A retrospective data analysis was performed to compare the performance of the new Auto ElastQ automated software feature against manual measurements performed by expert readers on retrospective clinical data.
Retrospective data analysis study; Retrospective performance comparison
Patients undergoing liver stiffness measurements via 2D-SWE
Manual measurements performed by expert readers
Agreement between Auto ElastQ algorithm-generated measurements and manual elastography measurements
Indications for Use
The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use: Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Cardiac), intra-luminal, intra-luminal, intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transveginal, Lung. Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging. The clinical environments where EPIQ Series Diagnostic ultrasound Systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients. When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live echo guidance. The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure. The intended use of Affiniti Series Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use: Abdominal, Cardiac Adult, Cardiac Other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculosketal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung. Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging. The clinical environments where the Affiniti diagnostic ultrasound systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients. The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Device Story
EPIQ and Affiniti Series Diagnostic Ultrasound Systems are diagnostic imaging platforms. The new Auto ElastQ software feature assists clinicians in liver stiffness measurements using 2D-Shear Wave Elastography (2D-SWE). The system analyzes cineloop buffer frames to identify and recommend up to three stable frames and optimal, homogeneous ROI positions for measurement. Clinicians review these automated suggestions and may adjust them if necessary. The system operates in clinics, hospitals, and point-of-care environments, managed by trained healthcare professionals. The output provides quantitative stiffness measurements, aiding clinical decision-making for liver assessment. The feature enhances workflow efficiency compared to manual frame selection and ROI placement.
Clinical Evidence
No clinical trials were conducted. Substantial equivalence is supported by non-clinical performance testing and a retrospective data analysis study. The study evaluated the performance of the Auto ElastQ software against manual measurements performed by expert readers (used as ground truth). Results demonstrated high agreement between algorithm-generated measurements and manual measurements, meeting all pre-determined acceptance criteria.
Technological Characteristics
Diagnostic ultrasound system using ultrasonic pulsed Doppler and echo imaging. Software version 12.0 includes the Auto ElastQ feature for 2D-SWE. Complies with IEC 62304 (software lifecycle) and ISO 14971 (risk management). No hardware or transducer changes. Connectivity via standard ultrasound system interfaces.
Indications for Use
Indicated for diagnostic ultrasound imaging and fluid flow analysis of the human body, including abdominal, cardiac (adult/pediatric/fetal), vascular (cerebral/peripheral), cephalic (neonatal), fetal/obstetric, gynecological, intraoperative, musculoskeletal, ophthalmic, urological, small organ (breast/thyroid/testicle), transesophageal, transrectal, transvaginal, and lung applications. Used in clinics, hospitals, and point-of-care settings by trained healthcare professionals.
Regulatory Classification
Identification
An ultrasonic pulsed doppler imaging system is a device that combines the features of continuous wave doppler-effect technology with pulsed-echo effect technology and is intended to determine stationary body tissue characteristics, such as depth or location of tissue interfaces or dynamic tissue characteristics such as velocity of blood or tissue motion. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Predicate Devices
EPIQ Series Diagnostic Ultrasound System and Affiniti Series Diagnostic Ultrasound System (K240850)
Submission Summary (Full Text)
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December 12, 2024
Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of a blue square with the letters "FDA" in white. To the right of the blue square, the words "U.S. FOOD & DRUG ADMINISTRATION" are written in blue.
