K191558 · Konan Medical, Inc. · NQE · Mar 26, 2020 · Ophthalmic
Device Facts
Record ID
K191558
Device Name
Konan Specular Microscope XVII
Applicant
Konan Medical, Inc.
Product Code
NQE · Ophthalmic
Decision Date
Mar 26, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 886.1850
Device Class
Class 2
Indications for Use
The Konan Specular Microscope XVII, CellChek 20, is a non-contact ophthalmic microscope, optical pachymeter, and camera intended for examination of the corneal endothelium and for measurement of the thickness of the cornea.
Device Story
The Konan Specular Microscope XVII (CellChek 20) is a non-contact ophthalmic device that captures images of the corneal endothelium and measures corneal thickness. It uses infrared-based auto-focusing and alignment to capture reflected light from the patient's eye. The device features a 3-axis mechanical alignment system (X, Y, Z). It provides computer-assisted cell counting and analysis, calculating corneal endothelial cell density (CD), coefficient of variation (CV), and hexagonality (HEX). The device is operated by ophthalmic staff in a clinical setting. The user interacts with a touch screen to perform manual analysis (placing dots or tracing boundaries) or utilizes automated algorithms. Output is displayed on the monitor and can be printed. The device aids clinicians in assessing corneal health by providing quantitative endothelial metrics, which support clinical decision-making regarding corneal function.
Clinical Evidence
A prospective clinical study of 80 subjects (65.6 years mean age) compared the subject device against the reference device (NONCON ROBO PACHY F&A). Primary endpoints were agreement, accuracy, and precision of CD, CV, and HEX. Results showed strong positive correlations between the subject device and reference device across center and peripheral corneal areas. Precision (repeatability/reproducibility) of the subject device was found to be superior or equivalent to the reference device. No adverse events were reported.
Technological Characteristics
Non-contact ophthalmic microscope/pachymeter. Materials: ABS resin (forehead/chin rests). Alignment: 3-axis (X, Y, Z). Energy: 100-240VAC, 50/60Hz. Connectivity: Touch screen display, printer output. Software: CellChek analysis program for endothelial cell metrics. Biocompatibility: Proven via ABS resin usage.
Indications for Use
Indicated for examination of the corneal endothelium and measurement of corneal thickness in patients requiring ophthalmic assessment.
Regulatory Classification
Identification
An AC-powered slitlamp biomicroscope is an AC-powered device that is a microscope intended for use in eye examination that projects into a patient's eye through a control diaphragm a thin, intense beam of light.
Special Controls
*Classification.* Class II (special controls). The device, when it is intended only for the visual examination of the anterior segment of the eye, is classified as Group 1 per FDA-recognized consensus standard ANSI Z80.36, does not provide any quantitative output, and is not intended for screening or automated diagnostic indications, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 886.9.
Predicate Devices
Konan Specular Microscope XIV, CellChek Plus (K120264)
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March 26, 2020
Konan Medical, Inc. % Alan Donald President Matrix Medical Consulting Inc 8880 Rio San Diego Drive Suite 800 San Diego, California 92108
Re: K191558
Trade/Device Name: Konan Specular Microscope XVII Regulation Number: 21 CFR 886.1850 Regulation Name: AC-Powered Slitlamp Biomicroscope Regulatory Class: Class II Product Code: NQE Dated: February 12, 2020 Received: February 18, 2020
Dear Alan Donald:
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.
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
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device 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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Elvin Ng Acting Assistant Director DHT1A: Division of Ophthalmic Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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| DEPARTMENT OF HEALTH AND HUMAN SERVICES | |
|--------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Food and Drug Administration | |
| | Form Approved: OMB No. 0910-0120 |
| | Expiration Date: 06/30/2020 |
| Indications for Use | |
| | See PRA Statement below. |
| 510(k) Number (if known) | K191558 |
| Device Name | Konan Specular Microscope XVII |
| Indications for Use (Describe) | The Konan Specular Microscope XVII, CellChek 20, is a non-contact ophthalmic microscope, optical pachymeter, and camera intended for examination of the corneal endothelium and for measurement of the thickness of the cornea. |
| Type of Use (Select one or both, as applicable) | |
| <label><input checked="checked" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D)</label> | <label><input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C)</label> |
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# 510(k) Summary
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The following 510(k) Summary is being submitted in accordance with the requirements of SMDA 1990 and CFR 807.92.
# 510(k) Summary
# Submitter Information
| A. Company Name: | Konan Medical, Inc. |
|---------------------------|-----------------------------------------------------------|
| B. Company Address: | 10-29, Miyanishicho, Nishinomiya<br>Hyogo 662-0976, Japan |
| C. Company Phone: | +81-798-36-3456 |
| D. Company facsimile: | +81-798-26-1028 |
| E. Contact Person: | Tatsuya Kasahara |
| F. Date Summary Prepared: | March 23, 2020 |
# Device Identification
| A. Device Trade Name: | Konan Specular Microscope XVII, CellChek 20 |
|----------------------------------|---------------------------------------------|
| B. Common Name: | Specular Microscope |
| C. Classification Name(s): | AC-powered Slit Lamp Biomicroscope |
| D. Classification Regulation(s): | 886.1850 |
| E. Device Class: | Class 2 |
| F. Product Codes: | NQE |
| G. Advisory Panel: | Ophthalmic |
# Identification of Predicate Device
The predicate device is the Konan Specular Microscope XIV, CellChek Plus, which was cleared by FDA under 510(k) number K120264 on April 11, 2012. In addition, the company has utilized the NONCON ROBO PACHY F&A, K062763, as a reference device.
