K201294 · Guangdong Long Yao Electronic Technology Co., Ltd. · DQA · Nov 27, 2020 · Cardiovascular
Device Facts
Record ID
K201294
Device Name
Pulse Oximeter
Applicant
Guangdong Long Yao Electronic Technology Co., Ltd.
Product Code
DQA · Cardiovascular
Decision Date
Nov 27, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2700
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
The Pulse Oximeter is a non-invasive device intended for spot checking of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR). This portable device is indicated for use in adult patients in clinical institution and home environments.
Device Story
Device is a non-invasive, portable fingertip pulse oximeter; measures SpO2 and pulse rate via photoplethysmography. Sensor uses dual light sources (660 nm red, 905 nm infrared) applied to pulsating arteriolar vascular bed; photodetector converts light intensity into electronic signals. Ratio of light absorption during systole and diastole determines SpO2. Device powered by connection to smartphone; results displayed on Apple iPhone or Android phone. Used by clinicians or patients for spot-checking; no alarms; not for life-support. Output provides numerical SpO2 and PR values to assist in health monitoring.
Clinical Evidence
Clinical hypoxia testing performed on human adult volunteers per ISO 80601-2-61. Accuracy validated against co-oximetry (SaO2). Results support accuracy claims for the specified saturation range.
Technological Characteristics
Fingertip pulse oximeter; dual-wavelength (660nm/905nm) LED light source; photodetector sensor. Powered via smartphone connection. Biocompatibility per ISO 10993-5 (cytotoxicity) and ISO 10993-10 (irritation/sensitization). Complies with IEC 60601-1 (safety), IEC 60601-1-2 (EMC), and ISO 80601-2-61 (performance).
Indications for Use
Indicated for spot checking functional oxygen saturation (SpO2) and pulse rate (PR) in adult patients in clinical and home settings.
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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November 27, 2020
Guangdong Long Yao Electronic Technology Co., Ltd. % Kevin Wang Consultant Chonconn Medical Device Consulting Co., Ltd. Room 508, Block C, No. 1029 Nanhai Avenue, Nanshan District Shenzhen, Guangdong 518067 China
Re: K201294
Trade/Device Name: Pulse Oximeter Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DOA Dated: October 28, 2020 Received: October 30, 2020
Dear Kevin 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
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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 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 (QS) 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 medical devices and radiation-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,
Todd Courtney Assistant Director DHT1C: Division of ENT, Sleep Disordered Breathing, Respiratory and Anesthesia 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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Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2020
See PRA Statement below.
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
## Indications for Use
510(k) Number (if known)
Device Name Pulse Oximeter
Indications for Use (Describe)
The Pulse Oximeter is a non-invasive device intended for spot checking of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR). This portable device is indicated for use in adult patients in clinical institution and home environments.
| Type of Use (Select one or both, as applicable) | <span> <span style="padding-right: 20px;"> <span style="border: 1px solid black; display: inline-block; width: 13px; height: 13px; text-align: center; vertical-align: middle;"><b>X</b></span> Prescription Use (Part 21 CFR 801 Subpart D) </span> <span> <span style="border: 1px solid black; display: inline-block; width: 13px; height: 13px; text-align: center; vertical-align: middle;"></span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </span> |
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## 510(K) Summary
### Prepared in accordance with the requirements of 21 CFR Part 807.92
# K201294
### Prepared Date: 2020/11/16
#### 1. Submission sponsor
Name: Guangdong Long Yao Electronic Technology Co., Ltd.
Address: Unit A03, 2nd Floor, No. 19, Huali Road, Tianhe District, Guangzhou, Guangdong, P.R. China Contact person: Lei Wang
Title: General Manager
E-mail: 965731439@qq.com
Tel: +86 135 80508450
#### 2. Submission correspondent
Name: Chonconn Medical Device Consulting Co., Ltd.
