Innova Vision Sphere and Asphere (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of ametropia (myopia and hyperopia) in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters. The lenses may be worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual acuity. Innova Vision Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of ametropia (myopia or hyperopia with astigmatism) in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters and astigmatic corrections from -0.25 to -2.25 diopters. Innova Vision Multifocal (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of refractive ametropia (myopia and hyperopia) and emmetropia with presbyopia in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters and with add powers from +0.25 to +4.00 diopters. The lenses may be worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual acuity. Innova Vision Multifocal Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the optic correction of distance and near vision in presbyopic phakic persons with nondiseased eyes in powers of -20.00 to +20.00 diopters with add powers from +0.25 to +4.00 diopters and astigmatism corrections from -0.25 to -2.25 diopters. Eye Care Practitioners may prescribe the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact lenses for frequent/planned replacement wear, with cleaning, disinfection and scheduled replacement or for single-use disposable wear. When prescribed for frequent/planned replacement, the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be cleaned, rinsed and disinfected each time the lens is removed. The contact lens is to be discarded after the recommended wearing period as prescribed by the Eye Care Professional. When prescribed for frequent/planned replacement wear, the lenses may be disinfected using a chemical disinfection only. When prescribed for single-use disposable wear, Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be discarded after each removal.
Device Story
Hemispherical silicone hydrogel contact lens; fabricated from inifilcon A (random co-polymer of silicone and hydrophilic monomers); 40% water content. Acts as refracting medium on cornea to focus light on retina. Available in sphere/asphere, toric, multifocal, and multifocal-toric configurations. Contains C.I. Reactive Blue 247 for handling and benzotriazole UV-blocking monomer. Prescribed by eye care practitioners for frequent/planned replacement (with chemical disinfection) or single-use disposable wear. Benefits include vision correction for ametropia and presbyopia.
Clinical Evidence
No clinical data provided; clinical performance testing was addressed by the predicate device. Non-clinical evidence includes GLP-compliant toxicology (cytotoxicity, systemic toxicity, ocular irritation), shelf-life stability, and bench testing (refractive index, water content, Dk, transmission, tensile strength, modulus).
Technological Characteristics
Material: inifilcon A (60%) and water (40%). UV blocker: benzotriazole. Manufacturing: cast-molded. Oxygen permeability: 100 (x 10-11). Refractive index: 1.410. Handling tint: C.I. Reactive Blue 247. Packaging: injection-molded polypropylene blister.
Indications for Use
Indicated for correction of ametropia (myopia/hyperopia), astigmatism, and presbyopia in aphakic and non-aphakic persons with non-diseased eyes. Powers -20.00 to +20.00D; add powers +0.25 to +4.00D; astigmatism correction -0.25 to -2.25D.
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 shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health and Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
April 17, 2024
Innova Vision Inc. % Bret Andre Principal Consultant Andre Vision and Device Research 6119 Canter Lane West Linn, OR 97068
Re: K240519
Trade/Device Name: Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens Regulation Number: 21 CFR 886.5925 Regulation Name: Soft (Hydrophilic) Contact Lens Regulatory Class: Class II Product Code: LPL. MVN Dated: January 31, 2024 Received: February 23, 2024
Dear Bret Andre:
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 (the 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 available 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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Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketingsafety-reporting-combination-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-devicereporting-mdr-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.
{2}------------------------------------------------
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,
# J Angelo Green -S
J. Angelo Green, Ph.D. 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
Submission Number (if known)
## K240519
#### Device Name
Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens
### Indications for Use (Describe)
### Sphere/Asphere:
Innova Vision Sphere and Asphere (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of ametropia (myopia and hyperopia) in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters. The lenses may be worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual acuity.
### Toric:
Innova Vision Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of ametropia (myopia or hyperopia with astigmatism) in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters and astigmatic corrections from -0.25 to -2.25 diopters.
### Multifocal:
Innova Vision Multifocal (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of refractive ametropia (myopia and hyperopia) and emmetropia with presbyopia in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters and with add powers from +0.25 to +4.00 diopters. The lenses may be worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual acuity.
