Clinical assessment of 118 (Site 1), 112 (Site 2), and 119 (Site 3) specimens
>1 (pathologists)
Indications for Use
The Virtuoso™ system provides automated digital slide creation, management, analysis, and viewing. It is intended for in vitro diagnostic use as an aid to the pathologist in the display, detection, counting, review and classification of tissues and cells of clinical interest based on particular morphology, color, intensity, size, pattern and shape. The Virtuoso™ System for Ki67 (30-9) is for digital read and image analysis applications. This particular Virtuoso™ system is intended for use as an aid to the pathologist in the detection and semi-quantitative measurement of Ki67 (30-9) protein in formalin-fixed, paraffin-embedded normal and neoplastic tissue. This device is an accessory to the Ventana Medical Systems, Inc. CONFIRM™ anti-Ki67 (30-9) Rabbit Monoclonal Primary Antibody assay. The Ventana Medical Systems, Inc. CONFIRM™ anti-Ki67 (30-9) assay is indicated for use in assessing the proliferative activity of normal and neoplastic breast tissue. When used with this assay, the Virtuoso™ System for Ki67 (30-9) is indicated for use as an aid in the assessment of Ki67 status in breast cancer patients (but is not the sole basis for treatment).
Device Story
Virtuoso System is an instrument-plus-software digital pathology solution for pathology laboratories. Input: digital images of formalin-fixed, paraffin-embedded tissue slides captured by iScan scanner. Operation: pathologist selects fields of view (FOVs) for analysis; software provides quantitative data on Ki-67 protein expression; pathologist reviews, verifies, or overrides software-generated scores. Output: quantitative scores for FOVs and aggregate slide scores. Used in clinical pathology labs by pathologists to assist in assessing Ki-67 status in breast cancer patients. System includes image quality assessment algorithms to ensure slide suitability. Benefits: provides consistent, semi-quantitative assessment of protein expression to aid clinical decision-making; requires human intervention for all analysis steps.
Clinical Evidence
Concordance studies evaluated 120 cases comparing digital read (DR) and image analysis (IA) against manual microscopic read (reference). For DR: PPA 100%, NPA 82.4%, OPA 90%. For IA: PPA ranged 67.5%–85.5%, NPA 95.6%–98.0%, OPA 78.0%–90.8% across three sites. All results met the 75% acceptance criterion.
Technological Characteristics
System includes iScan slide scanner, computer, monitor, and proprietary software. Operates on formalin-fixed, paraffin-embedded tissue slides stained with Ventana CONFIRM Ki-67 (30-9) antibody and DAB chromogen. Uses Benchmark ULTRA or XT automatic stainers. Software performs image quality assessment and quantitative analysis of nuclear staining. Web-based user interface.
Indications for Use
Indicated for use as an aid to pathologists in the detection and semi-quantitative measurement of Ki67 (30-9) protein in formalin-fixed, paraffin-embedded normal and neoplastic breast tissue specimens to assess proliferative activity in breast cancer patients.
Regulatory Classification
Identification
Immunohistochemistry test systems (IHC's) are in vitro diagnostic devices consisting of polyclonal or monoclonal antibodies labeled with directions for use and performance claims, which may be packaged with ancillary reagents in kits. Their intended use is to identify, by immunological techniques, antigens in tissues or cytologic specimens. Similar devices intended for use with flow cytometry devices are not considered IHC's.
Special Controls
(2) Class II (special control, guidance document: “FDA Guidance for Submission of Immunohistochemistry Applications to the FDA,” Center for Devices and Radiologic Health, 1998). These IHC's are intended for the detection and/or measurement of certain target analytes in order to provide prognostic or predictive data that are not directly confirmed by routine histopathologic internal and external control specimens. These IHC's provide the pathologist with information that is ordinarily reported as independent diagnostic information to the ordering clinician, and the claims associated with these data are widely accepted and supported by valid scientific evidence. Examples of class II IHC's are those intended for semiquantitative measurement of an analyte, such as hormone receptors in breast cancer.
{0}
1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
k121033
B. Purpose for Submission:
Device modification. Clearance for use with the Benchmark ULTRA™ stainer.
C. Manufacturer and Instrument Name:
Ventana Medical Systems, Inc., Virtuoso™ System for IHC Ki67 (30-9)
D. Type of Test or Tests Performed:
Computer-assisted image analysis scoring and manual scoring of digital images of Ki67 immunohistochemistry stained slides.
E. System Descriptions:
1. Device Description:
No change. See k111755.
2. Principles of Operation:
No change. See k111755.
3. Modes of Operation:
No change. See k111755.
4. Specimen Identification:
No change. See k111755.
5. Specimen Sampling and Handling:
No change. See k111755.
6. Calibration:
Calibration is performed at installation and annually by a Ventana Medical Services Inc.
{1}
field service technician.
