The Tomey Cornea/Anterior Segment OCT CASIA2 is a non-contact, high resolution tomographic and biomicrosopic device indicated for the in vivo imaging of ocular structures in the anterior segment. The Tomey Cornea/Anterior Segment OCT CASIA2 is indicated as an aid in the visualization of anterior segment findings.
Device Story
CASIA2 is a non-contact, high-resolution swept-source optical coherence tomography (SS-OCT) system for anterior segment imaging. It captures backscattered light intensity to generate cross-sectional tomographic images of the cornea, lens, iris, and iridocorneal angle. Operated by clinicians in a clinical setting, the device uses a 1310 nm swept-source laser to perform A-scans at 50,000 scans/second. The system includes a main unit, touch panel monitor, and external storage. Output consists of high-resolution images displayed on the monitor, which the clinician uses to visualize ocular structures and pathology. By providing detailed cross-sectional views of the anterior chamber, the device assists in the assessment of ocular conditions, potentially improving diagnostic accuracy and clinical decision-making regarding anterior segment diseases.
Clinical Evidence
Prospective comparative study of 134 subjects (45 normal, 46 cataract, 43 glaucoma). Image quality and visibility of anatomic structures (cornea, angle, lens, iris) were compared against the Optovue RTVue Avanti by 3 masked graders. Results showed CASIA2 provided better overall image quality in the pooled population and individual subgroups. Pathology was observed more frequently with CASIA2 images. Visibility of angle and lens was superior with CASIA2; cornea visibility was equivalent; iris visibility was equivalent or superior depending on scan type.
Technological Characteristics
Swept-source OCT; 1310 nm laser source; 50,000 A-scans/s; 13 mm depth scan range. Includes internal fixation, accommodation, external alignment, and front illumination (red/green) LED lamps. Connectivity via Windows-based PC. Complies with ISO 15004-1, IEC 60601-1, ANSI Z80.36, ISO 10993-1, and IEC 62304. Biocompatible materials per ISO 10993-1.
Indications for Use
Indicated for in vivo imaging of anterior segment ocular structures (cornea, iris, lens, iridocorneal angle) in patients, including those with cataracts or glaucoma, to aid in visualization of anterior segment findings.
Regulatory Classification
Identification
An ophthalmoscope is an AC-powered or battery-powered device containing illumination and viewing optics intended to examine the media (cornea, aqueous, lens, and vitreous) and the retina of the eye.
Special Controls
*Classification.* Class II (special controls). The device, when it is an AC-powered opthalmoscope, a battery-powered opthalmoscope, or a hand-held ophthalmoscope replacement battery, 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
RTVue XR OCT Avanti with AngioVue Software (K180660)
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Tomey Corporation % Ryan Bouchard Consultant ORA, Inc. 300 Brickstone Square Andover, Massachusetts 01801
Re: K213265
Trade/Device Name: Tomey Cornea/Anterior Segment OCT CASIA2 Regulation Number: 21 CFR 886.1570 Regulation Name: Ophthalmoscope Regulatory Class: Class II Product Code: OBO
Dear Mr. Bouchard:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated April 27, 2022. Specifically, FDA is updating the 510(k) Summary as an administrative correction.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Elvin Ng. OHT1: Office of Ophthalmic. Anesthesia, Respiratory. ENT and Devices, 240-402-4662. Elvin.Ng(a)fda.hhs.gov.
Sincerely,
Elvin Y. Ng -S
Elvin Ng 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
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April 27, 2022
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Tomey Corporation % Ryan Bouchard Consultant ORA, Inc. 300 Brickstone Square Andover, Massachusetts 01801
Re: K213265
Trade/Device Name: Tomey Cornea/Anterior Segment OCT CASIA2 Regulation Number: 21 CFR 886.1570 Regulation Name: Ophthalmoscope Regulatory Class: Class II Product Code: OBO Dated: March 25, 2022 Received: March 28, 2022
Dear Mr. Bouchard:
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 Mav 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/cfpm/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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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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 (QS) 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 (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 Y. Na -S
Elvin Ng 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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# Indications for Use
510(k) Number (if known) K213265
Device Name
Tomey Cornea/Anterior Segment OCT CASIA2
Indications for Use (Describe)
The Tomey Corneal Anterior Segment OCT CASIA2 is a non-contact, high resolution tomographic and biomicrosopic device indicated for the in vivo imaging of ocular structures in the anterior segment. The Tomey Corneal Anterior Segment OCT CASIA2 is indicated as an aid in the visualization of anterior segment findings.
