ITR2000: INTERNET TELERADIOLOGY, MODEL RELEASE 1.0
Applicant
Inteleradiology, Inc.
Product Code
LMD · Radiology
Decision Date
Sep 29, 1999
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.2020
Device Class
Class 1
Attributes
Software as a Medical Device
Indications for Use
iTR2000 is a software communications tool intended to be used in the transportation, storage and retrieval of digital medical images for the purpose of off-site review.
Device Story
iTR2000 is a standalone teleradiology software tool for remote access to medical images. It facilitates transmission, storage, and retrieval of digital images from modalities like CT, US, MRI, NM, and digital angiography. It enables web-based viewing via standard browsers or proprietary software. Used by radiologists and referring physicians in clinical settings for off-site review. The system supports JPEG compression for image transfer. It does not control imaging hardware; it acts as a communication layer for legacy or non-PACS equipment. Healthcare providers use the retrieved images to support clinical decision-making. Benefits include remote access to diagnostic studies, facilitating on-call activities and off-site consultations.
Clinical Evidence
Bench testing only. Functional validation included product specification development, coding, debugging, and in-house validation. System performance was verified through the successful transfer of over 1200 complete diagnostic imaging studies. No clinical data provided.
Technological Characteristics
Software-only product; operates on standard PC hardware. Supports JPEG compression (ISO/IEC 10918-1). Connectivity via internet/web browser. Implements standard data communications controls for error detection and correction. Designed for small-matrix imaging modalities.
Indications for Use
Indicated for use by radiologists, referring physicians, and licensed medical professionals for the remote transportation, storage, and retrieval of digital medical images (CT, US, MRI, NM, digital fluorography, digital angiography) for off-site review. Not intended for large-matrix imaging systems like mammography or computed radiography without specialized equipment.
Regulatory Classification
Identification
A medical image communications device provides electronic transfer of medical image data between medical devices. It may include a physical communications medium, modems, and interfaces. It may provide simple image review software functionality for medical image processing and manipulation, such as grayscale window and level, zoom and pan, user delineated geometric measurements, compression, or user added image annotations. The device does not perform advanced image processing or complex quantitative functions. This does not include electronic transfer of medical image software functions.
Predicate Devices
WINRAD Teleradiology System (Line Imaging Systems)
AMICAS Web/Intranet Image Server (AutoCyt Group, Inc.)
Submission Summary (Full Text)
{0}------------------------------------------------
#### INTEL
ITR 2000
2400 Lorain Road San Marino, California 91108 - Oan Manhol Callonia - Phone (626) 457-1789
Fax (626) 457-1789
Email: info@inteleradiology.com Website: www.inteleradiology.com
N C
SEP 2 9 1999
Food and Drug Administration Center for Devices and Radiological Health Document Mail Center (HFZ-401) 9200 Corporate Boulevard Rockville, Maryland 20850
## 510(k) Summary
## 1. Identification
| Date Prepared: | July 11, 1999 |
|----------------|-----------------------------------------------------------------------------|
| Submitter | inTeleRadiology, Inc.<br>2400 Lorain Road<br>San Marino, California 91108 |
| Contact | Michael Vincent Klein, M.D.<br>Phone: (626) 457-1789<br>Fax: (626) 457-1789 |
## 2. Device Name
| Proprietary Name: | iTR2000TM: internet TeleradiologyTM |
|-------------------------|--------------------------------------|
| Common Name: | Teleradiology Software |
| Classification<br>Name: | System, Digital Image Communications |
## 3. Registration Number:
Pending
## 4. Classification
| Class: | 2 |
|---------------|-----------|
| Panel: | Radiology |
| Product Code: | LMD |
{1}------------------------------------------------
# 510(k) Summary - continued
#### 5. Standards
| Performance: | None established |
|--------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Voluntary: | American College of Radiology Standard for Teleradiology (Revision 35 -<br>1998; for small matrix systems) |
| | ISO/IEC 10918-1 Digital Compression and Coding of Continuous-Tone Still<br>Images [also known as Joint Photographic Experts Group (JPEG):]<br>Revision 13. July 1994] |
#### 6. Predicate Devices
WINRAD Teleradiology System (Line Imaging Systems)
AMICAS Web/Intranet Image Server (AutoCyt Group, Inc.)