7. Quality Control:
No change. See k111755.
8. Software:
FDA has reviewed applicant’s Hazard Analysis and Software Development processes for this line of product types:
Yes ☐ x or No ☐
F. Regulatory Information:
1. Regulation section:
21 CFR §864.1860, Immunohistochemistry reagents and kits
2. Classification:
Class II
3. Product code:
NQN – Microscope, automated, image analysis, immunohistochemistry, operator intervention, nuclear intensity and percent positivity
NOT – Microscope, Automated, Image Analysis, Operator Intervention
OEO – Automated Digital Image Manual Interpretation Microscope
4. Panel:
Pathology (88)
G. Intended Use:
1. Indication(s) for Use:
The Virtuoso™ system provides automated digital slide creation, management, analysis, and viewing. It is intended for in vitro diagnostic use as an aid to the pathologist in the display, detection, counting, review and classification of tissues and cells of clinical interest based on particular morphology, color, intensity, size, pattern and shape.
The Virtuoso™ System for Ki67 (30-9) is for digital read and image analysis applications. This particular Virtuoso™ system is intended for use as an aid to the pathologist in the detection and semi-quantitative measurement of Ki67 (30-9) protein
2
{2}
in formalin-fixed, paraffin-embedded normal and neoplastic tissue. This device is an accessory to the Ventana Medical Systems, Inc. CONFIRM™ anti-Ki67 (30-9) Rabbit Monoclonal Primary Antibody assay. The Ventana Medical Systems, Inc. CONFIRM™ anti-Ki67 (30-9) assay is indicated for use in assessing the proliferative activity of normal and neoplastic breast tissue. When used with this assay, the Virtuoso™ System for Ki67 (30-9) is indicated for use as an aid in the assessment of Ki67 status in breast cancer patients (but is not the sole basis for treatment).
Note: The IHC Ki67 (30-9) Digital Read and Image Analysis applications are adjunctive computer-assisted methodologies for the qualified pathologist in the acquisition and measurement of images from microscope glass slides of breast cancer specimens stained for the presence of Ki67 protein. The pathologist should verify agreement with the Image Analysis software application score. The accuracy of the test results depends on the quality of the IHC staining. It is the responsibility of a qualified pathologist to employ appropriate morphological studies and controls as specified in the instructions for the CONFIRM™ anti-Ki67 (30-9) Rabbit Monoclonal Primary Antibody assay to assure the validity of the Virtuoso™ System for Ki67 (30-9) Digital Read and Image Analysis scores. The actual correlation of CONFIRM™ anti-Ki67 (30-9) Rabbit Monoclonal Primary antibody assay to clinical outcome has not been established.
2. Special Conditions for Use Statement(s):
For prescription use only
Indicated for use with either the Benchmark XT or ULTRA™ stainers.
* A precautionary statement indicating that this device has not been tested, or its safety and effectiveness validated, when used with a personal computer (PC) from home was included in the Limitations section of the device package insert.
H. Substantial Equivalence Information:
1. Predicate Device Name(s) and 510(k) numbers:
Ventana Virtuoso™ System for IHC Ki67 (30-9) for use with the Benchmark XT stainer (k111755)
2. Comparison with Predicate Device:
{3}
| Similarities | | |
| --- | --- | --- |
| Item | Device Ventana Virtuoso™ System for IHC Ki67 (30-9) with the Benchmark ULTRA™ stainer | Predicate Ventana Virtuoso™ System for IHC Ki67 (30-9) with the Benchmark XT stainer |
| Intended Use | This device is intended for in vitro diagnostic (IVD) use. The Virtuoso™ System provides automated digital slide creation, management, analysis, and viewing. It is intended for IVD use as an aid to the pathologist in the display, detection, counting, review and classification of tissues and cells of clinical interest based on particular morphology, color, size, intensity, pattern, and shape. | Same |
| Sample type | Formalin-fixed, paraffin embedded tissue stained by IHC. | Same |
| Device components | Automated digital slide scanner, computer, color monitor, and image analysis software and digital pathology information management software. | Same |
| Primary Antibody (Assay) Reagent | Ventana CONFIRM™ Ki-67 (30-9) | Same |
| Differences | | |
| --- | --- | --- |
| Item | Device Ventana Virtuoso™ System for IHC Ki67 (30-9) with the Benchmark ULTRA™ stainer | Predicate Ventana Virtuoso™ System for IHC Ki67 (30-9) with the Benchmark XT stainer |
| Stainer | Benchmark ULTRA™ Features 30 slide positions and 35 reagents. The Benchmark ULTRA™ is a continuous access stainer, capable of random access processing. | Benchmark XT™ Single drawer of 30 slide positions and 35 reagents. |
I. Special Control/Guidance Document Referenced (if applicable):
None.
