K Number
K242496
Device Name
Portable Liver Elastography Ultrasound Diagnostic System (Liverscan C)
Date Cleared
2024-11-19

(89 days)

Product Code
Regulation Number
892.1560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease. The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter). The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver. This device is designed to be used in a doctor's office to measure the stiffness and ultrasonic attenuation of the liver in patients with liver disease. It does so in a painless and completely noninvasive manner.
Device Description
The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease. The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter). The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver.
More Information

Not Found

No
The summary describes a device that measures physical properties (shear wave speed, stiffness, and attenuation) using ultrasound. There is no mention of AI, ML, or any data-driven algorithms for interpretation or analysis beyond these direct measurements.

No.

The device is intended for diagnosis and monitoring of liver disease, not for direct treatment.

Yes
The "Intended Use / Indications for Use" section explicitly states that "The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease".

No

The device description and performance studies mention electrical safety, electromagnetic compatibility, and basic safety and essential performance testing, which are typically associated with hardware components, not solely software. The device also utilizes ultrasound, which requires hardware for image acquisition.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the examination of specimens derived from the human body (such as blood, urine, or tissue) to provide information for diagnostic purposes.
  • Liverscan C Function: The Liverscan C is described as a non-invasive device that uses ultrasound to measure shear wave speed, tissue stiffness, and ultrasound attenuation directly within the liver of a patient. It does not analyze specimens taken from the body.
  • Intended Use: The intended use clearly states it's for "non-invasive measurement in the liver" and is used "in a doctor's office to measure the stiffness and ultrasonic attenuation of the liver in patients with liver disease." This is a direct measurement on the patient, not an analysis of a sample.

Therefore, the Liverscan C falls under the category of a medical device that performs in-vivo measurements, not an in-vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease.

The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter).

The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver.

Product codes

IYO, ITX

Device Description

The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease.

The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter).

The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound

Anatomical Site

Liver (internal structures of the body)

Indicated Patient Age Range

Adult patients

Intended User / Care Setting

Used in a doctor's office.
Operator shall meet the following requirements:

  1. Receive training as required by local, state and national requlations, if applicable
  2. Receive additional training as required by the authorized distributor or EIELING
  3. Has a thorough knowledge and understanding of the material presented in this manual

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)

Bench tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  1. Electrical safety: IEC6060-1:2005+A1:2012+A2:2020
  2. Electromagnetic compatibility(EMC): IEC 60601-1-2:2014 /AMD1:2020
  3. Basic Safety And Essential Performance: IEC 60601-2-37: Edition 2.1 2015, IEC 62359: 2017, IEC 61161: Edition 3.0 2013-01, IEC 60601-1-6 :2010+A1:2013+A2:2020, IEC 62366-1 Edition 1.0 2015-02.
  4. Software Verification and Validating Testing: conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."

A series of safety and performance tests were conducted on the subject device: Software Validation, Electromagnetic compatibility and electrical safety, Function test. All the test results demonstrate the Liverscan C meets the requirements of its pre-defined acceptance criteria and intended uses, and is substantially equivalent to the predicate devices.

No clinical test data was used to support the decision of substantial equivalence.

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

Not Found

Predicate Device(s)

K233401

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.1560 Ultrasonic pulsed echo imaging system.

(a)
Identification. An ultrasonic pulsed echo imaging system is a device intended to project a pulsed sound beam into body tissue to determine the depth or location of the tissue interfaces and to measure the duration of an acoustic pulse from the transmitter to the tissue interface and back to the receiver. 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 biopsy needle guide kit intended for use with an ultrasonic pulsed echo imaging 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

November 19, 2024

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo 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.

Eieling Technology (Shenzhen) Limited % Salon Chen System Engineer IMD Medical & Drug Technology Service Institutions Room 308, Building 11, No. 23 Jinqu Road, Wanjiang District, Dongguan City, Guangdong Province, 523069 CHINA

Re: K242496

Trade/Device Name: Portable Liver Elastography Ultrasound Diagnostic System (Liverscan C) Regulation Number: 21 CFR 892.1560 Regulation Name: Ultrasonic Pulsed Echo Imaging System Regulatory Class: Class II Product Code: IYO / ITX Dated: August 22, 2024 Received: August 22, 2024

Dear Salon Chen:

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"

1

(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 product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS 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.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

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.

