The Keeler Kapture Software Package is used by Health Professionals to capture, store and manage output images from Retinal Cameras, Fundus Cameras and Video Slit Lamps
Device Story
Keeler Kapture Software is a PC-based ophthalmic imaging system designed for use by health professionals in clinical settings. It interfaces with digital slit lamps, retinal cameras, and fundus cameras to capture, store, and manage patient images. The software allows users to perform basic image adjustments—including brightness, contrast, and color—and provides tools for image annotation, mosaicking, color plane splitting, and histogram generation. Images can be visually compared side-by-side to assist in clinical review. The system includes a patient database for managing records, audit trails for tracking database changes, and administrative controls for user access. By centralizing image management and providing basic enhancement tools, the device facilitates the review and documentation of ophthalmic examinations, supporting clinical decision-making through improved image organization and comparison capabilities.
Clinical Evidence
No clinical data. Bench testing only. Functional verification tests were performed to compare the Keeler Kapture Software against the EyeCap Imaging System predicate, confirming that all features and performance specifications are met.
Technological Characteristics
Software application running on Microsoft Windows OS on a PC. Features include image capture, storage, database management, and image processing tools (brightness, contrast, color adjustment, annotation, mosaicking, histogram). Connectivity via standard camera interfaces and network workstations. No specific hardware materials or energy sources defined as it is a software-only accessory.
Indications for Use
Indicated for use by health professionals to capture, store, and manage ophthalmic images from retinal cameras, fundus cameras, and video slit lamps.
Regulatory Classification
Identification
An ophthalmic camera is an AC-powered device intended to take photographs of the eye and the surrounding area.
Special Controls
*Classification.* Class II (special controls). The device, when it is a photorefractor or a general-use ophthalmic camera, 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
Clement Clarke International Ltd EyeCap Imaging System (K000368)
Submission Summary (Full Text)
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Ophthalmic Instruments
## 510(k) Summary of Safety and Effectiveness
#### 1. Submitter's Information
The submitter of this special pre-market notification is:
| Name: | Mr. Neil Atkins (Engineering Manager). |
|------------------------|----------------------------------------------------------------------|
| Address: | Keeler Limited, Clewer Hill Road, Windsor,<br>Berkshire, SL4 4AA, UK |
| Company Phone No: | +44 (0) 1753 827125 |
| Company Fax No: | +44 (0) 1753 827145 |
| Contact Person: | Mr. Neil Atkins |
| Date summary prepared: | 19th February, 2014 |
| Date summary reviewed: | 17th June, 2014 |
#### 2. Device Identification
| Device Trade Name: | Keeler Kapture Software |
|-----------------------|-----------------------------|
| Common Name: | Ophthalmic Camera Accessory |
| Class: | II |
| Classification Panel: | 86 |
| Product Code: | HKI |
| Regulation Number: | 886.1120 |
#### 3. Predicate Device
K000368 Clement Clarke International Ltd EyeCap Imaging System
#### 4. Device Description
The Keeler Kapture software is an ophthalmic imaging system. The Kapture software package is intended to run on a PC and will allow the user to capture images from a digital slit lamp or other camera for review and storage. Images can have basic adjustments (such as colour, brightness and contrast) and images can be visually compared.
#### ક. Indications for Use
The Keeler Kapture Software is used by Health Professionals to capture, store and manage output images from Retinal Cameras, Fundus Cameras and Video Slit Lamps.
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Keeler
## Ophthalmic Instruments
#### Summary of Technological Characteristics 6.
Both the Keeler Kapture Software and the EyeCap Imaging System predicate device are software applications running under the Microsoft Windows Operating System on a Personal Computer. Both products have exactly the same technological characteristics in terms of network capability, workstations, camera interfaces and patient database.
#### 7. Comparison with Cleared Device
The Keeler Kapture Software and the EveCap Imaging System predicate device have exactly the same Indications for Use, technological characteristics and performance specifications.
#### 8. Summary of Non-clinical Tests
A number of functional tests were carried out to verify the performance of the Keeler Kapture Software against the EyeCap Imaging System, a brief description of the tests is provided in the table below. All tests were passed.
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Image /page/2/Picture/0 description: The image contains the word "Keeler" in a bold, sans-serif font. The letters are evenly spaced and the word is horizontally oriented. The text is black against a white background.
