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510(k) Data Aggregation

    K Number
    K210432
    Manufacturer
    Date Cleared
    2021-11-03

    (264 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Leltek Ultrasound Imaging System (Model: LU700 Series) is a software-based imaging system and accessories intended for use by qualified physicians and healthcare professionals who has the ability to conduct ultrasound scan process for evaluation by ultrasound imaging system or fluid flow analysis of the human body.

    The clinical environments where the system can be used include physician offices, clinics, hospitals, and clinical point-of-care for diagnosis of patients

    The modes of operation include B mode, PWD mode, Color Doppler (CD) mode, Power Doppler mode, and the combined mode (B+M, B+CD, B+PWD). Specific clinical applications and exam types including: LU700C General abdominal imaging, musculoskeletal (conventional), musculoskeletal (superficial), peripheral vessel and OB/Gyn. LU700L General abdominal imagine, small organ (breast, thyroid), musculoskeletal (superficial) and peripheral vessel. LU710C Fetal, abdominal, pediatric, small organ (thyroid, prostate, scrotum, breast), musculoskeletal (conventional), urology, gynecology, cardiac adult, cardiac pediatric and peripheral vessel. LU710M Fetal, abdominal, pediatric, small organ (thyroid, prostate, scrotum, breast), musculoskeletal (conventional), urology, gynecology, cardiac adult, cardiac pediatric and peripheral vessel. LU710PA Fetal, abdominal, pediatric, cardiac adult, cardiac pediatric. LU710E Fetal, abdominal, small organ (thyroid, prostate, scrotum, breast), trans-vaginal, urology, gynecology.

    Device Description

    The Leltek Ultrasound Imaging System (Model: LU700 Series) is a portable, software controlled, handheld ultrasound system used to acquire and display hi-resolution, real-time ultrasound data through a commercial off-the-shelf (COTS) mobile device.

    • l. The imaging system software runs as an app on a mobile device.
    • II. The imaging system software can be download to a commercial off-the-shelf (COTS) mobile device and utilizes an icon touch-based user interface.
    • III. The imaging system consists of a series of wireless transducers employing Wi-Fi-based technology to communicate with traditional tablet/smartphone devices via direct Wi-Fi. This allows the user to export ultrasound images and display them across a range portable personal device.
    • IV. The imaging system houses a built-in battery, multichannel beamformer, prescan converter and Wi-Fi components

    The device is intended for use in environments where healthcare is provided by trained healthcare professionals, but not intended for use in emergency medical service, ambulance, or aircraft.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study proving device performance:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document (K210432) is a 510(k) summary for premarket notification of a medical device (Leltek Ultrasound Imaging System). It focuses on establishing substantial equivalence to predicate devices rather than defining and meeting specific analytical or clinical performance acceptance criteria in the traditional sense of a clinical trial.

    Therefore, the "acceptance criteria" here are compliance with recognized safety and performance standards and demonstrating similar performance characteristics to the predicate devices. The "reported device performance" is the system's demonstrated compliance with these standards and its functional equivalence.

    Acceptance Criteria (Implied by Substantial Equivalence and Standards Compliance)Reported Device Performance
    Similar Intended Use: Diagnostic ultrasound imaging or fluid flow analysis of the human body.Same as predicate and reference devices. The LU700 Series is a software-based imaging system and accessories intended for use by qualified physicians and healthcare professionals for evaluation by ultrasound imaging system or fluid flow analysis of the human body. (K210432, page 6, 9)
    Functional Equivalence in Operating Modes: B Mode, M mode, PWD, Color Doppler, Power Doppler, and combined modes.Same as predicate and reference devices. (K210432, page 6)
    Wireless Communication: Communication via Wi-Fi.Same as predicate. The device communicates wirelessly via Wi-Fi. (K210432, page 6)
    Portability: Portable ultrasound system.Same as predicate and reference devices. The Leltek Ultrasound Imaging System (Model: LU700 Series) is a portable, software-controlled, handheld ultrasound system. (K210432, page 5, 6)
    Power Source: Rechargeable battery (Li-ion).Same as predicate and reference devices. (K210432, page 6)
    Display: iOS or Android mobile device.Same as predicate and reference devices. The imaging system software runs as an app on a mobile device and utilizes an icon touch-based user interface, displaying images across a range of portable personal devices. (K210432, page 5, 6)
    Compliance with Safety Standards: AAMI/ANSI ES60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60601-2-37, IEC 62133, IEC 62304, IEC 62366-1, ISO 10993 (1, 5, 10), ISO 13485, ISO 14971, ISO 15223-1.The device has been designed, manufactured, tested, and certified to comply with all listed international standards. Acoustic output, biocompatibility, cleaning and disinfection effectiveness, wireless, thermal, electromagnetic, and mechanical safety have been evaluated and found to conform. The maximum acoustic output level is under the FDA recommended limit. (K210432, page 9, 10)
    Biosafety Equivalence: (Implied biological compatibility as per ISO 10993 series)Biosafety equivalence is asserted, and the device conforms to applicable electromedical device safety standards. Biocompatibility testing has been conducted for the new transducers. (K210432, page 8, 10)
    No Pragmatic Detriments: Differences from predicate devices (e.g., expanded Indications for Use, additional transducer types) do not negatively impact safety or effectiveness.The differences specified have no pragmatic detriments. All safety and performance tests of the essential requirements are met. The new models (LU710C, LU710PA, LU710E) were tested and determined to be in full compliance with acoustic output, biocompatibility, cleaning, and disinfection effectiveness, and have no pragmatic detriments. (K210432, page 8, 10)

