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brAIn™ Shoulder Positioning

Avatar Medical • Radiology • 03/20/2025

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

Device Purpose

The Avatar Medical brAIn™ Shoulder Positioning device is a Class II cloud-based medical image management system designed to assist in preoperative surgical planning for primary total shoulder replacement. It employs machine learning for automatic anatomical segmentation from CT-scan DICOM series, providing an interactive 3D viewer and multimodal planning summary, with nonclinical tests affirming its safety and effectiveness compared to a predicate device.

Summary

Avatar Medical's brAIn™ Shoulder Positioning device has been reviewed and determined to be substantially equivalent to a legally marketed predicate device. This determination permits the marketing of the device, which is a Class II Medical Image Management and Processing System. The product, dated February 14, 2025, is specifically intended to serve as an information tool for assisting in the preoperative surgical planning and visualization of a primary total shoulder replacement. The brAIn™ Shoulder Positioning software operates as a cloud-based application that processes patient CT-scan DICOM series. It features automatic segmentation of scapula and humerus anatomy using machine learning, an interactive 3D viewer for soft tissue visualization and implant positioning, and generates a multimodal planning summary. The device is subject to various regulatory requirements, including those for annual registration, device listing, good manufacturing practices, labeling, medical device reporting, and the Unique Device Identification System. Nonclinical tests, including software verification and validation, segmentation performance, shoulder side detection, measurement accuracy, and landmark performance, have confirmed that the device meets its specifications and is as safe and effective as its predicate.

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

brAIn™ Shoulder Positioning deviceMedical Image ManagementPreoperative surgical planningTotal shoulder replacementCloud-based applicationCT-scan DICOM seriesMachine learningAutomatic segmentation3D viewerNonclinical tests

Device Metadata

Submission Number
K243292
Company
Avatar Medical
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 clinical outcomes or improvements are anticipated in surgical accuracy or patient recovery due to the use of this preoperative planning tool?; How does the machine learning model in brAIn™ handle anatomical variations or pathologies that might deviate significantly from typical shoulder anatomy?; What is the level of user-friendliness and integration capability of this cloud-based system with existing hospital IT infrastructure and PACS systems?; Are there plans for expanding the brAIn™ platform's capabilities beyond primary total shoulder replacement to other orthopedic procedures or anatomical regions?; What are the long-term data security and privacy protocols for patient CT-scan data processed and stored on the cloud-based application?

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 Score30/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment✓ Detected in Summary
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, labeling)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, platform, infrastructure)
✓ 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.

• 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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brAIn™ Shoulder Positioning - Avatar Medical | ESL FDA AI Device Intelligence