NovaVision™ is intended for the diagnosis and improvement of visual functions in patients with impaired vision that may result from trauma, stroke, inflammation, surgical removal of brain tumors or brain surgery, and may also be used to improve visual function in patients with amblyopia.
Device Story
NovaVision consists of two software programs: Diagnosis Software for clinicians to assess visual deficits and create therapy programs; Therapy software for patient home use. Device presents visual stimuli on computer screen; patient responds to stimuli. System collects/interprets diagnostic data; generates patient-specific visual training tasks. Clinicians use output to monitor progress and adjust therapy. Home-based training aims to improve visual function in patients with neurological or amblyopic vision impairment.
Clinical Evidence
Two clinical studies confirmed effectiveness/reliability of diagnosis software; five clinical studies confirmed safety/effectiveness of patient therapy software. Third-party study correlates therapy software with improved vision in amblyopia patients.
Technological Characteristics
Computer-based software system. Presents visual stimuli on standard computer screen. Enables home-based training. Replaces physical light board hardware used in predicate devices.
Indications for Use
Indicated for patients with impaired vision resulting from trauma, stroke, inflammation, brain tumor surgery, or brain surgery, and patients with amblyopia.
Regulatory Classification
Identification
A perimeter is an AC-powered or manual device intended to determine the extent of the peripheral visual field of a patient. The device projects light on various points of a curved surface, and the patient indicates whether he or she sees the light.
AA-1 System for the Treatment of Amblyopia (K012530)
Submission Summary (Full Text)
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July 22, 2021
NovaVision, Inc. Navroze S. Mehta President and CEO 3701 Fau Boulevard Suite 210 Boca Raton, Florida 33431
Re: K023623
Trade/Device Name: NovaVision, Model 2.0 Regulation Number: 21 CFR 886.1605 Regulation Name: Perimeter Regulatory Class: Class I Product Code: HPT
Dear Navroze S. Mehta:
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 22, 2003. Specifically, FDA is updating this SE Letter as an administrative correction corresponding to the correct classification regulation number, regulation name, regulatory class, and product code.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Elvin Ng, OHT1: Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices, (240) 402-4662, Elvin.Ng@fda.hhs.gov.
Sincerely,
# Charles Chiang -S
for Elvin Ng
Assistant Director Retinal and Diagnostic Devices Team 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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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
# APR 2 2 2003
Mr. Navroze S. Mehta President and CEO NovaVision Inc. 3701 Fau Boulevard Suite 210 Boca Raton, Florida 33431
Re: K023623
Trade/Device Name: NovaVision Model 2.0 Regulation Number: Unclassified Regulation Name: Attention Task Performance Recorder Regulatory Class: Unclassified Product Code: LQD Dated: February 13, 2003 Received: February 19, 2003
Dear Mr. Mehta:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Muriam C. Provost
Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### III. Indications for Use Statement
Applicant: NovaVision, Inc.
510(k) Number (if known): K023623
Device Name: NovaVision™
Indications For Use: NovaVision™ is intended for the diagnosis and improvement of visual functions in patients with impaired vision that may result from trauma, stroke, inflammation, surgical removal of brain tumors or brain surgery, and may also be used to improve visual function in patients with amblyopia.
Muriam C. Provost
(Division Sign-Off) Division of General, Restorative and Neurological Devices
510(k) Number K023623
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/k023623
#### X. 510(k) Summary
This 510(k) summary is submitted in accordance with the requirements of the Safe Medical Devices Act of 1990 and 21 C.F.R. § 807.92.
| 510(k) Submitter | NovaVision, Inc.<br>Reservoir Place, Suite 205<br>1601 Trapelo Road<br>Waltham, MA 02451 |
|------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Contact: Bernhard A. Sabel, Ph.D.<br>Tel: +49-391-611 7100<br>Fax: +49-391-611 7103 |
| Date summary<br>was prepared | October 25, 2002 |
| Trade Name | NovaVision™ |
| Common Name | Attention Task Performance Recorder |
| Classification Name | Recorder, attention task performance |
| Product code | LQD |
| Predicate Devices | DynaVision 2000 (K911938)<br>AA-1 System for the Treatment of Amblyopia (K012530) |
| Description | NovaVision™ consists of two computer software<br>programs: (1) one intended for health care professionals -<br>for the precise diagnosis of patients' visual deficiencies,<br>the development of patient-specific therapy programs, and<br>the analysis of results of patient therapy (NovaVision™<br>Diagnosis Software and Training Program); and (2) one<br>intended for patients - therapeutic software for use by<br>patients in their homes to train and improve impaired visual<br>functions (NovaVision™-Therapy). |
| Intended Use | NovaVision™ is intended for the diagnosis and<br>improvement of visual functions in patients with impaired<br>vision that may result from trauma, stroke, inflammation,<br>surgical removal of brain tumors or brain surgery, and may<br>also be used to improve visual function in patients with<br>amblyopia. |
## Comparison of technological characteristics to predicate device
NovaVision™ is substantially equivalent to the DynaVision 2000. These systems have the same intended use/indications, target population, and functionality, i e , the diagnosis and improvement of visual functions in patients with impaired vision by repetitively
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presenting visual stimuli. NovaVision™ consists of different technology than the Dynavision 2000. but these differences do not raise new questions of safety and effectiveness, and NovaVision™ has been demonstrated to be as safe and effective as the Dynavision 2000.
NovaVision™ presents visual stimuli on a computer screen, while the Dynavision 2000 presents visual stimuli on a large light board. Further, NovaVision™'s computerization of visual stimuli makes it possible for patients to train at home.
NovaVision™ is also substantially equivalent to the AA-1 System for the Treatment of Amblyopia, a device consisting of software and accessories that is intended to treat amblyopia in patients nine years or older. Both devices consist of software that (1) collects and interprets diagnostic information concerning the extent of visual deficits in the form of patient responses to visual diagnostic tests: (2) reports diagnostic information useful for further diagnosis or treatment: and (3) presents visual training tasks individualized to each patient's specific diagnosis.
### Clinical performance data and support of substantial equivalence determination
Two clinical studies have confirmed the effectiveness and reliability of NovaVision™ Diagnosis Software and Training Program in diagnosing patients' visual deficiencies, and five clinical studies have confirmed the safety and effectiveness of patient use of NovaVision™-Therapy to improve visual functions. Moreover, reference to a third-party clinical study strongly correlates with the capabilities of NovaVision™-Therapy to improve the vision of patients with amblyopia.
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.