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# Device Description
The Konan Specular Microscope XVII, CellChek 20, is a non-contact ophthalmic microscope, optical pachymeter, and camera intended for examination of corneal endothelium and for measurement of the thickness of the cornea. Cell counting and analysis program are included, and allow for analysis of the images of the cell distribution of the eye.
When photographing the corneal endothelium, the device performs the alignment and automatically focuses by capturing the reflected light from patient's eye with the camera. The device permits visual inspection and photography of the corneal endothelium and measurement of the corneal thickness without any object contacting the eye. It features focusing by means of infrared techniques, as well as computer-assisted cell counting and cell analysis capabilities. The computer functions are also used to aid in setting up the various features of the machine and to aid in photography. Photographic images are temporarily stored in the system's memory and can be preserved by using a printer.
Both the image of the corneal endothelium and the various computerized control functions are displayed on the touch screen monitor.
The parts of the device that come into contact with a patient are the forehead rest and the chin rest. Their material is acrylonitrile butadiene styrene (ABS), the same material used in reference device and one with proven biocompatibility.
The function of the software installed in the device is to calculate mainly the cell density, the coefficient of variation of cell area and the percent hexagonality. In the manual methods, Actual identification if the cells and cell boundaries is done by the (physician) user. In the automatic method, the software detects the cells and cell boundaries, however, the user is given the opportunity to make corrections. In use, the user interacts with the software by visually placing dots in the center of cells as or by tracing cell boundaries as they appear or on a screen or uses the automatic algorithm.
### Indication for Use
The Konan Specular Microscope XVII, CellChek 20, is a non-contact ophthalmic microscope, optical pachymeter, and camera intended for examination of the corneal endothelium and for measurement of the thickness of the cornea.
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# Technological Characteristics
The Konan Specular Microscope XVII, CellChek 20, is technically equivalent to the Konan specular Microscope XIV, CellChek Plus. One of the principal design modifications for the device is that the mechanical unit used for alignment has changed. The mechanical unit of CellChek 20 has only three axes which work for X (right - left) - Y (up - down) - Z (forward - backward) alignment between the optics and a patient's eye. Therefore the patient needs to fixate on a peripheral target to obtain an image of endothelial cells at the peripheral position over the cornea. Another of the principal design modifications for the device is that the data analysis method has changed. The data analysis of CellChek 20 method consists of the Trace method with/without Auto-trace (which does not need to input parameter S, M, L or XL for analysis), the Center method with/without Auto-input (which uses the same algorithm as Auto-trace) and the Flex Center method with/without Auto-input (which uses the same algorithm as Auto-trace). A smaller CPU board (mother board) was implemented, and a new computer program was installed for the mechanical system and the data analysis system of CellChek 20.
| Comparative table between CellChek Plus and CellChek 20 | | | |
|---------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Model name | CellChek Plus | CellChek 20 | Comparison |
| 510(k) No. | K120264 | To Be Assigned by<br>FDA | |
| Device name<br>registered | Konan Specular<br>Microscope XIV | Konan Specular<br>Microscope XVII | |
| Intended use | The device is a<br>non-contact<br>ophthalmic<br>microscope, optical<br>pachymeter, and<br>camera intended for<br>examination of the<br>corneal endothelium<br>and for measurement<br>of the thickness of the | The device is a<br>non-contact<br>ophthalmic<br>microscope, optical<br>pachymeter, and<br>camera intended for<br>examination of the<br>corneal endothelium<br>and for measurement<br>of the thickness of | Same |
| | cornea. | the cornea. | |
| Composition | The device is<br>composed of the<br>optical unit, the<br>mechanical unit, the<br>electrical unit and the<br>display. | The device is<br>composed of the<br>optical unit, the<br>mechanical unit and<br>the power unit which<br>includes the electrical<br>unit and the display. | Different on expression.<br>No safety/effectiveness<br>concern. |
| Appearance | Image: Slit lamp | Image: Slit lamp | Different.<br>No safety/effectiveness<br>concern. |
| Size | 683(H) x 365(W) x<br>451(D) mm | 451(H) x 310(W) x<br>459(D) mm | Different.<br>No safety/effectiveness<br>concern. |
| Electric rating | Voltage: 100-230VAC<br>Frequency: 50/60Hz,<br>Power: 150VA | Voltage:<br>100-240VAC<br>Frequency: 50/60Hz<br>Power: 100VA | Almost same<br>No safety/effectiveness<br>concern. |
| Class (Electrical<br>Safety) | Class I<br>Type B applied part | Class I<br>Type B applied part | Same |
| Operating<br>Principle | The photographing<br>the corneal<br>endothelium, the<br>device performs the<br>alignment and<br>automatically focuses<br>by capturing the<br>reflected light from the<br>patient's eye with the<br>camera. | The photographing<br>the corneal<br>endothelium, the<br>device performs the<br>alignment and<br>automatically<br>focuses by capturing<br>the reflected light<br>from the patient's eye<br>with the camera. | Different on axes.<br>No safety/effectiveness<br>concern. |
| | | | |
| | The alignment is<br>performed by 5 axes<br>which are X (back and<br>forth), Y (right and<br>left), Z (up and down)<br>θX (horizontal turn)<br>and θY (vertical turn). | The alignment is<br>performed by 3 axes<br>which are X (back<br>and forth), Y (right<br>and left) and Z (up<br>and down). | |
| Photographed<br>Area | 0.24 x 0.46 mm² | 0.25 x 0.55 mm² | Almost same.<br>No safety/effectiveness<br>concern. |
| Analysis<br>method | CellChek software:<br>Corner method<br>Auto trace method<br>Center method<br>----------<br>Flex Center method<br>---------- | CellChek software:<br>Trace method<br>Auto Trace method<br>Center method<br>Auto Center<br>method<br>F Center method<br>Auto F Center<br>method | Different (Algorithm of<br>Trace method, Center<br>method and F center<br>method has not<br>changed).<br>No safety/effectiveness<br>concern.<br>• Nomenclature was<br>changed "Corner<br>method" to "Trace<br>method" and "Flex<br>Center method" to<br>"F Center method".<br>• The Auto trace<br>method does not<br>need to input<br>parameter S, M, L<br>or XL for analysis.<br>• "Auto Center<br>method" and "Auto<br>F Center method"<br>were added. They<br>use the same |
| Materials of<br>Patient<br>Contacting<br>Parts | PTFE (forehead rest)<br>and ABS resin (chin<br>rest) | ABS resin (forehead<br>rest and chin rest) | algorithm of “Auto<br>Trace method” and<br>the center point of<br>the endothelial cell<br>is calculated as the<br>gravity point of the<br>endothelial cell by<br>“Auto Trace<br>method”.<br><br>Different.<br>No safety/effectiveness<br>concern.<br>Material of<br>forehead rest was<br>changed to the<br>same material of<br>chin rest. |
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# Summary of Testing
- A. Non Clinical Testings
The following testing was performed on the Konan Specular Microscope XVII, CellChek 20:
- The CellChek 20 device was subjected to electrical safety testing in accordance with ANSI/AAMI ES 60601-1.
