K190954 · Chongqing Bio Newvision Medical Equipment , Ltd. · HKI · Jan 22, 2020 · Ophthalmic
Device Facts
Record ID
K190954
Device Name
Fundus Camera
Applicant
Chongqing Bio Newvision Medical Equipment , Ltd.
Product Code
HKI · Ophthalmic
Decision Date
Jan 22, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 886.1120
Device Class
Class 2
Indications for Use
The Fundus Camera RetiCam 3100 is intended to capture digital images of the posterior and external structures of the eye without the use of a mydriatic agent and is intended for use as an aid to clinicians in the evaluation, diagnosis and documentation of ocular health.
Device Story
RetiCam 3100 is a non-mydriatic fundus camera; captures digital images of posterior/external eye structures. Operates via monocular indirect ophthalmoscopy; uses infrared LED for observation/alignment and white LED flash for image capture. Features include motorized X, Y, Z platform for optical module positioning; internal 9-point fixation; touch screen interface. Used in clinical settings by eye care professionals. System performs real-time image display, digital caliper measurements, area measurements, image comparison, and montage. Output assists clinicians in evaluating ocular health; aids diagnosis and documentation. Benefits include non-invasive imaging without pupil dilation, enabling broader patient access.
Clinical Evidence
No clinical data. Bench testing only, including resolving power, field of view, focus range, and pixel pitch verification per ISO 10940, plus electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), and biocompatibility (ISO 10993).
Technological Characteristics
Optical module with infrared/white LED light sources; CMOS sensor; motorized X-Y-Z platform. Dimensions/form factor: desktop unit with chin rest. Connectivity: USB 2.0, VGA, Network Port. Software: Integrated computer system with touch screen. Standards: ISO 10940, ISO 15004-1/2, ANSI Z80.36-2016, IEC 60601-1, IEC 60601-1-2, ISO 10993-5/10.
Indications for Use
Indicated for patients requiring digital imaging of posterior and external eye structures without mydriatic agents; intended as an aid to clinicians for evaluation, diagnosis, and documentation of ocular health.
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.
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Chongqing Bio NewVision Medical Equipment Ltd. % Ray Wang Beijing Believe-Med Technology Service Co., Ltd. R912, B#15, XiYueHui, No.5, YiHe North Rd., Fangshan District Beijing, 102401 CHINA
Re: K190954
Trade/Device Name: Fundus Camera RetiCam 3100 Regulation Number: 21 CFR 886.1120 Regulation Name: Ophthalmic Camera Regulatory Class: Class II Product Code: HKI Dated: December 13, 2019 Received: December 16, 2019
Dear Ray Wang:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
for Tieuvi Nguyen, Ph.D. Director DHT1A: Division of Ophthalmic Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known): K190954
Device Name Fundus Camera RetiCam 3100
Indications for Use (Describe)
The Fundus Camera RetiCam 3100 is intended to capture digital images of the posterior and external structures of the eye without the use of a mydriatic agent and is intended for use as an aid to clinicians in the evaluation, diagnosis and documentation of ocular health.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(K) SUMMARY
This 510(k) Summary information is being submitted in accordance with requirements of SMDA 1990 and Title 21, CFR Section 807.92.
## APPLICANT INFORMATION
Date of Preparation: 01/20/2020
Sponsor Identification
## Chongqing Bio NewVision Medical Equipment Ltd.
#1-10, Floor 9th of building #4, Group 2N of 2nd Project, Fulicheng Zhihuiguoji, Shapingba District, 401331 Chongqing, PEOPLE'S REPUBLIC OF CHINA
Contact Person: Wang Hao, Quality Manager Tel: 86-13657617625 Fax: 86-23-65456482 Email: wh(@fortune-newvision.com
Designated Submission Correspondent: Mr. Ray Wang Beijing Believe-Med Technology Service Co., Ltd. Rm.912, Building #15, XiYueHui, No.5, YiHe North Rd., FangShan District BeiJing, China 102401Tel: +86-18910677558 Fax: +86-10- 56335780 Email: ray.wang@believe-med.com
## IDENTIFICATION OF SUBJECT DEVICE
Trade Name: Fundus Camera RetiCam 3100 Regulation Number:21 CFR 886.1120 Regulation Name: camera, ophthalmic, ac-powered Classification: II Product Code: HKI
# INDICATIONS FOR USE
The Fundus Camera RetiCam 3100 is intended to capture digital images of the posterior and external structures of the eye without the use of a mydriatic agent and is intended for use as an aid to clinicians in the evaluation, diagnosis and documentation of ocular health.
