PLANET Onco Dose is a standalone software intended to be used with PET or SPECT hybrid imaging systems in order to manage, process, display and analyze nuclear medical medical image series, to assist in medical diagnosis, to assist in treatment analysis and in therapy response assessment, to assist in the contouring of region of interest for radiotherapy. PLANET Onco Dose is dedicated to be used by qualified medical professionals in Molecular Imaging, and/or Medical Oncology. The medical modalities of these medical imaging systems include CT. MRI, SPECT, PET. XA, RT Struct and RT Dose as supported by ACR/NEMA DICOM 3 standard format. PLANET Onco Dose provides the user with the means to segment structures in medical image volumes by providing dedicated delineation, contouring and propagation tools for both tumors and normal tissues (i.e. Regions of Interest (ROI)). PLANET Onco Dose provides tools to display, co-register (including deformable registration), compute Standardized Uptake Value (SUV) and import / export results (contours and dosimetries) to / from Treatment Planning Systems (TPS) and PACS devices for assessment and response of patients undergoing a course of oncology treatment. PLANET Onco Dose provides the user with the means to assist in the assessment quantification of radiation doses received by tissues as a result of administering a radionuclide (e.g. Permanent Yttrium-90 microsphere implants). PLANET Onco Dose provides tools for post-treatment absorbed dose calculation and evaluation on PET and SPECT images. The following functions are available to allow dose calculations for patients after they have received a treatment using permanent Yttrium-90 (Y90) microspheres: - 3D liver-lung shunt assessment; - Local Deposition Model; - Voxel S Value approach based on the schema in MIRD Pamphlet 17 [1]: - Dosimetry based on 90Y-microspheres-PET (or SPECT Bremsstrahlung) series; - Compatible with PET images acquired with another radioisotope instead of Y90 when Y90 acquisitions are not supported by the scanner (correction of branching ratio and decay parameters). For Y90 microspheres. PLANET Onco Dose cannot be used to prescribe the radionuclide activity to be administered to the patient for the therapy. The user has to provide the parameters (e.g. activity) in order for PLANET Onco Dose to estimate the radiation doses that the tissues received as a result of the administration. PLANET Onco Dose should only be used for the retrospective determination of dose and not for the case where is a need for retreatment using Y90 microspheres.
Device Story
Standalone software platform for oncology; processes PET/SPECT/CT/MRI/XA images; used by molecular imaging/oncology professionals. Core functions: multi-modal image registration (rigid/deformable), tumor/tissue segmentation, contouring, and propagation. Provides SUV quantification, RECIST 1.1/PERCIST 1.0 reporting, and internal dosimetry computation for Targeted Radionuclide Therapy (TRT). Input: DICOM images/RT objects; Output: segmented volumes, dose distributions, and dosimetry reports. Workflow: imports data from PACS/TPS, performs post-treatment dose evaluation using Local Deposition Model or Voxel S Value (MIRD 17) approaches. Assists clinicians in monitoring disease progression and therapy response. Benefits: enables retrospective absorbed dose verification for Y90 microsphere treatments; supports multi-stage treatment analysis (internal dosimetry + external beam).
Clinical Evidence
Bench testing only. Device underwent performance, functional, and algorithmic testing, risk management assessment, and validation under clinically representative conditions. No clinical trial data presented.
Technological Characteristics
Standalone software; Linux OS. Supports DICOM 3.0 (CT, MRI, SPECT, PET, XA, RT Struct, RT Dose). Features: rigid/deformable registration, semi-automatic/automated segmentation, SUV calculation, MIRD 17-based Voxel S Value dosimetry, Local Deposition Model. Cybersecurity: access control for trusted users. Major Level of Concern software.
Indications for Use
Indicated for qualified medical professionals in Molecular Imaging and/or Medical Oncology to manage, process, display, and analyze nuclear medicine and digital medical image series (CT, MRI, SPECT, PET, XA, RT Struct, RT Dose) for diagnostic aid, treatment analysis, therapy response assessment, radiotherapy contouring, and retrospective post-treatment absorbed dose calculation/evaluation (e.g., Yttrium-90 microspheres). Not for prescribing radionuclide activity or for cases requiring retreatment planning.