Address: Room 508, Block C, No. 1029 Nanhai Avenue, Nanshan District, Shenzhen, Guangdong, P. R. China 518067
Contact person: Kevin Wang
E-mail: kevin@chonconn.com
Tel: +86-755 33941160
| Trade/Device Name | Pulse Oximeter |
|-------------------|---------------------------------|
| Model | LYOX01 |
| Common Name | Fingertip Pulse Oximeter |
| Regulatory Class | Class II |
| Classification | 21CFR 870.2700 / Oximeter / DQA |
| Submission type | Traditional 510(K) |
#### Subject Device Information 3.
#### 4. Predicate Device
Manufacturer: Shenzhen Aeon Technology Co., Ltd. Device name: Pulse Oximeter 510(K) Number: K190869
#### 5. Device Description
The Pulse Oximeter is intended for use in measuring and displaying functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR).
The Pulse Oximeter works by applying a sensor to a pulsating arteriolar vascular bed. The sensor contains
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a dual light source and photo detector. The one wavelength of light source is 660 nm, which is red light; the other is 905 nm, which is Infrared light. Skin, bone, tissue, and venous vessels normally absorb a constant amount of light over time. The photodetector in finger sensor 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 translated into an oxygen saturation measurement. This measurement is referred to as SpO2. The Pulse Oximeter is powered by smart phone and the measurement result will display on an Apple iPhone and Android phone.
The device is a spot-check pulse oximeter and does not include alarms. The device is not intended for lifesupporting or life-sustaining.
#### Intended use & Indication for use 6.
The Pulse Oximeter is a non-invasive device intended for spot checking of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR). This portable device is indicated for use in adult patients in clinical institution and home environments.
| Features | Subject Device<br>Pulse Oximeter | Predicate Device K190869<br>AEON Pulse Oximeter | Compariso<br>n | |
|------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|
| Applicant | Guangdong Long Yao<br>Electronic Technology Co.,<br>Ltd. | Shenzhen Aeon Technology<br>Co., Ltd. | / | |
| Classification<br>Regulation | 21CFR 870.2700 | 21CFR 870.2700 | Same | |
| Classification and<br>Code | Class II, DQA | Class II, DQA | Same | |
| Common name | Fingertip Pulse Oximeter | Fingertip Pulse Oximeter | Same | |
| Intended use | The Pulse Oximeter is a non-<br>invasive device intended for<br>spot checking of functional<br>oxygen saturation of arterial<br>hemoglobin (SpO2) and pulse<br>rate (PR). This portable device<br>is indicated for use in adult<br>patients in clinical institution<br>and home environments. | The Pulse Oximeter is a non-<br>invasive device intended for<br>spot checking of functional<br>oxygen saturation of arterial<br>hemoglobin (SpO2) and pulse<br>rate (PR). This portable device<br>is indicated for use in adult<br>patients in clinical institution<br>and home environments. | Same | |
| Patient populations | Adults | Adults | Same | |
| Principle | The device displays numerical<br>values for functional oxygen<br>saturation of arterial | The device displays numerical<br>values for functional oxygen<br>saturation of arterial | Same | |
| Features | | Subject Device | Predicate Device K190869<br>AEON Pulse Oximeter | Comparison |
| | | Pulse Oximeter | | n |
| | | hemoglobin (SpO2) and pulse<br>rate by measuring the<br>absorption of red and infrared<br>(IR) light passing through<br>perfused tissue. Changes in the<br>absorption caused by the<br>pulsation of blood in the<br>vascular bed are used to<br>determine oxygen saturation<br>and pulse rate. | hemoglobin (SpO2) and pulse<br>rate by measuring the<br>absorption of red and infrared<br>(IR) light passing through<br>perfused tissue. Changes in the<br>absorption caused by the<br>pulsation of blood in the<br>vascular bed are used to<br>determine oxygen saturation<br>and pulse rate. | |
| | Light Emitting | Red: 660<br>Infrared: 905nm | Red: 660<br>Infrared: 905nm | Same |
| | Power source | Cell phone | 2 AAA alkaline batteries | Different (1) |
| | Display data | SpO2%, PR | SpO2%, PR | Same |