### Multifocal Toric:
Innova Vision Multifocal Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the optic correction of distance and near vision in presbyopic phakic persons with nondiseased eyes in powers of -20.00 to +20.00 diopters with add powers from +0.25 to +4.00 diopters and astigmatism corrections from
-0.25 to -2.25 diopters.
Eye Care Practitioners may prescribe the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact lenses for frequent/planned replacement wear, with cleaning, disinfection and scheduled replacement or for single-use disposable wear.
When prescribed for frequent/planned replacement, the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be cleaned, rinsed and disinfected each time the lens is removed. The contact lens is to be discarded after the recommended wearing period as prescribed by the Eye Care Professional. When prescribed for frequent/planned replacement wear, the lenses may be disinfected using a chemical disinfection only.
When prescribed for single-use disposable wear, Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be discarded after each removal.
Type of Use (Select one or both, as applicable)
( Prescription Use (Part 21 CFR 801 Subpart D)
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# 510 (k) SUMMARY
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
K240519 The assigned 510(k) number is:
#### I. SUBMITTER
- January 29th 2024 Date Prepared:
| Name: | INNOVA VISION, INC. |
|-----------------|-----------------------------------------------------------------------------------|
| Address: | 2F., No. 20, Prosperity Rd. 1,<br>Hsinchu Science Park 300091,<br>Hsinchu, Taiwan |
| Contact Person: | Celine Hsu<br>Senior Engineer |
| Phone number: | +886-3-5927299 |
| Consultant: | Bret Andre<br>EyeReg Consulting, Inc.<br>6119 Canter Ln.<br>West Linn, OR 97068 |
| Phone number: | (503) 372-5226 |
#### II. DEVICE
| Trade Name: | Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft<br>Contact Lens |
|-------------------------|---------------------------------------------------------------------------------------------|
| Common<br>Name: | Contact Lens, Daily Wear |
| Classification<br>Name: | Soft (hydrophilic) Contact Lens (21 CFR 886.5925) |
| Regulatory<br>Class: | Class II |
| Product Codes: | LPL; MVN |
# Purpose of 510(k) Submission:
~ Device Change ~
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#### III. PREDICATE DEVICE
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is substantially equivalent to the following predicate devices:
- "Innova Vision (inifilcon A) Silicone Hvdrogel Soft (Hydrophilic) Contact Lens" ■ By Innova Vision, Inc. 510(k) number; K232139 Primary Predicate
- "Innova Vision Hydrogel (Etafilcon A) Soft (Hydrophilic) Contact Lens" By Innova Vision, Inc. 510(k) number; K222954 Primary Predicate
- "Total30, Total30 for Astigmatism, Total30 Multifocal, Total30 Multifocal Toric, Total30 Asphere" By Alcon Laboratories Inc. 510(k) number: K210436 Reference Predicate
#### IV. DEVICE DESCRIPTION
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is a hemispherical shell with a molded spherical base curve and a molded front surface. The hydrophilic characteristics allow aqueous solutions to enter the lenses are fabricated from inifilcon A, which is a random co-polymer of silicone containing monomers and hydrophilic monomers. The lens consists of 60.0% inifilcon A and 40.0% water by weight when immersed in saline solution. The inifilcon A name has been adopted by the United States Adopted Names Council (USAN).
