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SubtleMR (2.3.x)

Subtle Medical Inc. • Radiology • 05/11/2023

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

SubtleMR (2.3.x) is a medical image processing software that utilizes advanced convolutional neural network algorithms, specifically PGDnet for denoising and EDSR for sharpness enhancement, to improve the diagnostic quality of MRI images. Developed using PyTorch and incorporating an enhanced composite loss function, the system provides user-selectable image enhancements for various anatomical regions, with its efficacy validated through performance testing on retrospective clinical data.

Summary

SubtleMR (2.3.x) is an image processing software designed to enhance Magnetic Resonance Imaging (MRI) images for radiologists in clinical settings. Operating as a Software as a Medical Device (SaMD) without a direct user interface, it processes standard MRI images acquired from 1.2 Tesla, 1.5 Tesla, or 3 Tesla scanners, and can also handle images communicated in ISMRM Raw Data Format (ISMRMRD). The software's primary function is to improve image quality by offering either noise reduction for a broad range of anatomical areas (head, spine, neck, abdomen, pelvis, prostate, breast, and musculoskeletal MRI) or increased image sharpness, primarily for head MRI. The enhancement capabilities of SubtleMR are powered by convolutional neural network-based algorithms. End-users can select between noise reduction or sharpness enhancement via DICOM Series Description, command line arguments, or environment variables, with the software applying a fixed nonlinear filter based on this choice. The Denoising (DNE) model now utilizes a PGDnet neural network, while the Sharpness Enhancement (SRE) model continues to use an EDSR neural network; both models are built using the PyTorch machine learning framework and employ an advanced composite loss function. Performance evaluations using retrospective clinical data confirmed the software's effectiveness, showing that noise reduction improved the Signal-to-Noise Ratio (SNR) by at least 5% while preserving the visibility of small structures, and sharpness enhancement improved anatomical structure thickness and boundary sharpness in at least 90% of the test datasets.

AI Regulatory Concerns

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Keywords

MRI EnhancementImage Processing SoftwareNoise ReductionSharpness EnhancementConvolutional Neural NetworkSaMD (Software as a Medical Device)RadiologyPGDnetPyTorchISMRMRD

Device Metadata

Submission Number
K223623
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. How does the performance of the PGDnet model for denoising compare to the previous EDSR model in terms of specific image quality metrics beyond SNR and radiologist preference, particularly concerning subtle pathological findings?; What is the quantitative impact of the new composite loss function (L1, SSIM, perceptual, high frequency) on the preservation of fine anatomical details or the potential introduction of imaging artifacts compared to the previous L1/SSIM function?; Are there specific MRI sequences, acquisition parameters, or patient populations where SubtleMR (2.3.x) demonstrates significantly variable performance for noise reduction or sharpness enhancement?; Given the added capability to process images via ISMRM Raw Data Format (ISMRMRD), what are the practical implications for clinical workflow integration, particularly regarding image reconstruction times and data handling?; What were the specific characteristics (e.g., scanner vendors, field strengths, pathologies included) of the retrospective clinical datasets used for validating the noise reduction and sharpness enhancement features, and how do these ensure generalizability?

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 Score15/100
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(machine learning, deep learning, neural network, algorithm, dataset)
✓ 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(environment)
✓ 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, OBOM 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. These may be present in the full FDA submission.

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SubtleMR (2.3.x) - Subtle Medical Inc. | ESL FDA AI Device Intelligence