The OPERA and OPERA eco are multiple-user, powered breast pumps intended to express and collect milk from the breasts of lactating women.
Device Story
OPERA and OPERA eco are powered breast pumps for lactating women; used in hospital or home settings. Device generates negative pressure via diaphragm mechanism to express milk; includes backflow protector to prevent milk from entering tubing. User interface features LCD display and switch controls for mode selection (Massage/Expression), vacuum level, and cycle adjustment. OPERA model includes internal rechargeable lithium polymer battery; OPERA eco is AC-powered. Healthcare providers or patients operate device to facilitate milk collection; output is expressed breast milk. Device benefits include efficient milk expression and support for breastfeeding.
Clinical Evidence
Bench testing only. Performance data includes electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), home healthcare environment compliance (IEC 60601-1-11), biocompatibility (ISO 10993), and internal protocols for vacuum/cycle settings, backflow protection, battery operation, and use-life.
Technological Characteristics
Powered diaphragm breast pump; Class II. Materials assessed per ISO 10993. Power: AC/DC adapter (100-240V) or internal Li-polymer battery (OPERA only). Features: 2 modes (Massage/Expression), adjustable vacuum (45-280 mmHg) and cycles. Includes backflow protector. Software level of concern: Moderate. Connectivity: None.
Indications for Use
Indicated for lactating women requiring expression and collection of breast milk. Suitable for multiple-user environments.
Regulatory Classification
Identification
A powered breast pump in an electrically powered suction device used to express milk from the breast.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.
August 30, 2019
Unimom Co. Sang-Hyun Hong President 110-19, Gajangsaneopseobuk-ro Osan-si, 18102 Gyeongg1-do KOREA
Re: K190810 Trade/Device Name: OPERA, OPERA eco Regulation Number: 21 CFR 884.5160 Regulation Name: Powered Breast Pump Regulatory Class: II
Product Code: HGX Dated: July 22, 2019 Received: July 29, 2019
Dear Sang-Hyun Hong:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. 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
{1}------------------------------------------------
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,
Sharon M. Andrews Assistant Division Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known)
K190810
Device Name OPERA & OPERA eco
Indications for Use (Describe)
The OPERA and OPERA eco are multiple-user, powered breast pumps intended to express and collect milk from the breasts of lactating women.
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
# CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
### 510(k) Summary – K190810 [As Required by 21 CFR 807.92]
#### Submitter's Information
| Submitter's Name: | Unimom Co. |
|-------------------|----------------------------------------------------------------------------------|
| Address: | 110-19, Gajangsaneopseobuk-ro, Osan-si,<br>Gyeonggi-do, 18102, KOREA [Zip.18102] |
| Contact Person: | Hong, Sang-Hyun |
| Telephone No.: | +82-70-8798-5577 |
| Fax No.: | +82-31-372-6782 |
| Email Address: | infounimom@naver.com |
#### Date Prepared
August 29, 2019
# Trade Name, Regulation Name, Classification
| Trade/Device Name | OPERA & OPERA eco |
|-----------------------|-----------------------|
| Common Name | Powered breast pump |
| Classification Number | 21 CFR 884. 5160 |
| Classification Name | Powered breast pump |
| Regulation Class | Class II |
| Product Code | HGX |
| Product Code Name | Pump, Breast, Powered |
#### Identification of Predicate Device
The identified predicate devices within this submission are shown as follow;
| 510(k) Number: | K180075 |
|------------------------|----------------------------|
| Applicant: | Unimom Co. |
| Trade/Device Name: | MINUET LCD, MINUET LCD eco |
| Classification Number: | 21 CFR 884. 5160 |
| Classification Name: | Powered breast pump |
| Regulation Class: | Class II |
| Product Code: | HGX |
{4}------------------------------------------------
Product Code Name:
Pump, Breast, Powered
The predicate device has not been subject to a design-related recall.
#### Description of the Device
The OPERA & OPERA eco are multiple-user. powered breast pumps intended to express and collect milk from the breasts of lactating women. The OPERA eco are provided non-sterile. Two models are available; Opera and Opera eco.
- "OPERA" (pink color): powered by the adapter (AD/DC adapter, INPUT: AC 100 ~240V, . 50/60Hz, OUTPUT: DC14V, 2A) or by the internal battery (Rechargeable Lithium polymer battery, 11.1 V, 2200 mAh).
- . "OPERA eco" (blue color): powered by the adapter (AD/DC adapter, INPUT: AC 100 ~240V, 50/60Hz, OUTPUT: DC14V, 2A).
The OPERA & OPERA eco consists of a group of hardware and software components. The hardware component(s) consist of:
- Opera or Opera eco pump body ●
- Breast Shield Set (Breast shield, K-POP Diaphragm, Bottle Disk, Bottle Cover, Bottle ● Cap, Bottle, Nipple, White Valve, Diaphragm Cap, Air Tube Connector, Silicone Massager)
- Adaptor
The OPERA & OPERA eco provide the following user features:
- 1) Two Modes
- Massage Mode: 5 Levels
- Expression Mode: 8 Levels
- 2) Adjustment of vacuum level/cycles
- 3) LCD Display, for user assistance/device status
Principle and Theory of Operation:
The Opera and Opera eco generate negative pressure on the breast and it moves diaphragm up and down to express and collect milk from the breasts of lactating women. To prevent backflow of breastmilk, Opera & Opera eco include a backflow protector on the top of breast shield. The inserted diaphragm blocks the upper side and bottom side of breast shield, which are the pathway of air and the breastmilk.
