The GM85 Digital Mobile X-ray imaging System is intended for use in generating radiographic images of human anatomy by a qualified/trained doctor or technician. This device is not intended for mammographic applications.
Device Story
Mobile digital X-ray system captures radiographic images of human anatomy. X-rays pass through patient to detector; converted to electrical signals; amplified and digitized. S-Station software processes data, saves as DICOM files, and transmits to PACS server for clinical review. Includes Bone Suppression Image (BSI) software option to enhance chest pathology visualization by suppressing bone anatomy. Operated by qualified doctors or technicians in clinical settings. Output assists clinicians in diagnostic interpretation. Benefits include improved visualization of chest pathology via BSI and mobile imaging capability for patient convenience.
Clinical Evidence
No clinical data provided. Substantial equivalence supported by bench testing, including electrical, mechanical, and environmental safety (ES 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-54, ISO 14971, 21 CFR 1020.30/31), and non-clinical performance metrics (MTF, DQE per IEC 62220-1). BSI software verified and validated via system test cases.
Technological Characteristics
Mobile digital X-ray system. Components: High Voltage Generator, X-ray tube, digital detector. Software features: BSI, SimGrid, TLE, PEM, S-DAP, S-Align, S-Share. Connectivity: DICOM, PACS integration. Standards: ES 60601-1, IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-54, IEC 62220-1.
Indications for Use
Indicated for generating radiographic images of human anatomy. Intended for use by qualified/trained doctors or technicians. Not for mammographic applications.
Regulatory Classification
Identification
A mobile x-ray system is a transportable device system intended to be used to generate and control x-ray for diagnostic procedures. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 12, 2017
Samsung Electronics Co., Ltd. % Chulsin Kim Regulatory Affairs Manager 129, Samsung-ro, Yeongtong-gu Suwon-si. 16677 Gveonggi-do REPUBLIC OF KOREA
Re: K171119
Trade/Device Name: GM85 Regulation Number: 21 CFR 892.1720 Regulation Name: Mobile x-ray system Regulatory Class: II Product Code: IZL. MOB Dated: April 7, 2017 Received: April 14, 2017
Dear Chulsin Kim:
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 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
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forth in the quality systems (OS) 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" (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 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,
Michael D. O'Hara
For
Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
510(k) Number (if known)
K171119
Device Name GM85
Indications for Use (Describe)
The GM85 Digital X-ray imaging System is intended for use in generating radiographic images of human anatomy by a qualified/trained doctor or technician. This device is not intended for mammographic applications.
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------|
| <span> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> ☐ Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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510(k) Premarket Notification - Traditional
# Section 5: 510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted accordance with requirements of 21 CFR 807.92
- 1. Date: April 7, 2017
# 2. Submitter
- Company Name: SAMSUNG ELECTRONICS Co., Ltd. A.
- Address: 129, Samsung-ro, Yeongtong-gu, Suwon-si, Gyeonggi-do, 16677, B. Republic of Korea
# 3. Primary Contact Person
- A. Name: ChulSin Kim
- B. Title: Regulatory Affairs Manager
- Phone Number: +82-31-200-7661 ﻥ
- FAX Number: +82-31-200-1199 D. E-Mail:chulsin.kim@samsung.com
# 4. Secondary Contact Person
- A. Name: Ninad Gujar
- B. Title: Director, Regulatory & Quality
- C. Phone Number: 978-564-8503
- D. FAX Number: 978-750-6677 E-Mail: ngujar@samsungneurologica.com
#### 5. Proposed Device
- A. Trade Name: GM85
- B. Device Name: GM85
- C. Common Name: Digital Diagnostic Mobile X-ray System
- D. Classification Name: Mobile X-ray System
- Product Code: IZL & MQB ட்
- ட் Regulation: 21 CFR 892.1720
#### 6. Predicate Devices
| | Predicate Device #1 | Predicate Device #2 |
|------------------------|---------------------|----------------------------|
| Device Name | GM85 | GC70 |
| Classification<br>Name | MobileX-ray system. | Stationary<br>X-ray System |
| Product Code | IZL | KPR |
| Regulation | 21 CFR 892.1720 | 21 CFR 892.1680 |
| 510(K)# | K162278 | K163115 |
| 510(K) Decision Date | November 15, 2016 | December 07, 2016 |
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#### 510(k) Premarket Notification - Traditional
### 7. Device Description
The GM85 Digital Mobile X-ray imaging System is the equipment that captures images by transmitting X-ray to a patient's body. The X-ray passing through a patient's body is sent to the detector and then converted into electrical signals. These signals go through the process of amplification and digital data conversion in the signal process device before being sent to the S-Station (Operation Software) and saved in DICOM file, a standard for medical imaging. The captured images are sent to the Picture Archiving & Communication System (PACS) server, and can be used for reading images.