Philips Ultrasound LLC Chanrasmey White Senior Regulatory Affairs Specialist 22100 Bothell Everett Hwy Bothell, Washington 98021
Re: K242020
EPIQ Series Diagnostic Ultrasound System; Affiniti Series Diagnostic Ultrasound Trade/Device Name: Svstem Regulation Number: 21 CFR 892.1550 Regulation Name: Ultrasonic Pulsed Doppler Imaging System Regulatory Class: Class II Product Code: IYN, IYO, ITX, OBJ, OIH Dated: November 12, 2024 Received: November 12, 2024
Dear Chanrasmey White:
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 (the 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 available at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpm/pm.cfm identifies combination product submissions. The general controls 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements. the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket
{1}------------------------------------------------
review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatoryinformation/postmarketing-safety-reporting-combination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advice-comprehensive-regulatory-assistance/unique-deviceidentification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reporting-mdr-how-report-medicaldevice-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/deviceadvice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuingeducation/cdrh-learn). 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 (https://www.fda.gov/medical-devices/deviceadvice-comprehensive-regulatory-assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# YANNA S. KANG -S
Yanna Kang, Ph.D. Assistant Director Mammography and Ultrasound Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
{2}------------------------------------------------
## Indications for Use
510(k) Number (if known) K242020
### Device Name
EPIQ Series Diagnostic Ultrasound System; Affiniti Series Diagnostic Ultrasound System
Indications for Use (Describe) EPIO:
The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Cardiac), intra-luminal, intra-luminal, intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transveginal, Lung.
Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where EPIQ Series Diagnostic ultrasound Systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live echo guidance.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
### Affiniti:
The intended use of Affiniti Series Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal, Cardiac Adult, Cardiac Other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculosketal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where the Affiniti diagnostic ultrasound systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healtheare
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| professionals for the purposes for which they were designed. However, nothing stated in the user information reduces |
|----------------------------------------------------------------------------------------------------------------------|
| your responsibility for sound clinical judgement and best clinical procedure. |
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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### 510(k) Summary
### #K242020
This summary of safety and effectiveness information is submitted in accordance with 21 CFR § 807.92. Date Prepared: December 9, 2024
| I. | Submitter | |
|-----|---------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Manufacturer Name and Address | Philips Ultrasound LLC<br>22100 Bothell Everett Hwy<br>Bothell, WA 98021-8431 USA |
| | Contact Information | Chanrasmey White<br>Senior Regulatory Affairs Specialist<br>22100 Bothell Everett Hwy<br>Bothell, WA 98021-8431 USA<br>smey.white@philips.com<br>1-207-249-5503 |
| | Secondary Contact | Amy Yang<br>Regulatory Affairs Director<br>22100 Bothell Everett Hwy<br>Bothell, WA 98021-8431 USA<br>amy.yang@philips.com<br>1-304-266-8208 |
| II. | Device | |
| | Proprietary Name | EPIQ Series Diagnostic Ultrasound System<br>Affiniti Series Diagnostic Ultrasound System |
| | Common Name | Diagnostic Ultrasound System and Transducers |
| | Product Code;<br>Regulation Description;<br>Regulation Number | IYN; Ultrasonic Pulsed Doppler Imaging System; 21 CFR 892.1550 (Primary)<br>IYO; Ultrasonic Pulsed Echo Imaging System; 21 CFR 892.1560<br>ITX; Diagnostic Ultrasonic Transducer; 21 CFR 892.1570<br>OBJ; Diagnostic Intravascular Catheter; 21 CFR 870.1200<br>QIH; Medical image management and processing system; 21 CFR 892.2050 |
| | Device Class | Class II |
| | Review Panel | Radiology |
| | Predicate Device | K240850; EPIQ Series Diagnostic Ultrasound System and<br>Affiniti Series Diagnostic Ultrasound System |
#### lll. Device Description
The purpose of this Traditional 510(k) Pre-Market Notification is to introduce the Auto ElastQ software feature onto the EPIQ and Affiniti Series Diagnostic Ultrasound Systems. The proposed EPIQ Series Diagnostic Ultrasound System and Affiniti Series Diagnostic Ultrasound Systems with new Auto ElastQ software feature, which is a workflow-enhancement software feature, is equivalent to predicate device, K240850.
The Auto ElastQ software feature is intended to assist users in making stiffness measurements using 2D-SWE in the liver by recommending specific frames and ROI positions to the user.
