The Optos Advance Software is a web-based software system application intended for use in storing, managing, and displaying patient data, diagnostic data, videos and images from computerized diagnostic instruments or video documentation systems.
Device Story
Optos Advance is a web-based PACS application for ophthalmic image management. It interfaces with diagnostic instruments (Scanning Laser Ophthalmoscope, Fundus Camera, OCT) via secure network connections. Data is transmitted to a central Optos Advance Server, where a watchdog service processes and stores DICOM-compliant images and patient data. The server obfuscates patient information. Clinicians access the system via web browsers without requiring client-side software. The application allows viewing of studies, bilateral image comparison, manual magnification (zoom), and manual annotation (arrows/text). It does not perform automated image analysis or highlighting. The system supports archiving and secure remote sharing of data over HTTPS. By centralizing diagnostic data, it facilitates clinical review and decision-making for ophthalmic conditions.
Clinical Evidence
Bench testing only. Software and system verification and validation were performed according to the manufacturer's Software Development Lifecycle Process.
Technological Characteristics
Web-based PACS application; DICOM compatible; HTTPS protocol for secure remote data transfer; server-side data obfuscation; watchdog service for DICOM processing; browser-based client interface (no local installation); supports Scanning Laser Ophthalmoscope, Fundus Camera, and OCT inputs.
Indications for Use
Indicated for use by clinicians to store, manage, and display patient data, diagnostic data, videos, and images from computerized diagnostic instruments or video documentation systems.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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MAY 2 5 2012
### 510(k) SUMMARY
#### Optos' Optos Advance Software
## Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
| Sponsor: | Optos plc |
|----------|--------------------------|
| | Queensferry House |
| | Carnegie Business Campus |
| | Dunfermline |
| | Fife KY11 8GR |
| | United Kingdom |
Phone: 01144 1383 843300 Fax: 01144 1383 843333
Contact Person: Graham McLeod MSc.
Date Prepared: 16 December 2011
Name of Device: Optos Advance
Picture Archiving and Communications System Common Name:
Picture Archiving and Communications System Classification: (per 21 C.F.R. § 892.2050)
NFJ Product Code:
System, Image Management, Ophthalmic Device Device:
Carl Zeiss Surgical GmbH FORUM Software (K090439) Predicate Device:
#### Indications for use
The Optos Advance Software is a web-based software system application intended for use in storing, managing, and displaying patient data, diagnostic data, videos and images from computerized diagnostic instruments or video documentation systems.
#### Technological Characteristics
The Optos Advance Software is an image review application that allows the user to view DICOM compatible images. The Optos Advance Software organizes the digitized images into studies and sessions. The digitized studies and sessions may be viewed by using an overall or bilateral display (i.e., display provides comparisons between old and new images). The software also allows
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physicians or technicians to create on-line notes with the ability to zoom in or out (i.e., enlarge or decrease magnification of images) and annotate such images with arrows or text boxes to highlight areas the user determines by training and experience to be of interest. The Optos Advance Software does not automatically highlight, annotate, or otherwise alter the images. In addition, the digitized studies and sessions and on-line notes may be viewed, archived on a central file server, or electronically shared in a secure manner with other health care professionals.
The Optos Advance Software allows the user to interface a Scanning Laser Ophthalmoscope, Fundus Camera, OCT or other DICOM compliant diagnostic camera with the Optos Advanced Software via a secure network connection to the Optos Advance Server. The server has a watchdog service which processes the DICOM information sent via the network. The information is then processed and placed in local storage on the Optos Advance Server. The data is obfuscated at the server side to protect any patient information transferred.
The Optos Advance Software does not require any customized software installed on the client PC. The images, annotations and DICOM data are all stored on the Optos Advance Server, which handles the archiving, reporting, and retrieval of the data. This server can be set up remotely over an HTTPS connection which allows secure remote transfer of the stored data for archive purposes.
#### Performance Testing
A full software and system verification and validation was performed as per the Software Development Lifecycle Process in Optos PLC.
#### Substantial Equivalence
The Optos Advance Software has the same intended use and substantially similar indications for use as the cleared Carl Zeiss Surgical GmbH FORUM Software (K090439). Minor differences in technological characteristics allow the user to access the software from any web enabled browser without the need for any customizable software installed on their personal computer and to archive their data to a remote server for retrieval over an HTTPS protocol driven server. Both Optos Advance and FORUM Software are intended for the review, storage and retrieval of images and image data supplied by ophthalmic medical devices. Thus, the minor differences between the Optos Advance Software and its predicate device raise no new questions of safety and effectiveness and the Optos Advance is substantially equivalent.
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is a circular seal with the department's name around the perimeter. Inside the circle is a stylized image of a caduceus, a symbol often associated with medicine and healthcare.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Optos Plc c/o Mr. Howard M. Holstein, Partner Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington DC 20004
# MAY 2 5 2012
Re: K113696
Trade/Device Name: Optos Advance Software Regulation Number: 21 CFR 892.2050 Regulation Name: Picture Archiving and Communications System Regulatory Class: Class II Product Code: NFJ Dated: May 8, 2012 Received: May 8, 2012
# Dear Mr. Holstein:
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 to 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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 that I Dr has Intatutes and regulations administered by other Federal agencies. You must or uny I with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical Of K F ar 807), acomig (21 CFR 803); good manufacturing practice requirements as set de rico-related adverse overies) (2 - Salation (21 CFR Part 820); and if applicable, the electronic
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Page 2 - Mr. Howard M. Holstein
product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely vours.
Kesia Alexander
Malvina B. Eydelman, M.D. Director Division of Ophthalmic, Neurological, and Ear. Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use Statement
510(k) Number (if known):
K 113696
Device Name: Optos Advance Software
Indications for Use:
The Optos Advance Software is a web-based software system application intended for use in storing, managing, and displaying patient data, diagnostic data, videos and images from computerized diagnostic instruments or video documentation systems.
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)
Sem
(Division Sign-Off) (Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
Page 1 of 1
510(k) Number_
15
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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.
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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.
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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.
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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.
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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.
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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.