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SubtleHD (1.x)

Subtle Medical, Inc. • Radiology • 02/12/2025

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

Device Purpose

SubtleHD is an image processing software that leverages a convolutional neural network to enhance MRI image quality by adaptively reducing noise and increasing sharpness. Through rigorous clinical and non-clinical validation, the device demonstrably improves signal-to-noise ratio and image sharpness, positioning it as a tool to optimize diagnostic imaging without introducing artifacts.

Summary

Subtle Medical, Inc. developed SubtleHD (1.x), an image processing software designed to significantly enhance Magnetic Resonance Imaging (MRI) quality for clinical use by radiologists and technologists. This software utilizes a convolutional neural network-based algorithm, specifically engineered for adaptive noise reduction and increased sharpness across all body parts, processing standard and accelerated MRI DICOM files. Its core science revolves around an image-guided optimization process that outputs enhanced images capable of coexisting with the original diagnostic files. Extensive non-clinical and clinical validation studies were conducted, including software verification, standalone image quality metric testing, a detailed performance validation study, and a reader study involving board-certified radiologists. These comprehensive tests consistently demonstrated that SubtleHD effectively improves the signal-to-noise ratio and image sharpness without introducing any adverse artifacts. The device's performance led to a determination of substantial equivalence to existing legally marketed predicate devices, and the manufacturer has a Predetermined Change Control Plan in place to manage future enhancements, such as additional denoising and sharpening levels, ensuring ongoing safety and efficacy.

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

SubtleHDMRI image enhancementConvolutional neural networkImage processing softwareNoise reductionImage sharpnessDICOM filesClinical validationSignal-to-noise ratio (SNR)Radiologist reader study

Device Metadata

Submission Number
K243250
Company
Subtle Medical, 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 quantitative metrics beyond SNR and sharpness were evaluated, and how did SubtleHD perform against a broad range of image quality assessment tools?; How does the convolutional neural network adapt its processing to different MRI sequences, field strengths, and anatomical regions, and are there any limitations to its adaptability?; Were there any specific clinical scenarios or disease states where SubtleHD's enhancement provided a notable diagnostic advantage or, conversely, where it might obscure subtle findings?; Could the integration of SubtleHD lead to changes in standard MRI acquisition protocols, potentially allowing for faster scans or lower resolution acquisitions that are then post-processed?; What are the long-term implications of using AI-enhanced images on radiologist workflow, diagnostic confidence, and potential for misinterpretation in complex cases?

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 Score10/100
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(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.

• 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, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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SubtleHD (1.x) - Subtle Medical, Inc. | ESL FDA AI Device Intelligence