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Second Opinion® BLE

Pearl Inc. • Radiology • 05/09/2025

510(k)IEC 62304 Class B§524B Cyber Device
FDA Summary PDF

Device Purpose

Pearl Inc.'s Second Opinion® BLE is an automated radiological image processing software that employs machine learning to accurately identify and display bone level measurements in dental radiographs. This device serves as a crucial aid for dental professionals, enhancing the review of bitewing and periapical images by providing a validated, concurrent reading of interproximal bone levels, thereby improving diagnostic support.

Summary

Pearl Inc. has developed Second Opinion® BLE, a radiological automated image processing software designed to assist dental health professionals. Its primary purpose is to identify and display precise bone level measurements from bitewing and periapical radiographs, serving as a concurrent and second reader for permanent teeth in patients aged 12 years or older. The device leverages an Application Programming Interface (API), Machine Learning Modules, and a Client User Interface to facilitate its operation, thereby aiding clinicians in their review of bone levels without serving as the sole diagnostic tool.Following a comprehensive review, Second Opinion® BLE was deemed substantially equivalent to existing legally marketed devices. Both non-clinical and clinical studies rigorously evaluated its performance, confirming its software characteristics and demonstrating its safety and effectiveness for its intended application. The clinical trials specifically highlighted the system's strong precision and recall in measuring interproximal bone levels across both bitewing and periapical images, successfully meeting all pre-specified acceptance criteria and concluding that the device raises no new safety or effectiveness concerns, thus enabling its market clearance.

AI Regulatory Concerns

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

Keywords

Second Opinion BLERadiological imagingBone level measurementsBitewing radiographsPeriapical radiographsMachine learningDental health professionalsImage processing softwareClinical studiesInterproximal bone levels

Device Metadata

Submission Number
K243230
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 specific machine learning algorithms or architectures are employed within Second Opinion® BLE, and how do they handle variability in image quality or patient anatomy?; Beyond precision and recall, what other performance metrics were evaluated in clinical studies, particularly regarding diagnostic accuracy or reduction in diagnostic discrepancies?; How does the system's performance compare in patients with existing bone loss conditions versus those with healthy bone levels, and are there any limitations in specific pathological cases?; What is the process for integrating Second Opinion® BLE with existing dental practice management software or imaging systems, and what are the API capabilities for data export or integration with AI-driven treatment planning?; Are there plans for future iterations of Second Opinion® BLE to expand its capabilities to detect other dental pathologies or to measure bone levels around implants?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Qualifies as a cyber device under §524B (post-Dec 2023, networked)

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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 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)
✓ 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.

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Second Opinion® BLE - Pearl Inc. | ESL FDA AI Device Intelligence