2

For comprehensive regulatory information about mediation-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-regulatory-

assistance/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,

Marjan Nabili -S

for

Yanna Kang, Ph.D. Assistant Director Mammography and Ultrasound 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

Enclosure

3

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.

Submission Number (if known)

K242496

Device Name

Portable Liver Elastography Ultrasound Diagnostic System (Liverscan C)

Indications for Use (Describe)

The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease.

The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter).

The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver.

This device is designed to be used in a doctor's office to measure the stiffness and ultrasonic attenuation of the liver in patients with liver disease. It does so in a painless and completely noninvasive manner.

To ensure safe and effective operation, the operator shall meet the following requirements:

    1. Receive training as required by local,state and national requlations, if applicable
    1. Receive additional training as required by the authorized distributor or EIELING
    1. Has a thorough knowledge and understanding of the material presented in this manual

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

Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

4

K242496

510(k) Summary

1. Submitter's Identification:

  • Company Name: Eieling Technology(Shenzhen) Limited

  • Address: RM 610, Building E, Qihang Innovation Development Park, No. 1008 Songbai Road, Yangguang Community,Xili Street Nanshan District, Shenzhen, P.R. China

  • Phone: +86 0755-23100816/15919830132

  • Fax: +852 6103 2309 >
  • Contact Person (Title): like wang (General Manager) >
  • E-mail: mzzhu@eieling.com

  • Date of Preparation: Aug. 22, 2024

    1. Name of the Device:
  • Portable Liver Elastography Ultrasound Diagnostic System

  • Model: Liverscan C

3. Common Name and Classification:

  • Device Classification Name: system, imaging, pulsed echo, ultrasonic

  • Classification Product Code: IYO

  • Subsequent Product Code: ITX

  • Regulation Number:21 CFR 892.1560

  • Class:2

  • A Review Panel: Radiology

Predicate Device Information: 4.

  • 510(k) Number: K233401

  • Device Classification Name: system, imaging, pulsed echo, ultrasonic

  • Sponsor:Eieling Technology (Shenzhen) Limited

  • Classification Product Code: IYO

5

  • Subsequent Product Code: ITX

  • Regulation Number:21 CFR 892.1560

  • Class:2

  • A Review Panel: Radiology
  • Trade/Proprietary Name: Liverscan Mobile

  • A Common Name: Portable Liver Elastography Ultrasound Diagnostic System
  • Application Correspondent న్.
  • Company Name: IMD Medical & Drug technology service institutions A
  • Phone: +86-18613190779

  • Fax: +86-755-62809168 >
  • Contact Person (Title): Salon Chen (System engineer)

  • E-mail: 33999439@qq.com >
  • Address: Room 308, Building 11, No. 23 Jinqu Road, Wanjiang District, Dongguan City, A Guangdong Province, China

Device Description 6.

The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease.

The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter).

The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver.

7. Indications for Use

The Liverscan C is intended to provide shear wave speed measurements and estimates of tissue stiffness as well as ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter) in

6

internal structures of the body. The shear wave speed and stiffness measurements may be used as an aid to clinical management of adult patients with liver disease.

The Liverscan C is indicated for non-invasive measurement in the liver of 50 Hz shear wave speed and estimates of stiffness as well as determining a 3.5MHz ultrasound coefficient of attenuation (MAP: Mobile Attenuation Parameter).

The shear wave speed and stiffness, and MAP may be used as an aid to diagnosis and monitoring of adult patients with liver disease, as part of an overall assessment of the liver.

This device is designed to be used in a doctor's office to measure the stiffness and ultrasonic attenuation of the liver in patients with liver disease.It does so in a painless and completely non-invasive manner.