- The CellChek 20 device was subjected to electromagnetic compatibility (EMC) testing in accordance with IEC 60601-1-2.
- The CellChek 20 device was subjected to performance testing in accordance with ISO 15004-1.
- The CellChek 20 device was subjected to optical radiation safety testing in accordance with ANSI Z80.36.
- The CellChek 20 device was subjected to software validation testing in accordance with IEC 62304.
### Performance Testing - Clinical
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A prospective clinical study was conducted to assess the agreement, accuracy, and precision of the Konan Specular Microscope XVII, CellChek 20 by comparing the analytical results obtained with the NONCON ROBO PACHY F&A, a reference device, and also the predicate device for the Konan Specular Microscope XIV, CellChek Plus. This clinical performance testing includes the assessment of the agreement, accuracy, and precision of each of the 6 analysis methods, Trace Method, Auto Trace Method, Center Method, Auto Center Method, Flex Center Method, and Auto Flex Center Method of Konan Specular Microscope XVII, CellChek 20 by comparing with Center Method of NONCON ROBO PACHY F&A.
The examinees are all of the patients who came to the ophthalmic clinic, which has agreed to cooperate with this study, after the study start date. Some of the ophthalmic staffs basically photographed the right eyes of the examinees with Konan Specular Microscope XVII, CellChek 20 and NONCON ROBO PACHY F&A. However, when their right eyes could not be clearly photographed, the left eyes were photographed. Three analysts analyzed the examinees' images with each of the 6 methods, Center Method, Auto Center Method, Trace Method, Auto Trace Method, Flex Center Method, Auto Flex Center Method, of CellChek 20, and Center Method of F&A.
This study protocol pre-described criteria for the agreement limits is that the analysis result of each of the methods of CellChek 20 has a positive correlation with that of Center Method of F&A.
The mean (SD) age of the 80 subjects, whose breakdown was 55 females and 25 males, of this study was 65.6 (10.8) years.
No adverse events occurred in any examinees during this study. Additionally, no other safety issues of any kinds arose from the subject device and the reference device. The instruments of both of the devices were found to be safe and reliable in the assessment of corneal function.
The primary efficiency endpoints are the agreement and precision of the 3 variables, that is, Corneal Endothelial Cell Density, Coefficient of Variation, and Hexagonality (hereinafter mentioned as CD, CV, and HEX, respectively). The discussion on the results of this performance testing is shown as follows.
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l. Agreement/Accuracy Analysis (Comparison between subject device and reference device)
- 1) Cornea Measuring Area: Center Area
Analysis Method: Center Method of Subject Device and Reference Device
Table 1 Three Corneal Specular Microscopic Variables Assessed with Center Method of Subject Device and Reference Device – Center area
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|--------------------------------------------------------------|----------------------|-----------------|-------------------|
| NONCON ROBO PACHY F&A (Reference Device) | | | |
| Average (SD) | 2717.1 (486.74) | 33.8 (5.12) | 58.1 (7.42) |
| Median | 2738.5 | 33.0 | 58.3 |
| Min - Max | 849 - 3937 | 25 - 56 | 37 - 77 |
| Konan Specular Microscope XVII, CellChek 20 (Subject Device) | | | |
| Average (SD) | 2932.7 (527.83) | 34.0 (5.73) | 59.9 (7.05) |
| Median | 2915.9 | 33.2 | 59.9 |
| Min - Max | 816 - 4532 | 25 - 52 | 40 - 74 |
| Device Comparisons | | | |
| Average Difference (SD) | 215.6 (151.15) | 0.3 (3.85) | 1.8 (7.27) |
| Average Difference (SD) as<br>a % of F&A reading | 7.94% (5.563%) | 0.74% (11.403%) | 3.08% (12.523%) |
| 95% LOA | (-86.7, 517.9) | (-7.5, 8.0) | (-12.8, 16.3) |
| Correlation (R²) | 0.9193 | 0.5677 | 0.2460 |
| Deming Regression<br>Intercept (95% CI) | 107.6 (105.8, 109.4) | 5.5 (3.6, 7.5) | 32.5 (30.6, 34.5) |
| Deming Regression Slope<br>(95% CI) | 1.0 (1.0, 1.0) | 0.8 (0.8, 0.9) | 0.5 (0.4, 0.5) |
Abbreviations: CD = corneal endothelial cell density; CI = confidence interval; CV = coefficient of
variation; HEX = hexagonality; LOA = limits of agreement; SD = standard deviation
The average differences were calculated as (Konan Specular Microscope XVII, CellChek 20) -
(NONCON ROBO PACHY F&A).
