DAILIES TOTAL1 (delefilcon A) and DAILIES TOTAL1 Asphere (delefilcon A) soft contact lenses are indicated for the optical correction of refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased eyes with up to approximately 1.50 diopters (D) of astigmatism that does not interfere with visual acuity. DAILIES TOTAL1 for ASTIGMATISM (delefilcon A) soft contact lenses are indicated for the optical correction of refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased eyes with up to 6.00 diopters (D) of astigmatism. DAILIES TOTAL1 Multifocal (delefilcon A) soft contact lenses are indicated for the optical correction of presbyopia, with or without refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters (D) or less and who may have up to approximately 1.50 diopters (D) of astigmatism that does not interfere with visual acuity. DAILIES TOTAL1 Multifocal Toric (delefilcon A) soft contact lenses are indicated for the optical correction of presbyopia with or without refractive ametropia (myopia, hyperopia) in phakic or aphakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters (D) or less and who may have up to 6.00 diopters (D) of astigmatism. The lenses are to be used for single use, daily disposable wear (less than 24 hours while awake) only. The lenses are not intended to be cleaned or disinfected and should be discarded after a single use.
Device Story
DAILIES TOTAL1 are daily disposable soft contact lenses composed of delefilcon A, a silicone hydrogel with a water gradient surface treatment. Lenses incorporate benzotriazole UV-absorbing monomers and copper phthalocyanine handling tint. Available in spherical, asphere, toric, and multifocal designs. Lenses are supplied sterile in blister packs with phosphate-buffered saline and wetting agents. Intended for patient self-use for vision correction. Healthcare providers prescribe based on refractive needs. Benefits include daily replacement, eliminating cleaning/disinfection requirements, and providing oxygen permeability (140 barrer units).
Clinical Evidence
No clinical data. Substantial equivalence supported by non-clinical bench testing, including physicochemical characterization, biocompatibility (ISO 10993), and stability testing.
Technological Characteristics
Material: Delefilcon A (Group 5C silicone hydrogel). Water content: 33%. Oxygen permeability: 140 barrer. Refractive index: 1.42. Surface: Water gradient treatment. UV protection: Benzotriazole monomers. Tint: Copper phthalocyanine. Manufacturing: LightStream molded. Sterilization: Steam autoclave. Packaging: Polypropylene blister with PBS and wetting agents.
Indications for Use
Indicated for optical correction of refractive ametropia (myopia/hyperopia) and presbyopia in phakic or aphakic persons with non-diseased eyes. Supports astigmatism correction up to 1.50D or 6.00D depending on lens model. Reading addition up to +3.00D for multifocal models. For single-use, daily disposable wear only.
Regulatory Classification
Identification
A soft (hydrophilic) contact lens is a device intended to be worn directly against the cornea and adjacent limbal and scleral areas of the eye to correct vision conditions or act as a therapeutic bandage. The device is made of various polymer materials the main polymer molecules of which absorb or attract a certain volume (percentage) of water.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.
January 18, 2019
Alcon Laboratories, Inc. Martina Heim Global Project Regulatory Director, Global Regulatory Affairs, Vision Care 6201 South Freeway Fort Worth, TX 76134
Re: K182782
Trade/Device Name: DAILIES TOTAL1 Soft Contact Lenses: DAILIES TOTAL1, DAILIES TOTAL1 Asphere, DAILIES TOTAL1 for ASTIGMATISM, DAILIES TOTAL1 Multifocal, DAILIES TOTAL1 Multifocal Toric Regulation Number: 21 CFR 886.5925 Regulation Name: Soft (Hydrophilic) Contact Lens Regulatory Class: Class II Product Code: LPL, MVN Dated: December 17, 2018 Received: December 21, 2018
Dear Martina Heim:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act): 21 CFR 1000-1050.
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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely yours,
# J Angelo Green -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)
K182782
Device Name DAILIES TOTAL 1 soft contact lenses: DAILIES TOTAL 1, DAILIES TOTAL 1 Asphere, DAILIES TOTAL 1 for ASTIGMATISM, DAILES TOTAL 1 Multifocal, DAILIES TOTAL 1 Multifocal Toric
#### Indications for Use (Describe)
DAILIES TOTAL1 (delefilcon A) and DAILIES TOTAL1 Asphere (delefilcon A) soft contact lenses are indicated for the optical correction of refractive ametropia (myopia and hyperopia) in phakic persons with non-diseased eves with up to approximately 1.50 diopters (D) of astigmatism that does not interfere with visual acuity.
DAILIES TOTAL 1 for ASTIGMATISM (delefilcon A) soft contact leases are indicated for the optical correction of refractive ametropia (myopia and hyperopia) in phakic persons with non-diseased eves with up to 6.00 diopters (D) of astigmatism.
DAILIES TOTAL 1 Multifocal (delefilcon A) soft contact lenses are indicated for the optical correction of presbyopia, with or without refractive ametropia (myopia and hyperopia) in phakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters (D) or less and who may have up to approximately 1.50 diopters (D) of astigmatism that does not interfere with visual acuity.
