ZEN-7000 is a mobile fluoroscopy system is designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures. Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, cardiac, critical care and emergency room procedures. The system may be used for other imaging applications at the physician's discretion.
Device Story
Mobile fluoroscopy system consisting of C-arm mainframe and mobile workstation. Mainframe supports X-ray tube and image intensifier; performs linear/rotational positioning for imaging. Workstation supports image display and recording. Used in OR, clinic, or emergency settings by physicians/technicians. Captures X-ray signals; transforms into fluoroscopic/spot-film images. Output displayed for real-time visualization during procedures. Assists clinical decision-making by providing intraoperative anatomical guidance; benefits patients through minimally invasive surgical support.
Clinical Evidence
Bench testing only. Performance evaluated via electrical, mechanical, and environmental safety testing (IEC 60601-1, -1-3, -2-28, -2-43, -2-54), EMC testing (IEC 60601-1-2), and EPRC standards (21 CFR 1020.30, 31). Adherence to FDA guidance for Solid State X-ray Imaging Devices and DICOM (NEMA PS 3.1-3.18) confirmed. Results satisfactory; no clinical data provided.
Technological Characteristics
Mobile C-arm fluoroscopic X-ray system. High-frequency inverter generator (5kW or 15kW). Rotating X-ray tube (0.3mm/0.6mm focal spots). Image intensifier (9" or 12"). CCD camera. Connectivity via DICOM. Standards: IEC 60601-1 series, 21 CFR 1020.30/31, NEMA PS 3.1-3.18.
Indications for Use
Indicated for patients undergoing diagnostic, surgical, and interventional procedures requiring fluoroscopic and spot-film imaging, including cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, and cardiac procedures, as well as critical care and emergency room applications.
Regulatory Classification
Identification
An image-intensified fluoroscopic x-ray system is a device intended to visualize anatomical structures by converting a pattern of x-radiation into a visible image through electronic amplification. 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). An anthrogram tray or radiology dental tray intended for use with an image-intensified fluoroscopic 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. In addition, when intended as an accessory to the device described in paragraph (a) of this section, the fluoroscopic compression device 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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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 9, 2014
GENORAY Co., Ltd. % Ms. Kaitlynn Min Business Development Manager GENORAY America, Inc. 3002 Dow Avenue, Suite 420 TUSTIN CA 92780
Re: K140041
Trade/Device Name: Fluoroscopic X-ray System (Models: ZEN-7000) Regulation Number: 21 CFR 892.1650 Regulation Name: Image-intensified fluoroscopic x-ray system Regulatory Class: II Product Code: OWB, OXO, JAA Dated: October 29, 2014 Received: October 30, 2014
Dear Ms. Min:
This letter corrects our substantially equivalent letter of November 28, 2014.
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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
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Page 2 - Ms. Min
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Michael D.'Hara
for
Janine M. Morris Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K140041
Device Name
Fluoroscopic X-Ray System (Models: ZEN-7000)
#### Indications for Use (Describe)
ZEN-7000 is a mobile fluoroscopy system is designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures. Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, critical care and emergency room procedures. The system may be used for other imaging applications at the physician's discretion.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| ☑ Prescription Use (Part 21 CFR 801 Subpart D) |
|------------------------------------------------|
| ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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#### 510(k) Summary Exhibit 5
Date of Summary Preparation: January 2, 2014
| 1. | Submitter and US Official Correspondent: | | |