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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March 6, 2019
DOSIsoft % Mr. Luc Diot Quality Director 45/47, Avenue Carnot Cachan, 94230 FRANCE
Re: K182966
Trade/Device Name: PLANET Onco Dose Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: Class II Product Code: LLZ Dated: February 8, 2019 Received: February 21, 2019
Dear Mr. Diot:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice
(https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Michael D.'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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## Indications for Use
510(k) Number (if known) K182966
Device Name PLANET Onco Dose
#### Indications for Use (Describe)
PLANET Onco Dose is a standalone software intended to be used with PET or SPECT hybrid imaging systems in order to manage, process, display and analyze nuclear medical medical image series, to assist in medical diagnosis, to assist in treatment analysis and in therapy response assessment, to assist in the contouring of region of interest for radiotherapy.
PLANET Onco Dose is dedicated to be used by qualified medical professionals in Molecular Imaging, and/or Medical Oncology.
The medical modalities of these medical imaging systems include CT. MRI, SPECT, PET. XA, RT Struct and RT Dose as supported by ACR/NEMA DICOM 3 standard format.
PLANET Onco Dose provides the user with the means to segment structures in medical image volumes by providing dedicated delineation, contouring and propagation tools for both tumors and normal tissues (i.e. Regions of Interest (ROI)).
PLANET Onco Dose provides tools to display, co-register (including deformable registration), compute Standardized Uptake Value (SUV) and import / export results (contours and dosimetries) to / from Treatment Planning Systems (TPS) and PACS devices for assessment and response of patients undergoing a course of oncology treatment.
PLANET Onco Dose provides the user with the means to assist in the assessment quantification of radiation doses received by tissues as a result of administering a radionuclide (e.g. Permanent Yttrium-90 microsphere implants).
PLANET Onco Dose provides tools for post-treatment absorbed dose calculation and evaluation on PET and SPECT images. The following functions are available to allow dose calculations for patients after they have received a treatment using permanent Yttrium-90 (Y90) microspheres:
- 3D liver-lung shunt assessment;
- Local Deposition Model;
- Voxel S Value approach based on the schema in MIRD Pamphlet 17 [1]:
- Dosimetry based on 90Y-microspheres-PET (or SPECT Bremsstrahlung) series;
- Compatible with PET images acquired with another radioisotope instead of Y90 when Y90 acquisitions are not supported by the scanner (correction of branching ratio and decay parameters).
For Y90 microspheres. PLANET Onco Dose cannot be used to prescribe the radionuclide activity to be administered to the patient for the therapy. The user has to provide the parameters (e.g. activity) in order for PLANET Onco Dose to estimate the radiation doses that the tissues received as a result of the administration.
PLANET Onco Dose should only be used for the retrospective determination of dose and not for the case where is a need for retreatment using Y90 microspheres.
[1] Bolch WE et al. MIRD pamphlet no. 17: the dosimetry of nonuniform activity distributions-Radionuclide S values at the voxel level. J Nucl Med, 1999, 40:11S-36S
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Image /page/4/Picture/0 description: The image shows the word "DOSIsoft" with a butterfly image in between "DOSI" and "soft". The word "DOSI" is in a bold, serif font, and the word "soft" is in a thinner, sans-serif font. The butterfly image is blue and has red arrows pointing to it from the words on either side.
Image /page/4/Picture/1 description: The image is a logo with a blue circle and the letters "iSO" in the center. The word "CERTIFIED" is written in blue around the top of the circle. There are two red arrows on either side of the circle, pointing towards the center. The number "73485" is written in blue around the bottom of the circle.
# Premarket Notification 510(k) Summary [as required by 21 CFR 807.92]
# 510(k) Summary
K182966
- 1. Date the Summary was prepared: 2018-10-17
#### 2. Submitter:
| Company Name: | DOSIsoft SA |
|---------------|-----------------------------------------------|
| Address: | 45-47, Avenue Carnot<br>94230 CACHAN - France |
| Phone No.: | +33 1 41 24 26 26 |
| Fax No.: | +33 1 41 24 26 28 |
| Contact Name: | Mr. Marc USZYNSKI |
#### 3. Device Information:
| Proprietary Name: | PLANET Onco Dose |
|----------------------|-----------------------------------------------------------------------------------------|
| Trade Names: | PLANET Onco, PLANET Dose, PLANET Onco Dose |
| Common Name: | Medical Imaging Software |
| Classification Name: | System, Image Processing, Radiological<br>(21 CFR 892.2050, Class II, Product Code LLZ) |
## 4. Predicate Device:
K173636 - Velocity - Varian Medical Systems, Inc.