The average differences as a % of NONCON ROBO PACHY F&A reading were calculated by dividing the average differences with the averages of the reference device.
The 95% LOA's were calculated as the average differences +/- 2SD's.
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a) CD
Corneal endothelial cell density as measured with the subject device had the average (SD) of 2932.7 (527.83) compared with those of 2717.1 (486.74) for the reference device. The average difference (SD) were 215.6 (151.15).
The Deming regression lines had the associated R2 value of 0.9193.
b)
Coefficient of Variation as measured with the subject device had the average (SD) of 34.0 (5.73) compared with those of 33.8 (5.12) for the reference device. The average difference (SD) were 0.3 (3.85).
The Deming regression lines had the associated R2 value of 0.5677.
### c)
Percent of Hexagonality as measured with the subject device had the average (SD) of 59.9 (7.05) compared with those of 58.1 (7.42) for the reference device. The average difference (SD) were 1.8 (7.27).
The Deming regression lines had the associated R2 value of 0.2460.
#### 2) Cornea Measuring Area: Peripheral Area
Analysis Method: Center Method of Subject Device and Reference Device
| | | Table 2 Three Corneal Specular Microscopic Variables Assessed with Center Method of Subject | | | | |
|--|--|---------------------------------------------------------------------------------------------|--|--|--|--|
| | | Device and Reference Device – Peripheral Area | | | | |
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|--------------------------------------------------------------|-----------------|-----------------|-----------------|
| NONCON ROBO PACHY F&A (Reference Device) | | | |
| Average (SD) | 2782.4 (464.10) | 33.5 (5.25) | 58.8 (6.98) |
| Median | 2825.0 | 32.9 | 59.0 |
| Min – Max | 884 - 3802 | 23 - 55 | 34 - 76 |
| Konan Specular Microscope XVII, CellChek 20 (Subject Device) | | | |
| Average (SD) | 2969.5 (507.65) | 34.4 (6.36) | 59.8 (6.00) |
| Median | 3007.5 | 33.7 | 59.9 |
| Min – Max | 904 - 4021 | 25 - 61 | 42 - 71 |
| Device Comparisons | | | |
| Average Difference (SD) | 187.1 (144.61) | 0.8 (4.57) | 1.0 (7.28) |
| Average Difference (SD) as<br>a % of F&A reading | 6.72% (5.197%) | 2.46% (13.642%) | 1.67% (12.375%) |
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510(k) Summary – Konan Specular Microscope XVII, CellChek 20
| 95% LOA | (-102.1, 476.3) | (-8.3, 10.0) | (-13.6, 15.5) |
|-----------------------------------------|-------------------|----------------|-------------------|
| Correlation (R2) | 0.9209 | 0.4974 | 0.1439 |
| Deming Regression<br>Intercept (95% CI) | 48.8 (46.9, 50.8) | 5.7 (3.8, 7.6) | 40.6 (38.6, 42.6) |
| Deming Regression Slope<br>(95% CI) | 1.0 (1.0, 1.1) | 0.9 (0.8, 0.9) | 0.3 (0.3, 0.4) |
Abbreviations: CD = corneal endothelial cell density; CI = confidence interval; CV = coefficient of
variation; HEX = hexagonality; LOA = limits of agreement; SD = standard deviation
The average differences were calculated as (Konan Specular Microscope XVII, CellChek 20) -
(NONCON ROBO PACHY F&A).
The average differences as a % of NONCON ROBO PACHY F&A reading were calculated by dividing the average differences with the averages of the reference device.
The 95% LOA's were calculated as the average differences +/- 2SD's.
#### a) CD
Corneal endothelial cell density as measured with the subject device had the average (SD) of 2969.5 (507.65) compared with those of 2782.4 (464.10) for the reference device. The average difference (SD) were 187.1 (144.61).
The Deming regression lines had the associated R2 value of 0.9209.
# b)
Coefficient of Variation as measured with the subject device had the average (SD) of 34.4 (6.36) compared with those of 33.5 (5.25) for the reference device. The average difference (SD) were 0.8 (4.57).
The Deming regression lines had the associated R2 value of 0.4974.
# c) HEX
Percent of Hexagonality as measured with the subject device had the average (SD) of 59.8 (6.00) compared with those of 58.8 (6.98) for the reference device. The average difference (SD) were 1.0 (7.28).
The Deming regression lines had the associated R2 value of 0.1439.