# DEVICE DESCRIPTION
The RetiCam 3100 fundus camera is capable to capture, display, story, manage, process digital images of the posterior and external structures of the eye continuously, in real time.
The RetiCam 3100 fundus camera displays color fundus images continuously, in real time. The fundus
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digital image acquisition and image processing system is capable to perform measurement of the length (digital caliper), and perform area measurements, image comparison and image montage.
The RetiCam 3100 fundus camera function module includes: optical module, mobile platform module, power supply module, control module, chin rest module.
#### Optical Module
The optical module is responsible for providing background light illumination, flash shooting, fixing lamp control, lens focal length adjustment and pupil monitoring of patients when the fundus camera works. The optical module mainly consists of two parts: the light source module and the lens light path module.
- 1) The light source component is the source of the light source when the product works, including background light, fixation light and flash when shooting.
- 2) The lens light path is responsible for reflecting the patient's fundus image to the digital camera. The functions of lens focusing, pupil size switching and double camera pupil monitoring are used to ensure that the patient's fundus image can be presented clearly and reliably.
#### Mobile Platform Module
This module is mainly responsible for control of the position of optical module (i.e. up, down, left, right, back and forth movement of the optical module). This includes X, Y, Z axes, which are designed with servo motor and bearing, which are controlled by PCB board in the control module.
#### Power Supply Module
Power supply to each module through medical switching power supply.
#### Control Module
To enable operators to control the product, understand the working status of the product, observe the patient's condition, and carry out the corresponding inspection work normally.
There is a computer system integrated in the product, the input and output function are realized by touch screen display.
### Chin Rest Module
To place the patient's head and keep the patient's eyes stable and easy to observe.
# IDENTIFICATION OF PREDICATE DEVICE(S)
Primary Predicate Device 510(k) Number: K122572 Product Name: iCam Fundus Camera Manufacturer: Optovue, Inc.
Secondary Predicate Device 510(k) Number: K101935 Product Name: Digital Retinography System (DRS) Manufacturer: CENTERVUE SPA
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# NON-CLINICAL TESTING
Non clinical tests were conducted to verify that the proposed device met all design specifications as designed Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
- AAMI/ANSI/ES 60601-1:2005+A1:2012, Medical Electrical Equipment- Part 1: General ● requirements for basic safety and essential performance
- IEC 60601-1-2:2014. Medical Electrical Equipment-Part 1-2: General Requirements for Basic Safety . and Essential Performance - Collateral Standard: Electromagnetic Compatibility-Requirements And ISO 15004-1:2006 Ophthalmic instruments - Fundamental requirements and test methods -Part 1: General requirements applicable to all ophthalmic instruments
- ISO 15004-2:2007 Ophthalmic instruments -- Fundamental requirements and test methods --Part 2: Light hazard protection
- ISO 10940:2009 Ophthalmic instruments Fundus cameras ●
- ISO 10993-5:2009, Biological Evaluation of Medical Device, Part 5-Tests for Vitro cytotoxicity.
- . ISO 10993-10:2010 Standard, Biological Evaluation of Medical Device, Part 10-Test for irritation and delay-type hypersensitivity
- . ANSI Z80.36-2016 American National Standard for Ophthalmics - Light Hazard Protection for Ophthalmic Instruments
| | Specification | Test Results | Testing Basis |
|-------------------------------------------|--------------------------------------------------------------------------|----------------------------------|------------------|
| Resolving Power (Field<br>of view > 30° ) | Centre 2: 60lp/mm<br>Middle (r/2) 2: 40lp/mm<br>Periphery (r) 2: 25lp/mm | 60 lp/mm<br>40 lp/mm<br>25 lp/mm | 4.2 of ISO 10940 |
| Tolerance of angular<br>field of view | 50° ±5% | 48.0° | |
| Tolerance of pixel pitch | 6.45 um ±7% | 6.59 | |
| Range of Focus | -15D to +15D | Meet the<br>specification | |
Summary of the results of performance testing and the device requirements based on ISO 10940
# CLINICAL TEST CONCLUSION
No clinical study is included in this submission.
