The CM3910 is a device intended to take images of the anterior segment of the eye which includes the cornea, iris, pupil, anterior chamber and lens, to evaluate and analyse - Corneal shape - Lens shape - Pachymetry (thickness of the cornea) - Pupil size - Lens thickness - Condition of the lens - Location of cataracts (nuclear, subcapsular and or cortical), using Scheimpflug slit imaging with densitometry - State of the lens (opaque crystalline lens) - Condition and position of implants (e.g. iOLs, phakik IOLs, intracorneal rings) - Anterior chamber (size, volume and angle) - Scheimpflug Image - Position of the cornea relative to iris and lens
Device Story
Non-invasive diagnostic system for anterior eye segment analysis; utilizes Scheimpflug principle for slit image photography and Placido disc imaging. System table-mounted; AC-powered; consists of measurement unit and control unit with CPU. Input: blue light (UV-free) slit illumination and infrared LED (810nm) for eye tracking/Placido imaging; CCD camera captures rotating scans of anterior segment. Output: 3D-model and topography of eye displayed on 17" monitor. Operated by clinician in clinic setting. Healthcare provider uses output to evaluate corneal/lens shape, pachymetry, cataract location, and implant position. Benefits patient through non-invasive assessment of ocular structures and pathology.
Clinical Evidence
Bench testing only. No clinical data provided. Effectiveness demonstrated through internal performance tests.
Technological Characteristics
Non-invasive diagnostic system. Materials: metallic heat sinks, glass, non-inflammable encapsulation. Sensing: CCD camera, blue LED (470nm) slit illumination, infrared LED (810nm) observation. Connectivity: CPU-based, 17" monitor. Power: 110/220 VAC. Form factor: table-mounted measurement unit (10kg).
Indications for Use
Indicated for patients requiring anterior eye segment imaging and analysis, including corneal shape, lens condition (cataracts), pachymetry, pupil size, anterior chamber metrics, and implant positioning.
Regulatory Classification
Identification
An AC-powered slitlamp biomicroscope is an AC-powered device that is a microscope intended for use in eye examination that projects into a patient's eye through a control diaphragm a thin, intense beam of light.
Special Controls
*Classification.* Class II (special controls). The device, when it is intended only for the visual examination of the anterior segment of the eye, is classified as Group 1 per FDA-recognized consensus standard ANSI Z80.36, does not provide any quantitative output, and is not intended for screening or automated diagnostic indications, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 886.9.
Predicate Devices
Pentacam Scheimpflug Camera of OCULUS Optikgeräte GmbH (K013941)
Orbscan IITM Keratometer manufactured by Orbtek, Inc. (K984443)
Submission Summary (Full Text)
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Image /page/0/Picture/1 description: The image shows a handwritten string of characters. The characters appear to be a combination of letters and numbers. The string starts with the letter 'K', followed by the number '0', then '51940'. The characters are written in black ink on a white background.
# 510(k) Summary for the CM 3910 Rotating Double Scheimpflug Camera
#### Name and Address of Sponsor
SIS Surgical Instrument Systems Ltd. Registration Number: 9614468 Allmendstrasse 11 2502 Port Switzerland Phone: 0041 32 332 70 70 Fax: 0041 32 332 70 71 Email: frank.ziemer@sisItd.ch
#### Name and Address of Manufacturer
SIS Surgical Instrument Systems Ltd. Registration Number: 9614468 Allmendstrasse 11 2502 Port Switzerland Phone: 0041 32 332 70 70 Fax: 0041 32 332 70 71 Email: frank.ziemer@sisItd.ch
#### Name and Address of Official Correspondent
Kevin Walls, RAC Principal Consultant Regulatory Insight, Inc. 13 Red Fox Lane Littleton, Colorado 80127 Phone: 720-962-5412 Fax: 720-962-5413 Email: kevin@reginsight.com
#### Device Name
Device trade name: CM 3910 Rotating Double Scheimpflug Camera Classification name: Anterior segment analysis device Common name: AC-powered slitlamp biomicroscope
### Classification, Panel and Product Code
| Device Classification: | Class II, MXK |
|------------------------|--------------------|
| Reviewing Panel: | Ophthalmic Devices |
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#### Indications for Use
The CM3910 is a device intended to take images of the anterior segment of the eye which includes the cornea, iris, pupil, anterior chamber and lens, to evaluate and analyse
- · Corneal shape
- · Lens shape
- · Pachymetry (thickness of the cornea)
- · Pupil size
- · Lens thickness
- · Condition of the lens
- o Location of cataracts (nuclear, subcapsular and or cortical), using Scheimpflug slit imaging with densitometry
- State of the lens (opaque crystalline lens) o
- · Condition and position of implants (e.g. iOLs, phakik IOLs, intracorneal rings)
- · Anterior chamber (size, volume and angle)
- · Scheimpflug Image
- · Position of the cornea relative to iris and lens
#### Predicate Devices
The Pentacam Scheimpflug Camera is claimed to be substantially equivalent to the following legally marketed devices:
- . Pentacam Scheimpflug Camera of OCULUS Optikgeräte GmbH
- Orbscan IITM Keratometer manufactured by Orbtek, Inc. .
#### Device Description
The CM 3910 Double-Scheimpflug Camera is a non-invasive, diagnostic system designed for the analysis of the anterior eye segment by means of Scheimpflug and Placido images. The Scheimpflug images are based on the Scheimpflug Principle for Slit Image photography. The system is table mounted and AC powered. The device consists of a measurement unit and a control unit with a CPU. The measuring system uses blue light (UV-free) given to a slit to illuminate the eye, and a CCD-Camera for taking images. The measuring unit takes pictures by a rotating scan of the anterior eye segment. It also includes a top view for eye tracking means and Placido imaging in the near infrared. From the acquired pictures, the control unit calculates a 3D-model and the topography of the eye.
