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510(k) Data Aggregation

    Why did this record match?
    Device Name :

    CHISON DIAGNOSTIC ULTRASOUND SYSTEM, CONVEX PROBE, LINEAR PROBE, PHASED AND CONVEX PROBE, PENCIL AND

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The device is a general-purpose ultrasonic imaging instrument intended for use by a qualified physician for evaluation of Fetal/OB; Abdominal (GYN & Urology); Pediatric; Small Organ(breast, testes, thyroid); Neonatal Cephalic; Adult Cephalic; Cardiac (adult & pediatric); Peripheral Vascular, Musculo-skeletal Conventional & Superficial, Transvaginal.

    Device Description

    The Q6/Q8/Q9/Q10/i7/i8 /i9 ultrasound system is an integrated preprogrammed color doppler ultrasound imaging system, capable of producing high detail resolution intended for clinical diagnostic imaging applications. The CHISON ultrasound system can be configured either as a portable model (Q6/Q8/Q9/Q10), or as a roll-around model on wheels (i7/i8/i9). These systems are designed with the latest technology, using the same quality procedure as ultrasound systems which have been available in the market for years. This CHISON ultrasound system is a general purpose, software controlled, diagnostic ultrasound system. Its basic function is to acquire ultrasound echo data and display the image in B-Mode (including Tissue Harmonic Imaging), M-Mode, Pulsed (PW) Doppler Mode, Continuous (CW) Doppler Mode, Color Doppler Mode, Power Doppler Mode, Directional Power Doppler Mode, TDI Mode or a combination of these modes.3D/4D.

    AI/ML Overview

    The provided 510(k) submission for the CHISON Q Series & i7, i8, i9 Diagnostic Ultrasound System primarily focuses on demonstrating substantial equivalence to predicate devices, rather than presenting a de novo study with specific performance acceptance criteria and a detailed study proving those criteria are met in the way requested.

    The submission claims substantial equivalence by showing that the proposed device has the same intended use, basic operating modes, and similar design principles as the predicate devices (GE Voluson E6/E8/E8 Expert K101236 and CHISON iVis60EXPERT, Q6/Q8, i7 K120801). The "Modifications and Newly Added Features" (new transducers and software options) are also claimed to be substantially equivalent.

    No explicit acceptance criteria or a dedicated performance study against such criteria are presented in the document. Instead, the device's conformance to safety standards and comparison to predicate device specifications are used as the basis for demonstrating safety and effectiveness.

    Here's an analysis based on the provided text, addressing the requested information to the extent possible:


    1. Table of Acceptance Criteria and Reported Device Performance

    As stated above, no explicit acceptance criteria for individual performance metrics (e.g., sensitivity, specificity, accuracy for a specific diagnostic task) are defined or reported. The "acceptance criteria" in this context are implicitly that the device performs equivalently to the predicate devices and meets relevant safety standards.

