The TrueVision® 3D Visualization and Guidance System is an adjunct imaging tool that provides onscreen guidance with alignment, orientation, and sizing for eye surgery. The system is intended for use as a preoperative and postoperative image capture tool with visualization and guidance provided during anterior segment ophthalmic surgical procedures, including limbal relaxing incisions, capsulorhexis and toric intraocular lens (toric IOL) positioning. The system utilizes surgeon confirmation at each step for planning and positioning of guidance templates.
Device Story
The TrueVision 3D Visualization and Guidance System is a stereoscopic high-definition digital video camera and workstation. It functions as an adjunct to surgical microscopes during cataract surgery and slit lamp microscopes for pre/post-operative imaging. The system captures video and displays real-time 3D images on a flat-panel high-definition monitor for the surgeon and OR staff. Using TrueWare software, the system overlays surgeon-driven, on-screen graphical templates and guides onto the live video feed. These templates assist with limbal relaxing incisions, capsulorhexis sizing, and toric IOL rotational alignment. The surgeon controls the system via a remote keyboard and touchpad mouse, providing confirmation at each step of the planning and positioning process. This visual guidance aims to improve surgical precision and alignment, potentially benefiting patients through optimized IOL placement and incision accuracy.
Clinical Evidence
Performance verification and validation testing included software verification and a non-significant risk clinical study. All criteria were met, demonstrating the device meets performance specifications.
Technological Characteristics
Stereoscopic high-definition digital video camera, workstation, and flat-panel 3D display. Includes TrueWare software for graphical overlay and guidance. Controlled via remote keyboard and touchpad mouse. Operates as an adjunct to surgical and slit lamp microscopes.
Indications for Use
Indicated for patients undergoing anterior segment ophthalmic surgery, including limbal relaxing incisions, capsulorhexis, and toric IOL positioning. Used as an adjunct imaging tool for preoperative and postoperative image capture and intraoperative guidance.
Regulatory Classification
Identification
An ophthalmic camera is an AC-powered device intended to take photographs of the eye and the surrounding area.
Special Controls
*Classification.* Class II (special controls). The device, when it is a photorefractor or a general-use ophthalmic camera, 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
TrueVision® Visualization System for Microsurgery (Class 1 Device)
Optronics EPIC Color Television Camera System (K963333)
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510(k): k101961
TrueVision 3D Visualization and Guidance System 7/14/2010
DEC 2 2 2010
# II: 510(k) Summary
Image /page/0/Picture/5 description: The image shows the logo for TrueVision Systems, Inc. The logo consists of a globe-like graphic on the left, followed by the word "TrueVision" in a bold, sans-serif font. Below "TrueVision" are the words "SYSTEMS, INC" in a smaller, sans-serif font. The logo is black and white.
## TrueVision® 3D Visualization and Guidance System
Submitter:
TrueVision Systems Inc. 114 E. Haley Suite L Santa Barbara, CA 93101 Tel: (805) 963-9700 Fax: (805) 963-9719
#### Official Correspondent:
A. Burton Tripathi, Ph.D. Vice President of Product Development 114 E. Haley St., Suite L Santa Barbara, CA 93101 Tel: 805-963-9700 Email: btripathi@truevisionsys.com
Date: June 30, 2010
| Device Trade Name | Classification Name | Common Name |
|-----------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|
| TrueVision® 3D Visualization<br>and Guidance System | Microscope, Surgical<br>Class I per 21 CFR<br>878.4700<br><br>Camera, Ophthalmic<br>Class II, per 21 CFR<br>886.1120<br><br>Picture archiving and<br>communications System<br>Class II, Per 21 CFR<br>892.2050 | Visualization and<br>Guidance System |
Product Codes: HKI, NFJ
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#### Substantial Equivalence:
The TrueVision® 3D Visualization and Guidance System is substantially equivalent to the following devices:
- TrueVision® Visualization System for Microsurgery, Class 1 Device 1) TrueVision Systems, Inc. Surgical Microscope/21CFR878.4700, EPT
- Optronics EPIC Color Television Camera System 2) Karl Storz Imaging Ophthalmic camera/21CFR 886.1850 K963333, HKI
- 3) OphthaVision Imaging System MRP Group, Inc. Ophthalmic camera/21CFR 886.1850 K980295. HKI
- IMAGEnet Professional PC Software, Digital Image Management 4) Software Topcon Corporation Picture archiving and communications system/21 CFR 892.2050 K082364, NFJ
#### Description of the Device Subject to Premarket Notification:
The TrueVision® 3D Visualization and Guidance System is a stereoscopic highdefinition digital video camera and workstation, which operates as an adjunct to the surgical microscope during cataract surgery and the slit lamp microscope during pre-operative and post-operative image capture. The visualization system displays real-time images during eve surgery on a flat-panel, high-definition digital 3D display device positioned for live video image viewing by the surgeon and surgical personnel in the operating room.
