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Second Opinion® Pediatric

Pearl, Inc. • Radiology • 05/05/2025

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

Pearl, Inc.'s "Second Opinion® Pediatric" is a computer-aided detection (CADe) software designed to assist dental health professionals in identifying caries on radiographs for patients aged 4 years and older. The device employs machine learning and computer vision to process dental images and highlight areas of suspected caries, with clinical studies demonstrating high accuracy and sensitivity.

Summary

Pearl, Inc. has obtained clearance to market its "Second Opinion® Pediatric" software device, determined to be substantially equivalent to an existing product. This computer-aided detection (CADe) software is specifically engineered to aid dental health professionals in identifying caries, or cavities, on both bitewing and periapical radiographs for patients aged 4 years and older, encompassing those with primary or permanent dentition. The "Second Opinion® Pediatric" system leverages machine learning and computer vision technologies to analyze dental images and visually indicate areas suspected of caries, operating as a software-only solution. Its key differentiation from its predicate device is the inclusion of a younger patient population. Clinical studies have demonstrated the device's efficacy, showing high accuracy and sensitivity in caries detection, thereby affirming its safety and effectiveness for its stated purpose, although users are cautioned against exclusive reliance on its outputs for clinical decision-making due to potential false detections.

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

PearlInc.Second Opinion® PediatricComputer-aided detection (CADe)Caries detectionDental radiographsMachine learningComputer visionPediatric dentistrySubstantial equivalenceClinical studies

Device Metadata

Submission Number
K243893
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 and computer vision techniques are employed by the "Second Opinion® Pediatric" device for caries detection?; How do the accuracy and sensitivity metrics of the "Second Opinion® Pediatric" compare to the predicate device, particularly in the expanded pediatric patient population?; What are the reported false positive and false negative rates of the software, and what are the clinical implications of these errors in a pediatric dental setting?; Were the clinical studies supporting the device's effectiveness conducted independently, and what was the demographic breakdown and caries prevalence of the patient cohort?; What specific training and integration protocols are recommended for dental professionals to effectively use this CADe software and mitigate risks associated with potential false detections?

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

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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® Pediatric - Pearl, Inc. | ESL FDA AI Device Intelligence