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Image /page/5/Picture/0 description: The image shows the word "PHILIPS" in large, bold, blue letters against a white background. The font is sans-serif and the letters are evenly spaced. The word is horizontally oriented and fills most of the frame.
No hardware changes to the EPIQ or Affiniti Systems are reguired when using the Auto ElastQ software feature, and existing, commercialized Philips transducers are used for the Auto ElastQ software feature. The feature is supported by EPIQ and Affiniti models running software version 12.0.
#### IV. Indications for Use
### EPIQ:
The intended use of EPIQ Ultrasound Diagnostic System is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal, Cardiac Adult, Cardiac other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Adult). Cephalic (Neonatal). Fetal/Obstetric. Gynecological. Intraoperative (Vascular). Intraoperative (Cardiac), intra-luminal, intra-cardiac echo, Musculoskeletal (Conventional), Musculoskeletal (Superficial), Ophthalmic, Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode, M Mode, PW Doppler, CW Doppler, Color Doppler, Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where EPIQ Series Diagnostic ultrasound Systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
When integrated with Philips EchoNavigator, the systems can assist the interventionalist and surgeon with image guidance during treatment of cardiovascular disease in which the procedure uses both live X-ray and live echo guidance.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healthcare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
### Affiniti:
The intended use of Affiniti Series Diagnostic Ultrasound Systems is diagnostic ultrasound imaging and fluid flow analysis of the human body, with the following indications for use:
Abdominal. Cardiac Adult. Cardiac Other (Fetal), Cardiac Pediatric, Cerebral Vascular, Cephalic (Adult), Cephalic (Neonatal), Fetal/Obstetric, Gynecological, Intraoperative (Vascular), Intraoperative (Cardiac), Musculoskeletal (Conventional), Musculoskeletal (Superficial), Other: Urology, Pediatric, Peripheral Vessel, Small Organ (Breast, Thyroid, Testicle), Transesophageal (Cardiac), Transrectal, Transvaginal, Lung.
Modes of operation include: B Mode. PW Doppler. CW Doppler. Color Doppler. Color M Mode, Power Doppler, and Harmonic Imaging.
The clinical environments where the Affiniti diagnostic ultrasound systems can be used include clinics, hospitals, and clinical point-of-care for diagnosis of patients.
The systems are intended to be installed, used, and operated only in accordance with the safety procedures and operating instructions given in the product user information. Systems are to be operated only by appropriately trained healthcare professionals for the purposes for which they were designed. However, nothing stated in the user information reduces your responsibility for sound clinical judgement and best clinical procedure.
Image /page/5/Picture/16 description: The image shows the Philips logo, which is a blue shield with the word "PHILIPS" at the top and a wavy line with stars inside the shield. Below the logo is the number 2 in a simple, sans-serif font. The logo is a well-known brand symbol, and the number 2 is likely an identifier or label.
{6}------------------------------------------------
# PHILIPS
#### V. Comparison of Technological Characteristics with the Predicate
The purpose of the submission is to introduce the Auto ElastQ software feature onto the EPIQ and Affiniti Series Diagnostic Ultrasound Systems. The proposed EPIQ and Affiniti Series Diagnostic Ultrasound Systems are all Track 3 Devices and comply with the referenced standards as well as the FDA Ultrasound Guidance Document, Guidance for Industrly and FDA Staff – Marketing Clearance of Diagnostic Ultrasound Systems and Transducers, issued in February 2023. The subject devices are substantially equivalent to the predicate devices (K240850).