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- II. Agreement/Accuracy Analysis (Comparison between Center Method vs Trace Method, Auto Trance Method, Auto Center Method, Flex Center Method, and Auto Flex Center Method of Subject Device (Konan Specular Microscope XVII, CellChek 20))
- a) Corneal Measuring Area: Center Area Analysis Method: Center Method vs Trace Method of Subject Device
Table 3 Three Corneal Specular Microscopic Variables Assessed with Two Analysis Methods -Center Method vs Trace Method – Center Area
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|-----------------------------------------------------------------------------------------------------|----------------------|--------------------|------------------|
| Center Method | | | |
| Average (SD) | 2932.7 (527.83) | 34.0 (5.73) | 59.9 (7.05) |
| Median | 2915.9 | 33.2 | 59.9 |
| Min – Max | 816 - 4532 | 25 - 52 | 40 - 74 |
| Trace Method | | | |
| Average (SD) | 2931.7 (531.31) | 29.5 (7.68) | 57.4 (7.78) |
| Median | 2897.5 | 28.5 | 58.4 |
| Min – Max | 820 - 4565 | 17 - 52 | 38 - 73 |
| Method Comparisons | | | |
| Average Difference (SD) | -1.0 (28.00) | -4.5 (4.13) | -2.4 (3.39) |
| Average Difference (SD) as<br>a % of Center Method<br>reading | -0.03% (0.955%) | -13.34% (12.132%) | -4.06% (5.671%) |
| 95% LOA | (-57.0, 55.0) | (-12.8, 3.7) | (-9.2, 4.4) |
| Correlation (R2) | 0.9973 | 0.7215 | 0.8097 |
| Deming Regression<br>Intercept (95% CI) | -16.3 (-18.1, -14.5) | -9.2 (-11.3, -7.2) | -2.0 (-4.7, 0.7) |
| Deming Regression Slope<br>(95% CI) | 1.0 (1.0, 1.0) | 1.1 (1.1, 1.2) | 1.0 (0.9, 1.0) |
| Abbreviations: CD = corneal endothelial cell density; Cl = confidence interval; CV = coefficient of | | | |
| variation; HEX = hexagonality; LOA = limits of agreement; SD = standard deviation | | | |
The average differences were calculated as (Trace Method) - (Center Method).
The average differences as a % of Center Method reading were calculated by dividing the average differences with the averages of Center Method.
The 95% LOA's were calculated as the average differences +/- 2SD's.
{15}------------------------------------------------
(i) CD
> Corneal endothelial cell density as measured with Trace Method had the average (SD) of 2931.7 (531.31) compared with those of 2932.7 (527.83) for Center Method. The average difference (SD) were -1.0 (28.00).
The Deming regression lines had the associated R2 value of 0.9973.
- CV (ii)
Corneal endothelial cell density as measured with Trace Method had the average (SD) of 29.5 (7.68) compared with those of 34.0 (5.73) for Center Method. The average difference (SD) were -4.5 (4.13).
The Deming regression lines had the associated R2 value of 0.7215.
- (iii) HEX
Corneal endothelial cell density as measured with Trace Method had the average (SD) of 57.4 (7.78) compared with 59.9 (7.05) for those of Center Method. The average difference (SD) were -2.4 (3.39).
The Deming regression lines had the associated R2 value of 0.8097.
#### b) Cornea Measuring Area: Center Area
Analysis Method: Center Method vs Auto Trance Method of Subject Device
Table 4 Three Corneal Specular Microscopic Variables Assessed with Two Analysis Methods -Center Method vs Auto Trance Method - Center Area
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|----------------------------------------------------|-----------------|-------------------|-----------------|
| Center Method | | | |
| Average (SD) | 2932.7 (527.83) | 34.0 (5.73) | 59.9 (7.05) |
| Median | 2915.9 | 33.2 | 59.9 |
| Min – Max | 816 - 4532 | 25 - 52 | 40 - 74 |
| Auto Trace Method | | | |
| Average (SD) | 2756.1 (430.05) | 19.5 (4.34) | 59.5 (6.51) |
| Median | 2816.0 | 19.0 | 60.0 |
| Min – Max | 900 - 3475 | 11 - 35 | 38 - 73 |
| Device Comparisons | | | |
| Average Difference (SD) | -176.6 (213.31) | -14.5 (3.77) | -0.3 (5.80) |
| Average Difference (SD) as<br>a % of Center Method | -6.02% (7.273%) | -42.67% (11.065%) | -0.58% (9.695%) |
{16}------------------------------------------------
510(k) Summary – Konan Specular Microscope XVII, CellChek 20
| reading | | | |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------|-----------------|-------------------|
| 95% LOA | (-603.3, 250.0) | (-22.1, -7.0) | (-12.0, 11.3) |
| Correlation (R2) | 0.8479 | 0.5682 | 0.4050 |
| Deming Regression Intercept (95% CI) | 555.8 (554.2, 557.4) | 0.1 (-1.5, 1.6) | 24.3 (22.1, 26.5) |
| Deming Regression Slope (95% CI) | 0.8 (0.7, 0.8) | 0.6 (0.5, 0.6) | 0.6 (0.6, 0.6) |
| Abbreviations: CD = corneal endothelial cell density; CI = confidence interval; CV = coefficient of variation; HEX = hexagonality; LOA = limits of agreement; SD = standard deviation | | | |
| The average differences were calculated as (Auto Trace Method) - (Center Method). | | | |
| The average differences as a % of Center Method reading were calculated by dividing the average differences with the averages of Center Method. | | | |
| The 95% LOA's were calculated as the average differences +/- 2SD's. | | | |
#### CD (i)
Corneal endothelial cell density as measured with Auto Trace Method had the average (SD) of 2756.1 (430.05) compared with those of 2932.7 (527.83) for Center Method. The average difference (SD) were -176.6 (213.31).
The Deming regression lines had the associated R2 value of 0.8479.
#### (ii) CV
Corneal endothelial cell density as measured with Auto Trace Method had the average (SD) of 19.5 (4.34) compared with those of 34.0 (5.73) for Center Method. The average difference (SD) were -14.5 (3.77).
The Deming regression lines had the associated R2 value of 0.5682.
- HEX (iii)
Corneal endothelial cell density as measured with Auto Trace Method had the average (SD) of 59.5 (6.51) compared with those of 59.9 (7.05) for Center Method. The average difference (SD) were -0.3 (5.80).