    Feature / MetricAcceptance Criteria (Implicit)Reported Device Performance
    Indications for UseSame as predicate devices"Same" as predicate (Voluson E8/E8Expert K101236 and CHISON iVis60EXPERT, Q6/Q8, i7 K120801)
    Operating ModesSame as predicate devices"Same" as predicate (predicates offer B, M, PW, CFM, PD, TD, etc.; submission device adds new modes like 2D Steer, Elastography, Curved Panoramic Imaging, Supper needle, IMT) - claimed substantially equivalent despite additions.
    Safety ComplianceConform to specific IEC and ISO standardsConformity to IEC 60601-1, IEC 60601-1-2, IEC 60601-2-37, NEMA UD 2, NEMA UD3, ISO 10993-1 (biocompatibility).
    Acoustic OutputMax Derated Ispta: 720mW/cm² (Track 3); MI: 1.9 (Track 3)Derated Ispta: 720mW/cm² maximum (Track 3); Mechanical Index: 1.9 maximum (Track 3)
    BiocompatibilityBio-compatible (claimed by predicate)Bio-compatible (claimed by submission device)
    Performance with New Transducers/SoftwareSubstantially equivalent to predicate performance"The results show that these modifications are substantially equivalent to the predicate devices." (No specific metrics provided).
    Image ReverseRange compatible with clinical needsPredicate: Right/Left; Submission: B orientation flip: L/R, U/D (Claimed SE)
    B persistenceRange compatible with clinical needsPredicate (Voluson): 8 steps; Predicate (CHISON): 7 steps; Submission: 0-7 (Claimed SE)
    Frequency SelectionRange compatible with clinical needsPredicate (Voluson): 3 steps; Predicate (CHISON): 5 steps; Submission: 5 steps (Claimed SE)
    Angle CorrectionRange compatible with clinical needsPredicate (Voluson): ± 0-85°, 1° step; Predicate (CHISON): ± 0-72°, 5 step; Submission: ± 0-80°, 5 step (Claimed SE)
    Steered LinearRange compatible with clinical needsPredicate (Voluson): 0°-25°; Predicate (CHISON): 0-20°; Submission: -20°-20° (Claimed SE)
    Color MapsSufficient for clinical visualizationPredicate (Voluson/CHISON): 8 maps; Submission: 9 maps (Claimed SE)
    PD Color MapsSufficient for clinical visualizationPredicate (Voluson): 8 maps; Predicate (CHISON): 4 maps; Submission: 9 maps (Claimed SE)
    Monitor SizeClinically acceptablePredicate (Voluson): 19" LCD; Predicate (CHISON): 15" LCD; Submission: 19" LCD for i7/i8/i9, 15" LCD for Q6/Q8/Q9/Q10 (Claimed SE)
    Transducer ConnectorsSufficient for clinical functionsPredicate (Voluson): 4 ports; Predicate (CHISON i7): 4 ports; Other CHISON: 2-3 ports; Submission: i7/i8/i9: 4 ports, Q10/Q9/Q8/Q6: 2 ports (Claimed SE)
    Power SupplyComply with safety standardsPredicate (Voluson): AC: 100-240V; Predicate (CHISON): AC: 220-240V, 100V, 115-130V; Submission: AC: 100-240V (Complies with IEC 60601-1, 60601-1-2)

    2. Sample Size Used for the Test Set and Data Provenance

    • No specific "test set" in the context of diagnostic performance (e.g., images for measuring sensitivity/specificity) is described. The conformity assessment for the device relies on laboratory testing against engineering specifications and safety standards, as well as a comparison to predicate devices.
    • Data Provenance: Not applicable as no diagnostic performance test set is described.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    • Not applicable. No diagnostic performance study involving expert-established ground truth is presented.

    4. Adjudication Method for the Test Set

    • Not applicable. No diagnostic performance test set requiring adjudication is described.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No MRMC comparative effectiveness study was done. The submission focuses on demonstrating substantial equivalence to pre-existing ultrasound systems based on technical specifications and safety standards, not on assessing the improvement in human reader performance with or without AI assistance. The new software options (Elastography, IMT, Curved Panoramic, Supper needle) are listed as features, but no clinical efficacy data for them is provided.

    6. Standalone (Algorithm Only) Performance Study

    • No standalone performance study was done. The device is a diagnostic ultrasound system, not an AI-only algorithm. The "newly added software options" are features of the ultrasound system, and their performance is subsumed under the general claim of substantial equivalence, without specific standalone performance metrics.

    7. Type of Ground Truth Used

    • Not applicable. For this type of 510(k) submission, "ground truth" related to diagnostic accuracy (e.g., pathology, outcomes data, expert consensus on disease presence) is not typically required or provided unless the device makes a new or significantly modified diagnostic claim that deviates from established predicate devices. The basis for safety and effectiveness is compliance with recognized standards and comparison to a legally marketed equivalent device.

    8. Sample Size for the Training Set

    • Not applicable. The submission does not describe an AI or machine learning component that would require a "training set" in the conventional sense for diagnostic performance.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable. No training set is described.

    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The "study" presented is primarily a non-clinical performance evaluation and a substantial equivalence comparison to predicate devices.