| | EPIQ Series Diagnostic<br>Ultrasound System<br>Affiniti Series Diagnostic<br>Ultrasound System<br>Proposed Devices | EPIQ Series Diagnostic<br>Ultrasound System<br>Affiniti Diagnostic Ultrasound<br>System<br>(K240850)<br>Predicate Device | Comparison |
|----------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Feature | | | |
| USA FDA<br>Classification | Class II | Class II | Identical |
| Primary Product<br>Code | IYN | IYN | Identical |
| Primary Regulation<br>Number | 21 CFR 892.1550 | 21 CFR 892.1550 | Identical |
| Marketing Name of<br>Application | Auto ElastQ | ElastQ | Subject of this<br>submission |
| Application<br>Description | The Auto ElastQ software feature<br>is intended to assist the user in<br>making liver stiffness<br>measurements using 2D-SWE<br>through recommended particular<br>frames and ROI positions to the<br>user.<br>The system software will select up<br>to three frames that are assessed<br>to be the most stable and present<br>these to the user. The circle ROI<br>will be launched in the locations<br>that are identified to be<br>homogenous and temporally<br>stable. | The ElastQ feature ("manual<br>workflow") is a tool for measuring<br>the stiffness of the target organ<br>(liver) which requires the user to<br>review a loop of elastography<br>images displayed on the system<br>and uses the trackball to cine to<br>the frame(s) that are visually<br>perceived to be the most stable.<br>The circle ROI is then launched in<br>the center of the shear wave<br>imaging box, and the user<br>manually positions the ROI within<br>the box in a location that appears<br>to be homogenous and<br>representative of the tissue in the<br>entire box. | Subject of this<br>submission<br>The difference between<br>the predicate and the<br>subject device is:<br>The proposed Auto<br>ElastQ feature<br>recommends particular<br>frames and ROI locations<br>that are assessed to be<br>most stable homogenous<br>to the user.<br>The predicate device<br>requires users to review<br>a loop of elastography<br>images and then use the<br>trackball to cine to the<br>frames that are visually<br>perceived to be the most<br>stable. Then the user<br>must manually positions<br>the ROI in a location that<br>appears to be most<br>stable and homogenous. |
| | EPIQ Series Diagnostic | EPIQ Series Diagnostic<br>Ultrasound System | |
| Feature | Ultrasound System<br>Affiniti Series Diagnostic<br>Ultrasound System | Affiniti Diagnostic Ultrasound<br>System<br>(K240850)<br>Predicate Device | Comparison |
| | Proposed Devices | | |
| User Interface<br>Presentation | The Auto ElastQ workflow<br>analyzes the frames present in<br>the cineloop buffer. The system<br>software will automatically cine to<br>three frames that are assessed to<br>be the most stable and present<br>these to the user. The<br>measurement ROI will<br>automatically launch and be<br>placed on locations identified to<br>be homogeneous and temporally<br>stable.<br>Even though the Auto ElastQ<br>feature will suggest a particular<br>ROI placement, the user must<br>inspect the results and ensure<br>that it meets intended clinical use.<br>Otherwise, the user can make<br>adjustments to what the feature<br>proposes, by either selecting a<br>different frame or a different ROI<br>position. | In the current released software<br>("manual workflow"), the user<br>reviews a loop of elastography<br>images displayed on the system<br>display and then uses the<br>trackball to cine to the frame(s)<br>that are visually perceived to be<br>the most stable. The circle ROI is<br>then launched in the center of the<br>shear wave imaging box, and the<br>user manually positions the ROI<br>within the box in a location that<br>appears to be homogeneous and<br>representative of the tissue in the<br>entire box. | Subject of this<br>submission<br>The proposed Auto<br>ElastQ will provide a<br>recommendation to the<br>user where the predicate<br>device requires the user<br>to navigate the system<br>manually. |
| Compatible<br>transducers | Auto ElastQ Feature:<br>C5-1 | ElastQ Feature:<br>C5-1 | Identical, no new<br>transducers or modes<br>are being introduced in<br>this submission. |
| Measurements<br>Performed | The Auto ElastQ feature<br>calculates stiffness<br>measurements based on selected<br>frames and ROI positions<br>recommended to the user or<br>based on user adjustments to<br>what the feature recommended. | The ElastQ feature calculates<br>stiffness measurements based on<br>the manually selected frames and<br>ROI positions. | No new measurements<br>are being introduced in<br>this submission. The<br>subject of this<br>submission is to provide<br>workflow enhancements. |
| Application<br>performance | A retrospective data analysis<br>study was conducted to evaluate<br>the performance of the Auto<br>ElastQ software compared to<br>manual measurements performed<br>by expert readers.<br>The results demonstrated high<br>agreement of Auto ElastQ<br>algorithm-generated<br>measurements, based on<br>statistical analysis, with manual<br>elastography measurements. | N/A - the equivalent functionality<br>is performed manually by the<br>users to select the most<br>appropriate frames and ROI<br>positions. | Subject of this<br>submission |
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Image /page/7/Picture/0 description: The image shows the word "PHILIPS" in blue letters. The letters are bold and sans-serif. The background is a light gray color.