The Deming regression lines had the associated R2 value of 0.4050.
{17}------------------------------------------------
#### c) Cornea Measuring Area: Center Area
Analysis Method: Center Method vs Auto Center Method of Subject Device
Table 5 Three Corneal Specular Microscopic Variables Assessed with Two Analysis Method -Center Method vs Auto Center Method – Center Area
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|---------------------------------------------------------------|----------------------|----------------|-------------------|
| Center Method | | | |
| Average (SD) | 2932.7 (527.83) | 34.0 (5.73) | 59.9 (7.05) |
| Median | 2915.9 | 33.2 | 59.9 |
| Min - Max | 816 - 4532 | 25 - 52 | 40 - 74 |
| Auto Center Method | | | |
| Average (SD) | 2777.7 (433.55) | 34.3 (5.83) | 59.8 (6.96) |
| Median | 2828.0 | 34.5 | 60.0 |
| Min - Max | 921 - 3434 | 24 - 55 | 36 - 71 |
| Device Comparisons | | | |
| Average Difference (SD) | -155.0 (210.98) | 0.3 (3.39) | -0.1 (4.67) |
| Average Difference (SD) as<br>a % of Center Method<br>reading | -5.29% (7.194%) | 0.75% (9.966%) | -0.16% (7.796%) |
| 95% LOA | (-577.0, 266.9) | (-6.5, 7.0) | (-9.4, 9.2) |
| Correlation (R2) | 0.8504 | 0.6854 | 0.6055 |
| Deming Regression<br>Intercept (95% CI) | 556.3 (554.7, 557.9) | 5.6 (3.9, 7.4) | 13.8 (11.4, 16.2) |
| Deming Regression Slope<br>(95% CI) | 0.8 (0.8, 0.8) | 0.8 (0.8, 0.9) | 0.8 (0.7, 0.8) |
The average differences as a % of Center Method reading were calculated by dividing the average differences with the averages of Center Method.
The 95% LOA's were calculated as the average differences +/- 2SD's.
{18}------------------------------------------------
CD (i)
> Corneal endothelial cell density as measured with Auto Center Method had the average (SD) of 2777.7 (433.55) compared with those of 2932.7 (527.83) for Center Method. The average difference (SD) were -155.0 (210.98).
The Deming regression lines had the associated R2 value of 0.8504.
- CV (ii)
Corneal endothelial cell density as measured with Auto Center Method had the average (SD) of 34.3 (5.83) compared with those of 34.0 (5.73) for Center Method. The average difference (SD) were 0.3 (3.39).
The Deming regression lines had the associated R2 value of 0.6854.
- (iii) HEX
Corneal endothelial cell density as measured with Auto Center Method had the average (SD) of 59.8 (6.96) compared with those of 59.9 (7.05) for Center Method. The average difference (SD) were -0.1 (4.67).
The Deming regression lines had the associated R2 value of 0.6055.
#### d) Cornea Measuring Area: Center Area
Analysis Method: Center Method vs Flex Center Method of Subject Device
| Table 6 Three Corneal Specular Microscopic Variables Assessed with Two Analysis Method - | | |
|------------------------------------------------------------------------------------------|--|--|
| Center Method vs Flex Center Method – Center Area | | |
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|----------------------------------------------------|-----------------|----------------|----------------|
| Center Method | | | |
| Average (SD) | 2932.7 (527.83) | 34.0 (5.73) | 59.9 (7.05) |
| Median | 2915.9 | 33.2 | 59.9 |
| Min – Max | 816 - 4532 | 25 - 52 | 40 - 74 |
| Flex Center Method | | | |
| Average (SD) | 2917.8 (531.26) | 36.0 (5.80) | 59.9 (5.91) |
| Median | 2899.2 | 35.0 | 60.2 |
| Min – Max | 822 - 4524 | 26 - 57 | 48 - 74 |
| Device Comparisons | | | |
| Average Difference (SD) | -14.9 (28.88) | 2.0 (1.74) | 0.1 (3.47) |
| Average Difference (SD) as<br>a % of Center Method | -0.51% (0.985%) | 5.85% (5.106%) | 0.09% (5.798%) |
{19}------------------------------------------------
510(k) Summary – Konan Specular Microscope XVII, CellChek 20
| reading | | | |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------|----------------|-------------------|
| 95% LOA | (-72.6, 42.9) | (-1.5, 5.5) | (-6.9, 7.0) |
| Correlation (R2) | 0.9971 | 0.9114 | 0.7587 |
| Deming Regression<br>Intercept (95% CI) | -29.6 (-31.4, -27.8) | 3.1 (1.3, 5.0) | 16.2 (13.9, 18.6) |
| Deming Regression Slope<br>(95% CI) | 1.0 (1.0, 1.0) | 1.0 (0.9, 1.0) | 0.7 (0.7, 0.8) |
| Abbreviations: CD = corneal endothelial cell density; CI = confidence interval; CV = coefficient of<br>variation; HEX = hexagonality; LOA = limits of agreement; SD = standard deviation | | | |
| The average differences were calculated as (Flex Center Method) - (Center Method). | | | |
The average differences as a % of Center Method reading were calculated by dividing the average differences with the averages of Center Method.
The 95% LOA's were calculated as the average differences +/- 2SD's.
#### CD (i)
Corneal endothelial cell density as measured with Flex Center Method had the average (SD) of 2917.8 (531.26) compared with those of 2932.7 (527.83) for Center Method. The average difference (SD) were -14.9 (28.88).
The Deming regression lines had the associated R2 value of 0.9971.
