Retrospective analysis of clinical study patient records
Retrospective analysis of biometric data (lens thickness, anterior chamber depth, and central cornea thickness) to confirm the intraoperative accuracy of VICTUS OCT compared to the LENSTAR LS 900.
171 eyes (58 eyes for femtosecond-laser flap creation; 113 eyes for femtosecond laser assisted cataract surgery); Sample Size: 171 eyes; Number of Sites: Single-center
LENSTAR LS 900
Correlation and agreement of biometric data (lens thickness, anterior chamber depth, and central cornea thickness)
Indications for Use
The VICTUS Femtosecond Laser Platform is indicated for use in: · The creation of a corneal flap in patients undergoing LASIK surgery or other treatment requiring initial lamellar resection of the cornea · For anterior capsulotomy during cataract surgery • The creation of cuts / incisions in the cornea in patients undergoing cataract surgery or other ophthalmic treatment requiring cuts / incisions in the cornea.
Device Story
Precision ophthalmic surgical laser; uses femtosecond laser pulses to create corneal flaps, anterior capsulotomies, and corneal incisions. System utilizes sterile disposable patient interface (contact lens and suction clip) to fix eye and provide reference surface for depth control. Laser beam focused through scanning optic system; photodisruption creates continuous incisions. Operated by surgeons in clinical settings. Output consists of precise tissue incisions. Benefits include automated, accurate surgical cuts for cataract and refractive procedures. Device performance monitored via integrated optical coherence tomography (OCT) for biometry visualization.
Clinical Evidence
Open, controlled, multi-surgeon, single-center study. Retrospective analysis of 171 eyes (58 flap creation, 113 cataract surgery). Primary endpoint: intraoperative accuracy of biometry visualization (lens thickness, anterior chamber depth, central cornea thickness) compared to LENSTAR LS 900. Results showed consistent biometric data. 100% of capsulotomies completed without manual intervention. No adverse events or device malfunctions reported.
Technological Characteristics
Femtosecond laser; photodisruption principle. Patient interface: sterile disposable contact lens and suction clip. Materials: porcine eyes, agarose gel, PETG, PMMA (bench testing). Standards: EN ISO 60601-1, EN ISO 60601-1-2, EN ISO 60601-2-22. Integrated OCT for biometry.
Indications for Use
Indicated for patients undergoing LASIK surgery or other treatments requiring initial lamellar resection of the cornea, anterior capsulotomy during cataract surgery, or ophthalmic treatments requiring corneal cuts/incisions.
Regulatory Classification
Identification
An ophthalmic laser is an AC-powered device intended to coagulate or cut tissue of the eye, orbit, or surrounding skin by a laser beam.
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Image /page/0/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" written around the perimeter. Inside the circle is a stylized image of three human figures.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 16, 2015
Technolas Perfect Vision Gmbh % Mr. Ken Nehmer Senior Manager, Regulatory Affairs 1025 Sanchez Street San Francisco, California 94114
> K141379 Trade/Device Name: Victus Femtosecond Laser Platform Regulation Number: 21 CFR 886.4390 Regulation Name: Ophthalmic Laser Regulatory Class: II Product Code: OOE Dated: January 9, 2015 Received: January 12, 2015
Dear Mr. Nehmer:
Re:
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 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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) 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" (21 CFR 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 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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## Indications for Use
510(k) Number (if known) K141379
Device Name VICTUS Femtosecond Laser Platform
Indications for Use (Describe)
"The VICTUS Femtosecond Laser Platform is indicated for use in:
· The creation of a corneal flap in patients undergoing LASIK surgery or other treatment requiring initial lamellar resection of the cornea
· For anterior capsulotomy during cataract surgery
• The creation of cuts / incisions in the cornea in patients undergoing cataract surgery or other ophthalmic treatment requiring cuts / incisions in the cornea."
Type of Use (Select one or both, as applicable)
X 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) (Signature)
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# 5. 510(k) Summary of safety and effectiveness
This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
| Applicant: | Technolas Perfect Vision GmbH<br>Messerschmittstr. 1 +3<br>80992 Munich, Germany<br>Tel: 49 174 3494062 |
|---------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Ken Nehmer<br>Sr. Manager, Regulatory Affairs<br>Technolas Perfect Vision<br>c/o 1025 Sanchez Street<br>San Francisco, CA 94114<br>Ph: 415-297-0408<br>Email: ken.nehmer@bausch.com |
| Date of Summary: | January 9, 2015 |
| Trade Name: | VICTUS Femtosecond Laser Platform |
| Common Name: | Ophthalmic Laser |
| Classification<br>Name: | Laser, Ophthalmic |
| Device<br>Classification: | Class II |
| Product Code | OOE (Ophthalmic Femtosecond Laser)<br>HQF (Laser, Ophthalmic) |
| Predicate Devices: | VICTUS Femtosecond Laser Platform (K132534) |
#### Substantially Equivalent To
| | 510(k) Number Product Trade Name | Manufacturer |
|---------|------------------------------------|--------------------------|
| K132534 | VICTUS Femtosecond Laser | Technolas Perfect Vision |
| | Platform | GmbH |
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#### SECTION 5 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS
### Description of the Device Subject to Premarket Notification
The VICTUS Femtosecond Laser Platform (VICTUS) is a precision ophthalmic surgical laser and is cleared for use in the creation of a corneal flap in patients undergoing LASIK surgery or other treatment requiring initial lamellar resection of the cornea and for patients undergoing anterior capsulotomy during cataract surgery (via K120426). In addition, the VICTUS has been cleared for patients undergoing cataract surgery or other ophthalmic treatment requiring penetrating arcuate cuts / incisions in the cornea (K122386) and primary/secondary corneal incisions (K132534). This submission does not add to the indications previously cleared for the VICTUS Platform.
