The ATLAS is integrated into the user's stationary radiography system. This typical configuration permits a qualified/trained doctor or technologist to take a range of head-to-toe diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts on both adult and pediatric patients. Applications can be performed with patient sitting, standing or lying in the prone or supine positions in an integrated system. The Atlas is not intended for mammography.
Device Story
ATLAS is a digital X-ray detector integrated into stationary radiography systems. It captures X-ray signals using a single CCD detector with a scintillator, converting them into high-resolution digital images. The device eliminates the need for film, chemistry, cassettes, or imaging plates. Operated by physicians or technologists in clinical settings, the system supports various patient positions (sitting, standing, prone, supine). The output is a digital radiographic image displayed on a workstation, allowing for diagnostic review. By providing high-resolution digital capture with 98% pixel fill factor, the device enables efficient image acquisition and potentially lower radiation doses compared to conventional film systems. It is intended for general-purpose diagnostic procedures.
Clinical Evidence
Bench testing only. No clinical data provided.
Technological Characteristics
Digital X-ray detector; single CCD sensor with scintillator; 3,103 x 3,085 pixel array (9 Megapixel); 144-micron pixel size; 16-bit capture; 98% fill factor. Standards: EN ISO 14971, EN 60601-1, EN 60601-1-2, EN 60601-1-4. Connectivity: Integrated into stationary radiography systems.
Indications for Use
Indicated for diagnostic radiographic imaging of skull, spine, chest, abdomen, and extremities in adult and pediatric patients. Not for mammography.
Regulatory Classification
Identification
A stationary x-ray system is a permanently installed diagnostic system intended to generate and control x-rays for examination of various anatomical regions. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Special Controls
*Classification.* Class II (special controls). A radiographic contrast tray or radiology diagnostic kit intended for use with a stationary x-ray system only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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K100703
# 510(K) SUMMARY
[as required by 807.92(c)]
DEC 2 1 2010
## A. 510k Number:
## B. Applicant:
Company name: PATS CORP Address: 49 Candlewood Way, Buena Park, CA 90621, USA Contact person: Mr Brandon Choi Phone: 714-523-1592 Fax: 714-523-1592
C. Proprietary and Established Names: COMED CO LTD Address: #58, Hakdong-Ri, Chowol-Eup, Gwangju-City, Gyeonggi-Do, Korea
# D. Requlatory Information
Classification : Class II CFRcord : 892 . 1680 , Regular Name : Stationary X-ray system Product cord : MQB
### E. Intended Use
The ATLAS is integrated into the user`s stationary radiography system. This typical configuration permits a qualified/trained doctor or technicolgosist to take a range of head-to-toe diagnostic radiographic exposures of the skull, spinal column, chest abdomen, extremities, and other body parts on both adult and pediatric patients. Applications can be performed with patient. Applications can be performed with patient sitting, standing of lying in the prone or supine positions in an integrated system. The ATLAS is not intended for mammography.
### F. Device Description
The Atlas is provided high resolution radiographic images in a digital format without use of film , chemistry, cassettes or expensive imaging plates. With 98% of fill factor in each pixel, there is a maximum efficiency and lower dose required for image capture. It has single CCD detector.
- G. Substantial Equivalence Information
- 1. Predicate Device
- 1) Xaminer (K061595)
- 2) QXR-9 (K073056)
For the technological characteristics the Company is relying on the above mentioned
page 1 of 2
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ATLAS. COMED Co., Ltd. believes that ATLAS is substantially equivalent in intended use, principles of operation, and technological characteristics to the predicate devices presented above and any differences with Xaminer (K061595), QXR-9 (K073056) do not raise new types of safety or effectiveness issues, as further discussed below.
| Model Name | ATLAS | Xaminer | QXR-9 |
|----------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510K Number | Not yet | K061595 | K073056 |
| Classification | Class II Device /<br>MQB (21 CFR 892.1650) | Class II Device /<br>MQB (21 CFR 892.1650) | Class II Device /<br>MQB (21 CFR 892.1650) |
| INTENDED USE | The ATLAS is integrated into the user's<br>stationary radiography system.<br>This typical configuration permits a<br>qualified/trained doctor or technologist<br>to take a range of head-to-toe diagnostic<br>radiographic exposures of the skull,<br>spinal column, chest abdomen, extremities,<br>and other body parts on both<br>adult and pediatric patients. Applications can<br>be performed with patient. Applications can be<br>performed with patient sitting standing of<br>lying in the prone or supine positions in an<br>intergrated system<br>The ATLAS is not intended for mammography | The Xaminer (510k submission device) is<br>integrated into the user's stationary radiography<br>system This typical configuration permits a<br>qualified/trained doctor or technologist to take a<br>range of head-to-toe diagnostic radiographic<br>exposures of the skull spinal column, chest<br>abdomen, extremities, and other body parts on<br>both adult and pediatric patients. Applications<br>can be performed with patient sitting, standing or<br>lying in the prone or supine positions in an<br>integrated system<br>The Xaminer (510k submission device) is not<br>intended for mammography | QXR-9 Digital Radiography system is<br>indicated for digital imaging solution<br>designed for general radiographic system for<br>human anatomy. It is intended to replace film<br>or screen based radiographic systems in all<br>general purpose diagnostic procedures. Not<br>to be used for mammography. |