#### (ii) CV
Corneal endothelial cell density as measured with Flex Center Method had the average (SD) of 36.0 (5.80) compared with those of those of 34.0 (5.73) for Center Method. The average difference (SD) were 2.0 (1.74).
The Deming regression lines had the associated R2 value of 0.9114.
- HEX (iii)
Corneal endothelial cell density as measured with Flex Center Method had the average (SD) of 59.9 (5.91) compared with those of 59.9 (7.05) for Center Method. The average difference (SD) were 0.1 (3.47).
The Deming regression lines had the associated R2 value of 0.7587.
{20}------------------------------------------------
#### Cornea Measuring Area: Center Area e)
Analysis Method: Center Method vs Auto Flex Center Method of Subject Device
| Table 7 Three Corneal Specular Microscopic Variables Assessed with Two Analysis Method - | | | | |
|------------------------------------------------------------------------------------------|--|--|--|--|
| Center Method vs Auto Flex Center Method – Center Area | | | | |
| N=80 | CD (/mm²) | CV (%) | HEX (%) |
|-----------------------------------------------------------------------------------------------------|----------------------|-----------------|-------------------|
| Center Method | | | |
| Average (SD) | 2932.7 (527.83) | 34.0 (5.73) | 59.9 (7.05) |
| Median | 2915.9 | 33.2 | 59.9 |
| Min – Max | 816 - 4532 | 25 - 52 | 40 - 74 |
| Auto Flex Center Method | | | |
| Average (SD) | 2760.8 (433.37) | 35.1 (5.84) | 59.6 (6.83) |
| Median | 2835.0 | 35.0 | 60.0 |
| Min – Max | 905 - 3415 | 24 - 58 | 38 - 70 |
| Device Comparisons | | | |
| Average Difference (SD) | -172.0 (212.44) | 1.1 (3.60) | -0.3 (5.59) |
| Average Difference (SD) as<br>a % of Center Method<br>reading | -5.86% (7.244%) | 3.21% (10.586%) | -0.47% (9.342%) |
| 95% LOA | (-596.9, 252.9) | (-6.1, 8.3) | (-11.5, 10.9) |
| Correlation ( $R^2$ ) | 0.8480 | 0.6499 | 0.4564 |
| Deming Regression<br>Intercept (95% CI) | 543.5 (541.9, 545.0) | 7.2 (5.4, 8.9) | 20.4 (18.1, 22.7) |
| Deming Regression Slope<br>(95% CI) | 0.8 (0.8, 0.8) | 0.8 (0.8, 0.9) | 0.7 (0.6, 0.7) |
| Abbreviations: CD = corneal endothelial cell density; Cl = confidence interval; CV = coefficient of | | | |
| variation; HEX = hexagonality; LOA = limits of agreement; SD = standard deviation | | | |
| The average differences were calculated as (Auto Flex Center Method) - (Center Method). | | | |
| The average differences as a % of Center Method reading were calculated by dividing the average | | | |
differences with the averages of Center Method.
The 95% LOA's were calculated as the average differences +/- 2SD's.
{21}------------------------------------------------
CD (i)
> Corneal endothelial cell density as measured with Auto Flex Center had the average (SD) of 2760.8 (433.37) compared with those of 2932.7 (527.83) for Center Method. The average difference (SD) were -172.0 (212.44).
The Deming regression lines had the associated R2 value of 0.8480.
- CV (ii)
Corneal endothelial cell density as measured with Auto Flex Center had the average (SD) of 35.1 (5.84) compared with those of 34.0 (5.73) for Center Method. The average difference (SD) were 1.1 (3.60).
The Deming regression lines had the associated R2 value of 0.6499.
- (iii) HEX
Corneal endothelial cell density as measured with Auto Flex Center had the average (SD) of 59.6 (6.83) compared with those of 59.9 (7.05) for Center Method. The average difference (SD) were -0.3 (5.59).
The Deming regression lines had the associated R2 value of 0.4564.
- III. Precision Analysis
- Cornea Measuring Area: Center Area 1)
Analysis Method: Center Method of Subject Device vs Center Method of Reference Device
Table 8 Precision Analyses for Center Method of Subject Device vs Center Method of Reference Device
- Center Area
| Variable | Konan Specular<br>Microscope XVII,<br>CellChek 20<br>(Subject Device)<br>Center Method | NONCON ROBO<br>PACHY F&A<br>(Reference Device)<br>Center Method |
|-----------------------------------------|----------------------------------------------------------------------------------------|-----------------------------------------------------------------|
| CD | | |
| Repeatability SD | 9.1 | 9.8 |
| Repeatability SD as a% of the Average | 0.3% | 0.4% |
| Repeatability limit | 25.5 | 27.4 |
| Repeatability Ratio (CellChek 20/F&A) | 0.9286 | ----- |
| Reproducibility SD | 53.2 | 99.3 |
| Reproducibility SD as a% of the Average | 1.8% | 3.8% |
| Reproducibility limit | 149.0 | 278.0 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.5358 | ----- |
| CV | | |
| Repeatability SD | 0.4 | 0.6 |
{22}------------------------------------------------
| 310(k) Summary - Konan Specular Microscope XVII, CellChek 20 | | |
|--------------------------------------------------------------|--------|-------|
| Repeatability SD as a% of the Average | 1.2% | 1.8% |
| Repeatability limit | 1.1 | 1.7 |
| Repeatability Ratio (CellChek 20/F&A) | 0.6667 | ----- |
| Reproducibility SD | 0.9 | 3.2 |
| Reproducibility SD as a% of the Average | 2.7% | 9.1% |
| Reproducibility limit | 2.5 | 9.0 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.2813 | ----- |
| HEX | | |
| Repeatability SD | 0.8 | 1.2 |
| Repeatability SD as a% of the Average | 1.3% | 2.1% |
| Repeatability limit | 2.2 | 3.4 |
| Repeatability Ratio (CellChek 20/F&A) | 0.6667 | ----- |
| Reproducibility SD | 1.3 | 2.2 |
| Reproducibility SD as a% of the Average | 2.2% | 3.8% |
| Reproducibility limit | 3.6 | 6.2 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.5909 | ----- |
510(k) Summary – Konan Specular Microscope XVII. CellChek 20
The repeatability limit was 2.8 times the repeatability standard deviation, which is the square root of the residual within subject variance component.