#### 7. Device Description
iTR2000™ is a stand-alone software product which may be marketed as a software-only product, as well as for use in conjunction with standard PC hardware, off-the-shelf software or third-party teleradiology/PACS software.
iTR2000™ provides short-term remote access to medical images by radiologists, referring physicians and other licensed professionals, utilizing a personal computer or workstation with internet access. Images are securely stored on a internet website for on-demand remote retrieval via the iTR2000™ software, or via a standard web browser without the use of propriety software. The iTR2000™ system employs the latest internet security techniques and meets all current federal medical communications standards including recent proposals from HCFA and HHS.
iTR2000™ is primarily intended to allow the transmission, retrieval and review of images produced by imaging equipment otherwise not part of a digital Picture Archive and Communication System (PACS) network or legacy equipment not compatible with ACR/NEMA DICOM 3.0. Conventional film-based images can be optically digitized and stored in a standard image format, such as JPEG. iTR2000™ can also be configured to web-enable third-party DICOM-capable teleradiology/PACS systems in low-volume environments for remote or on-call activities.
iTR2000™ is designed for use primarily with small-matrix imaging modalities, such as images produced by Computed Tomography (CT), Ultrasound (US), Magnetic Resonance Imaging (MRI), Nuclear Medicine (NM), digital flourography and digital angiography. The use of images produced by large-matrix imaging systems, such as digitized radiographic films and computed radiography or mammography. requires the use of digitization and viewing equipment which exceed the stated minimum requirements for the standard iTR2000™ system. iTR2000™ does not control the actual image-taking system (i.e. x-ray, MRI, ultrasound or scintography machines).
{2}------------------------------------------------
N C
iTR2000™ is a software communications tool intended to be used in the transportation, storage and retrieval of digital medical images for the purpose of off-site review.
#### 9. Safety and Effectiveness
The iTR2000™ software is primarily an image communications software program used to transfer digital image files between personal computers and is utilized only by competent medical professionals. The system has no patient contacting components. The device does not impact the quality of the original acquired image data. It does not require specialized or nonstandard devices of any type. Competent health professionals would reasonably be expected to exercise judgment and professional expertise in the use and interpretation of the transferred image files.
Similar to the predicate devices. iTR2000™ can be used with image compression to remove redundant or unimportant information in the original image data. The recommended JPEG image compression libraries and default compression settings are believed to be substantially equivalent to the libraries used in the previously cleared products.
#### 9. Testing
The safety of this program has been determined through the various stages of software development which included the development of product specifications, coding, testing, debugging, in-house validation and field maintenance. Functional testing including the transfer of diagnostic imaging studies for over 1200 complete studies. Standard data communications controls for error detection and correction are utilized.
#### 10. Conclusions
iTR2000™ software is a medical device, and it has the same indications for use, the same technological characteristics and the same target population as the legally marketed predicate devices.
Any differences between the iTR2000™ software and the predicate devices have no significant influence on safety or efficacy. The iTR2000™ system employs the latest internet security techniques and meets all current federal medical communications standards including recent proposals from HCFA and HHS. No new issues of safety and effectiveness are raised.
InTeleRadiology, Inc., believes sufficient information is included to reach a determination of substantial equivalence. We conclude that the iTR2000™ software is as safe and effective as the legally marketed devices and is substantially equivalent to the previously marketed devices (as listed above in Part 6),
Michael Vincent Klein.
July 11, 1999
July 11, 1996
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three lines forming its body and wings. The eagle is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP 2 9 1999
Michael Vincent Klein, M.D. CEO Inteleradiology, Inc. 2400 Lorain Road San Marino, CA 91108
Dear Dr. Klein:
Re:
K992352 ITR2000 Internet Teleradiology Dated: July 11, 1999 Received: July 14, 1999 Product Code: 90 LMD Requlatory Class: I (one) 21 CFR 892.2020
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration. Ilsing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition. FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in with diagnostic devices), please contact the Office of Compliance at (301) 594-4613. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification"(21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597, or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
CAPT Daniel G. Schultz, M.D. Acting Director, Division of Reproductive, Abdominal, Ear, Nose and Throat, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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0002
Page 2 of 2
| 510(k) Number (if known): ____ | K992352 |
|--------------------------------|---------|
|--------------------------------|---------|
iTR2000 Device Name:
Indications For Use:
iTR2000 is a software communications tool intended to be used in the transportation, storage and retrieval of digital medical images for the purpose of off-site review.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
David G. Syphm
(Division Sign-Off)
Division of Reproductive, Abdominal, ENT, and Radiological Devices 510(k) Number
**Prescription Use**
(Per 21 CFR 801.109)
OR
Over-The-Counter Use_
(Optional Format 1-2-96)
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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.