#### VI. Safety Considerations
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The subject device comply with the referenced standards as well as the FDA ultrasound guidance document. Guidance for Industry and FDA Staff – Marketing Clearance of Diagnostic Ultrasound Systems and Transducers, issued on February 2023.
#### VII. Non-Clinical Performance Data
The proposed modification of the EPIQ Series and Affiniti Series Diagnostic Ultrasound Systems was tested in accordance with Philips Internal Procedures. The design process incorporated IEC 62304 Medical Device Software - Software life cycle processes, 2006 + A 2015 and Risk Management procedures were applied in accordance with ISO 14971 Medical devices - Application of risk management to medical devices, to ensure the continued safe and effective performance. All software verification tests met the acceptance criteria.
Non-clinical verification testing was conducted to address the change and performance test data were provided to support the introduction of the subject software algorithm for the Auto ElastQ software feature. All software verification tests met the acceptance criteria.
A retrospective data analysis study was conducted to evaluate the performance of the Auto ElastQ software compared to manual measurements performed by expert readers, with the manual measurements used as ground truth for the study. The results demonstrated high agreement of Auto ElastQ algorithm-generated measurements with manual elastography measurements, meeting the acceptance criteria for the study.
#### VIII. Clinical Data
The proposed EPIQ and Affiniti Series Diagnostic Ultrasound System did not require clinical data for determination of substantial equivalence since substantial equivalence was demonstrated based on the following attributes:
- Design features ●
- Indications for use ●
- Fundamental scientific technology .
- Non-clinical performance testing ●
- Safety and effectiveness ●
#### IX. Conclusion
For testing, all pre-determined acceptance criteria were met. Results of these tests show that the proposed Auto ElastQ software feature meets the intended use. The proposed devices and predicate device:
- Are indicated for the diagnostic ultrasonic imaging and fluid flow analysis. ●
- Have identical intended users and use environments. ●
- . Have the same device classification, product codes.
- Have identical software. ●
- Are introducing no new hardware or transducers. ●
The differences between the proposed device and predicate device do not raise new questions of safety and/or effectiveness. The major differences include:
- The Auto ElastQ feature recommends particular frames that are assessed to be most stable and ROI locations that are assessed to be the most stable and homoqenous to the user, where the predicate devices require users to review a loop of elastography images then uses the trackball to cine to the frames that are visually perceived to be the most stable and manually positions the ROI in a location that appears to be most stable and homogenous.
Image /page/8/Picture/22 description: The image shows the Philips logo at the top, which is a blue shield with stars and waves inside. Below the logo, there is a large number 5. The number is in a simple, sans-serif font and is the most prominent element in the image.
{9}------------------------------------------------
## PHILIPS
Therefore, the proposed Auto ElastQ feature for the EPIQ and Affiniti Series Diagnostic Ultrasound Systems is substantially equivalent to the predicate EPIQ and Affiniti Series Diagnostic Ultrasound Systems in terms of safety and effectiveness.
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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.