## Ophthalmic Instruments
| Kapture function/Feature | Present in EyeCap |
|-------------------------------------------------------------------------------------------------------------|-------------------|
| Administration | Yes |
| Allow log-in as administrator or user | Yes |
| Add and manage users and their scope | Yes |
| Add cameras and manage cameras | Yes |
| Assign cameras to workstations | Yes |
| Manage user configurable options | Yes |
| Manage user definable fields | Yes |
| Manage data entry formats | Yes |
| Manage system settings and file locations | Yes |
| Manage the database | Yes |
| Track changes to the database in an audit trail | Yes |
| Show statistical information about the system | Yes |
| Patient Database | Yes |
| Allow addition, deletion and editing of patient data | Yes |
| Information and images collected from each patient<br>visit shall be stored separately | Yes |
| Allow review of patient data and images | Yes |
| Allow searching of the database | Yes |
| Allow configuration of search reports | Yes |
| Image Capture | Yes |
| Image capture shall be available from within a patient<br>episode | Yes |
| It shall be possible to capture images from a camera | Yes |
| It shall be possible to adjust the brightness of images<br>captured from a camera | Yes |
| It shall be possible to import an image from a file | Yes |
| When and image is captured, an "X" is assigned to<br>indicate that there is no left or right eye assignment | Yes |
| It shall be possible to manually assign "L" or "R" to an<br>image to indicate left or right eye | Yes |
| Image Adjustment | |
| It shall be possible to assign notes to an image | Yes |
| It shall be possible to alter how images are printed | Yes |
| It shall be possible to mosaic several images together | Yes |
| It shall be possible to split image planes by colour | Yes |
| It shall be possible to make annotations on the<br>captured image | Yes |
| It shall be possible to present images together for<br>comparison | Yes |
| Tools shall be provided to grade images | Yes |
| An image brightness map, or histogram shall be<br>provided | Yes |
| It shall be possible to undo any image manipulation | Yes |
| It shall be possible to apply a time and date to<br>captured images | Yes |
510(k) Keeler Kapture Software
.
/
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# Keeler
## Ophthalmic Instruments
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Image /page/4/Picture/0 description: The image shows the logo for Keeler Ophthalmic Instruments. The word "Keeler" is in a large, bold font at the top of the image. Below that, in a smaller font, are the words "Ophthalmic Instruments."
#### 9. Conclusion
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this Premarket Notification, Keeler Limited conclude that the Keeler Kapture Software is substantially equivalent to the predicate device.
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#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Commi Center - WO66-G60 Silver Spring, MD 20993-0002
#### June 17, 2014
Keeler Ophthalmic Instruments. Inc. Mr. Eugene R. VanArsdale Marketing Manager 456 Parkway Broomall, PA 19008
Re: K140450
Trade/Device Name: Kecler Kapture Software (Versions: KAPTURE, KAPTURE Lite. KAPTURE Digital, KAPTURE View, and KAPTURE View+) Regulation Number: 21 CFR 886.1120 Regulation Name: Ophthalmic Camera Regulatory Class: II Product Code: HKI Dated: May 8, 2014 . Received: May 9, 2014
Dear Mr. Arnsdale:
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 docs 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.
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## Page 2 - Mr. Eugene R. VanArsdale
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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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/Safetv/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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
## Kesia Y. Alexander -S
for Malvina B. Eydelman, M.D. 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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## DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
## Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
#### 510(k) Number (if known) K140450
#### Device Name
Keeler Kapture Software Package (Versions: KAPTURE Lite, KAPTURE Digital, KAPTURE View, and KAPTURE View+)
#### Indications for Use (Describe)
The Keeler Kapture Software Package is used by Health Professionals to capture, store and manage output images from Retinal Cameras, Fundus Cameras and Video Slit Lamps
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
## PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
#### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signalure)
Marsha L. Burke Nicholas -S
Digitally signed by Marsha L. Burke Nicholas -S DN: c=US, o=U.S. Govemment, ou=HHS, ou=FDA, ou=People, 0.9.2342.19200300.100.1.1=1300014022, cn=Marsha L. Burke Nicholas
Date: 2014.06.11 20:33:36 -04'00'
This section applies only to requirements of the Paperwork Reduction Act of 1995.
## *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW."
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
FORM FDA 3881 (1/14)
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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.
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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.
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.
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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.
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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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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.
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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.