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# SUBSTANTIALLY EQUIVALENT (SE) COMPARISON
Table 1 Comparison of Technology Characteristics
| Item | Proposed Device | Primary Predicate Device (K122572) | Secondary Predicate Device (K101935) | Remark |
|------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| Device name | Fundus Camera<br>RetiCam 3100 | iCam Fundus Camera | Digital Retinography System (DRS) | / |
| Classification Name | Ophthalmic Camera | Ophthalmic Camera | Ophthalmic Camera | SAME |
| Product Code | HKI | HKI | HKI | SAME |
| Regulation Number | 886.1120 | 886.1120 | 886.1120 | SAME |
| Comparison<br>Statement | The proposed device has same classification information as the predicate device. | | | |
| Intended Use | The Fundus Camera RetiCam 3100 is<br>intended to capture digital images of the<br>posterior and external structures of the eye<br>without the use of a mydriatic agent and is<br>intended for use as an aid to clinicians in<br>the evaluation, diagnosis and<br>documentation of ocular health. | The iCam takes digital images of the<br>posterior and external structures of the eye<br>without the use of a mydriatic agent and is<br>intended for use as an aid to clinicians in the<br>evaluation, diagnosis and documentation of<br>ocular health. | The CenterVue Digital Retinography<br>System DRS is intended for taking<br>digital images of a human retina<br>without the use of a mydriatic agent. | SAME |
| Usage | Prescription Use | Prescription Use | Prescription Use | SAME |
| Comparison<br>Statement | The proposed device has similar intended use as the predicate device. | | | |
| Main Unit Technical Specifications | | | | |
| Operation Principle | The optical design of fundus camera is based on the principle of monocular indirect ophthalmoscopy.<br>1. Fundus observation<br>A build in light ray from the infrared light LED source to illuminate the fundus. Alignment of the device is performed by build in eye<br>tracking indicator and working distance indicator to adjust system to best XYZ position automatically. | | | |
| | | | | |
| | 2. Image capture: | | | |
| | System use split-image technique to do image focus adjustment automatically to capture the best quality of image. White light from | | | |
| | LEDs Flash module irradiates the fundus. The light reflected from eye portions forms an image, and the image is captured by built-in | | | |
| | color CMOS camera module for fundus image capture. | | | |
| Light Source | Observation: Infrared LED | | | SAME |
| | | Image capture: White LED | | |
| Eye Fixation | Internal 9 points | Internal 6 points | Not Available | Analysis 1 |
| Alignment | Manual focus tracking | Manual focus tracking | Automatic | SAME |
| Image Resolution | 2304 x 1728 (4 MP) | 1.3 MP | 2592 x 1944 (5 MP) | Analysis 2 |
| Field of view | 50 degrees | 45 degrees | 45 degrees | Analysis 3 |
| Operation Range | From -15 D to +15D | From -15 D to +15D | From -15 D to +15D | SAME |
| Interface | USB2.0, VGA, Network Port | USB 2.0 | USB 2.0 | Analysis 4 |
| Minimum Pupil Size | 3.0 mm | 4.0 mm | 4.0 mm | Analysis 5 |
| Working Distance | 35 mm | 25 mm | 37 mm | Analysis 6 |
| Power Supplier | A.C. 100-240 V, 50/60 Hz, 220 VA | AC100V to 240V, 50/60Hz | 100-240 VAC, 50/60 Hz | SAME |
| Comparison Statement: | The proposed device has the similar main unit specifications with the predicate device. Please refer to the difference analysis below the table | | | |
| Applied Standards: | | | | |
| Biocompatibility | ISO10993-5&ISO10993-10 | ISO10993-5&ISO10993-10 | ISO10993-5&ISO10993-10 | SAME |
| Electrical Safety | IEC60601-1 | IEC60601-1 | IEC60601-1 | SAME |
| EMC | IEC60601-1-2 | IEC60601-1-2 | IEC60601-1-2 | SAME |
| Performance | ISO 15004-1<br>ISO 15004-2<br>ISO 10940<br>ANSI Z80.36-2016 | ISO 15004-1<br>ISO 15004-2<br>ISO 10940 | ISO 15004-2<br>ISO 10940 | SAME |
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# Substantially Equivalent (SE) Conclusion
The subject device has differences with predicate device, the difference analysis shown as followings:
- 1. The eye fixation points are more than predicate device, it provides more different angle of fundus images.
- 2. The higher pixel provides high resolution image, it does not adversely affect safety and effectiveness.
- The larger field view provides bigger observation range, it does not adversely affect safety and 3. effectiveness.
- More options are available for data transfer interface, all interface used are international standard 4. interface, it does not adversely affect safety and effectiveness.
- న్. The smaller minimum pupil size could be applied to more wider patient population with same quality fundus images.
- The working distance is changed by the different framework of device, it does not adversely affect 6. safety and effectiveness.
Therefore, the above differences between the proposed device and predicate device do not affect the basic design principle, usage, effectiveness and safety of the subject device. There is no new technology used in the subject device.
Conclusion: The proposed device is Substantially Equivalent (SE) in safety and effectiveness to the selected predicate devices
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.