| Feature | The Atlas is provided high resolution<br>radiographic images in a digital format without<br>use of film, chemistry, cassettes or expensive<br>imaging plates. With 98% of fill factor in each<br>pixel there is a maximum efficiency and lower<br>dose required for image capture. It has single<br>CCD detector | The Xaminer is the latest version of Xplorer<br>digital radiographic detectors. It includes<br>features and functions that have been developed<br>since the introduction of the original Xplorer<br>1000 (predicate device). Xaminer provides high<br>resolution radiographic images at 3.2 lp/mm<br>in a digital format without use of film, chemistry,<br>cassettes or expensive imaging plates. With 98 %<br>of fill factor in each pixel there is a maximum<br>efficiency and lower dose required for image<br>capture. It has single CCD detector with 9 mega<br>pixel digitized at 14 bits per pixels | The QXR-9 Digital Radiography Systems is a<br>high-resolution digital imaging system<br>designed for digital radiography. It is<br>designed to replace conventional film<br>radiography techniques. This system consists<br>of Detector Power Supply Unit, Accessories,<br>and S/W. The S/W is operated at a<br>workstation that is using Windows XP based<br>OS as its operating system. The system allows<br>the operator to acquire and display<br>images(Image size 3072x3072 pixels) or<br>1600 x 1200 high resolution monitor.<br>Various features of S/W such as image<br>inversion, image processing, zooming,<br>panning, window level adjustment, contrast<br>adjustment etc enable the operator to view<br>diagnostic details difficult to see using<br>conventional non-digital techniques. |
| STANDARD | EN ISO 14971<br>EN 60601-1<br>EN 60601-1-4<br>EN 60601-1-2 | EN ISO 14971<br>EN 60601-1<br>EN 60601-1-4<br>EN 60601-1-2 | EN ISO 14971<br>EN 60601-1<br>EN 60601-1-2 |
| Sensor | CCD+ scintillator | CCD- scintillator | CCD- scintillator |
| Imaging Pixels | 3,103 x 3,085(9 Megapixel) | 3,072 x 3,072 (9 Megapixel) | 3,072 x 3,072 (9 Megapixel) |
#### Comparison with predicate 2.
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| Active Image Size | 17" x 17" | 43 cm x 43 cm (17" x 17") | 43 cm x 43 cm (17" x 17") |
|----------------------------|---------------------|---------------------------|---------------------------|
| Pixel Size | 144 microns | 144 microns | 144 microns |
| Nyquist Resolution | 3.5 lp/mm | 3.2 lp/mm | 3.5 lp/mm |
| Bit Depth | 16Bit capture | 14 bit capture | 14 bit capture |
| Fill Factor | 98% | 100% | << |
| Preview Image | Less than 5 seconds | Less than 5 seconds | Less than 3 5 seconds |
| Imaging Detector<br>Weight | 45kg-50kg | 75 kg (165 lb) | << |
# 3. Conclusion
Based on the above, we conclude that the Digital X-ray Detector ATLAS has substantial equivalent intended use as the-market-cleared Xaminer (K061595), QXR-9 (K073056) and has substantial equivalent technological and performance characteristics. After analyzing both bench as well as laboratory testing to applicable standards, it is the conclusion of ATLAS is as safe and effective as the predicate devices, has few technological differences, but there are no new indications for use and without raising any new safety and/or effectiveness concerns.
Consequently, it is clear that it substantially equivalent to the predicate devices.
# H. Performance Characteristics (If/when applicable)
Applied by standard of
- Council Directive 93/42/EEC of 14 June 1993 concerning medical devices
- IEC 980:2003, Graphical symbols for use in the labeling of medical devices
- IEC1041:1998, Information supplied by the manufacturer with medical devices
- · ISO 13485:2003. Medical devices Quality management systems -Requirements for requlatory purposes
- ISO 14155-1:2003, Clinical investigation of medical devices for human subjects - Part 1: General requirements
- ISO 14971:2007, Medical devices Application of risk management to medical devices
- · IEC 60601-1 Medical electrical equipment Part 1:General requirements for safety (IEC 60601-1:1988/A1:91/A2:95)
- IEC 60601-1-2:2001/A1:2006, Medical electrical equipment Part 1: General requirements for safety - Collateral standard: Electromagnetic compatibility -
- Requirements and tests
- IEC 60601-1-4:1996+A1:1999:1999, Medical electrical equipment. Part 1-4: General requirements for safety- Collateral standard: Programmable electrical medical systems
page 3 of 3
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Image /page/3/Picture/0 description: The image shows the seal of the Department of Health & Human Services USA. The seal is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. In the center of the seal is an emblem of a stylized eagle with its wings spread. The eagle is facing to the left and has three lines representing its wings.
## DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room - WO66-G609 Silver Spring, MD 20993-0002
COMED Co., Ltd. c/o Mr. Brandon Choi Representative PATS Corporation 49 Candlewood Way BUENA PARK CA 90621
DEC 2 1 2010
K100703 Trade Name: ATLAS (Digital X-Ray Detector) Regulation Number: 21 CFR § 892,1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: MBQ Dated: November 5, 2010 Received: November 10, 2010
Dear Mr. Choi:
Re:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration. Iisting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA). it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical
{4}------------------------------------------------
medical device-related adverse events) (21 CFR 803); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Parts 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
signature
David G. Brown. Ph.D. Acting Director Division of Radiological Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
{5}------------------------------------------------
Indications for Use
510(k) Number (if known):
Device Name: ATLAS (Digital X-Ray Detector)
Indications For Use: The ATLAS is integrated into the user's stationary radiography system. This typical configuration permits a qualified/trained doctor or technologist to take a range of head-to-toe diagnostic radiographic exposures of the skull, spinal column, chest, abdomen, extremities, and other body parts on both adult and pediatric patients. Applications can be performed with patient sitting, standing or lying in the prone or supine positions in an integrated system.
The Atlas is not intended for mammography.
Prescription Use x (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
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### Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign Off)
Division of Radiological Devices
Division of Radiological Devices
Office of In Vitro Diagnostic Device Evaluation and Safety
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.