To ensure safe and effective operation,the operator shall meet the following requirements:

  • 1 ) Receive training as required by local,state and national regulations,if applicable
  • 2 ) Receive additional training as required by the authorized distributor or EIELING
  • 3 ) Has a thorough knowledge and understanding of the material presented in this manual

8. Comparison to the predicate device

Table 1 General Comparison

| Elements of

ComparisonProposed DevicePredicate DeviceJudgment
Company
NameEieling Technology (Shenzhen)
LimitedEieling Technology Limited/
Device
NamePortable Liver Elastography
Ultrasound Diagnostic SystemPortable Liver Elastography
Ultrasound Diagnostic System/
Classificatio
n Product
CodeIYOIYOSE
Subsequent
Product
CodesITXITXSE
Regulation21 CFR 892.156021 CFR 892.1560SE
Classificatio
n Namesystem, imaging, pulsed echo,
ultrasonicsystem, imaging, pulsed echo,
ultrasonicSE
Class22SE
Prescription
or OTCPrescription UsePrescription UseSE
ApplicationAbdominalAbdominalSE
UltrasoundPiezoelectric ultrasound sourcePiezoelectric ultrasound sourceSE
Intended
UseThe Liverscan C is intended to provide
shear wave speed measurements and
estimates of tissue stiffness as well as
ultrasound coefficient of attenuation
(MAP: Mobile Attenuation Parameter)
in internal structures of the body. The
shear wave speed and stiffness
measurements may be used as an aid to
clinical management of adult patients
with liver disease.

The Liverscan C is indicated for
non-invasive measurement in the liver
of 50 Hz shear wave speed and
estimates of stiffness as well as
determining a 3.5MHz ultrasound
coefficient of attenuation (MAP: Mobile
Attenuation Parameter).

The shear wave speed and stiffness, and
MAP may be used as an aid to diagnosis
and monitoring of adult patients with
liver disease, as part of an overall
assessment of the liver. | The Liverscan Mobile is intended to provide shear wave speed
measurements and estimates of tissue
stiffness as well as ultrasound
coefficient of attenuation (MAP:
Mobile Attenuation Parameter) in
internal structures of the body. The
shear wave speed and stiffness
measurements may be used as an aid to
clinical management of adult patients
with liver disease.

The Liverscan Mobile is indicated for
non-invasive measurement in the liver
of 50 Hz shear wave speed and
estimates of stiffness as well as
determining a 3.5MHz ultrasound
coefficient of attenuation (MAP:
Mobile Attenuation Parameter).

The shear wave speed and stiffness, and
MAP may be used as an aid to
diagnosis and monitoring of adult
patients with liver disease, as part of an
overall assessment of the liver. | SE |
| Safety factor &
Performance | Proposed Device | Predicate Device | Judgment |
| Electrical
Safety | Compliance with IEC 60601-1 | Compliance with IEC 60601-1 | SE |
| EMC | Compliance with IEC
60601-1-2 | Compliance with IEC 60601-1-2 | SE |
| Usability | Compliance with IEC
60601-1-6 | Compliance with IEC 60601-1-6 | SE |
| Usability
Engineering | Compliance with IEC 62366-1 | Compliance with IEC 62366-1 | SE |
| Software | Compliance with IEC 62304 | Compliance with IEC 62304 | SE |
| Biocompatiblity | Compliance with ISO 10993-1 | Compliance with ISO 10993-1 | SE |
| Performance | Compliance with IEC
60601-2-37/ IEC 62359: 2017/
IEC 61161 | Compliance with IEC 60601-2-37/
IEC 62359: 2017/ IEC 61161 | SE |
| Imaging Modes | B-mode
Transient Elastography (TE) | B-mode
Transient Elastography (TE) | SE |
| Probes | LS01 probe (3.5 MHz) | LS01 probe (3.5 MHz) | SE |
| Depth Analysis
Method | 25-65 / 35-75 mm | 25-65 / 35-75 mm | SE |
| TE Mode | Shear wave speed
measurements and tissue
stiffness | Shear wave speed measurements and
tissue stiffness | SE |
| TE Range | Shear wave speed (0.7-5.0 m/s)
Stiffness (1.5-75 kPa) | Shear wave speed (0.7-5.0 m/s)
Stiffness (1.5-75 kPa) | SE |
| TE Display | Shear wave speed and stiffness
medians and IQR/median ratio | Shear wave speed and stiffness
medians and IQR/median ratio | SE |
| Attenuation
Mode | Mobile Attenuation
Parameter(MAP) | Mobile Attenuation Parameter(MAP) | SE |
| Safety factor &
Performance | Proposed Device | Predicate Device | Judgment |
| Attenuation
Range | MAP value (100-400 dB/m) | MAP value (100-400 dB/m) | SE |
| Attenuation
Display | MAP median and IQR | MAP median and IQR | SE |
| Attenuation
Display -
Probes
compatibility | LS01 Probe | LS01 Probe | SE |
| Size and
Weight | 522mm x 492mm x 265mm
(Lx W x H)
8.0kg with accessories | 525mm x 175mm x 315mm
(Lx W x H)
4.15kg with accessories | Note 1 |
| Power supply | 100-240 V ~ 50-60 Hz | 100-240 V ~ 50-60 Hz | SE |
| Core
Component | Elastography engine
Analog front end High
frequency (US): Transducer
3.5L3213A-001
Analog front end Low
frequency (servo control):
Transducer 3.5L3213A-001 | Elastography engine
Analog front end High frequency
(US): Transducer 3.5L3213A-001
Analog front end Low frequency
(servo control): Transducer
3.5L3213A-001 | SE |
| Operating
system | Windows 10 Embedded | Windows 10 Embedded | SE |
| Screen | Size: Minimum 13 inches or
above
Resolution: 1920 X 1080 | Size: Minimum 13 inches or above
Resolution: 1920 X 1080 | SE |
| Internet | / | / | SE |
| Safety factor &
Performance | Proposed Device | Predicate Device | Judgment |
| Battery | Rechargeable Li-ion battery pack (Model:XDD-SNP5600) | Rechargeable Li-ion battery pack (Model:18650) | Note 2 |
| Accessories | N/A | N/A | N/A |

