IC-Flow™ Imaging System 2.0, used in conjunction with Indocyanine Green (ICG), is indicated for fluorescence imaging of blood flow, tissue perfusion, and the lymphatic system in both adult and pediatric patients one month of age and older. Upon intravenous administration of ICG, the IC-Flow™ Imaging System 2.0 is used for fluorescence angiography before and after vascular, and plastic, micro-, and reconstructive procedures. Additionally, upon subcutaneous administration, the system is used for fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels.
Device Story
IC-Flow™ Imaging System 2.0 is a real-time near-infrared (NIR) fluorescence imaging system. It consists of a controller (with LAN/HDMI connectivity) and a handheld camera. The camera uses a high-power LED to excite ICG molecules in the patient's tissue; the camera captures the resulting fluorescent emission. The system displays real-time video on the controller touchscreen or an external monitor. Physicians or healthcare professionals operate the device in clinics or hospitals to visualize blood flow, tissue perfusion, and lymphatic vessels. Images and videos are recorded via camera buttons or controller icons and can be exported to USB, cloud, or external storage. The device assists clinicians in assessing tissue perfusion and vascular/lymphatic structures, potentially improving surgical planning or post-procedural monitoring.
Clinical Evidence
No clinical studies were required. Substantial equivalence was established through bench testing, engineering analysis, and comparison to predicate devices. Testing included software lifecycle (IEC 62304), electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), photobiological safety (IEC 62471), and usability (IEC 62366-1).
Technological Characteristics
NIR fluorescence imaging system using a high-power LED excitation source. Features a CMOS image sensor with 1920x1200 resolution. Working distance 170-200 mm; image section 75x100 mm. Connectivity via LAN, HDMI, and USB. Non-patient contacting. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 62471.
Indications for Use
Indicated for fluorescence imaging of blood flow, tissue perfusion, and lymphatic system in adult and pediatric patients (≥1 month). Used for fluorescence angiography (IV ICG) before/after vascular, plastic, micro-, and reconstructive procedures, and for lymphatic system visualization (subcutaneous ICG).
Regulatory Classification
Identification
An angiographic x-ray system is a device intended for radiologic visualization of the heart, blood vessels, or lymphatic system during or after injection of a contrast medium. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
Predicate Devices
SPY Portable Handheld Imaging (SPY-PHI) System (K230727)
{0}
FDA
U.S. FOOD & DRUG
ADMINISTRATION
September 22, 2025
Diagnostic Green GMBH
% Moj Eram
RA/QA Sr. Consultant
Jeff Yuen and Associates
1121 Military Cutoff Rd
C 376
Wilmington, North Carolina 28405
Re: K243645
Trade/Device Name: IC-Flow™ Imaging System 2.0
Regulation Number: 21 CFR 892.1600
Regulation Name: Angiographic X-Ray System
Regulatory Class: Class II
Product Code: IZI
Dated: September 18, 2025
Received: September 18, 2025
Dear Moj Eram:
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/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
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K243645 - Moj Eram
Page 2
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 (QS) 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 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 (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-regulatory-information/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-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-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-devices/medical-device-safety/medical-device-reporting-mdr-how-report-medical-device-problems.
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K243645 - Moj Eram
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For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/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/device-advice-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,
TANISHA
L. HITHE -S
Digitally signed by
TANISHA L. HITHE -S
Date: 2025.09.22
18:11:01 -04'00"
Tanisha Hithe
Assistant Director
DHT4A: Division of General Surgery Devices
OHT4: Office of Surgical and
Infection Control Devices
Office of Product Evaluation and Quality
Center for Devices and Radiological Health
Enclosure
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FORM FDA 3881 (6/20)
Page 1 of 1
PSC Publishing Services (301) 443-6740
EF
| DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Indications for Use | Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below. |
| --- | --- |
| 510(k) Number (if known) K243645 | |
| Device Name IC-Flow™ Imaging System 2.0 | |
| Indications for Use (Describe) IC-Flow™ Imaging System 2.0, used in conjunction with Indocyanine Green (ICG), is indicated for fluorescence imaging of blood flow, tissue perfusion, and the lymphatic system in both adult and pediatric patients one month of age and older. Upon intravenous administration of ICG, the IC-Flow™ Imaging System 2.0 is used for fluorescence angiography before and after vascular, and plastic, micro-, and reconstructive procedures. Additionally, upon subcutaneous administration, the system is used for fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels. | |
| Type of Use (Select one or both, as applicable) ☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C) | |
| CONTINUE ON A SEPARATE PAGE IF NEEDED. | |
| This section applies only to requirements of the Paperwork Reduction Act of 1995. *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* | |
| The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov | |
| "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." | |
{4}
Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
# 510(k) Summary
# #K243645
A summary of 510(k) safety and effectiveness information in accordance with the requirements of 21 CFR 807.92.