DAILIES TOTAL 1 Multifocal Toric (delefilcon A) soft contact lenses are indicated for the optical correction of presbyopia with or without refractive ametropia (myopia, in phakic or aphakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters (D) or less and who may have up to 6.00 diopters (D) of astigmatism.
The lenses are to be used for single use, daily disposable wear (less than 24 hours while awake) only. The lenses are not intended to be cleaned or disinfected and should be discarded after a single use.
| 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) |
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# 510(k) Summary
This 510(k) summary document has been prepared in accordance with section 21 CFR 807.92.
#### Submitter of the 510(k) I.
| Company: | | Alcon Laboratories, Inc. | |
|-------------------------|--|--------------------------------|--|
| | | 6201 South Freeway | |
| | | Fort Worth, TX 76134-2099, USA | |
| Primary Contact Person: | | Martina Heim, Ph.D., RAC | |
| Phone: | | (678) 415-3565 | |
| Fax: | | n/a | |
| Email: | | Martina.Heim@alcon.com | |
| Back up Contact Person: | | Sherri Lakota | |
| Phone: | | (817) 615-5472 | |
| Fax: | | 817-302-4574 | |
| Email: | | Sherri.Lakota@alcon.com | |
| Date Prepared: | | 17 December 2018 | |
# II. Devices Subject to this 510(k)
| Trade Names: | DAILIES TOTAL1® soft contact lenses:<br>DAILIES TOTAL1®, DAILIES TOTAL1® Asphere,<br>DAILIES TOTAL1® for ASTIGMATISM, DAILIES<br>TOTAL1® Multifocal, DAILIES TOTAL1® Multifocal<br>Toric<br>Alternate family trade name: DAILIES TOTAL1® PRO |
|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | Soft contact lens |
| Classification Name: | Soft (hydrophilic) contact lens [for daily wear] |
| Device Classification: | 21 CFR 886.5925 (b) (1) |
| Product Code: | LPL, MVN |
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### III. Predicate Device
The subject device is a modification of the currently commercialized DAILIES TOTAL 10 (delefilcon A) soft contact lens. The predicate DAILIES TOTAL1 soft contact lenses have received FDA clearance per Premarket Notification 510(k) K113168, with recent updates cleared under K180398 and K180669.
## IV. Device Description
The DAILIES TOTAL 1® family of daily disposable soft contact lenses are made from delefilcon A, a silicone hydrogel with a water content of approximately 33% and a water gradient surface treatment. The delefilcon A silicone hydrogel material is considered a Group 5C material according to ISO 18369-1:2017 (defined as: "enhanced oxygen permeable material", water content less than 50%, no ionic monomer or oligomer at pH 6 to pH 8).
Modified DAILIES TOTAL1® lenses contain a combination of light absorbing chromophores. Specifically, benzotriazole UV absorbing monomers are used to block UV radiation and, additionally, reduce transmittance in the range from 380 nm. The color additive [phthalocyaninato (2-)] copper (synonym: copper phthalocyanine) provides a light blue-green handling tint.
Lens designs for the modified DAILIES TOTALI® (delefilcon A) lenses include spherical, asphere, toric, multifocal, and multifocal toric lenses in the following parameter range:
- 13.0 to 15.0 mm . Diameter Range:
| • Base Curve Range: | 8.0 to 9.2 mm |
|---------------------|------------------------------|
| • Power Range: | -20.00D to +20.00D |
| • Center Thickness: | varies with design and power |
- (0.09 mm for -3.00D spherical)
Lenses have the following properties:
| • Refractive index: | 1.42 (hydrated) |
|-----------------------|-------------------------------------------------------|
| • Water content: | 33% by weight in normal saline |
| • Oxygen permeability | 140 barrer units |
| | measured at 35 °C (intrinsic Dk - Coulometric method) |
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- % Light transmittance, visible: 90 ± 5% (average over 380 to 780 nm) . UVA (315-380 nm): < 10.0% % UV transmittance . UVB (280-315 nm): < 1.0%
Lenses are supplied sterile in sealed blister packs containing isotonic phosphate buffered saline solution (PBS) with polymeric wetting agents that form the water gradient surface. The compatibility and package integrity of the blister pack packaging system has been demonstrated and successfully used for other marketed lens products, and packaged lenses are effectively steam sterilized in a validated autoclave. Blister pack containers are labeled with the lens parameters, lot number and product expiration date. The expiration date has been established through stability studies that have assessed the chemical stability of the lens and package integrity (ability to maintain sterility). Shelf-life studies are ongoing to further extend the labeled expiration date.
#### V. Indications for Use
DAILIES TOTAL1 (delefilcon A) and DAILIES TOTAL1 Asphere (delefilcon A) soft contact lenses are indicated for the optical correction of refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased eyes with up to approximately 1.50 diopters (D) of astigmatism that does not interfere with visual acuity.
DAILIES TOTAL1 for ASTIGMATISM (delefilcon A) soft contact lenses are indicated for the optical correction of refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased eyes with up to 6.00 diopters (D) of astigmatism.