The Bone Suppression Image (BSI) is a post-image processing software option which provides companion images to assist diagnosis in addition to the images obtained from normal diagnosis protocol. The BSI software option suppresses bone anatomy to enhance visualization of chest pathology in a companion image that is delivered in addition to the original diagnostic image.
The BSI option is designed to be exclusively installed in S-station, SAMSUNG digital Xray operation software, while it uses the radiological image as an input and do not depend on how the image is acquired or which radiology device is used.
#### 8. Intended Use
The GM85 Digital Mobile X-ray imaging System is intended for use in generating radiographic images of human anatomy by a qualified/trained doctor or technician. This device is not intended for mammographic applications.
# 9. Summary of Technological characteristic of the proposed device compared with the predicate devices
The proposed device GM85 applies a post-image processing software feature as BSI (Bone Suppression Image), which was cleared with K163115, to the predicate device GM85 (K162278) without changes in technical characteristics, materials, energy sources and biocompatibility such as High Voltage Generator(HVG), X-ray Tube Assembly and Detectors.
Comparisons of technological characteristics were executed and demonstrate the substantial equivalence to the predicates.
#### A. Comparing with Predicate Device #1 and #2
The proposed device is shown as its parts are identical or equivalent with predicate device #1 or #2 while the BSI is applied, which does not show significant difference in safety and effectiveness.
| Specification | Predicate Device #1 | Proposed Device | Predicate Device #2 | Discussion |
|------------------|-----------------------|-----------------------|-----------------------|------------|
| Device<br>Name | GM85 | GM85 | GC70 | |
| Manufacture | SAMSUNG | SAMSUNG | SAMSUNG | |
| | ELECTRONICS co., ltd. | ELECTRONICS co., ltd. | ELECTRONICS co., ltd. | |
| 510(k)<br>Number | K162278 | - | K163115 | |
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510(k) Premarket Notification - Traditional
| Appearances | Image: Samsung GM85 Digital Mobile X-ray | Image: Samsung GM85 Digital Mobile X-ray | Image: GC70 Digital X-ray Imaging System | Same as<br>PD#1 |
|-----------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|
| Intended<br>Use | The GM85 Digital<br>Mobile X-ray imaging<br>System is intended for<br>use in generating<br>radiographic images of<br>human anatomy by a<br>qualified/trained doctor<br>or technician. This<br>device is not intended<br>for mammographic<br>applications. | The GM85 Digital<br>Mobile X-ray imaging<br>System is intended for<br>use in generating<br>radiographic images of<br>human anatomy by a<br>qualified/trained doctor<br>or technician. This<br>device is not intended<br>for mammographic<br>applications. | The GC70 Digital X-ray<br>Imaging System is<br>intended for use in<br>generating radiographic<br>images of human<br>anatomy by a<br>qualified/trained doctor<br>or technician. This<br>device is not intended<br>for mammographic<br>applications. | Same as<br>PD#1 |
| Manufacturer Contents | Predicate Device #1 | Proposed Device<br>GM85 | Predicate Device<br>#2 | Discussion |
|---------------------------------------|---------------------|-------------------------|------------------------|-----------------|
| Software Feature | | | | |
| SimGrid | SimGrid | SimGrid | SimGrid | Same as<br>PD#1 |
| Tube & Line<br>Enhancement(TLE) | TLE | TLE | - | Same as<br>PD#1 |
| Pediatric Exposure<br>Management(PEM) | PEM | PEM | - | Same as<br>PD#1 |
| S-DAP | S-DAP | S-DAP | S-DAP | Same |
| S-Align | S-Align | S-Align | S-Align | Same as<br>PD#1 |
| S-Share | S-Share | S-Share | S-Share | Same |
| BSI | - | BSI | BSI | Same as<br>PD#2 |
#### B. Safety, EMC and Performance Data
Electrical, mechanical, environmental safety and performance testing according to standard ES 60601-1,IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-28, IEC 60601-2-54, ISO14971, 21CFR1020.30 and 21CFR1020.31 were performed, and EMC testing was conducted in accordance with standard IEC 60601-1-2. Wireless function was tested and verified followed by guidance, Radio frequency Wireless Technology in Medical Devices. All test results were satisfying the standards.
#### C. Non-clinical data
Non-clinical data was provided in conformance to the FDA "Guidance for the Submission of 510(k)'s for Solid-State X-ray Imaging Devices", which includes MTF and DQE measurements as tested by IEC 62220-1.
The proposed device has same detectors so it shows no difference in non-clinical testing data such as MTF and DQE measurements from the predicate device #1 and #2. BSI installed in S-Station of GM85 has been verified and validated through GM85
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#### 510(k) Premarket Notification - Traditional Software System Test Case.
# D. Clinical data
The application of BSI, cleared with K163115, to the proposed device GM85 does not require clinical data.
### E. Conclusions
The non-clinical demonstrates that the proposed device is as safe, as effective, and performs as well as the legally marketed predicate devices.
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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.
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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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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.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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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.