# Executive Summary
## 5. Product Description:
PLANET Onco Dose is a software platform dedicated to medical diagnosis aid, therapy response assessment aid, contouring for radiotherapy and internal dosimetry computation, using molecular imaging modalities.
PLANET Onco Dose is a modular software suite composed of three elements:
- PLANET: Core System: license controller, reviewing of multi-modal molecular image series -(PET/CT, SPECT/CT, PET/MRI, SPECT/MRI): fusion and registration;
- -PLANET Onco: Oncology Module: contouring of region of interest, turnor segmentation, tumoral activity monitoring, therapy response assessment;
- -PLANET Dose: Dosimetry Module: internal dosimetry computation for the Targeted Radionuclide Therapy (TRT).
## 6. Intended Use and User profiles:
PLANET Onco Dose is a standalone software intended to be used with PET or SPECT hybrid imaging systems in order to manage, process, display and analyze nuclear medicine and other digital mage series, to assist in medical diagnosis, to assist in treatment analysis and in therapy response assessment, to assist in the contouring of region of interest for radiotherapy.
PLANET Onco Dose is dedicated to be used by qualified medical professionals in Molecular Imaging, and/or Medical Oncology.
The medical modalities of these medical imaging systems include CT, MRI, SPECT, PET, XA, RT Struct and RT Dose as supported by ACR/NEMA DICOM 3 standard format.
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Image /page/5/Picture/0 description: The image shows the word "DOSIsoft" in a stylized font. The words "DOSI" and "soft" are in black, while the "I" is replaced with a blue butterfly-like shape. The text is horizontally aligned and the font is sans-serif.
Image /page/5/Picture/1 description: The image is a blue circular logo with the text "CERTIFIED" at the top. Inside the circle is the text "iSO" in a sans-serif font. Below the text "iSO" is the number "73485" with a bullet point on either side. There are two red arrows on either side of the text "iSO".
PLANET Onco Dose provides the user with the means to segment structures in medical image volumes by providing dedicated delineation, contouring and propagation tools for both tumors and normal tissues (i.e. Regions of Interest (ROI)).
PLANET Onco Dose provides to display, co-register (including deformable registration), compute Standardized Uptake Value (SUV) and import / export results (contours and dosimetries) to / from Treatment Planning Systems (TPS) and PACS devices for assessment and response of patients undergoing a course of oncology treatment.
PLANET Onco Dose provides the user with the means to assessment quantification and verification of radiation doses received by tissues as a result of administering a radionuclide (e.g. Permanent Yttrium-90 microsphere implants).
PLANET Onco Dose provides tools for post-treatment absorbed dose calculation and evaluation on PET and SPECT images. The following functions are available to allow dose calculations for patients after they have received a treatment using permanent Yttrium-90 (Y90) microspheres:
- ー 3D liver-lung shunt assessment;
- । Local Deposition Model;
- Voxel S Value approach based on the schema in MIRD Pamphlet 17 [1]; ।
- Dosimetry based on 90Y-microspheres-PET (or SPECT Bremsstrahlung) series; ।
- Compatible with PET images acquired with another radioisotope instead of Y90 when Y90 acquisitions are not supported by the scanner (correction of branching ratio and decay parameters).
For Y90 microspheres, PLANET Onco Dose cannot be used to prescribe the radionuclide activity to be administered to the patient for the therapy. The user has to provide the radionuclide parameters (e.g. activity) in order for PLANET Onco Dose to estimate the radiation doses that the tissues received as a result of the administration.
PLANET Onco Dose should only be used for the retrospective determination of dose and not for the case where there is a need for retreatment using Y90 microspheres.