    • Non-Clinical Performance Evaluation: This involved laboratory testing to verify that the system (including new transducers) met all design specifications. This testing also confirmed conformity to various medical device safety standards:

      • IEC 60601-1: 2005 (General Requirements for Safety)
      • IEC 60601-1-2: 2007 (Electromagnetic Compatibility)
      • IEC 60601-2-37: 2007 (Particular Requirements for Ultrasonic Equipment Safety)
      • NEMA UD 2-2004 (Acoustic Output Measurement)
      • NEMA UD3: 2004 (Real-time Display of Acoustic Output Indices)
      • ISO 10993-1 (Biological Evaluation of Medical Devices - Biocompatibility)
    • Substantial Equivalence Comparison (to K101236 and K120801): The submission provides a detailed comparison table (Table 1) highlighting similarities in:

      • Indications for Use
      • Design principles (e.g., autocorrelation for color processing, FFT for Doppler)
      • Operating Controls (e.g., TGC 8 slider, Depth Range, shades of gray)
      • Safety Compliance (adherence to the same IEC/ISO standards)
      • Patient Contact Materials (Bio-compatible)
      • Scanning Modes (Electronic Sector, Convex, Linear, Mechanic Volume Sweep)
      • Operation Modes (B, M, PW, CFM, PD, TD, 3D/4D, etc., including newly added features like Elastography/Curved Panoramic)
      • Display characteristics and annotations
      • Monitor specifications
      • Measurement packages
      • Transducer Types & Connectors
      • Principle of Operation (high voltage burst to piezoelectric material, reflected echo detection)
      • Acoustic Output (matching the predicate's stated maximums for MI and Ispta)

    The conclusion drawn from this comparison is that any differences are minor and do not affect the basic design, usage, effectiveness, or safety, thereby establishing substantial equivalence. No clinical testing was required or performed for this submission.

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    K Number
    K131305
    Date Cleared
    2013-08-01

    (86 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    CHISON DIAGNOSTIC ULTRASOUND SYSTEM, CONVEX PROBE, LINCAR PROBE, PHASED PROBE

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The device is a general-purpose ultrasonic imaging instrument intended for use by a qualified physician for evaluation of Fetal/OB; Abdominal (GYN & Urology); Pediatric; Small Organ (breast, testes, thyroid); Cardiac (adult & pediatric); Peripheral Vascular, Musculo-skeletal Conventional & Superficial, Transrectal and Transvaginal.

    Device Description

    The ECO Series Diagnostic Ultrasound Systems is a very compact and portable diagnostic ultrasound system having five variations: ECO6, ECO5, ECO3, ECO2, and ECO1, each with options and features suited for its market niche. It has an integrated keyboard, LED display and several interchangeable electronic-array transducers and provides digital acquisition, processing and display capability. The user interface includes a keyboard, an intuitive layout of specialized controls, color GUI display.

    AI/ML Overview

    This device is a Diagnostic Ultrasound System and therefore does not include acceptance criteria, as one would typically find for an AI/ML powered device. The document provided is primarily an FDA 510(k) summary for the "ECO Series Diagnostic Ultrasound System," submitted by Chison Medical Imaging Co., Ltd.

    Instead of acceptance criteria and a study to prove performance, this document focuses on substantial equivalence to a predicate device, which is the standard regulatory pathway for many medical devices.

    Here's a breakdown of the relevant information provided:

    1. Table of Acceptance Criteria and Reported Device Performance:

    There is no table of acceptance criteria or reported device performance in the context of an AI/ML device validating specific metrics (e.g., sensitivity, specificity, AUC). Instead, the document states:

    • Acceptance Criteria (Implied): Substantial equivalence to the predicate device in terms of safety and effectiveness, and compliance with applicable safety standards.
    • Reported Device Performance: The device performs general-purpose ultrasonic imaging and fluid flow analysis. Its capabilities are outlined by the clinical applications and modes of operation available for each transducer.