## Submitter and Regulatory Information – (21 CFR 807.92(a)(1))
| Submitter Information | |
| --- | --- |
| Name | Diagnostic Green GmbH |
| Address | Feldkirchener Str. 7c
85551 Kirchheim b.
München, Germany |
| Contact Name | Ann M Maloney |
| Telephone Number | 614-561-7877 |
| Email | amaloney@diagnosticgreen.com |
| Date Summary Prepared | 12 September 2025 |
| Primary Regulatory Contact | |
| Name | Moj Eram, PhD |
| Title | Regulatory Affairs Consultant
Jeff Yeun and Associates |
| Telephone Number | 801-230-8611 (Mobile) |
| Email | Moj_eram@jeffyuen.com |
## Name of the Device – (21 CFR 807(a)(2))
| Trade Name | IC-Flow™ Imaging System 2.0 |
| --- | --- |
| Classification Name | Angiographic X-Ray System |
| Regulatory Class | Class II |
| Product Code | IZI |
| Regulation Number | 21 CFR 892.1600 |
| Regulation Medical Specialty | Radiology |
| Review Panel | General & Plastic Surgery |
## Predicate Information – (21 CFR 807(a)(3))
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Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
| Table 10-3A: Predicate Device Regulatory Information | | |
| --- | --- | --- |
| Regulatory Information | Predicate Device 1
SPY-PHI
(Primary) | Predicate Device 2
Pde-neo |
| K Number | K230727 | K133719 |
| Device Name | SPY Portable Handheld
Imaging (SPY-PHI) System | Pde-neo |
| Manufacturer/ Applicant | Novadaq Technologies ULC | HAMAMATSU
PHOTONICS, K.K. |
| Date of Clearance | 06/05/2023 | 03/27/2014 |
| Device Classification Name | Angiographic X-ray System | Angiographic X-ray System |
| Device Classification | Class II | Class II |
| Product Code | IZI | IZI
Subsequent: OWN |
| Regulation Number | 21 CFR 892.1600 | 21 CFR 892.1600 |
| Regulation Definition | Angiographic X-ray System | Angiographic X-ray System |
| Regulatory Medical Specialty | Radiology | Radiology |
| Review Panel | General & Plastic Surgery | Radiology |
## Device Description
The IC-Flow™ Imaging System 2.0 is a real time near-infrared (NIR) fluorescence imaging system which facilitates visualization of the distribution and intensity of the Indocyanine Green (ICG) fluorescent imaging agent during medical procedures.
The IC-Flow™ Imaging System 2.0 consists of a Controller with further connections to LAN and HDMI and a handheld Camera. The IC-Flow™ Imaging System 2.0 has a medical, near-infrared (NIR) Camera which emits a light to excite the ICG molecules and view ICG emitted fluorescence. The captured fluorescent image data is displayed on the Controller and/or connected monitor.
Images and videos are recorded using buttons located on the Camera and icons on the Controller. The NIR light source illumination (excitation light) and Camera sensitivity can also be adjusted using controls on either the Camera or Controller. Images are stored in the Controller but can easily be transferred to a USB memory device, Cloud Drive or an external mass storage device.
When ICG is injected consistent with its indications for use, it binds to plasma proteins and exhibits fluorescence when illuminated with near infrared (NIR) light. The excitation light source of IC-Flow™ imaging System 2.0 consists of a high-power LED.