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

    The document does not provide details on specific sample sizes for a "test set" in the context of clinical performance or image-based evaluation.

    Instead, the submission relies on:

    • Compliance with recognized performance and safety standards: This implicitly means testing against defined criteria within those standards.
    • Bench testing and engineering verification: "Acoustic output, biocompatibility, cleaning, and disinfection effectiveness as well as wireless, thermal, electromagnetic and mechanical safety" were evaluated by tests, but specific sample sizes for these tests are not mentioned.
    • Substantial equivalence argument: The core of the 510(k) relies on demonstrating that the new device performs as safely and effectively as a legally marketed predicate device (K191235) and a reference device (K192107).

    The data provenance is related to the testing performed to ensure compliance with the listed standards. This would typically be internal testing by the manufacturer (LELTEK, Inc. in Taiwan) as part of their design, manufacturing, and quality control processes. The document does not indicate the use of external or clinical data for the performance evaluation in the way a clinical trial would. It states, "The Leltek Ultrasound Imaging System did not require clinical testing to establish substantial equivalence." (K210432, page 10).

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

    Since the document explicitly states that clinical testing was not required, there was no "test set" in the clinical sense that would require expert-established ground truth for diagnostic accuracy. The evaluation focused on engineering, safety, and performance characteristics against established standards.

    4. Adjudication Method for the Test Set

    Not applicable, as a clinical "test set" requiring adjudication for diagnostic accuracy as described in the prompt was not part of this 510(k) submission.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, an MRMC comparative effectiveness study was not done. The document states, "The Leltek Ultrasound Imaging System did not require clinical testing to establish substantial equivalence." (K210432, page 10). The submission is based on demonstrating technical and safety equivalence to predicate devices, not on a clinical comparison of diagnostic efficacy with human readers.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    This question is not directly applicable in the context of this device. The Leltek Ultrasound Imaging System is an ultrasound imaging device, not an AI algorithm intended for automated diagnosis or interpretation. The "software" aspect refers to the app running on a mobile device and controlling the ultrasound hardware, not a standalone diagnostic algorithm. Therefore, "standalone" performance for an algorithm is not a relevant concept for this type of device based on the provided information.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    Given that clinical testing for diagnostic performance was not required, there was no "ground truth" of the type typically used for evaluating diagnostic accuracy (e.g., pathology, surgical findings, long-term outcomes, expert consensus on images). The ground truth for this submission was based on:

    • Engineering specifications and measurements: To ensure parameters like acoustic output, image quality (implied by functional equivalence), and electrical safety met defined standards.
    • Biocompatibility testing results: Against ISO 10993 standards.
    • Compliance with cleaning/disinfection protocols.

    8. The Sample Size for the Training Set

    Not applicable. This device is an ultrasound imaging system, and the submission does not describe it as an AI/ML-based diagnostic algorithm that would require a "training set" of data in the sense used for machine learning. The "software" is for image acquisition, processing, and display, not for learning to diagnose from a dataset.

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

    Not applicable, as there is no mention of a "training set" for an AI/ML algorithm in this 510(k) submission.

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