#### Indications for Use
The OPERA & OPERA eco are multiple-user, powered breast pumps intended to express and collect milk from the breasts of lactating women.
{5}------------------------------------------------
Substantial Equivalence Comparison
subject and predicate devices.
| | Proposed Device | Predicate Device |
|-------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Product Name | OPERA, OPERA eco | MINUET LCD, MINUET LCD eco |
| 510(k) Number | Not known | K180075 |
| Manufacturer | Unimom Co. | Unimom Co. |
| Product Code | HGX | HGX |
| Device Class | II | II |
| Indications for Use | The OPERA & OPERA eco are multiple- user, powered breast pumps intended to express and collect milk from the breasts of lactating women. | The MINUET LCD and MINUET LCD eco are multiple-user, powered breast pumps intended to express and collect milk from the breasts of lactating women. |
| Intended use environment | Hospital, Home environment | Hospital, Home environment |
| Specifications | | |
| Power source (Adapter) | AC/DC Adapter<br>- Rated input: AC 100~240V, 50/60Hz<br>- Rated output: DC14V, 2A | AC/DC Adapter with Micro USB Cable<br>- Rated input: AC 100~240V, 50/60Hz<br>- Rated output: 5Vdc, 2A |
| Power source (Battery) | Rechargeable Lithium Polymer Battery (Only for OPERA) | Rechargeable Lithium Polymer Battery (Only for MINUET LCD) |
| Pump type | Diaphragm | Diaphragm |
| Pump Options | Single or Double | Single or Double |
| Mode | 2 Modes<br>(Massage Mode, Expression Mode) | 2 Modes<br>(Massage Mode, Expression Mode) |
| Vacuum Levels | Massage Mode: 5 Levels Expression Mode: 8 Levels | Massage Mode: 7 Levels Expression Mode: 9 Levels |
| Vacuum Strength | 45 - 280 mmHg | 50 - 280 mmHg |
| Cycle Range | Massage Mode<br>: 60 – 100 cycles/min<br>Expression Mode<br>: 26 - 42 cycles / min | Massage Mode<br>: 23 – 120 cycles/min<br>Expression Mode<br>: 13 - 60 cycles / min |
| User Interface | Switch control<br>- Power, Vacuum / Cycle Up or Down<br>- Mode switch<br>LCD Display | Switch control<br>- Power, Vacuum / Cycle Up or Down<br>- Mode switch<br>LCD Display |
| Accessories | Air Tube<br>Breast Shield Kit with back-flow protector<br>Bottle<br>Bottle Cover<br>Nipple<br>Bottle Cap<br>Bottle Disk<br>Bottle Stand<br>Adapter<br>Air Tube Connector<br>Silicone Massager | Air Tube<br>Breast Shield Kit with back-flow protector<br>Bottle<br>Bottle Cover<br>Nipple<br>Bottle Cap<br>Bottle Disk<br>Bottle Stand<br>Adapter<br>B-Connector<br>Micro USB Cable<br>Silicone Massager<br>Micro USB Jack Cover |
| Backflow Protection | Yes<br>(Milk is prevented from entering the tubing) | Yes<br>(Milk is prevented from entering the tubing) |
| Proposed Device | Predicate Device | |
| Wipe with clean, damp cloth<br>- Breast Shield Kit: Boiling water | Wipe with clean, damp cloth<br>- Breast Shield Kit: Boiling water | |
{6}------------------------------------------------
The indications for use statement of the subject device is unchanged from the predicate device; accordingly, the subject and predicate device have the same intended use. The subject and predicate device have similar technological characteristics, and the differences in technological characteristics do not raise different questions of safety or effectiveness.
#### Summary of Performance Testing
The following performance data were provided in support of the substantial equivalence determination:
1) Electrical Safety, Electromagnetic Compatibility and Performance:
The OPERA & OPERA eco comply with the electrical safety and electromagnetic compatibility requirements established by the standards.
- Electrical Basic Safety and Essential Performance requirements in accordance with IEC 60601-1:2005/AM1:2012
- Electromagnetic Compatibility Testing in accordance with IEC 60601-1-2:2014 ●
- Medical electrical equipment and medical electrical systems used in the home healthcare environment . in accordance with IEC 60601-1-11:2015
#### 2) Software Validation
The OPERA & OPERA eco have a MODERATE level of concern. The software was designed and developed according to a software development process and was verified and validated. Software information is provided in accordance with FDA guidance:
- "The content of premarket submissions for software contained in medical devices, published on May ● 11, 2005"
#### 3) Biocompatibility
The OPERA & OPERA eco were assessed for biocompatibility per ISO 10993.
#### 4) Performance testing
Bench tests using internal test protocols to demonstrate device performance, including vacuum level settings, speed settings, backflow/cross-contamination protection, battery operation, and use-life.
#### Conclusion
The performance testing demonstrate that the OPERA eco (K190810) are substantially equivalent to the predicate device, MINUET LCD, MINUET LCD eco (K180075).
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.