Medscape Medical NewsAll articles

Second Opinion CC

Pearl Inc. • Radiology • 01/16/2025

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

Pearl Inc.'s Second Opinion CC is a Class II medical image analyzer designed to aid dental professionals in detecting caries on radiographs in adult patients. It leverages computer vision and machine learning algorithms, with its efficacy supported by a non-inferiority clinical study, to provide computer-aided detection by outlining suspicious areas on dental images.

Summary

Pearl Inc.'s Second Opinion CC device, a medical image analyzer, has received a determination of substantial equivalence to legally marketed devices, allowing its commercialization. Classified as a Class II device, it is subject to general controls and specific ongoing regulatory requirements for marketing, including annual registration, device listing, good manufacturing practices, appropriate labeling, medical device reporting, and compliance with the Unique Device Identification System. The Second Opinion CC functions as computer-aided detection (CADe) software, specifically designed to assist dental professionals in identifying dental caries. It operates by drawing bounding polygons on bitewing and periapical radiographs of permanent teeth in adult patients aged 19 years or older. Its core technology is based on advanced computer vision and machine learning algorithms, with its performance validated through a non-inferiority clinical study to support its marketing clearance.

AI Regulatory Concerns

Powered byJev by TypeSafe AI

Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

Second Opinion CCPearl Inc.Medical image analyzerSubstantial equivalenceComputer-aided detection (CADe)Dental cariesRadiographsComputer visionMachine learningClinical study

Device Metadata

Submission Number
K242522
Company
Pearl Inc.
Panel
Radiology
Product Code
N/A
Data Type
N/A
Clinical Function
N/A
AI Function
N/A
AI Subclass
N/A

Relevant Clinical Questions

  • Q1. What were the specific metrics used in the non-inferiority clinical study, and what were the confidence intervals for the primary endpoints?; How does the device's performance compare across different types and severities of caries (e.g., incipient vs. advanced, occlusal vs. interproximal)?; What are the limitations of the computer vision and machine learning algorithms, particularly concerning false positives or negatives in complex dental anatomies?; Are there plans to expand the device's indications for use to younger patients or other dental pathologies beyond caries?; What training or calibration is required for dental professionals to effectively integrate Second Opinion CC into their diagnostic workflow?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Post-§524B but no clear network capability detected

Learn how Parasoft automates IEC 62304 compliance testing →

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 Score5/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment⚠ Not in summary - likely in full submission per §524B
Postmarket Plan⚠ Not in summary - likely in full submission per §524B
§524B ApplicableYes

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, algorithm, labeling)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials
- Not 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 detected in AI-generated device summary.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Cybersecurity risk assessment not referenced in AI-generated device summary. FDA cybersecurity guidance (2023) expects this for cyber devices.

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

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

Preparing a similar submission?

ESL takes complete ownership of your software evidence work - SBOM & CVE remediation with SBOMator™, static analysis & unit testing with Parasoft, traceability, and full IEC 62304 lifecycle support.

Assess Your Readiness →Or contact ESL directly
Second Opinion CC - Pearl Inc. | ESL FDA AI Device Intelligence