7

Table 2 Safety factor & Performance Comparison

8

9

10

As shown in the above comparison Table, Portable Liver Elastography Ultrasound Diagnostic System in similarity to the predicate device. Accordingly, we are substantially equivalent to the predicate device Liverscan Mobile (K233401).

Design and Technology - The basic design and technology of providing Portable Liver

Elastography Ultrasound Diagnostic System is the same or similar.

Performance and Specifications - The subject device has similar Portable Liver Elastography

Ultrasound Diagnostic System and specifications to the

predicate device.

Indications - The indications include in. the predicate device scope.

Review of Differences:

Note 1:

Differences in weight and size between the predicate device and the proposed device do not affect the safety and effectiveness of the product.

Note 2:

The built-in lithium battery model is not the same, in line with IEC62133

Bench tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

1) Electrical safety

IEC6060-1:2005+A1:2012+A2:2020 Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance.

11

2) Electromagnetic compatibility(EMC)

IEC 60601-1-2:2014 /AMD1:2020 Medical Electrical Equipment -- Part 1-2: General Requirements For Basic Safety And Essential Performance -- Collateral Standard: Electromagnetic Disturbances -- Requirements And Tests.

3) Basic Safety And Essential Performance

IEC 60601-2-37: Medical Electrical Equipment - Part 2-37: Particular Requirements for The Basic Safety And Essential Performance Of Ultrasonic Medical Diagnostic And Monitoring Equipment; Edition 2.1 2015.

IEC 62359: 2017 Ultrasonics - Field characterization - Test methods for the determination of thermal and mechanical indices related to medical diagnostic ultrasonic field

IEC 61161: Ultrasonics -- Power Measurement -- Radiation Force Balances and Performance Requirements; Edition 3.0 2013-01.

IEC 60601-1-6 :2010+A1:2013+A2:2020 Medical Electrical Equipment - Part 1-6: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Usability. IEC 62366-1 Edition 1.0 2015-02: Medical Devices - Application of Usability Engineering To Medical Devices.

4) Software Verification and Validating Testing

Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."

9. Discussion of Non-clinical Tests Performed for Determination of Substantial Equivalence are as follows:

The proposed device is the same as the predicate device but the two devices are different. A series of safety and performance tests were conducted on the subject device: Software Validation

12

Electromagnetic compatibility and electrical safety

Function test

All the test results demonstrate the Liverscan C meets the requirements of its pre-defined acceptance criteria and intended uses, and is substantially equivalent to the predicate devices.

10. Clinical Tests Performed

No clinical test data was used to support the decision of substantial equivalence.

11. Conclusion

The subject devices have all features of the predicate devices. The few differences do not affect the safety and effectiveness of the subject devices.

Thus, the subject devices are substantially equivalent to the predicate devices.