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{6}
Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
# Intended Use
IC-Flow™ Imaging System 2.0, used in conjunction with Indocyanine Green (ICG), is indicated for fluorescence imaging of blood flow, tissue perfusion, and the lymphatic system in both adult and pediatric patients one month of age and older. Upon intravenous administration of ICG, the IC-Flow™ Imaging System 2.0 is used for fluorescence angiography before and after vascular, and plastic, micro-, and reconstructive procedures.
Additionally, upon subcutaneous administration, the system is used for fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels.
# Comparison of Technological Characteristics with the Predicate Devices
A comparison of the subject device, IC-Flow™ Imaging System 2.0 and predicate devices, SPY Portable Handheld Imaging (SPY-PHI) System (K230727) & Pde-neo (K133719), is based on the following same technologies:
- Similar Intended Use / Indications for Use (IC-Flow 2.0 is not intended for use during surgery)
- Same requirement for ICG as imaging agent
- Similar operating principle with camera positioned toward observed area
- Using LED as light source
- Similar optical imaging specifications
- Same intended user by Physicians and healthcare professional (IC-Flow 2.0 is not intended for use during surgery)
- Same operating environment when not used in the operating room (IC-Flow 2.0 is not intended for use during surgery)
In addition to the same and similarities stated above, the differences in the technological characteristics between the subject device, IC-Flow™ Imaging System 2.0 and Predicate devices, SPY Portable Handheld Imaging (SPY-PHI) System (K230727) & Pde-neo (K133719) do not pose questions on safety and/or performance of the subject device and as has shown with safety and performance testing.
| Table 10-3B: Subject and Predicate Devices Comparison | | | |
| --- | --- | --- | --- |
| | Subject Device
IC-Flow™ Imaging System 2.0 | Predicate Device 1
SPY Portable Handheld
Imaging (SPY-PHI) System
(Primary) | Predicate Device 2
Pde-neo |
| 510(k) Number | Current Submission | K230727 | K133719 |
| Sponsor / Owner | Diagnostic Green GmbH | Novadaq Technologies
ULC | HAMAMATSU
PHOTONICS, K.K. |
{7}
Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
| Table 10-3B: Subject and Predicate Devices Comparison | | | |
| --- | --- | --- | --- |
| | Subject Device
IC-Flow™ Imaging System 2.0 | Predicate Device 1
SPY Portable Handheld
Imaging (SPY-PHI) System
(Primary) | Predicate Device 2
Pde-neo |
| Regulation Number | 21 CFR 892.1600 | 21 CFR 892.1600 | 21 CFR 892.1600 |
| Product Code | IZI | IZI | IZI |
| Intended Use | Visible white light and near-infrared illumination during vascular and lymphatic assessments and before and after surgical procedures. | Visible white light and near-infrared illumination during open-field surgical procedures. | The pde-neo is an imaging system used in capturing and viewing fluorescent images for the visual assessment of blood flow, as an adjunctive method for the evaluation of tissue perfusion, and related tissue-transfer circulation in tissue and free flaps used during plastic, micro-, reconstructive, and organ transplant surgeries. |
| Indications for Use | IC-Flow™ Imaging System 2.0, used in conjunction with Indocyanine Green (ICG), is indicated for fluorescence imaging of blood flow, tissue perfusion, and the lymphatic system in both adult and pediatric patients one month of age and older. Upon intravenous administration of ICG, the IC-Flow™ Imaging System 2.0 is used for fluorescence angiography before and after vascular, and plastic, micro-, and reconstructive procedures.