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens contains C.I. Reactive Blue 247 (21 CFR Part 73.3100 ) for visibility and handling. The Innova Vision (inifilcon A) Silicone Hydrogel (Hvdrophilic) Daily Wear Soft Contact Lens incorporates a benzotriazole UV blocking monomer to help protect against transmission of harmful UV radiation. The lens blocks >95% in the UVB range (280nm - 315nm), and >50% in the UVA range (315mm - 380mm). The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is manufactured in sphere/asphere, toric, multifocal and multifocal-toric design configurations. The material properties and available parameters of the finished lenses are as follows:
| Parameter | Range | Tolerance |
|-------------------------|-------------------------------------------|-------------------------------------------------------------------------------------------------------------|
| Chord Diameter | 13.00 mm to 15.00 mm | ±0.20 mm |
| Center Thickness | 0.050 mm to 0.580 mm | When ≤ 0.10 mm $\rightarrow$ ±0.010 mm + 10%<br>When > 0.10 mm $\rightarrow$ ±0.015 mm + 5% |
| Base Curve | 8.0 mm to 9.8 mm | ±0.20 mm |
| Back Vertex Power (F'v) | -20.00 D to +20.00 D<br>(in 0.25 D steps) | When 0.00 < $ F'v $ ≤ 10.00 D $\rightarrow$ ±0.25 D<br>When 10.00 < $ F'v $ ≤ 20.00 D $\rightarrow$ ±0.50 D |
| Cylinder Power (F'c) | -0.25 D to -2.25 D<br>(in 0.25 D steps) | When 0.00 < $ F'c $ ≤ 2.00 D $\rightarrow$ ±0.25 D<br>When 2.00 < $ F'c $ ≤4.00 D $\rightarrow$ ±0.37 D |
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| Cylinder Axis | 10° to 180° in 10° steps<br>(in 10° steps) | When 0.00 $ < F'c \le 1.50 D \rightarrow \pm 8^\circ $<br>When $ F'c > 1.50 D\rightarrow \pm 5^\circ $ |
|---------------------------------------------------------------|--------------------------------------------|------------------------------------------------------------------------------------------------------------|
| Multifocal Power | +0.25 D to +4.00 D<br>(in 0.25 D steps) | ±0.25D |
| Oxygen Permeability<br>(x 10-11 (cm2•ml<br>O2)/(sec•ml•mmHg)) | 100 | ±20% |
| Visible Light Transmittance | >95% | ±5% |
| Ultraviolet radiation Transmittance | < 5% TUVB<br><50% TUVA | TUVB (280 to 315nm) < 0.05 TV<br>TUVA (315 to 380nm) < 0.05 TV |
| Water Content | 40% | ±2% |
| Refractive Index | 1.410 | ±0.005 |
#### V. INDICATIONS FOR USE
### Sphere/Asphere:
Innova Vision Sphere and Asphere (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of ametropia (myopia and hyperopia) in aphakic and non-aphakic persons with nondiseased eyes in powers from -20.00 to +20.00 diopters. The lenses may be worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual acuity.
### Toric:
Innova Vision Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of ametropia (myopia or hyperopia with astigmatism) in aphakic and non-aphakic persons with nondiseased eves in powers from -20.00 to +20.00 diopters and astigmatic corrections from -0.25 to -2.25 diopters.
# Multifocal:
Innova Vision Multifocal (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the correction of refractive ametropia (myopia and hyperopia) and emmetropia with presbyopia in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00 diopters and with add powers from +0.25 to +4.00 diopters. The lenses may be worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual acuity.
# Multifocal Toric:
Innova Vision Multifocal Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the optic correction of distance and near vision in presbyopic phakic persons with non-diseased eyes in powers of -20.00 to +20.00 diopters with add powers from +0.25 to +4.00 diopters and astigmatism corrections from -0.25 to -2.25 diopters.
Eye Care Practitioners may prescribe the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact lenses for frequent/planned replacement wear, with cleaning, disinfection and scheduled replacement or for single-use disposable wear.
When prescribed for frequent/planned replacement, the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be cleaned, rinsed and disinfected each time the lens is
{8}------------------------------------------------
removed. The contact lens is to be discarded after the recommended wearing period as prescribed by the Eye Care Professional. When prescribed for frequent/planned replacement wear, the lenses may be disinfected using a chemical disinfection only.
When prescribed for single-use disposable wear. Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be discarded after each removal.
#### VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH PREDICATE DEVICE
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is substantially equivalent to the primary predicate device identified (K232139) regarding the following features:
- E FDA category - Group V
- FDA classification Soft (hydrophilic) Contact Lens (21 CFR 886.5925) ■
- USAN Material (inifilcon A)
- 트 Intended use – daily wear contact lenses
- Actions
- Indications for use (same lens design configurations)
- Benzotriazole UV absorbing monomer (same monomer)
- 트 Cast molded production method (same manufacturing facility and quality controls)
- Injection molded polypropylene blister packaging (same packaging)
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is substantially equivalent to the reference predicate device identified (K222954) regarding the following features:
- FDA classification Soft (hydrophilic) Contact Lens (21 CFR 886.5925) ■
- Intended use - daily wear contact lenses
- Indications for use
- Cast molded production method (same manufacturing facility and quality controls)
- Injection molded polypropylene blister packaging (same packaging and storage solution)
- Buffer solution (same formulation)
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is substantially equivalent to the reference predicate device identified (K210436) regarding the following features:
- 트 FDA classification - Soft (hydrophilic) Contact Lens (21 CFR 886.5925)
- Intended use daily wear contact lenses ■
- 트 Indications for use
- Cast molded production method
- Handling tint (Reactive Blue 247)
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The following matrix illustrates the production method, lens function and material characteristics of the Innova Vision (inifilcon A) Silicone Hydrogel Soft (Hydrophilic) Contact Lens, as well as the predicate devices.
| | Innova Vision Silicone<br>Hydrogel<br>By Innova Vision Inc.<br>(Subject Device) | Innova Vision Silicone<br>Hydrogel<br>By Innova Vision Inc.<br>(K232139) | Innova Vision Hydrogel<br>By Innova Vision Inc.<br>(K222954) | TOTAL30 by Alcon<br>Laboratories, Inc.<br>(K210436) |
|------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | Daily wear,<br>Soft (hydrophilic) contact lens | Daily wear,<br>Soft (hydrophilic) contact lens | Daily wear,<br>Soft (hydrophilic) contact<br>lens | Daily wear,<br>Soft (hydrophilic) contact<br>lens |
| Actions | In its hydrated state, the<br>contact lens, when placed on<br>the cornea, acts as a refracting<br>medium to focus light rays on<br>the retina | In its hydrated state, the<br>contact lens, when placed on<br>the cornea, acts as a refracting<br>medium to focus light rays on<br>the retina | In its hydrated state, the<br>contact lens, when placed on<br>the cornea, acts as a<br>refracting medium to focus<br>light rays on the retina | In its hydrated state, the<br>contact lens, when placed<br>on the cornea, acts as a<br>refracting medium to focus<br>light rays on the retina |
| FDA Classification | Soft (hydrophilic) Contact<br>Lens (21 CFR 886.5925) | Soft (hydrophilic) Contact<br>Lens (21 CFR 886.5925) | Soft (hydrophilic) Contact<br>Lens (21 CFR 886.5925) | Soft (hydrophilic) Contact<br>Lens (21 CFR 886.5925) |
| FDA Classification<br>Product Code(s) | LPL; MVN | LPL; MVN | LPL; MVN | LPL; MVN |
| FDA Group | FDA Group V | FDA Group V | FDA Group II | FDA Group V |
| USAN name | inifilcon A | inifilcon A | etafilcon A | lehfilcon A |
| Water Content (%) | $40\pm2$ % | $40\pm2$ % | $58\pm2$ % | $55\pm2$ % |
| Oxygen Permeability<br>x 10-11 (cm2/sec)(mlO2)/(ml x<br>mmHg (@ 35℃)) (revised Fatt<br>method) | 100 | 100 | 24 | 123 |
| Refractive Index<br>(hydrated) | 1.410 | 1.410 | 1.400 | 1.40 |
| UV Blocker | Yes - benzotriazole | Yes - benzotriazole | Yes - benzotriazole | Yes - two benzotriazole<br>monomers |
| Manufacturing | Cast-Molded (Heat Curing) | Cast-Molded (UV Curing) | Cast-Molded (UV Curing) | Cast-Molded |
| Color | Blue Handling Tint<br>Reactive Blue 247 | Blue Handling Tint<br>C.I. Reactive Blue No. 19 | Blue Handling Tint<br>C.I. Reactive Blue No. 19 | Blue Handling Tint<br>Reactive Blue 247 |
| Buffer Contains H2O2 | Yes | No | Yes | No |
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The following matrix compares the indications for use of the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens with the predicate device.
