MODIFICATION TO:FINGERTIP PULSE OXIMETER, MODEL MD300C SERIES
Applicant
Beijing Choice Electronic Technololgy Co., Ltd.
Product Code
DQA · Cardiovascular
Decision Date
Dec 2, 2010
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.2700
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Fingertip Pulse Oximeters, MD300C series, are portable, non-invasive devices intended for spot checking of arterial hemoglobin oxygen saturation (SpO2) and pulse rate of adult and pediatric patient at home and hospital (including clinical use in internist/surgery, Anesthesia, and intensive care units). Not for continuous monitoring.
Device Story
Fingertip pulse oximeter series (MD300C3, MD300CF3, MD300C310, MD300C9111, MD300C9211, MD300C61, MD300C63) provides non-invasive spot checks of SpO2 and pulse rate. Device uses dual-wavelength LED (660nm red, 940nm infrared) and photodetector to measure light absorption in pulsating arteriolar vascular bed. CPU calculates SpO2 based on systolic/diastolic light absorption ratios. Operated by clinicians or patients at home/hospital; results displayed on integrated OLED or LED screen. Some models include pulse beep/sound alerts or USB ports for external probes. Output used as adjunct to clinical assessment; not for life-support or continuous monitoring.
Clinical Evidence
Clinical testing conducted for model MD300C9111 per ISO 9919:2005, Annex EE.4. Study compared SpO2 readings against 'Golden Standard' CO-oximeter in 15 healthy adult subjects. Results demonstrated accuracy compliance with manufacturer specifications. Other models (MD300C3, MD300CF3, MD300C61, MD300C63) share the same blood oxygen module as the predicate and were exempted from clinical testing.
Technological Characteristics
Portable fingertip form factor; dual-wavelength LED (660nm/940nm) and photodetector sensing; powered by 2 AAA alkaline batteries. Models feature OLED or LED displays. Connectivity includes optional USB port for external probes. Software-driven; non-sterile, reusable transducers. Complies with IEC 60601-1, IEC 60601-1-2, and ISO 9919:2005.
Indications for Use
Indicated for spot checking arterial hemoglobin oxygen saturation (SpO2) and pulse rate in adult and pediatric patients in home and hospital settings. Contraindicated for use with flammable anesthetic gases, MRI, or CT scanning. Not for continuous monitoring.
Regulatory Classification
Identification
An oximeter is a device used to transmit radiation at a known wavelength(s) through blood and to measure the blood oxygen saturation based on the amount of reflected or scattered radiation. It may be used alone or in conjunction with a fiberoptic oximeter catheter.
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## Attachment VI 510(k) Summary
2 2010
## (As required by 21 CFR 807.92)
## 1. Date Prepared: May 26, 2010
## 2. Statement
This is a special 510(k) report for Fingertip Pulse Oximeters MD300C series, which are modification devices to Fingertip Pulse Oximeter MD300C (K070371). The modification does not change intended use or trade name. The main modifications are listed below:
| Model | Difference to MD300C |
|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| MD300C3 | 1. PCB layout<br>2. Add a speaker, pulse beep and sound tips<br>3. The shape and size of shell |
| MD300CF3 | 1. PCB layout<br>2. Add a speaker, pulse beep and sound tips<br>3. The shape and size of shell |
| MD300C310 | 1. PCB layout<br>2. Add a speaker, pulse beep and sound tips<br>3. The shape and size of shell<br>4. The screen: MD300C310 is coloured OLED, MD300C is double-colour OLED |
| MD300C9111 | 1. The screen: MD300C9111 is LED digital tube, MD300C is double-colour OLED.<br>2. PCB layout<br>3. Add a USB port for an external probe connected.<br>4. The shape and size of shell |
| MD300C9211 | 1. The screen: MD300C9211 is coloured OLED, MD300C is double-colour OLED.<br>2. PCB layout<br>3. Add a USB port for an external probe connected.<br>4. The shape and size of shell |
VI-I
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| MD300C61 | 1. The screen: MD300C61 is LED digital tube, MD300C is double-colour OLED.<br>2. PCB layout<br>3. The shape and size of shell |
|----------|-------------------------------------------------------------------------------------------------------------------------------|
| MD300C63 | The shape and size of shell |
## 3. Sponsor Information
Establishment Registration Number: 3005569927 Beijing Choice Electronic Technology Co., Ltd. North Building 3F,No.9 Shuangyuan road, Badachu Hi-tech Zone, Shijingshan District, Beijing, CHINA 100041
