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Second Opinion® 3D

Pearl, Inc. • Radiology • 05/23/2025

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

Device Purpose

The Second Opinion® 3D is an FDA-cleared radiological automated image processing system designed to serve as a concurrent diagnostic aid for dental professionals reviewing CBCT radiographs. This device leverages advanced computer vision and neural network-based machine learning algorithms to accurately identify and segment key anatomical structures, enhancing diagnostic support.

Summary

Pearl, Inc. has successfully obtained a determination from the U.S. Food & Drug Administration (FDA) for its Second Opinion® 3D device, classifying it as a radiological automated image processing system. This clearance, based on the device being found substantially equivalent to existing legally marketed products for its specified indications, grants Pearl, Inc. authorization to market Second Opinion® 3D. The device is now subject to standard general regulatory controls applicable to such medical products, signifying a significant step forward in its commercial availability for dental health professionals. The Second Opinion® 3D is a sophisticated software device engineered to serve as a concurrent, second reader for dental health professionals reviewing CBCT radiographs of patients aged 12 and older. Its core science relies on advanced computer vision and machine learning, specifically utilizing neural network algorithms, to automatically identify and precisely mark a range of clinically relevant anatomical structures. Performance bench testing unequivocally demonstrated the device's safety and effectiveness, achieving statistically significant accuracy in segmenting structures such as dentition, maxilla, mandible, inferior alveolar canal and mental foramen, maxillary sinus, nasal space, and airway, while also adhering to ongoing compliance requirements including quality system regulations and cybersecurity controls.

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® 3DCBCT radiographsComputer visionMachine learningNeural network algorithmsFDA clearanceDental imagingAnatomical segmentationRadiological image processingDiagnostic aid

Device Metadata

Submission Number
K243989
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 accuracy, sensitivity, and specificity metrics achieved during bench testing for each identified anatomical structure, and how do these compare to human expert performance?; What was the diversity and size of the dataset used to train the neural network algorithms, particularly concerning variations in patient age, ethnicity, and radiographic quality?; How does the device integrate into existing clinical workflows, and what is its expected impact on diagnostic efficiency and consistency in dental practices?; Are there any known limitations or specific types of pathologies or anomalies that the Second Opinion® 3D device is not designed to detect or that might lead to false positives/negatives?; What post-market surveillance plans are in place to monitor the device's long-term performance, especially regarding cybersecurity and real-world clinical effectiveness?

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 Score45/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment✓ Detected in Summary
Postmarket Plan✓ Detected in Summary
§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, neural network, algorithm, dataset)
✓ 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.

• 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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Second Opinion® 3D - Pearl, Inc. | ESL FDA AI Device Intelligence