K113151 · Abbott Medical Optics, Inc. · GEX · Mar 8, 2012 · General, Plastic Surgery
Device Facts
Record ID
K113151
Device Name
IFS LASER SYSTEM
Applicant
Abbott Medical Optics, Inc.
Product Code
GEX · General, Plastic Surgery
Decision Date
Mar 8, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The iFS Laser System is an ophthalmic surgical laser indicated for use: - In the creation of a corneal flap in patients undergoing LASIK surgery or other in the Greation on initial lamellar resection of the cornea - In patients undergoing surgery or other treatment requiring initial lamellar resection of the cornea - In patients undergoing surgery or other treatment requiring initial lamellar m pallents undergoing Surgery of Unior treatment of corneal ring segments - In lamellar keratoplasty and corneal harvesting - In the creation of a lamellar cut/resection of the cornea for lamellar keratoplasty in the creation of a familiar sucting cutfincision for penetrating keratoplasty - In patients undergoing ophthalmic surgery or other treatment requiring arcuate cuts/incisions in the cornea, penetrating and/or intrastromal
Device Story
iFS Laser System is a precision ophthalmic surgical laser; uses focused femtosecond laser pulses to create corneal incisions and separate tissues. Operates via precise micro-photodisruptions at laser focus; system scans thousands of pulses per second to produce continuous incisions. Delivered through disposable applanation lens contacting cornea under low vacuum. Used in clinical settings by physicians. Output is physical corneal tissue separation/incision. Assists surgeons in LASIK, keratoplasty, and arcuate incision procedures; benefits patients by enabling precise, controlled corneal surgery.
Clinical Evidence
Clinical trial enrolled 21 subjects in a non-randomized, two-arm study. Primary safety endpoint (adverse events) met. No eyes with baseline BSCVA 20/20 or better had post-op BSCVA worse than 20/40. No induced refractive astigmatism >2.00D. No statistically significant differences in endothelial cell counts or worsening of ophthalmic symptoms (glare, halos, dry eye) compared to fellow eyes. Bench testing confirmed pattern fidelity for depth, position, angle, and diameter at 95% confidence interval. Animal studies (rabbits) confirmed safety of penetrating and intrastromal incisions.
Technological Characteristics
Femtosecond laser system; uses focused laser pulses for photodisruption. Includes disposable applanation lens. Complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-22. Biocompatibility per ISO 10993-5 and ISO 10993-10. Sterilization per AAMI 11137-1/2. System performs automated scanning of laser pulses to create incisions.
Indications for Use
Indicated for patients undergoing ophthalmic surgery requiring corneal lamellar resection, corneal flap creation for LASIK, corneal ring segment tunnel creation, lamellar/penetrating keratoplasty, corneal harvesting, or arcuate incisions (penetrating or intrastromal).
Regulatory Classification
Identification
(1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
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KI13151
## 14.0 510(k) SUMMARY
This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92(a).
Submitter's name, address, telephone number, contact person, and date summary prepared:
a. Applicant:
Abbott Medical Optics Inc. 1700 East St. Andrew Place Santa Ana, CA 92705 · Tel: 714-247-8930
b. Contact Person:
Keslev Gallagher, MS Regulatory Affairs Manager 1700 East St. Andrew Place Santa Ana, CA 92705 Tel: 714-247-8930 Fax: · · 714-247-8784 Email: kesley.gallagher@amo.abbott.com
c. Date of Summary Preparation: March 7, 2012
NAME OF DEVICE, INCLUDING TRADE NAME AND CLASSIFICATION NAME:
Trade/Proprietary Name: iFS Laser System Common/Usual Name: Laser Classification Name: Keratome Classification Code(s): 79 GEX, 86 HNO
IDENTIFICATION OF THE PREDICATE DEVICE OR LEGALLY MARKETED DEVICE OR DEVICES TO WHICH SUBSTANTIAL EQUIVALENCE IS BEING CLAIMED:
| <b>510(k) #</b> | <b>Trade Name</b> | <b>Manufacturer</b> |
|-----------------|------------------------|-----------------------------------------|
| K101626 | LenSx 550 Laser System | LenSx Lasers |
| K073404 | IntraLase FS Laser | IntraLase Corp. |
| K863725 | Cataract Diamond Knife | Medical Technology<br>Development Corp. |
A DESCRIPTION OF THE DEVICE THAT IS THE SUBJECT OF THE 510(K), INCLUDING EXPLANATION OF HOW THE DEVICE FUNCTIONS, BASIC SCIENTIFIC CONCEPTS, SIGNIFICANT PHYSICAL AND PERFORMANCE CHARACTERISTICS (DESIGN, MATERIAL, PHYSICAL PROPERTIES):