The patient interfaces used for the VICTUS platform remain unchanged from that which was previously discussed and cleared via K132534. For all indications for use, laser pulses are delivered through a sterile disposable Patient Interface, consisting of a contact lens and suction clip to provide suction. The contact lens and suction clip assembly creates a reference surface for depth control and fix the eye relative to the delivery of the laser beam. Surgical effects are produced by scanning thousands of individual pulses, producing continuous incisions. The location of the tissue photodisruption is controlled by a fixed laser beam focused through a scanning optic system to the desired location.
The fundamental scientific technology and indications for use remains the same as previously cleared for the VICTUS Femtosecond Laser Platform under K132534.
### Indications for Use
The VICTUS Femtosecond Laser Platform is indicated for use for:
- the creation of a corneal flap in patients undergoing LASIK surgery or other treatment ● requiring initial lamellar resection of the cornea.
- for anterior capsulotomy during cataract surgery. ●
- the creation of cuts / incisions in the cornea in patients undergoing cataract surgery or ● other ophthalmic treatment requiring cuts / incisions in the cornea.
# Technical Characteristics Comparison
The design principle of the VICTUS Platform is fundamentally the same as that previously cleared for VICTUS under K132534. The VICTUS Platform mode of operation is the same as that previously cleared for the VICTUS Platform via K132534 which delivers femtosecond pulses to produce a pattern of photodisruption to create cuts / separation in ophthalmic tissue.
The means of fixation of the patient contact portion of the VICTUS Platform is the same as that present in the VICTUS Platform cleared in K132534. The VICTUS Platform uses vacuum to affix a suction ring to the corneal surface prior to use. There is no change to vacuum suction or force pressure related to the patient interface as compared to that previously described and cleared in K132534.
The VICTUS Platform mode of operation and the technology used to create the cutting action are identical to the predicate VICTUS Platform device (K132534), and therefore substantially
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#### SECTION 5 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS
equivalent to the legally marketed predicate device.
#### Performance Data
The VICTUS Femtosecond Laser Platform has undergone testing and is in compliance with applicable safety standards as listed in the following table.
| Standard | Title |
|-------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|
| EN ISO 60601-1 | Medical electrical equipment – Part I: General requirements<br>for safety |
| EN ISO 60601-1-2 | Medical electrical equipment – Part 1: General requirements<br>for safety; 2. Collateral standard: electromagnetic<br>compatibility; requirements and tests |
| EN ISO 60601-2-22 | Medical electrical equipment – Part 2: Particular requirements<br>for the safety of diagnostic and therapeutic laser equipment |
The VICTUS Femtosecond Laser Platform has been found to perform equivalently to the predicate device. The VICTUS Femtosecond Laser Platform and the predicate device therefore have a similar performance profile.
#### Non-Clinical Performance Data
A variety of test procedures were conducted to demonstrate that the performance of the modified VICTUS Platform remains substantially equivalent to that previously cleared in K132534. The collected data were evaluated by comparing the mean values to the specified acceptance criteria and their 95% confidence intervals. Four different materials were used for the bench performance testing: porcine eyes, agarose gel, polyethylene terephthalate (PETG), and polymethyl methacrylate (PMMA). The acquired test data successfully verified that the various parameters meet their pre-defined acceptance criteria.
### Clinical Performance Data
An open, controlled, multi-surgeon, single-center clinical study was performed to confirm the intraoperative accuracy of biometry visualization performed by VICTUS optical coherence tomography (OCT) and its comparability with LENSTAR LS 900 by means of axial optical resolution accuracy comparison. Two groups of patients from two clinical applications i.e. femtosecond-laser flap creation (flap group - 58 eyes) and femtosecond laser assisted cataract surgery (cataract group - 113 eyes) were observed in this study. All 113 and 58 eyes assigned in the femto-cataract and flap group, respectively were available for a retrospective analysis of the correlation and agreement of the biometric data for lens thickness, anterior chamber depth (ACD) and central cornea thickness (CCT). The lens thickness, ACD and CCT measured by VICTUS OCT were compared with LENSTAR LS900 and the results are consistent.
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All the enrolled cataract patients were treated with femtosecond laser assisted capsulotomy before the femtosecond laser assisted lens fragmentation by VICTUS femtosecond laser platform. The cataract group (113 eyes) represented cataract grades I through IV (Grade I = 76, Grade II = 16, Grade III = 16, Grade IV = 5). All laser assisted capsulotomy procedures were completed fully using the VICTUS laser platform with no need for manual intervention to complete the capsulotomy. There were no adverse or serious adverse events reported by the investigators during the clinical study. In addition, there were no device malfunctions which led or potentially led to adverse or serious adverse events.
#### Basis for Determination of Substantial Equivalence
The technological characteristics of the VICTUS Platform are substantially equivalent to the technological characteristics of the predicate VICTUS Platform which was cleared via K132534.
The indications for the VICTUS Platform remain unchanged from those cleared via K132534.
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
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.
How do you verify an AI chat answer on the device detail page?
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.