81±0.07 | 0.79 ± 0.18 |
| TMJ_L | 0.85±0.02(0.83) | 0.84±0.02 | 0.84± 0.06 |
| TMJ_R | | | |
| | 0.86±0.15(0.81) | 0.85±0.15 | 0.83 ± 0.06 |
| InternalAcousticCanal_L | 0.76±0.02(0.71) | 0.73±0.12 | 0.71 ± 0.17 |
| InternalAcousticCanal_R | 0.79±0.02(0.75) | 0.77±0.05 | 0.73±0.15 |
| MiddleEar_L | 0.82±0.12(0.78) | 0.72±0.02 | 0.70±0.16 |
| MiddleEar_R | 0.85±0.03(0.81) | 0.80±0.13 | 0.77 ± 0.17 |
| TemporalLobe_withHippo_L | 0.89±0.08(0.85) | 0.87±0.14 | 0.85 ± 0.18 |
| TemporalLobe_withHippo_R | 0.90±0.05(0.86) | 0.88±0.09 | 0.87 ± 0.06 |
| Submandibular_L | 0.91±0.06(0.88) | 0.81±0.11 | 0.75 ± 0.10 |
| Submandibular_R | 0.92±0.03(0.89) | 0.72±0.16 | 0.74±0.09 |
| PharyngealConstrictors_U | 0.82±0.12(0.76) | 0.77±0.13 | None |
| PharyngealConstrictors_M | 0.86±0.14(0.83) | 0.76±0.11 | None |
| PharyngealConstrictors_L | 0.84±0.17(0.80) | 0.74±0.07 | None |
| BrachialPlexus_L | 0.81±0.13(0.79) | 0.71±0.08 | 0.37±0.13 |
| BrachialPlexus_R | 0.82±0.11(0.69) | 0.52±0.06 | 0.36±0.16 |
| Hippocampus_L | 0.76±0.03(0.73) | 0.75 ± 0.12 | 0.75 ± 0.02 |
| Hippocampus_R | 0.79±0.02(0.76) | 0.73 ± 0.09 | 0.76 ± 0.02 |
| EustachianTubeBone_L | 0.85±0.05(0.84) | 0.81±0.05 | 0.88 ± 0.07 |
| EustachianTubeBone_R | 0.87±0.07(0.80) | 0.77±0.09 | 0.72 ± 0.17 |
| TympanicCavity_L | 0.84±0.03(0.83) | 0.80±0.13 | 0.75 ± 0.15 |
| TympanicCavity_R | 0.86±0.09(0.81) | 0.76±0.05 | 0.74 ± 0.17 |
| Vestibule_L | 0.85±0.06(0.82) | 0.80±0.16 | 0.79 ± 0.10 |
| Vestibule_R | 0.87±0.02(0.86) | 0.77±0.10 | 0.74±0.10 |
| InnerEar_L | 0.87±0.10(0.83) | 0.83±0.11 | 0.82 ± 0.07 |
| InnerEar_L | 0.86±0.13(0.83) | 0.87±0.03 | 0.91 ± 0.07 |
| Lung_L | 0.98±0.05(0.96) | 0.92±0.16 | 0.96 ± 0.02 |
| Lung_R | 0.99±0.03(0.98) | 0.95±0.08 | 0.96 ± 0.02 |
| Lung_All | 0.98±0.14(0.97) | 0.91±0.04 | None |
| Heart | 0.93±0.16(0.90) | 0.91±0.06 | 0.90 ± 0.07 |
| Trachea | 0.89±0.03(0.88) | 0.89±0.03 | 0.73 ± 0.17 |
| Esophagus | 0.88±0.11(0.85) | 0.78±0.07 | 0.70 ± 0.15 |
| Breast_L | 0.92±0.08(0.86) | 0.82±0.05 | 0.74 ± 0.17 |
| Breast_R | 0.93±0.01(0.92) | 0.83±0.04 | 0.77 ± 0.10 |
| Aorta | 0.89±0.09(0.87) | 0.70 ± 0.08 | 0.74 ± 0.10 |
| Liver | 0.96±0.07(0.95) | 0.86±0.17 | 0.93 ± 0.07 |
| Kidney_L | 0.92±0.03(0.91) | 0.82±0.13 | 0.92 ± 0.05 |
| Kidney_R | 0.93±0.04(0.91) | 0.88±0.07 | 0.91 ± 0.06 |
| Duodenum | 0.88±0.16(0.83) | 0.81±0.012 | None |
| Pancreas | 0.86±0.01(0.86) | 0.87±0.03 | 0.45 ± 0.22 |
| Smallintestine | 0.89±0.12(0.85) | 0.88±0.08 | None |
| Bowelbag | 0.93±0.16(0.88) | 0.83 ± 0.08 | 0.68 ± 0.08 |
| Bladder | 0.95±0.15(0.93) | 0.87±0.15 | 0.52 ± 0.19 |
| Stomach | 0.86±0.01(0.86) | 0.79 ± 0.21 | 0.81 ± 0.11 |
| Femur_Head_L | 0.92±0.12(0.89) | 0.90±0.16 | 0.93 ± 0.05 |
| Femur_Head_R | 0.91±0.14(0.86) | 0.90±0.09 | 0.93 ± 0.04 |
| Pelvis | 0.87±0.01(0.87) | 0.88±0.08 | 0.93 ± 0.11 |
| Marrow | 0.85±0.13(0.84) | 0.81±0.03 | None |
| Sigmoid | 0.82±0.02(0.81) | 0.70 ± 0.17 | 0.60 ± 0.26 |
| Rectum | 0.87±0.15(0.83) | 0.73 ± 0.18 | 0.83 ± 0.11 |
| Spleen | 0.91±0.01(0.90) | 0.92±0.07 | 0.95 ± 0.03 |
| SeminalVesicle | 0.86±0.02(0.85) | 0.78 ± 0.27 | 0.68 ± 0.15 |
| Testis | 0.87±0.03(0.84) | 0.79 ± 0.16 | 0.63 ± 0.16 |
| Prostate | 0.87±0.02(0.85) | 0.74 ± 0.12 | 0.85 ± 0.06 |
| Ovid_L | $0.85\pm0.03(0.82)$ | $0.65\pm0.03$ | $0.39 \pm 0.17$ |
| Ovid_R | $0.86\pm0.01(0.85)$ | $0.66\pm0.01$ | $0.43 \pm 0.15$ |
| Bladder-Brt | $0.86\pm0.02(0.84)$ | $0.82 \pm 0.23$ | $0.91 \pm 0.12$ |
| SmallIntestine-Brt | $0.87\pm0.04(0.85)$ | $0.76 \pm 0.14$ | $0.73 \pm 0.11$ |
| Rectum-Brt | $0.86\pm0.03(0.84)$ | $0.85 \pm 0.18$ | $0.83 \pm 0.11$ |
| Sigmoid-Brt | $0.79\pm0.02(0.78)$ | $0.70 \pm 0.17$ | $0.60 \pm 0.26$ |
| SpinalCord | $0.93\pm0.01(0.92)$ | $0.66 \pm 0.14$ | $0.63\pm0.16$ |
| Body | $0.98\pm0.05(0.96)$ | $0.97\pm0.03$ | None |