    The device meets its implied acceptance criteria by being shown to be "substantially equivalent in safety and effectiveness to the predicate systems" (GE LOGIQ i, LOGIQ e, and Vivid e Diagnostic Ultrasound (K102256)). The justification for this equivalence includes:

    • Transmits ultrasonic energy into patients.
    • Performs post-processing of received echoes to generate on-screen display of anatomic structures and fluid flow.
    • Has the same intended uses and basic operating modes as the predicate device.
    • Allows for specialized measurements of structures and flow, and calculations.
    • Has the same gray-scale (presumably imaging capabilities).
    • Acoustic output levels are below FDA limits.
    • Designed to applicable electrical and physical safety standards (NEMA UD 2, NEMA UD 3, IEC 60601-1, IEC 60601-1-2, IEC 60601-2-37, IEC 10993-1).

    2. Sample Size Used for the Test Set and Data Provenance:

    Not applicable. This is not a study evaluating an AI/ML algorithm's performance on a test set. This is a premarket notification demonstrating substantial equivalence.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

    Not applicable. No ground truth was established for a test set in the context of an AI/ML algorithm.

    4. Adjudication Method for the Test Set:

    Not applicable. No test set requiring adjudication was used.

    5. Multi-Reader, Multi-Case (MRMC) Comparative Effectiveness Study:

    No MRMC comparative effectiveness study was done. The document does not describe human reader performance or improvements with or without AI assistance.

    6. Standalone (Algorithm Only) Performance Study:

    Not applicable. This is a general-purpose ultrasound system, not an AI/ML algorithm.

    7. Type of Ground Truth Used:

    Not applicable. There is no ground truth established for an algorithm. The "ground truth" for this regulatory submission is the established safety and effectiveness of the predicate device.

    8. Sample Size for the Training Set:

    Not applicable. This device does not involve a "training set" in the AI/ML sense.

    9. How the Ground Truth for the Training Set Was Established:

    Not applicable. No training set or associated ground truth was established.


    Summary of the Study (Substantial Equivalence Justification):

    The "study" in this context is the comparison to predicate device(s).

    • Predicate Device: GE LOGIQ i, LOGIQ e, and Vivid e Diagnostic Ultrasound (K102256).
    • Methodology: The manufacturer presented information demonstrating that the ECO Series Diagnostic Ultrasound Systems share fundamental technological characteristics, intended uses, and operational modes with the legally marketed predicate devices. The comparison highlights similarities in how they transmit and process ultrasonic energy, display anatomical structures and fluid flow, and perform measurements and calculations. The manufacturer also asserts compliance with relevant safety standards and FDA acoustic output limits.
    • Conclusion: Based on this comparison, the FDA determined that the ECO Series Models are "substantially equivalent in safety and effectiveness to the predicate systems." This allows the device to be marketed without requiring a more extensive premarket approval (PMA) pathway.
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    K Number
    K120801
    Date Cleared
    2012-06-14

    (90 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    CHISON DIAGNOSTIC ULTRASOUND SYSTEM

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The system is a general-purpose ultrasonic imaging instrument intended for use by a qualified physician for the evaluation of Fetal (Obstetrics), Abdomen, Cardiac (Adult, Pediatric), Small Organ (Thyroid, testes and breast etc), Peripheral Vascular, Transvaginal, Musculo-skeletal (Conventional and Superficial), Pediatric, OB/Gyn and Urology.

    Device Description

    The CHISON Q6 / Q8 / iVis60 / iVis60 / EXPERT / i7 ultrasound system is an integrated preprogrammed color Doppler ultrasound imaging system, capable of producing high detail resolution intended for clinical diagnostic imaging applications. The CHISON ultrasound system can be configured either as a portable model (Q6/Q8), or as a roll-around model on wheels (iVis60 / iVis60 EXPERT/i7). These systems are designed with the latest technology, using the same quality procedure as ultrasound systems which have been available in the market for years. This CHISON ultrasound system is a general purpose, software controlled, diagnostic ultrasound system. Its basic function is to acquire ultrasound echo data and display the image in B-Mode (including Tissue Harmonic Imaging), M-Mode, Pulsed (PW) Doppler Mode, Continuous (CW) Doppler Mode, Color Doppler Mode, Power Doppler Mode, Directional Power Doppler Mode, or a combination of these modes.