Contact Person: Mr. Lei Chen RD Manager Phone: +86-10-88798251 Fax: +86-10-88791726
#### 4. Submission Correspondent
Ms. Diana Hong Mr. Tarzan Wang Shanghai Mid-Link Business Consulting Co., Ltd Suite 5D, No.19, Lane 999, Zhongshan No.2 Road(S) Shanghai,200030, China Tel: +86-21-64264467 Fax: 240-238-7587 Email: Diana.hong@mid-link.net
## 5. US Agent
Wei Huang Mid-Link International INC 307 Eagle Heights Apt E, Madison, Wisconsin, 53705, United States Phone: 608-3355979 Fax: 760-4665084
Email:info@mid-link.net
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#### 6. Proposed Device Information
Device Common or Usual Name: Pulse Oximeter Device Trade or Proprietary Name: Fingertip Pulse Oximeter Model: MD300C3/ MD300CF3/ MD300C310/ MD300C9111/ MD300C9211/ MD300C61/ MD300C63 Classification Name: Oximeter Regulation Number: 21 CFR 870.2700 Product Code: DQA Panel: Anesthesiology
## 7. Predicate Device
Fingertip Pulse Oximeter MD300C (K070371) Beijing Choice Electronic Technology Co., Ltd. Suite 418, Building D4, 83 Fuxin Road Beijing, CHINA 100856
#### 8. Device Description
The applicant devices of Fingertip Pulse Oximeters MD300C series are fingertip devices, which can display % SpO2 and pulse rate value.
The applicant devices consist of detector and emitter LED, signal amplify unit, CPU, data display unit and power unit.
The Pulse oximeter works by applying a sensor to a pulsating arteriolar vascular bed. The sensor contains a dual light source and photo detector. The one wavelength of light source is 660 mm, which is red light; the other is 940 nm, which is ultra red light. Skin, bone, tissue, and venous vessels normally absorb a constant amount of light over time. The photodetector in fingersensor collects and converts the light into electronic signal which is proportional to the light intensity. The arteriolar bed normally pulsates and absorbs variable amounts of light during systole and diastole, as blood volume increases and decreases. The ratio of light absorbed at systole and diastole is
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translated into an oxygen saturation measurement. This measurement is referred to as SpO2.
The power source of the applicant devices is 2 AAA alkaline batteries. The applicant devices of MD300C3/ MD300CF3/ MD300C310 have pulse beep and sound tips function. The applicant devices of MD300C9111/ MD300C9211 have a USB port which can connect external probe.
The applicant devices are not for life-supporting or life-sustaining, not for implant. The devices or transducers are not sterile and the transducers are reusable and do not need sterilization or re-sterilization. The devices are for prescription. The devices do not contain drug or biological products.
The devices are software-driven and the software validation is provided in Section 10 Software.
## 9. Intended use
The Fingertip Pulse Oximeters, MD300C series, are portable, non-invasive devices intended for spot checking of arterial hemoglobin oxygen saturation (SpO2) and pulse rate of adult and pediatric patient at home and hospital (including clinical use in internist/surgery, Anesthesia, and intensive care units). Not for continuous monitoring.
#### 10. Substantial Equivalence
The applicant devices of Finger Pulse Oximeters MD300C series have same classification information, same indications and intended use, same design principle, similar product design and specifications, same performance effectiveness, performance safety as the predicate device Pulse Oximeter MD300C (K070371).
Specific model of MD300C series has specific difference with MD300C. These differences include adding pulse beep and sound tips function, adding a USB port to connect external probe, display screen and the shape & size of the shell. For adding pulse beep and sound tips function, MD300C series is safer than MD300C. For adding a USB port to connect external probe, we have conducted clinical trials according to ISO 9919. And the difference of display screen and shell is slight and dose not effluence the effectiveness and safety of the device.
The proposed devices are Substantially Equivalent (SE) to the predicate device which is US legally market device. Therefore, the subject devices are determined as safe and effectiveness.
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#### 11. Testing
The Fingertip Pulse Oximeters MD300C series are designed, tested and will be manufactured in accordance with both mandatory and voluntary standards, including:
- . IEC 60601-1:1988+A1:1991+A2:1995. Medical Electrical Equipment - Part1: General requirements for safety.