| | SpO2 Measuring<br>Range | 50%-100% | 35%-100% | Different (2) |
| | SpO2 Resolution | 1% | 1% | Same |
| | SpO2 Accuracy | 70~100%, ±3%;<br>0-69%, unspecified; | 70~100%, ±3%;<br>0-69%, unspecified; | Same |
| | PR Range | 30 bmp – 240 bmp | 30 bmp – 250 bmp | Different (3) |
| | PR Resolution | 1 bpm | 1 bpm | Same |
| | PR Accuracy | ± 1 | ± 2 | Different (4) |
| | Sterile | No | No | Same |
| | Application site | Finger | Finger | Same |
| | Electrical Safety | Complied with IEC 60601-1 | Complied with IEC 60601-1 | Same |
| | EMC | Complied with IEC 60601-1-2 | Complied with IEC 60601-1-2 | Same |
| | Performance | Complied with ISO 80601-2-<br>61 | Complied with ISO 80601-2-<br>61 | Same |
| Biocompatibility | Cytotoxicity | Complied with ISO 10993-5 | Complied with ISO 10993-5 | Same |
| | Skin Irritation | Complied with ISO 10993-10 | Complied with ISO 10993-10 | Same |
| | Sensitization | Complied with ISO 10993-10 | Complied with ISO 10993-10 | Same |
#### Comparison to the Predicate Device 7.
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Justifications for differences between proposed device and the predicate device are shown as below: Different (1): The power source is different. The subject device is powered by cell phone through connector cable. The predicate device is powered by internal battery. The electricity safety testing was conducted according to IEC 60601-1: 2012. Thus, this difference does not raise different questions of safety and effectiveness.
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Different (2): The SpO2 measuring range is different. The SpO2 measurement of the subject device was validated according to ISO 80601-2-61. Thus, this difference does not raise different questions of safety and effectiveness.
Different (3) & (4): The pulse rate measuring range and accuracy is different. The PR measurement of the subject device was validated according to declared range and accuracy. Thus, this difference does not raise different questions of safety and effectiveness.
#### 8. Performance Data
The following performance data were provided in support of the substantial equivalence determination.
### Biocompatibility testing
The biocompatibility evaluation for the Pulse Oximeter was conducted in accordance with the FDA Guidance for Industry and Food and Drug Administration Staff: Use of International Standard ISO 10993-1. "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The testing included the following:
- . Cytotoxicity
- Sensitization .
- Irritation .
The subject devices are considered surface contacting for a duration of not exceed 24 hours.
### Non-clinical data
The Pulse Oximeter has been tested according to the following standards:
- . IEC 60601-1-2005+CORR.1:2006+CORR.2:2007+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 tests
- ISO 80601-2-61: 2017 Medical Electrical Equipment Part 2-61: Particular Requirements for . Basic Safety and Essential Performance of Pulse Oximeter Equipment.
### Clinical data
Clinical studies were conducted to verify the accuracy of proposed device. The clinical studies were conducted per following standards:
- ISO 80601-2-61: 2017 Medical Electrical Equipment Part 2-61: Particular Requirements for . Basic Safety and Essential Performance of Pulse Oximeter Equipment.
- Pulse Oximeters-Premarket Notification Submissions: Guidance for Industry and Food and . Drug Administration Staff
Clinical testing has been performed under an approved protocol with subject informed consent. Clinical hypoxia test results were obtained in human adult volunteers to validate the accuracy of Pulse Oximeter
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versus arterial oxygen saturation (SaO2) as determined by co-oximetry. Clinical test results support device accuracy claims for the specified saturation range.
## 9. Conclusion
Performance testing and compliance with voluntary standards demonstrate that the proposed subject device is substantially equivalent to the predicate device. The subject device has the same intended use as the predicate device, and the technological differences do not raise different questions of safety and effectiveness.
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.