|----|-------------------------------------------------------------------|----------------------------------------------|--------------------------------------------------------|
| | 1.1 Submitter | | |
| | Submitter: | | GENORAY Co., Ltd. |
| | Address: | | #512, Byucksan Technopia, 434-6, Sangdaewon 1-dong, |
| | | | Jungwon-gu, Seongnam-city, Gyeonggi-do, 462-716, Korea |
| | Telephone No.: | | +82-31-740-4100 |
| | Fax: | | +82-31-737-8025 |
| | 1.2 Official Correspondent (U.S): Kaitlynn Min - Business Manager | | |
| | Correspondent: | GENORAY America Inc. | |
| | Address: | 3002 Dow Avenue, Suite 420, Tustin, CA 92780 | |
| | Telephone No.: | 714-289-8020 | |
| | Fax: | 714-786-8919 | |
| | Email: | kaitlynn@genorayamerica.com | |
| 2. | Establishment Registration Number | | |
| | 3005843418 | | |
| 3. | Device Information | | |
| | Proprietary/Trade Name: | | ZEN-7000 |
| | Common/Usual Name: | | Fluoroscopic X-Ray System |
| | Classification Name: | | System, X-Ray, Fluoroscopic, Image-Intensified |
| | Product Code: | | Primary product code OWB |
| | | | Secondary product code JAA, OXO |
| | Device Class: | | Class II per regulation 21 CFR 892.1650 |
| 4. | Legally Marketed Predicate Device | | |
| | Manufacturer: | | GENORAY Co., Ltd. |
| | Trade Name: | | ZEN-7000 |
| | 510(k) Number: | | K103425 (Decision Date - Mar 29, 2011) |
| | Classification Name: | | System, X-Ray, Fluoroscopic, Image-Intensified |
| | Product Code: | | Primary product code OWB |
| | | | Secondary product code JAA, OXO |
| | Manufacturer: | | GE Healthcare Surgery |
| | Trade Name: | | OEC 9900 Elite |
| | 510(k) Number: | | K082781 (Decision Date - May 01, 2009) |
| | Classification Name: | | System, X-Ray, Fluoroscopic, Image-Intensified |
| | Product Code: | | Primary product code OWB |
| | | | Secondary product code JAA, OXO |
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## 5. Description of the Device
ZEN-7000 mobile fluoroscopy system is an image intensified fluoroscopic system consisting of two mobile units: a Mainframe (C-Arm) and a Workstation. The Mainframe (C-Arm) is comprised of a high voltage generator, x-ray control, and a "C" shaped apparatus, which supports an X-ray tube and an image intensifier. The Mainframe is designed to perform linear and rotational motions that allow the user to position the x-ray imaging components at various angles and distances with respect to the patient. The Workstation is a mobile platform that supports image display monitors and recording devices.
- 6. Indications for use
ZEN-7000 is a mobile fluoroscopy system is designed to provide fluoroscopic and spotfilm images of the patient during diagnostic, surgical and interventional procedures. Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, cardiac, critical care and emergency room procedures.
The system may be used for other imaging applications at the physician's discretion.
| 7. Substantial Equivalence Chart | | | |
|----------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Proposed device | Predicate device | Predicate device |
| | GENORAY<br>Fluoroscopic X-Ray System,<br>ZEN-7000 | GENORAY<br>Fluoroscopic X-Ray System,<br>ZEN-7000<br>K103425 | GE Healthcare Surgery<br>Fluoroscopic X-Ray System<br>OEC 9900 Elite<br>K082781 |
| Name | | | |
| Manufacturer | GENORAY Co., Ltd | GENORAY Co., Ltd | GE Healthcare Surgery |
| Indications for use | ZEN-7000 is a mobile fluoroscopy system is designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures. Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, cardiac, critical care and emergency room procedures. The system may be used for other imaging applications at the physician's discretion. | ZEN-7000 is a mobile fluoroscopy system is designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures. Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, cardiac, critical care and emergency room procedures. The system may be used for other imaging applications at the physician's discretion. | The OEC 9900 Elite mobile fluoroscopy system is designed to provide fluoroscopic and spot-film images of the patient during diagnostic, surgical and interventional procedures. Examples of clinical application may include cholangiography, endoscopy, urologic, orthopedic, neurologic, vascular, cardiac, critical care and emergency room procedures. The system may be used for other imaging applications at the physician's discretion. |