J. Performance Characteristics:
1. Analytical Performance:
{4}
# a. Accuracy:
The performance of the Virtuoso™ System for Ki67 (30-9) when used in conjunction with the Benchmark ULTRA™ stainer was validated by assessing the positive percent agreement (PPA), negative percent agreement (NPA), and overall percent agreement (OPA) between the reference manual method (with a traditional microscope) and both the digital read (DR) and image analysis (IA) applications of the Virtuoso™ system. Patient slides were scored as positive or negative for Ki67 status using the percent positive staining cutoff of $< 10\%$ for the distinction between positive and negative staining.
Concordance with manual scoring was assessed between scores assigned to 120 specimens for both digital reads and image analysis. The acceptance criteria of an overall agreement rate of at least $75\%$ were met in these studies. Concordance of digital reads with manual scoring was assessed at one site, whereas concordance of image analysis with manual scoring was performed at 3 study sites. The agreements with the $95\%$ confidence intervals (CI) around the agreements are shown below. All confidence intervals are 2-sided $95\%$ confidence intervals calculated using the score method.
Clinical Assessment between Digital Read and Manual Scoring
| | Manual Microscopic Read | | |
| --- | --- | --- | --- |
| Digital Read | Positive | Negative | Total |
| Positive | 52 | 12 | 64 |
| Negative | 0 | 56 | 56 |
| Total | 52 | 68 | 120 |
| PPA n/N (%) (95% CI) | 52/52 (100.0%) (93.1-100.0) | | |
| NPA n/N (%) (95% CI) | 56/68 (82.4%) (71.6-89.6) | | |
| OPA n/N (%) (95% CI) | 108/120 (90.0%) (83.3-94.2) | | |
Clinical Assessment between Image Analysis and Manual Scoring
| Site 1 | Manual Microscopic Read | | |
| --- | --- | --- | --- |
| Image Analysis | Positive | Negative | Total |
| Positive | 52 | 1 | 53 |
| Negative | 25 | 40 | 65 |
| Total | 77 | 41 | 118 |
| PPA n/N (%) (95% CI) | 52/77 (67.5%) (56.5-76.9) | | |
| NPA n/N (%) (95% CI) | 40/41 (97.6%) (87.4-99.6) | | |
| OPA n/N (%) (95% CI) | 92/118 (78.0%) (69.7-84.5) | | |
| Site 2 | Manual Microscopic Read | | |
| --- | --- | --- | --- |
| Image Analysis | Positive | Negative | Total |
| Positive | 54 | 2 | 56 |
| Negative | 13 | 43 | 56 |
| Total | 67 | 45 | 112 |
{5}
| PPA n/N (%) (95% CI) | 54/67 (80.6%) (69.6-88.3) |
| --- | --- |
| NPA n/N (%) (95% CI) | 43/45 (95.6%) (85.2-98.8) |
| OPA n/N (%) (95% CI) | 97/112 (86.6%) (79.1-91.7) |
| Site 3 | Manual Microscopic Read | | |
| --- | --- | --- | --- |
| Image Analysis | Positive | Negative | Total |
| Positive | 59 | 1 | 60 |
| Negative | 10 | 49 | 59 |
| Total | 69 | 50 | 119 |
| PPA n/N (%) (95% CI) | 59/69 (85.5%) (75.3-8-91.9) | | |
| NPA n/N (%) (95% CI) | 49/50 (98.0%) (89.5-99.6) | | |
| OPA n/N (%) (95% CI) | 108/119 (90.8%) (84.2-94.8) | | |
Agreement between digital reads and image analysis to manual scoring was assessed using two Ventana DAB detection kits (iVIEW™ vs. ultraView™). Reanalysis of the results summarized in the four tables above by stratification by detection kit also yielded results that met the pre-established acceptance criteria of an overall agreement rate of at least $75\%$ .
b. Precision/Reproducibility: Not applicable.
c. Linearity: Not applicable.
d. Carryover: Not applicable.
e. Interfering Substances: Not applicable.
2. Other Supportive Instrument Performance Data Not Covered Above: Not applicable.
# K. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
# L. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
Predicate graph will load when search results are available.
Embedding visualization will load when search results are available.
PDF viewer will load when search results are available.
Loading panels...
Select an item from Submissions
Click any panel, subpart, regulation, product code, or device to see details here.
Section Matches
Results will appear here.
Product Code Matches
Results will appear here.
Special Control Matches
Results will appear here.
Loading collections...
Loading
My Alerts
You will receive email notifications based on the filters and frequency you set for each alert.
Sort by:
Create Alert
Search Filters
Agent Token
Create a read-only bearer token for Claude, ChatGPT, or other agents that can call HTTP APIs.
Copy this now. It will not be shown again.
Connected apps
Apps you authorized through browser sign-in. Disconnecting revokes their access immediately.
Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
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.
6. Collections
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.