The iFS Laser System intended use is a precision ophthalmic surgical laser designed for use as an ophthalmic surgical laser. It is indicated for use as follows:
- . In the creation of a corneal flap in patients undergoing LASIK surgery or other treatment requiring initial lamellar resection of the cornea
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- . In patients undergoing surgery or other treatment requiring initial lamellar resection of the cornea
- . In patients undergoing surgery or other treatment requiring initial lamellar resection of the cornea to create tunnels for placement of corneal ring seaments
- . In lamellar keratoplasty and corneal harvesting
- In the creation of a lamellar cut/resection of the cornea for lamellar keratoplasty . and in the creation of a penetrating cut/incision for penetrating keratoplasty
- In patients undergoing ophthalmic surgery or other treatment requiring arcuate . cuts/incisions, both penetrating and intrastromal
The iFS Laser System uses focused femtosecond laser pulses to create incisions and separates tissues in the cornea. Corneal dissection with the iFS Laser is achieved through precise individual micro-photodisruptions of tissue, which are controlled by repeatedly repositioning the laser focus. The light pulse is focused into a sufficiently small spot in order to achieve photodisruption of the tissue inside the focus. A tiny volume of tissue, a few microns in diameter, is thereby photodisrupted at the laser focus. The surgical effect is produced by scanning thousands of individual pulses per second to produce continuous incisions or tissue separation. These laser pulses are delivered through a disposable applanation lens that contacts the cornea while fixating the eye under low vacuum.
STATEMENT OF HOW THE TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE COMPARE TO THOSE OF THE PREDICATE OR LEGALLY MARKETED DEVICE:
The technological characteristics of the iFS Laser System are substantially equivalent to those cleared under K101626 and K073404 for corneal resections and incisions. No new software and/or hardware were required for the additional indication for arcuate incisions for the iFS Laser System.
## BRIEF SUMMARY OF NONCLINICAL TESTS AND RESULTS:
The iFS Laser System has undergone testing and is in compliance with applicable safety standards. The iFS Laser System was able to create arcuate incisions, both penetrating and intrastromal, safely and effectively. Thus, the iFS Laser System and the predicate devices have similar safety, effectiveness and performance profiles.
## APPLICABLE STANDARDS (LASER AND PATIENT INTERFACE):
- IEC 60601-1 Medical Electrical Equipment General Requirements for Safety, . 2nd edition, Amendment 2
- IEC 60601-1-2 Medical Electrical Equipment -- Electromagnetic Compatibility, . 200 Edition, Amendment 1
- · IEC 60601-2-22 Medical Electrical Equipment Safety of Diagnostic and Therapeutic Laser Equipment, 2nd Edition, Amendment 2
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- · ISO 10993-10:2002 Biological Evaluation of Medical Devices Part 10: Tests for Irritation and Delayed Type Hypersensitivity
- · ISO 10993-5:2009 Biological Evaluation of Medical Devices Part 5 Tests for In Vitro Cytotoxicity
- AAMI 11137-1:2006/(R) 2010 Sterilization of Health Care Products Radiation - Part 1: Requirements for Development
- · AAMI 11137-2:2006/(R) 2010 Sterilization of Health Care Products Radiation - Part 2: Establishing the Sterilization Dose
## Pattern Fidelity Testing:
Data were collected from the iFS Laser System to measure depth pattern fidelity for arcuate incisions at the 95% confidence interval. All results met the 95% confidence acceptance criteria. Data were additionally collected from the iFS Laser System to measure pattern fidelity for position, angle and diameter for arcuate incisions at the 95% confidence interval. All results met the 95% confidence acceptance criteria.
## HUMAN CADAVER EYE TESTING:
An AMO directed study was executed to determine the effectiveness of laser parameters in the creation of arcuate incisions in the human cadaver eye model. The iFS Laser System was used to cut intrastromal and penetrating arcuate incisions in the human cornea. For comparison, a standard radial keratotomy diamond blade was used to create penetrating incisions. Results of the study indicate that the iFS Laser System can create single or paired arcuate incisions. With appropriate depth in glass settings, the intrastromal incision can be created without risking perforation of either corneal surface.