All light sources used (Slit lamp, Placido Disc illumination, Top view illumination) are Light Emitting Diodes (LED) which produce little heat. Excess heat is conducted by appropriate metallic heat sinks. The encapsulation of the light sources consists of non-inflammable materials (metals, glass). The device does not contain any incandescent lamp.
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Product Comparison
| Characteristics | CM 3910 | Pentacam Scheimpflug Camera (Predicate) | Orbscan II™ Keratometer (Predicate) |
|------------------------------|--------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|
| References<br>Intended use | Taking photos of the anterior segment of the eye which includes the cornea, pupil, anterior chamber and lens of the eye. | 510(k): K013941<br>Taking photos of the anterior segment of the eye which includes the cornea, pupil, anterior chamber and lens of the eye. | 510(k): K984443<br>Scan, map and display the geometry of the anterior segment of the eye. |
| Measuring Principle | Rotational scan of Double-Scheimpflug slit images merged with Placido Disc images. | Rotational scan of Scheimpflug slit images. | Parallel scanned slit images and Placido Disc images |
| Optical<br>Viewing Means | Three Apertures<br>LCD on Measurement Unit, 17" monitor on table | Single Aperture<br>15" Coloured Screen | Single Aperture<br>15" Coloured Screen |
| Observation<br>Illumination | Infrared LED 810nm | Infrared LED 800nm | White flash light |
| Flash Output<br>Illumination | Blue LED Light (UV-free) 470 nm, max. 15 mWsec | Blue LED Light (UV-free) 475nm, max. 2.5 Wsec | |
| Photography<br>Camera | CCD Camera | CCD Camera | CCD Camera |
| Display<br>Image Resolution | Data digital, displayed on a CPU<br>1004 x 1004 pixels | Data digital, displayed on a CPU<br>800 x 600 pixels | Data digital, displayed on a CPU<br>0.25 diopters |
| Image Size | 7.4 x 7.4 mm | 5.6 x 4.5 mm | Parallel scan |
| Photographic Range | Eligible 0 to 180° | Eligible 0 to 180° | 2x 20 images from two sides |
| Photographic Series | 1 to 60 images | 1 to 50 photos | |
| Slit Length | 15 mm | 14 mm | |
| Power Requirement | 110/220 VAC, 50/60 Hz | 110/220 VAC, 50/60 Hz | 110/220 VAC, 50/60 Hz<br>220/240 VAC, 50/60 Hz |
| Weight | 10 kg (Measurement Unit) | 9 kg | 15kg |
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# K051990
### Rationale for Substantial Equivalence
- . The devices have the same intended use
- The devices utilize the same measuring principles (Slit Scan and Placido Disc) .
- The devices utilize the same photographic medium (CCD Camera) .
- The CM 3910 and one predicate device use light sources of comparable wavelength and intensity . .
- The devices use the same features like a
- o Head stabilizing device
- Fixation target o
- Joy stick for measurement head adjustment o
- All devices are considered "non invasive" as defined in 21 CFR §812.3(k) .
#### Safety
The CM 3910 is a non-invasive diagnostic system, which contacts the patient only on his/her chin and forehead. The CM 3910 does not present or pose any new or additional risks for the prescribed intended uses. The light output is of an eye safe intensity and wavelength. The electrical safety requirements for medical devices are met. The CM 3910 is proven effective for its intended uses through internal performance tests.
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is a stylized symbol resembling a caduceus, with three angled lines representing the staff and a wavy line at the bottom representing the serpent.
SEP 2 8 2005
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Surgical Instrument Systems c/o Kevin Walls, RAC Principal Consultant Regulatory Insight, Inc. 13 Red Fox Lane Littleton, CO 80127
Re: K051940
Trade/Device Name: CM 3910 Rotating Double Scheimpflug Camcra Regulation Number: 21 CFR 886.1850 Regulation Name: Anterior Eye-Segment Analysis Device Regulatory Class: Class II Product Code: MXK Dated: July 15, 2005 Received: July 20, 2005
Dear Mr. Walls:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments. or 10 devices that have been reclassified in accordance with the provisions of the Federal Food, Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2- Kevin Walls, RAC
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to 2 legal) v marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 827-8910. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html
Sincerely yours,
David M. Whizzle
David M. Whipple Acting Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known): ______________________
Device Name: CM 3910 Rotating Double Scheimpflug Camera
Indications for Usc: The CM3910 is a device intended to take images of the anterior segment of the eye which includes the cornea, iris, pupil, anterior chamber and lens, to evaluate and analyse
- · Corneal shape
- Lens shape
- · Pachymetry (thickness of the cornea)
- · Pupil size
- · Lens thickness
- · Condition of the lens
- > Location of cataracts (nuclear, subcapsular and or cortical), using Scheimpflug slit imaging with densitometry
- > State of the lens (opaque crystalline lens)
- · Condition and position of implants (e.g. IOLs, phakik IOLs, intracorneal rings)
- · Anterior chamber (size, volume and angle)
- · Scheimpflug Image
- · Position of the cornea relative to iris and lens
Prescription Use × (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Senio L. M'Carthy
(Division Sign-Off)
Division of Ophthalmic Ear,
Nose and Throat Devises
510(k) Number
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
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Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.