The Cataract and Refractive Toolset system combines the TrueVision FDAregistered Class 1 Device (TrueVision® 3D Visualization System for Microsurgery) with proprietary TrueWare™ software (controlled via remote keyboard with included touchpad mouse) to provide enhanced visualization and surgical quidance assistance to the surgeon during specific procedures such as Limbal Relaxing Incision, Capsulorhexis, and toric IOL positioning.
Using standard pre-operative clinical data, together with surgeon-driven, onscreen templates and guides, the Refractive Cataract Toolset provides graphical assistance to the surgeon as desired during the surgery. Guidance
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applications include incision templates to optimize the position of limbal relaxing incisions, sizing and positioning of capsulorhexis tears, and rotational alignment of toric intraocular lenses (toric IOL).
#### Indications for Use:
The TrueVision® 3D Visualization and Guidance System is an adjunct imaging tool that provides onscreen quidance with alignment, orientation, and sizing for eve surgery. The system is intended for use as a preoperative and postoperative image capture tool with visualization and quidance provided during anterior seqment ophthalmic surgical procedures, including limbal relaxing incisions. capsulorhexis and toric intraocular lens (toric IOL) positioning. The system utilizes surgeon confirmation at each step for planning and positioning of quidance templates.
## Performance Standards:
None. There are no mandatory performance standards for this type of device.
## Basis for Determination of Substantial Equivalence:
The TrueVision® 3D Visualization and Guidance System described in this submission is substantially equivalent to the predicate device(s) listed above. All of the devices are used in ophthalmic imaging applications, provide means for capture, storage, and manipulation of said images, and provide practitioners with tools to provide visualization or surgical guidance assistance. All of the devices contain similar system components (camera, processor, and display), and all are used on the same anatomical location. The minor differences between the TrueVision 3D Visualization and Guidance System and the listed predicate devices do not raise any new questions of safety or of effectiveness in comparison to the predicate devices.
#### Performance Data:
Performance verification and validation testing was completed to demonstrate that the device performance complies with specifications and requirements identified for the TrueVision® 3D Visualization and Guidance System. This was accomplished by software verification testing and a nonsignificant risk clinical study. All criteria for this testing were met and results demonstrate that the TrueVision® 3D Visualization and Guidance System meets all performance specifications and requirements.
#### Conclusions:
As described in this 510(k) Summary, all testing deemed necessary was conducted on the TrueVision® 3D Visualization and Guidance System to ensure that the device is safe and effective for its intended use and is substantially
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equivalent to legally marketed devices.
·
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus symbol, which is a staff with two snakes coiled around it. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
TrueVision Systems, Inc. c/o Dr. A. Burton Tripathi Vice President. Product Development 114 East Haley Street, Suite L Santa Barbara, CA 93101
DFC 2 2 2010
Re: K101861
Trade/Device Name: TrueVision 3D Visualization and Guidance System Regulation Number: 21 CFR 886.1120 Regulation Name: Ophthalmic Camera Regulatory Class: II Product Code: HKI, NFJ, EPT Dated: Not Dated Received: October 14, 2010
Dear Dr. Tripathi:
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. Iisting 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 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
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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/ucm115809.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,
Malvina B. Eydelman, M.D.
Director
Division of Ophthalmic, Neurological,
and Ear, Nose and Throat Devices
Office of Device Evaluation
Center for Devices and
Radiological Health
Enclosure
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510(k) Number (if known): Original Premarket Notification
Device Name: TrueVision® 3D Visualization and Guidance System
## Indications for Use:
DEC 2 2 2010
K101861
The TrueVision® 3D Visualization and Guidance System is an adjunct imaging tool that provides onscreen guidance with alignment, orientation, and sizing for eye surgery. The system is intended for use as a preoperative and postoperative image capture tool with visualization and guidance provided during anterior segment ophthalmic surgical procedures, including limbal relaxing incisions, capsulorhexis and toric intraocular lens (toric IOL) positioning. The system utilizes surgeon confirmation at each step for planning and positioning of guidance templates.
Prescription Use X
(Part 21 CFR 801 Subpart D)
Signature
(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
510(k) Number K101861
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.