Additionally, upon Subcutaneous administration, the system is used for fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels. | Upon intravenous administration of SPY AGENT GREEN (indocyanine green for injection, USP), the SPY-PHI System is used with SPY AGENT GREEN to perform intraoperative fluorescence angiography. The SPY-PHI System is indicated for use in adult and pediatric patients one month of age and older. The SPY-PHI System is indicated for fluorescence imaging of blood flow and tissue perfusion before, during, and after vascular, gastrointestinal, organ transplant, and plastic, micro- and reconstructive surgical procedures. Upon interstitial administration of SPY AGENT GREEN, the SPY-PHI System is used to perform intraoperative fluorescence imaging and visualization of the lymphatic system, including lymphatic vessels and lymph nodes. | The pde-neo is an imaging system used in capturing and viewing fluorescent images for the visual assessment of blood flow, as an adjunctive method for the evaluation of tissue perfusion, and related tissue-transfer circulation in tissue and free flaps used during plastic, micro-, reconstructive, and organ transplant surgeries. |
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Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
| Table 10-3B: Subject and Predicate Devices Comparison | | | |
| --- | --- | --- | --- |
| | Subject Device
IC-Flow™ Imaging System 2.0 | Predicate Device 1
SPY Portable Handheld
Imaging (SPY-PHI) System
(Primary) | Predicate Device 2
Pde-neo |
| | | Upon intradermal administration of SPY AGENT GREEN, the SPY-PHI System is indicated for fluorescence imaging of lymph nodes and delineation of lymphatic vessels during lymphatic mapping in adults with breast cancer for which this procedure is a component of intraoperative management. | |
| Device Description | The IC-Flow™ Imaging System 2.0 is a real time near-infrared (NIR) fluorescence imaging system which facilitates visualization of the distribution and intensity of the Indocyanine Green (ICG) fluorescent imaging agent during medical procedures.
The IC-Flow™ imaging System 2.0 consists of a Controller with further connections to LAN and HDMI and a handheld Camera. The IC-Flow™ imaging System 2.0 has a medical, near-infrared (NIR) Camera which emits a light to excite the ICG molecules and view ICG emitted fluorescence. The captured fluorescent image data is displayed on the Controller and/or connected monitor.
Images and videos are recorded using buttons located on the Camera and icons on the Controller. The NIR light source illumination (excitation light) and Camera sensitivity can also be adjusted using controls on | The SPY-PHI System is a real-time white-light and near-infrared illumination/fluorescence imaging system used during open-field surgical procedures. Near-infrared illumination is used for fluorescence imaging using SPY AGENT® GREEN for the visual assessment of blood flow, tissue perfusion and visualization of the lymphatic system, including lymphatic vessels and lymph nodes. It consists of the SPY Portable Handheld Imager/ imaging head with an integrated light guide and camera cable and the Video Processor/Illuminator. Additionally, SPY-QP Fluorescence Assessment Software is provided as an optional upgrade to the SPY-PHI System that enables relative quantification of NIR fluorescence. | The pde-neo is an imaging system used in capturing and viewing fluorescent images for the visual assessment of blood flow, as an adjunctive method for the evaluation of tissue perfusion, and related tissue-transfer circulation in tissue and free flaps used during plastic, micro-, reconstructive, and organ transplant surgeries. The pde-neo is intended for intraoperative visual assessment of blood vessels and related tissue perfusion by enabling surgeons to observe fluorescent images of blood vessels and related tissue perfusion. Indocyanine green (ICG) is injected intravenously into patients. Infrared light-emitting diodes (LEDs) are used to excite the fluorescence of ICG and illuminate the regions of a patient's anatomy to be observed. A charge |
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Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
| Table 10-3B: Subject and Predicate Devices Comparison | | | |
| --- | --- | --- | --- |
| | Subject Device
IC-Flow™ Imaging System 2.0 | Predicate Device 1
SPY Portable Handheld
Imaging (SPY-PHI) System
(Primary) | Predicate Device 2
Pde-neo |
| | either the Camera or Controller.
Images are stored in the
Controller but can easily be
transferred to a USB memory
device, Cloud Drive or an
external mass storage device.
When ICG is injected consistent
with its indications for use, it
binds to plasma proteins and
exhibits fluorescence when
illuminated with near infrared
(NIR) light. The excitation light
source of IC-Flow™ imaging
System 2.0 consists of a high-
power LED. | | coupled device (CCD)
camera captures the
fluorescent image that is
used to assess the blood
vessels and related tissue
perfusion.
The pde-neo consists of the
following components:
Camera Unit, Controller,
and Remote Controller.
The Camera Unit contains
a CCD camera and LED
light sources and is used
either by hand or attaching
it to a mechanical arm. The
Controller receives the
video signal of the
fluorescent image from the
Camera Unit and outputs
the processed fluorescent
image to the external video
monitor and recorder.