#### Animal Testing:
AMO conducted a series of studies in rabbits to evaluate the safety of penetrating and intrastromal incisions. The first studies assessed the initial safety of the intrastromal arcuate incisions. Subsequent studies, including a GLP rabbit study, were performed to demonstrate safety of penetrating and intrastromal arcuate incisions when performed by the iFS Laser System. The GLP study conclusively demonstrates the safety of arcuate incisions in the cornea, both penetrating and intrastromal, when performed by the iFS Laser System.
#### Clinical Trial Results:
A clinical trial assessed the iFS Laser System for demonstration of safety of the intrastromal arcuate incisions in the cornea. A total of 21 subjects were enrolled at one investigative site in a non-randomized, two-arm study design based on cataract status.
No eyes in this study with a BSCVA of 20/20 or better at baseline had a post-operative BSCVA of worse than 20/40. No eyes in this study had induced manifest refractive astigmatism of greater than 2.00 diopters. No eyes experienced an adverse event.
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Endothelial cell counts (central and two peripheral endothelium locations) were compared between the study and non-study fellow eyes. No statistically significant differences were observed.
Ophthalmic symptoms such as glare, halos, clarity, dry eve, photophobia, gritty/scratchy/sandy feelings in eye and vision quality were assessed by each subject for both the study and non-study fellow eyes at baseline and post-operative visits. The changes in symptoms were evaluated and there were no statistically significant worsening symptoms or quality of vision.
The primary safety criterion of rate of adverse events was met, as well as other secondary variables of safety and surgical experience. The results of this study indicated that the iFS Laser System can safely perform intrastromal arcuate incisions in the cornea.
## Conclusion:
The laboratory and animal study data support that the arcuate incisions can be executed by the iFS Laser System as prescribed by the physician. These data demonstrate the iFS Laser System is safe and effective when used in conjunction with the directions for use and inherent warnings.
. .
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Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized caduceus, which is a symbol of medicine, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circle around the caduceus. The caduceus is depicted as a stylized human figure with outstretched arms, and the words are written in a simple, sans-serif font. The logo is black and white.
# DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Abbott Medical Optics. Inc. c/o Ms. Keslev E. Gallagher Project Manager, Refractive Regulatory Affairs 1700 E. St. Andrew Place Santa Ana, CA 92705
MAR - 8 2012
Re: K113151
Trade/Device Name: iFS Laser System Regulation Number: 21 CFR 878.4810
Regulation Name: Laser Surgical Instrument for Use in General and Plastic Surgery and in
Dermatology
Regulatory Class: Class II Product Code: GEX, HNO Dated: February 15, 2012 Received: February 17, 2012
Dear Ms. Gallagher:
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. Kesley E. Gallagher
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/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/ResourcesforYou/Industry/default.htm.
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Sincerely yours,
Kesia Alexander
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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# CDRH INDICATIONS FOR USE
510(k) Number (if known):
KII 315 l
Device Name(s):
iFS Laser System
Indications for Use:
The iFS Laser System is an ophthalmic surgical laser indicated for use:
- In the creation of a corneal flap in patients undergoing LASIK surgery or other . in the Greation on initial lamellar resection of the cornea
- In patients undergoing surgery or other treatment requiring initial lamellar . resection of the cornea
- In patients undergoing surgery or other treatment requiring initial lamellar . m pallents undergoing Surgery of Unior treatment of corneal ring segments
- · In lamellar keratoplasty and corneal harvesting
- In the creation of a lamellar cut/resection of the cornea for lamellar keratoplasty . in the creation of a familiar sucting cutfincision for penetrating keratoplasty
- In patients undergoing ophthalmic surgery or other treatment requiring arcuate ● cuts/incisions in the cornea, penetrating and/or intrastromal
Prescription Use: X (Part 21 CFR 801 Subpart D)
AND/OR
Over-the-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
| (Division Sign-Off) | |
|-----------------------------------------------|---------|
| Division of Ophthalmic, Neurological and Ear, | |
| Nose and Throat Devices | |
| 510(k) Number | K113151 |
Page 1 of 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.