[1] Bolch WE et al. MIRD pamphlet no. 17: the dosimetry of nonuniform activity distributions-Radionuclide S values at the voxel level. J Nucl Med, 1999, 40:11S-36S
## 7. Technological Characteristics:
4230 Cachan - France
The table below compares the technological characteristics and the features of PLANET Onco Dose and its predicate Velocity K173636.
| PLANET Onco Dose (This submission) | Velocity K173636 (Predicate) |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use / Intended Use | |
| PLANET Onco Dose is a standalone software<br>intended to be used with PET or SPECT hybrid<br>imaging systems in order to manage, process,<br>display and analyze nuclear medicine and other<br>digital medical image series, to assist in medical<br>diagnosis, to assist in treatment analysis and in<br>therapy response assessment, to assist in the<br>contouring of region of interest for radiotherapy.<br>PLANET Onco Dose is dedicated to be used by<br>qualified medical professionals in Molecular Imaging,<br>and/or Medical Oncology. | Velocity is a software package that provides the<br>physicians a means for comparison of medical data<br>including imaging data that is DICOM compliant.<br>It allows the display, annotation, volume operation,<br>volume rendering, registration and fusion of medical<br>images as an aid during use by diagnostic radiology,<br>oncology, radiation therapy planning and other<br>medical specialties.<br>Velocity is not intended for mammography. |
| Device Type | |
| Standalone software | Standalone software |
| Users | |
| Qualified medical professionals in Molecular<br>Imaging, and/or Medical Oncology | Physicians |
| Cybersecurity | |
| DOSISOFT SA<br>45/47, avenue Carnot | +33 (0)1 41 24 26 26<br>info@dosisoft.com<br>Page 2/5 |
| PLANET Onco Dose (This submission) | Velocity K173636 (Predicate) |
| Limits software access to trusted users only | Limits software access to trusted users only |
| Workflow | Workflow |
| Oncology workflow automation | Oncology workflow automation |
| Receive, store and retrieve digital DICOM medical<br>images from a variety of sources and modalities<br>PET/SPECT/CT/MRI | Receive, store and retrieve digital DICOM medical<br>images from a variety of sources and modalities<br>PET/SPECT/CT/MRI |
| Digital medical images patient's structured database | Organize data into a logical overview of a patient's<br>imaging history |
| Image and registered image data export as DICOM<br>series | Image and registered image data export as DICOM<br>series |
| Structure Import, Save & Export as DICOM RT<br>Object | Structure Import, Save & Export as DICOM RT<br>Object |
| Dose data Import, Save & Export as DICOM RT<br>Object | Dose data Import, Save & Export as DICOM RT<br>Object |
| Reports can be exported as DICOM files | Reports can be exported as print sessions |
| Image Management Tools | Image Management Tools |
| Support of 4D series | Support of 4D series with breathing cine mode |
| Advanced visualization and navigation features | Advanced visualization and navigation features |
| Management of multi-time point image<br>series | Management of multi-time point image<br>series |
| Manual registration methods including landmarks | Manual registration method |
| Automatic rigid image registration and fusion of<br>medical series from multiple modalities | Automatic rigid image registration and fusion of<br>medical series from multiple modalities |
| Automatic deformable image registration and fusion<br>of medical images from multiple modalities | Automatic deformable image registration and fusion<br>of medical images from multiple modalities |
| Combines images from different modalities for<br>enhanced volume definition | Combines images from different modalities for<br>enhanced volume definition |
| Visualization Tools | Visualization Tools |
| General image viewer with view layout selection and<br>toolbars | General image viewer with view layout selection and<br>toolbars |
| 2D visualization (Multi-planar) | 2D visualization (Multi-planar) |
| 3D volume rendering | 3D volume rendering |
| Image fusion<br>Anatomical and functional series | Image fusion<br>Anatomical and functional series |
| Image analysis tools | Image analysis tools |
| General Contouring Features | General Contouring Features |
| Multi-modality manual contouring tools | Multi-modality manual contouring tools |
| Contour transformation tools | Contour transformation tools |
| Semi-automatic advanced contouring tools | Contouring with automated scripting |
| Automated structure of interest segmentation tools | Atlas auto-segmentation |
| Propagates contours from one time point to another | Propagates contours from one time point to another |
| Contour transformation (interpolation,<br>margining) between modalities | - |
| Functional Segmentation Tools | - |