Table 5: Clinical performance comparison (Peking Union Medical College Hospital)

14

15

16

Data format: Mean ± Std Dice coefficient (lower 95th percentile confidence bound based on normal distribution in parentheses)

Dice coefficients of LCTSC American public datasets compared to the predicate device are presented here:

| Structure: | DeepContour | AI-Rad CAI-Rad
Companion Organs RT
(K221305) | Contour
ProtégéAI
(K223774) |
|------------|-----------------|----------------------------------------------------|-----------------------------------|
| SpinalCord | 0.92±0.02(0.91) | 0.64±0.13 | 0.62 ± 0.21 |
| Lung L | 0.97±0.15(0.96) | 0.90±0.13 | 0.95 ± 0.05 |
| Lung R | 0.98±0.06(0.98) | 0.93±0.11 | 0.94 ± 0.08 |
| Heart | 0.92±0.11(0.90) | 0.91±0.04 | 0.90 ± 0.04 |
| Esophagus | 0.89±0.13(0.86) | 0.75±0.13 | 0.68 ± 0.19 |

Table 6: Clinical performance comparison (LCTSC American public datasets)

Data format: Mean ± Std Dice coefficient (lower 95th percentile confidence bound based on normal distribution in parentheses)

Dice coefficients of Pancreas-CT American public datasets compared to the predicate device are presented here:

Table 7: Clinical performance comparison (Pancreas-CT American public datasets)

17

| Structure: | DeepContour | AI-Rad CAI-Rad
Companion Organs RT
(K221305) | Contour
ProtégéAI
(K223774) |
|------------|-----------------|----------------------------------------------------|-----------------------------------|
| Spleen | 0.90±0.05(0.88) | 0.91±0.12 | 0.89 ± 0.08 |
| Pancreas | 0.85±0.03(0.83) | 0.84±0.02 | 0.43 ± 0.25 |
| Kidney_L | 0.93±0.02(0.91) | 0.84±0.03 | 0.92 ± 0.17 |
| Esophagus | 0.88±0.02(0.87) | 0.80±0.06 | 0.70 ± 0.06 |
| Liver | 0.97±0.03(0.97) | 0.85±0.13 | 0.92 ± 0.06 |
| Stomach | 0.85±0.02(0.84) | 0.80±0.05 | 0.81 ± 0.17 |
| Duodenum | 0.86±0.02(0.85) | 0.82±0.12 | None |

Data format: Mean ± Std Dice coefficient (lower 95th percentile confidence bound based on normal distribution in parentheses)

A comparison of the median Average Symmetric Surface Distance (ASSD) between the subject device and the predicate device is also performed and the results are comparable as shown in the following table. The subject device achieved a median ASSD of 0.95 in comparison to the predicate device achieving a median ASSD of 0.96 for existing organs.

Table 8: Rigid and deformable registration

| | DeepContour | | AI-Rad CAI-Rad
Companion Organs RT
(K221305) | | Contour ProtégéAI
(K223774) | |
|------|-------------|-----------------------|----------------------------------------------------|-----------------------|--------------------------------|-----------------------|
| | Median | 95% CI
(Bootstrap) | Median | 95% CI
(Bootstrap) | Median | 95% CI
(Bootstrap) |
| ASSD | 0.95 | [0.85,1.13] | 0.96 | [0.84,1.15] | 0.95 | [0.86,1.17] |

8 CONCLUSION

DeepContour is believed to be substantially equivalent to predicate device in terms of its indications for use, technical characteristics, and overall performance. The information provided in this submission indicates the subject device is as safe, is as effective, and performs as well as predicate device. Therefore, it is in the opinion of Wisdom Technologies, Inc. that the medical device, DeepContour, is substantially equivalent to predicate device.