VitreaView is a medical image viewing and information distribution application that provides access, through the internet and within the enterprise, to multi-modality softcopy medical images, reports and other patient-related information, that may be hosted within disparate archives and repositories for review, communication and reporting of DICOM and non-DICOM data. VitreaView is not intended for primary diagnosis. When accessed from a mobile tablet, VitreaView is for informational purposes only and not intended for diagnostic use. Display monitors used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance. Lossy compressed mammographic images and digitized film screen images must not be reviewed for primary image interpretations. Mammographic images may only be interpreted using an FDA approved monitor that offers at least 5 MP resolution and meets other technical specifications reviewed and accepted by FDA.
Device Story
VitreaView is a zero-footprint, cross-platform universal image viewer for DICOM and non-DICOM medical images. It integrates with EHR, EMR, HIE, and PHR systems to provide clinicians with multi-modality image review, MPR, and 3D viewing capabilities. The device functions as a web-based application accessible via standard browsers on Windows, Linux, Mac OS, and mobile tablets. It supports basic review tools including zoom, pan, and measurement. No advanced image processing occurs on mobile tablets. The system facilitates collaboration and treatment planning by providing access to imaging data and reports in context. It is used by physicians and clinicians in clinical settings. The device does not perform primary diagnosis; it serves as a tool for information distribution and review. Spatial accuracy of measurements and orientation is verified using imaging phantoms.
Clinical Evidence
No clinical data. Bench testing only. Verification and validation included performance testing, safety testing, and simulated use testing. Spatial accuracy of 2D/3D rendering, measurements, and orientation markers was verified using imaging phantoms.
Technological Characteristics
Zero-footprint, cross-platform software architecture. Supports DICOM and non-DICOM data. Complies with NEMA PS 3.1-3.20 (2011) DICOM standards. Features include MPR, 3D viewing, and basic measurement tools. Connectivity via internet/enterprise network. No hardware components; software-only solution.
Indications for Use
Indicated for clinicians and medical professionals to access, review, communicate, and report multi-modality medical images and patient information within an enterprise or via the internet. Not intended for primary diagnosis. Mobile tablet access is for informational purposes only, not for diagnostic use. Mammographic images require specific FDA-approved 5 MP monitors.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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Vital Images
VitreaView 510(k) Pre-market Notification
# 510(k) Summary
This 510(k) summary is submitted in accordance with the requirements of 21 C.F.R. Part 807.92.
| Purpose of<br>Submission: | Vital Images, Inc. hereby submits this traditional 510(k) to provide notification<br>submission for an addition to the Indications for Use of our already cleared VitreaView<br>software. | | |
|--------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------|--|
| Submitter: | Vital Images, Inc.<br>5850 Opus Parkway<br>Suite 300<br>Minnetonka, MN 55343-4414 | | |
| | Image: SEP 7 2012 | | |
| Establishment<br>Registration: | 2134213 | | |
| Contact Person: | Ian Nemerov<br>Vice President, General Counsel & Secretary<br>Phone: 952-487-9622<br>Fax: 952-487-9510<br>E-mail: inemerov@vitalimages.com | | |
| 510(k) Type: | Traditional 510(k) | | |
| Summary Date: | August 27, 2012 | | |
| Device Name | Trade Name: | VitreaView | |
| | Common Name: | Picture Archiving and Communications System | |
| | Classification Name: | System, Image Processing, Radiological (21 C.F.R. 892.2050, LLZ) | |
- Predicate Device: VitreaView (K111892)
## Device Description:
VitreaView is a cross-browser, cross-platform, zero-footprint universal image viewer solution capable of displaying both DICOM and non-DICOM medical images. VitreaView enables clinicians and other medical professionals to access patients' medical images with integrations into a variety of medical record systems, such as Electronic Health Record (EHR), Electronic Medical Record (EMR), Health Information Exchange (HIE), Personal Health Record (PHR), and image exchange systems. It supports the physician in medical image viewing and treatment planning.
VitreaView offers medical professionals a universal viewer for accessing imaging data in context with reports from enterprise patient health information databases, fosters collaboration, and provides workflows and interfaces appropriate for referring physicians and clinicians. IT departments will not have to incur time to install client systems, due to the zero footprint, zero- download nature of VitreaView. VitreaView offers scalability to add new users as demand grows, may be deployed in a virtualized environment, and is designed to be integrated with enterprise patient health information databases. When accessed from a mobile tablet, no advanced image processing is performed by the tablet.
Some of the general features include:
- . Performance speed
- . Zero-footprint architecture
- DICOM and non-DICOM display �
- Vendor neutrality .
- Function within a virtual environment .
- Multi-modality review of data .
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# Vital Images
- . Basic image review tools (zoom, pan, measure)
- Easy study navigation and search capability .
- Radiology key images .
- Comparative review .
- . Cross-platform viewing capabilities (Windows, Linux, Mac OS)
- Leveraging of next-generation protocols for image viewing (i.e. MINT) .
- Single sign-on .