| | Indications for Use | |
|---------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| Innova<br>Vision<br>Silicone<br>Hydrogel<br>By Innova<br>Vision Inc.<br>(Subject<br>Device) | Sphere/Asphere:<br>Innova Vision Sphere and Asphere (inifilcon A) Silicone Hydrogel Soft Contact lenses are<br>indicated for the correction of ametropia (myopia and hyperopia) in aphakic and non-aphakic<br>persons with non-diseased eyes in powers from -20.00 to +20.00 diopters. The lenses may be<br>worn by persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with<br>visual acuity. | |
| | Toric:<br>Innova Vision Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for the<br>correction of ametropia (myopia or hyperopia with astigmatism) in aphakic and non-aphakic<br>persons with non-diseased eyes in powers from -20.00 to +20.00 diopters and astigmatic<br>corrections from -0.25 to -2.25 diopters. | |
| | Multifocal:<br>Innova Vision Multifocal (inifilcon A) Silicone Hydrogel Soft Contact lenses are indicated for<br>the correction of refractive ametropia (myopia and hyperopia) and emmetropia with presbyopia<br>in aphakic and non-aphakic persons with non-diseased eyes in powers from -20.00 to +20.00<br>diopters and with add powers from +0.25 to +4.00 diopters. The lenses may be worn by<br>persons who exhibit astigmatism of 2.00 diopters or less that does not interfere with visual<br>acuity. | |
| | Multifocal Toric:<br>Innova Vision Multifocal Toric (inifilcon A) Silicone Hydrogel Soft Contact lenses are<br>indicated for the optic correction of distance and near vision in presbyopic phakic or aphakic<br>persons with non-diseased eyes in powers of -20.00 to +20.00 diopters with add powers from<br>+0.25 to +4.00 diopters and astigmatism correction from -0.25 to -2.25 diopters. | |
| | Eye Care Practitioners may prescribe the Innova Vision (inifilcon A) Silicone Hydrogel Soft<br>(Hydrophilic) Contact lenses for frequent/planned replacement wear, with cleaning,<br>disinfection and scheduled replacement or for single-use disposable wear. | |
| | When prescribed for frequent/planned replacement, the Innova Vision (inifilcon A) Silicone<br>Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is to be cleaned, rinsed and disinfected<br>each time the lens is removed. The contact lens is to be discarded after the recommended<br>wearing period as prescribed by the Eye Care Professional. When prescribed for<br>frequent/planned replacement wear, the lenses may be disinfected using a chemical disinfection<br>only. | |
| | When prescribed for single-use disposable wear, Innova Vision (inifilcon A) Silicone Hydrogel<br>(Hydrophilic) Daily Wear Soft Contact Lens is to be discarded after each removal. | |
| Innova<br>Vision<br>Silicone<br>Hydrogel<br>By Innova | Same as the subject device | |
| Vision Inc.<br>(K232139) | | |
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| Innova<br>Vision<br>Hydrogel<br>By Innova<br>Vision Inc.<br>(K222954) | Same as the subject device |
|-----------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| TOTAL30 by<br>Alcon<br>Laboratories,<br>Inc.<br>(K210436) | TOTAL30 (lehfilcon A) spherical soft contact lenses are indicated for the optical correction of<br>refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased<br>eyes with up to approximately 1.50 diopters (D) of astigmatism that does not interfere with<br>visual acuity. |
| | TOTAL30 Asphere (lehfilcon A) soft contact lenses are indicated for the optical correction of<br>refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with non-diseased<br>eyes with up to approximately 1.50 diopters (D) of astigmatism that does not interfere with<br>visual acuity. |
| | TOTAL30 for Astigmatism (lehfilcon A) toric soft contact lenses are indicated for the optical<br>correction of refractive ametropia (myopia and hyperopia) in phakic or aphakic persons with<br>nondiseased eyes with up to 6.00 diopters (D) of astigmatism. |
| | TOTAL30 Multifocal (lehfilcon A) soft contact lenses are indicated for the optical correction<br>of presbyopia with or without refractive ametropia (myopia and hyperopia) in phakic or<br>aphakic persons with non-diseased eyes who may require a reading addition of +3.00 diopters<br>(D) or less and who may have up to approximately 1.50 diopters of astigmatism that does not<br>interfere with visual acuity. |