| PLANET Onco Dose (This submission) | Velocity K173636 (Predicate) |
| Assessment Aid and Patient Follow-up Tools | |
| Visualization and analytical monitoring of disease<br>progression or response to treatment or therapy<br>using multiexam comparison and correlation | Visualization and analytical monitoring of disease<br>progression or response to treatment or therapy<br>using multiexam comparison and correlation |
| Quantification of metabolic activity and volume<br>measurement of segmented tumors on PET modality | Volume operations<br>Biological effective dose (BED) scaling |
| Measure Standard Uptake Value - SUV | Measure Standard Uptake Value - SUV |
| Advanced Tumor SUV Statistics | - |
| Patient's follow up analysis with volumetric graphs | Patient's follow up analysis with volumetric graphs |
| Allows generation of RECIST 1.1 & PERCIST 1.0<br>format reports. | - |
| Dose Distribution Import and Estimation Tools | |
| The dose distribution can be imported from any<br>system such as radiation therapy planning systems<br>using DICOM RT Dose format | The dose distribution can be imported from any<br>system such as radiation therapy planning systems<br>using DICOM RT Dose format |
| Intended for post-treatment absorbed dose<br>calculation and evaluation | Intended for post-treatment absorbed dose<br>calculation and evaluation |
| Compatible with Y90 PET and SPECT image types | Compatible with Y90 PET and SPECT image types |
| Use the Local Deposition Model for dose calculation | Use the Local Deposition Model for dose calculation |
| Use the Voxel S Value approach based on the<br>schema in MIRD Pamphlet 17 ([1]) | - |
| Dosimetry Analysis Tools | |
| Display of the dose distribution in patient tissues | Display of the dose distribution in patient tissues |
| Dose Volume Histogram statistics display | Dose Volume Histogram statistics display |
| Table of dose to organs | Table of dose to organs |
| Simultaneous display of two dose distributions and<br>comparison tools | - |
| Addition of multiple treatment stages: internal<br>dosimetry and/or external beam radiotherapy | Addition of multiple treatment stages: internal<br>dosimetry and/or external beam radiotherapy |
| Operating System | |
| Linux operating system | Microsoft Windows and Apple macOS operating<br>systems |
www.dosisoft.com
RCS Créteil 443 195 433
+33 (0)1 41 24 26 28 |
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Image /page/6/Picture/0 description: The image shows the word "DOSI" in bold, black font, followed by a blue butterfly outline, and the word "soft" in a thin, black font. The butterfly is positioned between the two words, creating a visual break. The overall design is simple and clean, with a focus on the text and the butterfly symbol.
Image /page/6/Picture/1 description: The image is a logo for ISO certification. The logo is a blue circle with the letters "iSO" in white in the center. There are two red arrows on either side of the letters. The number "73485" is printed in black at the bottom of the circle. The word "CERTIFIED" is printed in white at the top of the circle.
DOSISOFT SA 45/47, avenue Carnot 94230 Cachan - France
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Image /page/7/Picture/0 description: The image shows the word "DOSI" in bold, black font, followed by a blue butterfly outline. The word "soft" is written in a thin, black font to the right of the butterfly. The image appears to be a logo or brand name.
Image /page/7/Picture/1 description: The image is a logo with the letters "iSO" in a white circle with a light blue background. The word "CERTIFIED" is written in blue letters above the circle, and the number "73485" is written in blue letters below the circle. There are two small red arrows on either side of the circle, pointing towards the letters "iSO".
## 8. Performance Testing - Bench:
PLANET Onco Dose was designed and documented in accordance with the recommandations of FDA "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" for software devices identified as Major Level of Concern.
PLANET Onco Dose was submitted to performance, functional and algorithmic testing, risk management assessment and validation activities under clinically representative conditions. The results of performance, functional and algorithmic testing, risk management assessment and validation activities under clinically representative conditions demonstrate the safety and effectiveness of PLANET Onco Dose.
PLANET Onco Dose meets the requirements of the device, its user needs and intended use, which are demonstrated to be substantially equivalent to those of the predicate device.
DOSISOFT SA 45/47, avenue Carnot 94230 Cachan - France
+33 (0)1 41 24 26 26 |
+33 (0)1 41 24 26 28 |
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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.