DAILIES TOTAL1 Multifocal (delefilcon A) soft contact lenses are indicated for the optical correction of presbyopia, with or without refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters (D) or less and who may have up to approximately 1.50 diopters (D) of astigmatism that does not interfere with visual acuity.
DAILIES TOTAL1 Multifocal Toric (delefilcon A) soft contact lenses are indicated for the optical correction of presbyopia with or without refractive ametropia (myopia, hyperopia) in phakic or aphakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters (D) or less and who may have up to 6.00 diopters (D) of astigmatism.
3
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The lenses are to be used for single use, daily disposable wear (less than 24 hours while awake) only. The lenses are not intended to be cleaned or disinfected and should be discarded after a single use.
# VI. Comparison to Technological Characteristics with the Predicate Device
Table 5-1 summarizes the characteristics of the modified device compared to the predict devices:
| | Predicate Device | Subject Device |
|----------------------------|---------------------------------------------------------------------------|------------------------------------------------------------|
| Trade Name (brand) | DAILIES TOTAL1® | DAILIES TOTAL1® |
| Submission Number | K113168 | 510(k) # to be assigned |
| Device Classification Name | Daily Wear Soft Contact Lens<br>21 CFR 886.5925 (b)(1) | Daily Wear Soft Contact Lens<br>21 CFR 886.5925 (b)(1) |
| Intended Use | Vision correction | Same |
| Wearing Schedule | Daily wear | Same |
| Replacement Schedule | Daily disposable | Same |
| Material Classification | Group 5C, low water silicone<br>hydrogel according to<br>ISO 18369-1:2017 | Same |
| Lens Material | Delefilcon A | Same |
| Surface Treatment | Water gradient surface treatment | Same |
| Manufacturing Method | LightStream (molded) | Same |
| Visibility Tint | [phthalocyaninato (2-)] copper | Same |
| Lens marks | none | Molded lens marks (e.g. fiducial<br>mark for toric lenses) |
| Lens Designs | Spherical, toric, multifocal,<br>multifocal toric | Spherical, asphere, toric, multifocal,<br>multifocal toric |
Table 5-1 Substantial Equivalence Comparison
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| | Predicate Device | Subject Device |
|------------------------------------|--------------------------------------------------------------------------------------|----------------|
| Power Range | +20.00 to -20.00D | Same |
| Base Curve Range | 8.0 to 9.2 mm | Same |
| Diameter Range | 13.0 to 15.0 mm | Same |
| Water Content | 33% | Same |
| Refractive Index | 1.42 | Same |
| Oxygen<br>Permeability | 140 barrer units* | Same |
| Sterilization | Steam sterilization, validated<br>autoclave | Same |
| Packaging | Polypropylene blister shell sealed<br>with polyester coated aluminum<br>foil lidding | Same |
| Package Storage<br>Saline Solution | Phosphate buffered saline (PBS)<br>with polymeric wetting agents | Same |
* 1 barrer = x 10 -11 (cm2/sec)(ml O2 /ml x mm Hg)
#### Performance Data VII.
Performance testing was performed in accordance with the May 1994 FDA guideline, Premarket Notification 510(k) Guidance Document for Daily Wear Contact Lenses, and applicable ISO standards for contact lenses. Performance data are provided in support of the substantial equivalence determination.
#### Non-clinical Testing
A series of non-clinical testing was performed to characterize the lens material properties of the modified DAILIES TOTAL1® lenses and demonstrate the substantial equivalence of the modified device to the predicate device. Light transmittance properties (incl. UV and UV-Vis) are supported by testing in accordance with ISO 18369-3:2017. Non-clinical biocompatibility testing was conducted in accordance with the GLP regulation (21 CFR Part 58). All biocompatibility testing was conducted in accordance with the GLP regulation (21 CFR Part 58) and relevant ISO 10993 series biocompatibility standards.
The results of all non-clinical testing demonstrate:
{8}------------------------------------------------
- . Physicochemical characteristics of the modified device are substantially equivalent to the predicate lens, currently commercialized DAILIES TOTAL 1® lenses.
- The lens material, lens extracts and package saline of the device are non-toxic, non-irritating, non-sensitizing, and non-genotoxic.
- Successful stability testing supports the labeled expiration date. .
#### Clinical Testing
The scope of the device modification did not require clinical testing to establish safety and effectiveness of the modified device. The claim of substantial equivalence to a lens with an existing USAN and the same manufacturing process is supported by the pre-clinical testing summarized above.
## VIII. Conclusions
DAILIES TOTAL1® (delefilcon A) soft contact lenses as modified are substantially equivalent to the predicate device lenses, DAILIES TOTAL1, and similar to other daily wear soft contact lenses in terms of technological characteristics and intended use.
Non-clinical data demonstrates that the modified device is as safe, as effective, and performs as well as or better than the legally marketed, predicate device, unmodified DAILIES TOTAL1 soft contact lenses.
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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.
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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.
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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.
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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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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.