Adjustments of the
fluorescent image are
possible either by the
Camera Unit or the Remote
Controller. |
| System Components | • Camera
• Camera Cable
• Controller
• Power Unit
• Stand + 4 screws
• HDMI Cables | • SPY-PHI Imager
• Video Processor/
Illuminator
• SPY-QP Fluorescence
Assessment Software | • Camera Unit
• Controller
• Remote Controller |
| Environment for Use | Hospitals and Clinics | Operating room | Operating room |
| Intended User | Physicians, trained healthcare
professionals | Physician, or under
supervision of physician | Surgeon or assistance |
| Principle of Operation | IC-Flow™ Imaging System 2.0
is near infrared imaging system.
The handset camera is
positioned over the patient such
that the NIR excitation light is
emitted and illuminates the area | Full color visible light and
NIR fluorescence video
imaging. The imaging head is
positioned over the patient
such that the NIR excitation
light is emitted and | The pde-neo II is a medical
infrared camera designed
to observe the fluorescent
images from indocyanine
green (ICG) in the patient’s
body. It is equipped with |
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Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
| Table 10-3B: Subject and Predicate Devices Comparison | | | |
| --- | --- | --- | --- |
| | Subject Device
IC-Flow™ Imaging System 2.0 | Predicate Device 1
SPY Portable Handheld
Imaging (SPY-PHI) System
(Primary) | Predicate Device 2
Pde-neo |
| | of interest. When the patient is injected with ICG, the ICG binds to the plasma in the blood and travels through the blood to the area of interest. The camera captures the fluorescent image, the controller receives the video signal and displays the video image on the integrated touchscreen and if available on a connected monitor.
Pictures and videos can be recorded and stored on the memory of the controller and can be transferred to a Cloud Drive, USB stick or an external memory device. | illuminates the area of interest. When the patient is injected with ICG, the ICG binds to the plasma in the blood and travels to the area of interest through the bloodstream. The camera in the Imaging Head captures the fluorescent image under laser illumination or a color image under white light illumination. The VPI receives the video signal from the Imaging Head and processes and outputs the video image to a medical grade video monitor and/or video recorder. | Light Emitting Diodes (LEDs) used to excite the fluorescence from ICG.
The camera is positioned toward the observed area such that the excitation light is irradiated from the camera window to the observed area. When the patient is injected with ICG, the ICG binds to plasma in the blood and travels to the area of interest through the bloodstream. The camera captures the fluorescent image or a color image under white light illumination. External video monitor and recorder are connected to the controller, receiving the video signal and displaying the video image. |
| Imaging Mode | Fluorescence mode | White Light
Near-Infrared:
- Overlay Model
- SPY Mode (Contrast) 1
- SPY Color Segmented Fluorescence (CSF) | LED light |
| Light Source | LED | LED and NIR laser | LED |
| Optical Imaging Specification | Continuous wave lamp (CW)
The camera has a resolution of 1920x1200 pixels.
Working distance is 170-200 mm
Image section 75x100 mm.
Camera lens depth 47 mm | Dynamic Range
The user shall be able to visualize SPY AGENT GREEN in physiology applications.
The response on the system monitor to the minimum clinically relevant concentration of SPY AGENT GREEN shall be at least 6.9(ΔE), and the system response to the | Unknown |
Page 7 of 10
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Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
| Table 10-3B: Subject and Predicate Devices Comparison | | | |
| --- | --- | --- | --- |
| | Subject Device
IC-Flow™ Imaging System 2.0 | Predicate Device 1
SPY Portable Handheld
Imaging (SPY-PHI) System
(Primary) | Predicate Device 2
Pde-neo |
| | | maximum clinically relevant concentration shall be at least twice that at low concentrations.