- . MPR and 3D viewing
- . Access on various iOS and Android tablet devices through the default internet browser
### Intended Use / Indications for Use:
VitreaView is a medical image viewing and information distribution application that provides access, through the Internet and within the enterprise, to multi-modality softcopy medical images, reports and other patient-related information, that may be hosted within disparate archives and repositories for review, communication and reporting of DICOM and non-DICOM data. VitreaView is not intended for primary diagnosis. When accessed from a mobile tablet, VitreaView is for informational purposes only and not intended for diagnostic use.
Display monitors used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance.
Lossy compressed mammographic images and digitized film screen images must not be reviewed for primary image interpretations. Mammographic images may only be interpreted using an FDA approved monitor that offers at least 5 MP resolution and meets other technical specifications reviewed and accepted by FDA.
### Summary of Non-Clinical Tests:
VitreaView was designed, developed, and tested according to written procedures. Testing included verification, validation, and evaluation of previously acquired medical images.
The following quality assurance measures were applied to the development of VitreaView:
- Risk analysis .
- Requirements reviews .
- Design reviews .
- . Performance testing (Verification)
- Safety testing (Verification) .
- Simulated use testing (Validation) �
The software verification team had a primary goal of assuring that the software fully satisfies all expected new and previously defined detailed level system requirements and features. This was accomplished through new feature test case authoring on the system requirements and their execution. In addition to reviewing and authoring test cases based upon the system requirements and features the verification team reviewed and monitored the Requirements Traceability Matrix (RTM) to ensure coverage of said items as well as review and authoring of additional cases to meet the FMEA submitted for the project.
The software validation team had a primary goal of assuring that the software conforms to user needs and intended uses. The result of the validation team's efforts was evidence that system requirements and features were implemented, reviewed and met through workflow testing.
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# Vital Images
The software validation team provided internal validation of the VitreaView product once verification was completed. Internal validation included internal beta testing, internal user acceptance testing, and installation and upgrade path testing.
The software was designed, developed and tested according to written procedures, Software testing was completed to ensure the new feature functions according to its requirements and interacts without impact to existing functionality.
#### Summary of Clinical Tests:
The subject of this traditional 510(k) notification, VitreaView, did not require clinical studies to support safety and effectiveness of the software.
#### Cyber and Information Security:
VitreaView is designed to follow security best practices, including those outlined by the Open Web Application Security Project (OWASP) and Health Insurance Portability and Accountability Act (HIPAA), to limit the risk of unauthorized access to the system or data. Security is enforced at multiple layers within the system.
#### Measurement Accuracy:
Measurements and orientation in VitreaView were verified using various imaging phantoms. These imaging phantoms contain markers at known positions, distances, and angles from one another. The known positions, distances, and angles were used as input into expected results for verification tests that verified the spatial accuracy of image rendering of 2D and 3D images, the accuracy of distance, angular measurement, and navigational tools, and the accuracy of orientation markers within the VitreaView application.
#### Performance Standard:
The software is designed to meet NEMA PS 3.1-3.20 (2011) Digital Imaging and Communications in Medicine (DICOM).
#### Conclusion:
The VitreaView software is substantially equivalent to the predicate device and is safe and effective for its intended use.
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Image /page/3/Picture/0 description: The image contains the logo for the U.S. Department of Health and Human Services. The logo features a stylized graphic of an abstract human form, composed of three curved lines, positioned to the right of the department's name. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES · USA" is arranged in a circular fashion around the graphic.
## DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -- WO66-G609 Silver Spring, MD 20993-00002
Mr. Ian Nemerov Vice President, General Counsel & Secretary Vital Images. Inc. 5850 Opus Parkway, Suite #300 MINNETONKA MN 55343
Re: K122136
Trade/Device Name: VitreaView Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ Dated: July 17, 2012 Received: July 18, 2012
### Dear Mr. Nemerov:
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, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. 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 Parts 801 and 809); medical device reporting of
\$\text{SEP} \qquad 7 \ 2012\$
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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 requirement as be form arketing 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 11 you dose 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,
Janine M. Morris
Acting Director Division of Radiological Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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# Indications for Use Form
K 122136 510(k) Number (if known):
Device Name: VitreaView
#### Indications for Use:
VitreaView is a medical image viewing and information distribution application that provides access, through the internet and within the enterprise, to multi-modality softcopy medical images, reports and other patient-related information, that may be hosted within disparate archives and repositories for review, communication and reporting of DICOM and non-DICOM data. VitreaView is not intended for primary diagnosis. When accessed from a mobile tablet, VitreaView is for informational purposes only and not intended for diagnostic use. .
Display monitors used for reading medical images for diagnostic purposes must comply with applicable regulatory approvals and with quality control requirements for their use and maintenance.
Lossy compressed mammographic images and digitized film screen images must not be reviewed for primary image interpretations. Mammographic images may only be interpreted using an FDA approved monitor that offers at least 5 MP resolution and meets other technical specifications reviewed and accepted by FDA.
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 OF NEEDED)
Concurrence of CDRH, Office of In Vitro Diagnostic Devices (OIVD)
Division Sign-Off
In Vitro Diagnostic Device
510(k) K122136
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VitreaView
Page 26 of 125
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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.