The reproducibility limit is 2.8 times the reproducibility standard deviation, which is the square root of the sum of the variance components of operator + device, operator + device x subject interaction, and residual within subject.
#### Cornea Measuring Area: Center Area 2)
Analysis Method: Trace Method of Subject Device vs Center Method of Reference Device
Table 9 Precision Analyses for Trace Method of Subject Device vs Center Method of Reference Device – Center Area
| Variable | Konan Specular<br>Microscope XVII,<br>CellChek 20<br>(Subject Device)<br>Trace Method | NONCON ROBO<br>PACHY F&A<br>(Reference Device)<br>Center Method |
|-----------------------------------------|---------------------------------------------------------------------------------------|-----------------------------------------------------------------|
| CD | | |
| Repeatability SD | 12.1 | 9.8 |
| Repeatability SD as a% of the Average | 0.4% | 0.4% |
| Repeatability limit | 33.9 | 27.4 |
| Repeatability Ratio (CellChek 20/F&A) | 1.2347 | ------- |
| Reproducibility SD | 38.6 | 99.3 |
| Reproducibility SD as a% of the Average | 1.3% | 3.8% |
| Reproducibility limit | 108.1 | 278.0 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.3887 | ------- |
| CV | | |
{23}------------------------------------------------
| Repeatability SD | 0.9 | 0.6 |
|-----------------------------------------|--------|-------|
| Repeatability SD as a% of the Average | 3.1% | 1.8% |
| Repeatability limit | 2.5 | 1.7 |
| Repeatability Ratio (CellChek 20/F&A) | 1.5000 | ----- |
| Reproducibility SD | 2.8 | 3.2 |
| Reproducibility SD as a% of the Average | 8.9% | 9.1% |
| Reproducibility limit | 7.8 | 9.0 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.8750 | ----- |
| HEX | | |
| Repeatability SD | 0.6 | 1.2 |
| Repeatability SD as a% of the Average | 1.0% | 2.1% |
| Repeatability limit | 1.7 | 3.4 |
| Repeatability Ratio (CellChek 20/F&A) | 0.5000 | ----- |
| Reproducibility SD | 1.7 | 2.2 |
| Reproducibility SD as a% of the Average | 3.0% | 3.8% |
| Reproducibility limit | 4.8 | 6.2 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.7727 | ----- |
510(k) Summary – Konan Specular Microscope XVII, CellChek 20
The repeatability limit was 2.8 times the repeatability standard deviation, which is the square root of the residual within subject variance component.
The reproducibility limit is 2.8 times the reproducibility standard deviation, which is the square root of the sum of the variance components of operator + device, operator + device x subject interaction, and residual within subject.
- Cornea Measuring Area: Center Area 3)
Analysis Method: Auto Trace Method of Subject Device vs Center Method of Reference Device
Table 10 Precision Analyses for Auto Trace Method of Subject Device vs Center Method of Reference Device – Center Area
| Variable | Konan Specular<br>Microscope XVII,<br>CellChek 20<br>(Subject Device)<br>Auto Trace Method | NONCON ROBO<br>PACHY F&A<br>(Reference Device)<br>Center Method |
|-----------------------------------------|--------------------------------------------------------------------------------------------|-----------------------------------------------------------------|
| CD | | |
| Repeatability SD | 0.0 | 9.8 |
| Repeatability SD as a% of the Average | 0.0% | 0.4% |
| Repeatability limit | 0.0 | 27.4 |
| Repeatability Ratio (CellChek 20/F&A) | 0.0000 | ----- |
| Reproducibility SD | 22.4 | 99.3 |
| Reproducibility SD as a% of the Average | 0.8% | 3.8% |
| Reproducibility limit | 62.7 | 278.0 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.2256 | ----- |
{24}------------------------------------------------
| CV | | |
|-----------------------------------------|--------|-------|
| Repeatability SD | 0.0 | 0.6 |
| Repeatability SD as a% of the Average | 0.0% | 1.8% |
| Repeatability limit | 0.0 | 1.7 |
| Repeatability Ratio (CellChek 20/F&A) | 0.0000 | ----- |
| Reproducibility SD | 0.7 | 3.2 |
| Reproducibility SD as a% of the Average | 3.6% | 9.1% |
| Reproducibility limit | 2.0 | 9.0 |
| Reproducibility Ratio (CellChek 20/F&A) | 0.2188 | ----- |
| HEX | | |
| Repeatability SD | 0.0 | 1.2 |
| Repeatability SD as a% of the Average | 0.0% | 2.1% |
| Repeatability limit | 0.0 | 3.4 |
| Repeatability Ratio (CellChek 20/F&A) | 0.0000 | ----- |
| Reproducibility SD | 1.4 | 2.2 |
| Reproducibility SD as a% of the Average | 2.4% | 3.8% |
| Reproducibility limit…
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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.