| | TOTAL30 Multifocal Toric (lehfilcon A) soft contact lenses are indicated for the optical<br>correction of presbyopia with or without refractive ametropia (myopia and hyperopia) in phakic<br>or aphakic persons with non-diseased eyes who may require a reading addition of +3.00<br>diopters (D) or less and who may have up to 6.00 diopters (D) of astigmatism. |
| | The lenses are to be prescribed for daily wear with removal for cleaning and disinfection<br>(chemical not heat) prior to reinsertion, or disposal, as recommended by the eye care<br>professional. Lenses should be discarded and replaced with a new pair each month, or more<br>often if recommended by the eye care professional. |
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#### PERFORMANCE DATA VII.
The following performance data were provided in support of the substantial equivalence determination.
### Non-Clinical Performance Testing
A series of non-clinical performance tests were performed to demonstrate the safety and effectiveness of the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens. The results support the claim that the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is substantially equivalent to the currently marketed predicate devices. Refer below to a summary of the results from the non-clinical studies.
# Toxicology:
All biocompatibility/toxicology tests were conducted in accordance with the GLP regulation.
- · In-Vitro Cytotoxicity: Cytotoxicity testing was performed in accordance with ISO 10993-5 with results indicating that the finished lenses are not cytotoxic.
- · Systemic Toxicity: The finished lenses meet the requirements of the systemic injection test in accordance with ISO 10993-11 and do not produce acute systemic toxicity.
- · Acute Ocular Irritation: Acute ocular irritation testing was performed in accordance with ISO 10993-10, and the extracts from finished lenses produced no ocular irritation.
The Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens uses the same blister packaging materials and packaging solution as the predicate devices. Biocompatibility testing for the packaging materials and solution was addressed in previously submitted biocompatibility assessments.
# Shelf Life:
Testing was performed to evaluate the stability, sterility, and package integrity of the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens over the duration of the labeled expiration date. The data presented supports establishment of the proposed shelf life.
# Solution Compatibility
The physical compatibility of Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens with commonly available cleaning and disinfection solutions (peroxide and MPDS) was confirmed.
# Preservative Uptake and Release
Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lenses were analyzed for uptake and release of preservatives found in lens care products. Preservative uptake and release testing is referenced in K232139.
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Performance Testing - Bench:
The following bench tests were completed: refractive index, water content, Dk, % transmission (visible & UV), tensile strength, modulus, % elongation to break, specific gravity and quantification of polymerization residuals. Results of physicochemical and mechanical property testing demonstrate consistent material properties between the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens and the predicate device.
# Clinical Testing
Clinical performance testing for the Innova Vision (inifilcon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens was addressed by the predicate device.
# VIII. CONCLUSIONS
# Validity of Scientific Data
Laboratories under Good Laboratory Practice regulations conducted toxicology, microbiology, and shelflife stability studies following scientific protocols. The data were determined to be scientifically valid under 21 CFR 860.7.
# Substantial Equivalence
Information presented in this Premarket Notification establishes that the Innova Vision (inifilicon A) Silicone Hydrogel (Hydrophilic) Daily Wear Soft Contact Lens is as safe and effective as the predicate device when used in accordance with the labeled directions for use and for the proposed indication.
# Risks and Benefits
The risks of the subject device are the same as those normally attributed to the wearing of soft (hydrophilic) daily wear contact lenses. The benefits to the patient are the same as those for other soft (hydrophilic) daily wear contact lenses.
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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.