| Generator | High Frequency Inverter | High Frequency Inverter | High Frequency Inverter |
| Max. output power | 5 kW<br>15kW(Optional) | 5 kW | 15kW |
| X-ray tube | Rotating tube<br>Large: 0.6 mm<br>Small: 0.3 mm | Rotating tube<br>Large: 0.6 mm<br>Small: 0.3 mm | Rotating tube<br>Large: 0.6 mm<br>Small: 0.3 mm |
| Fluoroscopy | 40-120 kV / 0.2-6.0 mA | 40-120 kV / 0.2-6.0 mA | 40-120 kV / 0.2- 10 mA |
| | | | |
| Pulsed<br>Fluoros<br>copy | 1 mA to 20 mA(5kW)<br>1 mA to 48 mA(15kW) | 1 mA to 20 mA | 0.2 mA to 40 mA |
| Radiog<br>raphy | 40-120 kV / 1-100 mAs | 40-120 kV / 0.4-100 mAs | 40~120 kV / 1-300mAs |
| TV<br>Camer<br>a | CCD Type | CCD Type | CCD Type |
| | 9"(9"/6"/4.5") | | 9"(9"/6"/4.5") |
| | • Minimum central resolution<br>(at the monitor):<br>-9" (23cm): 2.2 lp/mm | | • Minimum central resolution<br>(at the monitor):<br>-9" (23cm): 2.1 lp/mm |
| | -6" (15cm): 2.8 lp/mm | 9"(9"/6"/4.5") | -6" (15cm): 2.9 lp/mm |
| | -4.5" (11cm): 3.0 lp/mm | • Minimum central resolution | -4.5" (11cm): 3.4 lp/mm |
| Image<br>Intensif | • DQE: 65% (typical) | (at the monitor):<br>-9" (23cm): 2.2 lp/mm | • DQE: 65% (typical) |
| ier | 12"(12"/9"/6") | -6" (15cm): 2.8 lp/mm | 12"(12"/9"/6") |
| | • Minimum central resolution<br>(at the monitor):<br>-12" (31cm): 1.6 lp/mm | -4.5" (11cm): 3.0 lp/mm<br>• DQE: 65% (typical) | • Minim m central resolution<br>(at monitor):<br>-12" (31cm): 1.5 lp/mm |
| | -9" (23cm): 2.0 lp/mm | | -9" (23cm): 2.1 lp/mm |
| | -6" (15cm): 2.5 lp/mm | | -6" (15cm): 2.6 lp/mm |
| | • DQE: 65% (typical) | | • DQE: 65% (typical) |
| | SID: 1000mm | SID: 1000mm | SID: 1000mm |
| | Free space: 786 mm | Free space: 750mm | Free space: 787mm |
| | Depth: 730 mm | Depth: 700 mm | Depth: 660mm |
| Dimens<br>ions | C-arm wig wag: ±12.5° | C-arm wig wag: ±12.5° | C-arm wig wag: ±20° |
| | Orbital Rotation: 135° | Orbital Rotation: 135° | Orbital Rotation: 115° |
| | Vert. Travel: 500mm | Vert. Travel: 450mm | Vert. Travel: 457mm |
| | Horiz. Travel: 200mm | Horiz. Travel: 200mm | Horiz. Travel: 203mm |
- Substantial Equivalongo Chart ー
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The proposed ZEN-7000 is based on the predicate device, ZEN-7000(k103425). The generation is similar to predicate devices with optional output power, 15kW. And Image intensifier has 9" and 12" sizes as predicate device OEC 9900 Elite (K082781). The ZEN-7000 is substantially equivalent to the predicate devices, ZEN-7000(k103425) and OEC 9900 Elite (K082781).
- 8. Safety and Effectiveness, comparison to Predicate
ZEN-7000 complies with industry standards such as IEC 60601-1 Series and 21 CFR 1020.30 and 21 CFR 1020.31 to minimize electrical, mechanical and radiation hazards. The new device modified from the predicate device was completed in accordance with GENORAY quality management system design controls.
{6}------------------------------------------------
- Electrical, mechanical, environmental safety and performance testing according to standard IEC 60601-1, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-43, and IEC 60601-2-54 were performed.
- EMC testing was conducted in accordance with standard IEC 60601-1-2.
- FDA Guidance "Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging Devices" was performed.
- ZEN-7000 meets the EPRC standards (21 CFR 1020.30, 31).
- ZEN-7000 also meets the provisions of NEMA PS 3.1-3.18, Digital Imaging and Communications in Medicine (DICOM) Set.
All test results were satisfactory and the result of bench and clinical evaluation indicates that the ZEN-7000 is as safe and effective as the predicate devices.
- 9. Conclusion
ZEN-7000 has the same indication for use as the predicate devices. And there have been no changes implemented in the modifications to the predicate ZEN-7000 and OEC 9900 Elite that impact either the fundamental technology or the indications for use. The New device outlined in this Premarket Notification is substantially equivalent to the currently commercially available predicate devices.
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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.