Localization
The user shall be able to visualize SPY AGENT GREEN in anatomy applications. The response on the system monitor shall be at least 10.35 (ΔE) under clinically relevant conditions. | |
| Imager | Image Sensor: Complementary Metal Oxide Semiconductor (CMOS) Image Sensor | Image Sensor: Complementary Metal Oxide Semiconductor (CMOS) Image Sensor | Image Sensor: Charge Coupled Device (CCD) Image Sensor |
| Video Processor / Illuminator | LED, Near Infrared
1920 x1200 pixels | • Light Source: RGB LEDs
• Laser: Infrared Laser
• Laser Safety Class: Class 3R
• Image Processing Video Output: Digital
• Resolution 2180p (1920 x 1080)
Frame Rate: 60 Hz | LED |
| Safety Standards | IEC 60601-1
IEC 60601-1-2
IEC 60601-1-6
IEC 62471 | IEC 60601-1
IEC 60601-1-2
IEC 60601-1-6
IEC 60825-1 | EC 60601-1
IEC 60601-1-2
IEC 60825-1 |
| Single Use / Reusable | Reusable | Reusable | Reusable |
| Patient Contacting | No direct or indirect patient contact | No direct or indirect patient contact | No direct patient contact |
| Prescription or Over the Counter | Prescription Only | Prescription Only | Prescription Only |
| Imaging Agent | ICG (Indocyanine Green for Injection) | SPY AGENT™ GREEN (Indocyanine green for injection, USP) | ICG (Indocyanine Green for injection) from PDE/pde-neo II Kit |
Summary of Safety and Performance Testing
Page 8 of 10
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Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification - AI Response (K243645)
Table 10-3C provides a summary of the testing performed to address the risks associated with the subject device, IC-Flow™ Imaging System 2.0. All tests were conducted based on the predetermined acceptance criteria and passed the required testing.
| Table 10-3C: IC-Flow™ Imaging System 2.0, Safety and Performance Testing Summary | | |
| --- | --- | --- |
| Test | Standards | Test Description |
| Software Lifecycle | IEC 62304 | Software Development and V&V |
| Electrical Safety | IEC 60601-1 | Safety Testing |
| Electromagnetic Compatibility | IEC 60601-1-2 | EMC Testing |
| Basic Safety and Essential Performance | IEC 60601-1-6 | Usability Testing |
| EMC Testing / Radio Equipment | EN 301 489-1 v2.2.1
EN 301 893 V2.1.1
EN 301 328 V2.2.2 | EMC / Radio Equipment |
| Photobiological Safety of Lamps and Lamp System | IEC 62471 | Lamp Safety |
| Cleaning and Disinfection | Internal protocol | Manual Cleaning and Disinfection |
| Service Life | IEC 60601-1 | EMC |
| Packaging | Internal protocol | Drop, Vibration, Compression |
| Performance Testing / Usability | IEC 62366-1 & Internal Protocol | Usability Testing & Device Performance |
| Performance Testing (Bench) | Internal Protocol | Performance Testing on Attributes |
| Performance Testing (In vivo) | Clinical Demonstration | ICG Imaging Video and Image Capture |
| Performance Testing (Animal) | N/A - No animal studies were required as appropriate verification of the subject devices was achieved based on the comparison to the predicate devices and from the results of the bench testing and engineering analysis. | |
| Performance Testing (Clinical) | N/A - No clinical studies were required as appropriate verification of the subject devices was achieved based on the comparison to the predicate devices and from the results of the bench testing and engineering analysis. | |
| Sterilization | N/A - IC-Flow™ Imaging System 2.0 is not offered sterilized and does not require sterilization. | |
| Biocompatibility | N/A - IC-Flow™ Imaging System 2.0 is not patient contacting (direct or indirect). | |
# Conclusion
The IC-Flow™ Imaging System 2.0 has the same or similar design, intended use, indications for use, principle of operation, and safety features as the predicate devices, the SPY Portable Handheld Imaging (SPY-PHI) System (K230727) and the pde-neo (K133719). The subject device also demonstrates
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{13}
Diagnostic Green GmbH
IC-Flow™ Imaging System 2.0
Traditional 510(k) Premarket Notification – AI Response (K243645)
substantially equivalent technological characteristics and has been shown to be as safe and effective as the identified predicate devices.
Any technological differences between the IC-Flow™ Imaging System 2.0 and its predicate devices do not raise new or different questions of safety or effectiveness. Comprehensive risk management activities conducted in accordance with ISO 14971 confirm that no new risks are introduced by the subject device. Based on the intended use, technological characteristics, and results from safety and performance testing, the IC-Flow™ Imaging System 2.0 meets the necessary requirements for its intended application. Therefore, the subject device is considered substantially equivalent to the SPY-PHI System (K230727) and the pde-neo (K133719).
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.