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SubtlePET

Subtle Medical, Inc. • Radiology • 09/28/2021

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

SubtlePET is an image processing software that employs a deep neural network-based algorithm, specifically a convolutional neural network with residual learning, to reduce noise and improve image quality in PET scans for various radiotracers. Its methodology involves predicting and separating noise from structural components, integrating into DICOM workflows to provide enhanced diagnostic images for clinical use by radiologists and nuclear medicine physicians.

Summary

SubtlePET is an image processing software, version V 2.0.0, designed for radiologists and nuclear medicine physicians. Its primary function is to enhance the quality of Positron Emission Tomography (PET) images by reducing noise. The software integrates into existing radiology workflows as a DICOM node, receiving DICOM 3.0 digital medical image data, processing it, and then forwarding the enhanced study to a selected destination, typically a PACS system or workstation. SubtlePET supports various radiotracers, including fluorodeoxyglucose (FDG), amyloid, 18F-DOPA, 18F-DCFPyL, Ga-68 Dotatate, and Ga-68 PSMA, for PET imaging. The core technology of SubtlePET utilizes a deep neural network-based algorithm, specifically a convolutional neural network employing a residual learning approach. This method analyzes each pixel's neighborhood to predict and separate noise components from structural components, thereby enhancing image structure while reducing noise. Performance testing, including software verification, validation, and a noise reduction bench test using representative human data, demonstrated a significant average increase in quantitative metrics, confirming its efficacy in noise reduction. The device has been updated to support additional tracers with its main PET machine learning model, while previous models specific to PET/CT and PET/MRI have been removed.

AI Regulatory Concerns

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Keywords

SubtlePETImage Processing SoftwareNoise ReductionPET ImagesDeep Neural NetworkConvolutional Neural NetworkRadiotracersDICOMResidual LearningImage Enhancement

Device Metadata

Submission Number
K211964
Company
Subtle Medical, Inc.
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Generation
AI Subclass
image enhancement

Relevant Clinical Questions

  • Q1. What specific quantitative metrics were used to evaluate the 'significant average increase' in image quality, and what were the benchmarks for these metrics?; How does the performance of the updated single PET deep learning model compare to the previous separate models for PET, PET/CT, and PET/MRI in terms of noise reduction efficacy for the supported tracers?; Are there any known limitations or specific types of PET image artifacts that the SubtlePET algorithm is less effective at reducing or might potentially exacerbate?; What is the typical processing time added to the workflow per PET study when using SubtlePET, and how does this vary with image matrix size or complexity?; How has the training dataset for the deep neural network been curated to ensure robustness and generalizability across different PET scanner manufacturers and imaging protocols for the newly added radiotracers (18F-DOPA, 18F-DCFPyL, Ga-68 Dotatate, Ga-68 PSMA)?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score10/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan⚠ Not mentioned in summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(training data, machine learning, deep learning, neural network, algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(network)
✓ Detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Postmarket cybersecurity monitoring plan not clearly documented in AI-generated device summary.

• Not detected in AI-generated device summary: SBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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SubtlePET - Subtle Medical, Inc. | ESL FDA AI Device Intelligence