    AI/ML Overview

    The provided document K120801 is a 510(k) premarket notification for the CHISON iVis & Q Series, i7 Diagnostic Ultrasound Systems. However, this type of submission is for establishing substantial equivalence to a legally marketed predicate device, not for proving a device meets specific clinical performance acceptance criteria through a study with ground truth.

    Therefore, the document does not contain the detailed information requested regarding acceptance criteria and a study that proves the device meets those criteria. Specifically, it does not include:

    1. A table of acceptance criteria and reported device performance.
    2. Sample sizes used for a test set, nor its data provenance.
    3. The number of experts used to establish ground truth or their qualifications.
    4. Adjudication methods for a test set.
    5. Results of a multi-reader multi-case (MRMC) comparative effectiveness study, or any effect size on human reader improvement with AI assistance.
    6. Standalone (algorithm-only) performance results.
    7. The type of ground truth used (e.g., expert consensus, pathology, outcomes data).
    8. The sample size for a training set.
    9. How ground truth for a training set was established.

    Instead, the submission focuses on demonstrating that the CHISON ultrasound systems are "substantially equivalent in safety and effectiveness to the predicate systems" (GE Voluson E8 Diagnostic Ultrasound System, K101236) based on having:

    • Comparable type and intended uses.
    • The same basic operating modes (B-Mode, M-Mode, Pulsed Doppler, Continuous Doppler, Color Doppler, Power Doppler, Directional Power Doppler).
    • Similar specialized measurements and calculations.
    • Acoustic output levels below FDA limits.
    • Compliance with applicable electrical and physical safety standards (NEMA UD 2, NEMA UD 3, IEC 60601-1, IEC 60601-1-2, IEC 60601-2-37, IEC 10993-1).

    The "Indications For Use" sections (pages 5-15) list the various clinical applications and operation modes for the main system and each specific transducer, indicating whether they are "N = new indication" (for the submitted device) or "P = previously cleared by FDA" (implying the predicate device covered these). This is a statement of intended use, not a performance metric from a study.

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    K Number
    K113359
    Date Cleared
    2012-02-03

    (81 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    CHISON DIAGNOSTIC ULTRASOUND SYSTEM,CONVEX PROBE,LINEAR PROBE,TRANSVAGINAL MICRO-CONVEX PROBE

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The system is a general-purpose ultrasonic imaging instrument intended for use by a qualified physician for evaluation of Abdomen, Cardiac, Small Organ (Thyroid, parotid, submaxillary gland, testes and breast.). Peripheral Vascular, Transvaginal, Transrectal, Musculo-skeletal (Conventional and Superficial), Pediatric, Fetal, OB/Gyn and Urology.

    Device Description

    The CHISON iVis20/iVis30/i3/ Q1/Q2/Q3/Q5 ultrasound system is an integrated preprogrammed color doppler ultrasound imaging system, capable of producing high detail resolution intended for clinical diagnostic imaging applications. The CHISON ultrasound system can be configured as a roll-around model on wheels (iVis20/iVis30/i3/ Q1/Q2/Q3/Q5). These systems are designed with the latest technology, using the same quality procedure as ultrasound systems which have been available in the market for years. This CHISON ultrasound system is a general purpose, software controlled, diagnostic ultrasound system. Its basic function is to acquire ultrasound echo data and display the image in B-Mode (including Tissue Harmonic Imaging), M-Mode, Pulsed (PW) Doppler Mode, Color Doppler Mode, Power Doppler Mode, Directional Power Doppler Mode, or a combination of these modes.

    AI/ML Overview

    Acceptance Criteria and Study for CHISON iVis Series & Q Series, i3 Diagnostic Ultrasound Systems

    This document describes the acceptance criteria and study information for the CHISON iVis Series & Q Series, i3 Diagnostic Ultrasound Systems, extracted from the provided 510(k) summary.