- · IEC 60601-1-2:2001+A1:2004, Medical Electrical Equipment Part 1: General requirements for safety-2, Collateral Standard: Electromagnetic compatibility - Requirements and tests.
- ISO 9919:2005, Medical electrical equipment Particular requirements for the basic safety and ● essential performance of pulse oximeter equipment for medical use
The Fingertip Pulse Oximeters MD300C3/ MD300CF3/ MD300C61/ MD300C61/ MD300C63 share the same Blood Oxygen Module with the predicate device MD300C, so we believe the clinical test of these models can be exempted. The Fingertip Pulse Oximeters MD300C9111 and MD300C9211 were added a USB port to connect external probe compared with MD300C, and these two models share same Blood Oxygen Module and external probe, so we conducted clinical test for MD300C9111 with external probe M-50G and M-50H, the clinical test of MD300C9211 can be exempted.
The Clinical Test of MD300C9111 following ISO 9919:2005, Annex EE.4 was conducted in the lab of Beijing Friendship Hospital. The study protocol was subjected to ISO 9919:2005 Annex EE. Procedures of testing required in EE2 were adopted. It can be determined from the result of the study that the accuracy of the proposed device is compliance to the specification claimed by the manufacturer compared with "Golden Standard" Co-Oximeter.
#### The clinical protocol for adult:
The study protocol is subjected to ISO 9919:2005 Annex EE. Procedures of testing required in EE.2 are adopted. SpO2 readings of the pulse oximeter equipment MD300C9111 are compared with CO-oximeter SaO2 values.
The protocol: 15 healthy adult are selected as subjects should lie on beds. The pulse oximeter sensor M-50G is set to the subjects' index fingertip, and the sensor M-50H is set to the female subjects' little fingertips. Pulse oximeter sensors should better be covered with opaque material to prevent optical interference. The measuring value which is stabilized for more than 30
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seconds can be considered as an endpoint. The readings of SpO2 and pulse rate should be recorded.
#### Indication, scope, contraindication and caution:
The MD300C9111 pulse oximeter is appropriate to any person in the hospital and home. It can not be used in the environment with flammable anesthetic gas.
It can not be used during the MRI and CT scanning.
The MD300C9111 pulse oximeter is intended for use only as an adjunct in patient assessment. It must be used in conjunction with clinical signs and symptoms.
#### Conclusion:
It can be determined from the result of the study that the accuracy of the proposed device is compliance to the specification claimed by the manufacturer compared with "Golden Standard" Co-Oximeter.
The accuracy of the proposed device is compliance to the requirement, and the product is safe during the use. It can be used in the clinical environment. It is substantially equivalent to other pulse oximeter product with the same effectiveness and safety.
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## DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring. MD 20993-0002
**DEC. 8 2019**
Beijing Choice Electronic Technology Company, Limited C/O Ms. Diana Hong Shanghai Midlink Business Consulting Company, Limited Suite 5D, No. 19, Lane 999 Zhongshan No. 2 Shanghai China 20030
Re: K101577
Trade/Device Name: Fingertip Pulse Oximeter Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: II Product Code: DQA Dated: November 2, 2010 Received: November 2, 2010
Dear Ms. Hong:
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. 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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### Page 2- Ms. Hong
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm 115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Nh for
Anthony D. Watson, B.S., M.S., M.B.A. Director
Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Attachment VII Indication for Use Form
## 510(k) Number: K101577
DEC 2 2010
Device Name: Fingertip Pulse Oximeter
## Indications for Use:
The Fingertip Pulse Oximeters, MD300C series, are portable, non-invasive devices intended for spot checking of arterial hemoglobin oxygen saturation (SpO2) and pulse rate of adult and pediatric patient at home and hospital (including clinical use in internist/surgery, Anesthesia, and intensive care units). Not for continuous monitoring.
Prescription Use V (Part 21 CFR 801 Subpart D)
AND/OR
· Over-The-Counter Use (21 CFR 801 Subpart C)
(Please do not write below this line-continue on another Page of Needed)
Concurrence of CDRH, Office of Device Evaluation (ODE)
L. Schuttheis ANDREAS SCHUTTHEIS
(Division Sign-Off) (Division Sign-Off)
Division of Anesthesiology, General Hospital
Division of Anesthesiology, General Devices Division of Ansolitic Read Devices
510(k) Number:
VII-1
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.