Type of Use (Select one or both, as applicable)
| <div><span style="font-size:100%;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D)</div> |
|------------------------------------------------------------------------------------------------|
| <div><span style="font-size:100%;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C)</div> |
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This summary of the 510(k) premarket notification for the Tomey Cornea/Anterior Segment OCT CASIA2 is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR\$807.92.
Submitter Information:
## Owner/Company name, address
Tomey Corporation 2-11-33 Noritakeshinmachi Nishi-ku, Nagoya 451-0051 Japan
Contact person Yuko Matsushita Regulatory Telephone: [+81] 52-581-5327 E-mail: ymatsushita@tomey.co.jp
## Contact/Application Correspondent
Ryan Bouchard Ora, Inc. 300 Brickstone Square Andover, MA 01810 Telephone: (978) 332-9574 Facsimile: (978) 689-0020 E-mail: rbouchard@oraclinical.com
## Date Prepared
April 27, 2022
#### Device Information 1.
| Trade Name: | Tomey Cornea/Anterior Segment OCT CASIA2 |
|----------------------------|------------------------------------------|
| Common Name: | OCT (Optical Coherence Tomography) |
| Classification Name: | Tomography, optical coherence |
| Product Code: | OBO |
| Classification Regulation: | 21 CFR 886.1570 |
#### Predicate Device 2.
The CASIA2 is substantially equivalent to the following legally marketed device:
| 510(k) Number | Trade name | Product code |
|---------------|--------------------------------------------|--------------|
| K180660 | RTVue XR OCT Avanti with AngioVue Software | OBO, HLI |
The predicate device is hereinafter called the Avanti.
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#### Description of the Device 3.
The Tomey Cornea/Anterior Segment OCT CASIA2 (CASIA2) is a non-contact, high resolution tomographic and biomicroscopic device indicated for in vivo imaging of ocular structures in the anterior segment. The Tomey Cornea/Anterior Segment OCT CASIA2 is indicated as an aid in the visualization of anterior segment findings.
CASIA2 consists of several components: the main unit, AC input power source, a touch panel LCD monitor, an external hard drive (HDD), a mouse and a keyboard.
There are two types of OCT, which are based on different measurement principles: time domain (TD) and Fourier domain (FD). In the TD, the reference mirror is moved mechanically in the direction of depth; in the FD, the depth-wise tissue data is obtained without moving the reference mirror. With the FD, since the reference mirror does not need to be moved mechanically, images can be obtained at a higher speed compared to the TD.
The FD is further classified into spectral-domain OCT Idetected in Fourier space using broadband light source and spectroscope (grating) without moving the reference mirror] and swept-source OCT (optical interference performed in the Fourier space by changing the wavelength of the light source at a high speed).
CASIA2 is an anterior segment OCT that obtains images by A-scanning with swept-source OCT. OCT images are created by the intensity of the light (backscattered light) that returns in the same path as that of incident light among the scattered light of each tissue. Thus, it is created with higher intensity in the tissues that generate strong backward scattering.
The various structures which are imaged, and the related scans include the following:
- . Cornea
- 0 AS Global scan
- 0 AS H+V Scan
- O AS Single
- Lens ●
- Lens scan O
- Lens Raster O
- Lens Global scan O
- o Lens H+V Scan
- Lens Single O
- Iridocorneal Angle ●
- Angle HD N (nasal) O
- Angle HD T (temporal) O
- Angle HD S (superior) O
- Angle HD I (inferior) O
#### 3.1 Performance specification
- Scan speed: 50,000 A scans/second
- Scan Range: ●
- o Depth: 13mm
- Radial: 16mm in diameter O
- Transverse: Raster: 12 x 12 mm O
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#### Indications for Use 4.
The Tomey Cornea/Anterior Segment OCT CASIA2 is a non-contact, high resolution tomographic and biomicroscopic device indicated for the in vivo imaging of ocular structures in the anterior segment. The Tomey Cornea/Anterior Segment OCT CASIA2 is indicated as an aid in the visualization of anterior segment findings.
#### 5. Statement of substantial equivalence
For its indications, the Tomey Cornea/Anterior Segment OCT CASIA2 has the same intended use as the RTVue XR OCT Avanti for the anterior segment as shown in the comparison table below.