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document is a 510(k) premarket notification summary. For medical devices seeking substantial equivalence, performance characteristics are typically compared against an existing "predicate device" rather than predefined numerical acceptance criteria in the same way as an AI/ML device. The "acceptance criteria" here are implicitly that the new device performs comparably to the predicate device, GE Voluson E6/E8/E8 Expert (K101236), across various imaging modes and clinical applications.

    The reported device performance is that the CHISON iVis Models and Q Models and i3 are "substantially equivalent in safety and effectiveness" to the predicate. This equivalence is based on the systems having the "same intended uses and basic operating modes," "same gray-scale and Doppler capabilities," and acoustic output levels "below the applicable FDA limits."

    The 510(k) summary itself does not contain specific quantitative performance metrics (e.g., sensitivity, specificity, accuracy) for image quality or diagnostic effectiveness, as would often be the case for AI/ML devices or novel technologies. Instead, the focus is on demonstrating that the new device meets the same safety and performance standards as the predicate device already on the market.

    Table: Comparison to Predicate Device (Implied Acceptance Criteria)

    Feature/Performance AspectAcceptance Criteria (Comparable to Predicate: GE Voluson E6/E8/E8 Expert (K101236))Reported Device Performance (CHISON iVis Series & Q Series, i3)
    Intended UsesSame as predicate deviceSame as predicate device
    Basic Operating ModesSame as predicate device (B-Mode, M-Mode, Pulsed Doppler, Color Doppler, Power Doppler, Directional Power Doppler)Same as predicate device
    Gray-scale CapabilitiesComparable to predicate deviceSame capabilities as predicate device
    Doppler CapabilitiesComparable to predicate deviceSame capabilities as predicate device
    Acoustic Output LevelsBelow applicable FDA limitsBelow applicable FDA limits
    Product Safety StandardsCompliance with relevant standards (NEMA UD 2, NEMA UD 3, IEC 60601-1, IEC 60601-1-2, IEC 60601-2-37, IEC 10993-1)Designed to meet listed product safety standards

    2. Sample Size Used for the Test Set and Data Provenance

    The provided 510(k) summary does not contain information about a specific test set, its sample size, or data provenance (e.g., country of origin, retrospective/prospective study design).

    The submission is for a diagnostic ultrasound system aiming for substantial equivalence to a predicate device. This type of submission typically relies on device design specifications, performance testing (e.g., electrical safety, acoustic output, electromagnetic compatibility), and a comparison of technical features and intended uses to the predicate, rather than a clinical study with a "test set" in the context of AI/ML or novel diagnostic algorithms.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    Since the 510(k) summary does not describe a clinical study with a test set requiring ground truth established by experts, there is no information provided regarding the number or qualifications of experts for this purpose.

    4. Adjudication Method for the Test Set

    As there is no mention of a clinical study or a test set requiring expert adjudication for ground truth, no adjudication method is described in the provided document.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    The document does not indicate that a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was performed, nor does it provide any effect size of human readers improving with or without AI assistance. The device is a diagnostic ultrasound system, not explicitly described as incorporating AI for interpretation.

    6. Standalone (Algorithm Only) Performance Study

    The document does not describe a standalone (algorithm only) performance study. The device is a complete ultrasound system, and its performance is evaluated in the context of its overall functionality and comparison to a predicate device, not as a standalone algorithm.

    7. Type of Ground Truth Used

    Given the nature of a 510(k) for a diagnostic ultrasound system (not an AI algorithm or a novel diagnostic modality), the concept of "ground truth" in the context of a clinical test set is not directly applicable or described. The submission focuses on demonstrating that the device's technical specifications, imaging capabilities (B-Mode, M-Mode, Doppler), and safety aspects are equivalent to those of a legally marketed predicate device.

    8. Sample Size for the Training Set

    The provided 510(k) summary does not contain any information about a training set or its sample size. This is consistent with a traditional medical device submission for substantial equivalence, which does not typically involve machine learning model training as a documented component of the submission.

    9. How Ground Truth for the Training Set Was Established

    Since no training set is mentioned or implied, there is no information on how ground truth for a training set was established.

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