Both the CASIA2 and the Avanti are indicated as an optical coherence tomography system intended for in vivo imaging of anterior ocular structures of the anterior chamber of the eye.
The Tomey OCT CASIA2 does not include the posterior segment indications.
| Feature | Tomey CASIA2 | Optovue RTVue XR OCT Avanti with<br>AngioVue Software (K180660) |
|----------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Tomey | Optovue, Inc. |
| Classification | 886.157 | 886.157 |
| Product Code | OBO | HLI, OBO |
| Indications for use | The Tomey Cornea/Anterior Segment<br>OCT CASIA2 is a non-contact, high<br>resolution tomographic and<br>biomicroscopic device indicated for the<br>in vivo imaging of ocular structures in<br>the anterior segment. The Tomey<br>Cornea/Anterior Segment OCT CASIA2<br>is indicated as an aid in the visualization<br>of anterior segment findings. | The Avanti is an optical coherence<br>tomography system intended for the in<br>vivo imaging, cross-sectional, and three<br>dimensional imaging and measurement of<br>anterior and posterior ocular structures,<br>including retina, retinal nerve fiber layer,<br>ganglion cell complex (GCC), optic disc,<br>cornea, corneal epithelia, corneal stroma,<br>pachymetry, corneal power, and anterior<br>chamber of the eye. With the integrated<br>normative database, Avanti is also a<br>quantitative tool for the comparison of<br>retina, retinal nerve fiber layer, and optic<br>disc measurements in the human eye to a<br>database of a known normal subjects. It is<br>indicated for use as a diagnostic device to<br>aid in the detection and management of<br>ocular diseases.<br>The Avanti with the AngioVue software<br>feature is indicated as an aid in the<br>visualization of vascular structures of the<br>retina and choroid in normal subjects, and<br>in subjects with glaucoma and retinal<br>diseases. The AngioAnalytics software<br>feature of AngioVue is indicated for the<br>measurement of vascular density, the<br>foveal avascular zone, the thickness of<br>retinal layers, and nerve fiber layer, and<br>measurement of optic disc parameters in<br>normal subjects, and in subjects with<br>glaucoma and retinal diseases. |
| Feature | Tomey CASIA2 | Optovue RTVue XR OCT Avanti with<br>AngioVue Software (K180660) |
| Technological Characteristics: OCT | | |
| Imaging | Swept Source OCT | Spectral Domain OCT |
| Scan Rate | 50,000 A-Scan/s | 70,000 A-Scan/s |
| Technological Characteristics: Swept Source Laser | | |
| -Wave Length | 1310 nm (LD) | 840 nm (SLD) |
| -Power Output | <6 mW | Unknown |
| -Continuous/Pulsed | Pulsed | Unknown |
| -Pulse Durations | 12.56µs | Unknown |
| Field of View | Transverse:<br>Radial scan: 16 mm<br>Raster scan: 12mm x 12mm<br>Scan depth: 13 mm | Corneal image: 12 mm x 8 mm<br>CAM-L: 13 mm |
| Optical Resolution | Axial: 10µm or less (in tissue)<br>Transverse: 30µm or less (in air) | 15µm (in the X and Y directions), 5 µm<br>(in the Z direction) |
| Exposure Power at<br>Pupil | 893 μW | <750 μW |
| Technological Characteristics: Internal Fixation Lamp Center | | |
| -Wavelength | 605 nm (LED) | Unknown |
| -Power Output | 30mW | Unknown |
| -Continuous/Pulsed | Continuous | Unknown |
| Technological Characteristics: Accommodation Target | | |
| Wavelength | 605 nm (LED) | Unknown |
| Power output | 30mW | Unknown |
| Continuous/Pulsed | Continuous | Unknown |
| Technological Characteristics: External Fixation Lamp | | |
| Wavelength | 670 nm (LED) | Unknown |
| Power output | 2.8mW | Unknown |
| Continuous/Pulsed | Continuous | Unknown |
| Technological Characteristics: Alignment Lamp | | |
| Wavelength | 810 nm (LED) | Unknown |
| Power output | 2.32 mW | Unknown |
| Continuous/Pulsed | Continuous | Unknown |
| Technological Characteristics: Front Illumination (red) Lamp | | |
| Wavelength | 940 nm (LED) | Unknown |
| Power output | 2.32 mW | Unknown |
| Continuous/Pulsed | Continuous | Unknown |
| Technological Characteristics: Front Illumination (green) Lamp | |…
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1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
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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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Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
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What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.