K151783 · Abbott Medical Optics, Inc. · HQC · Sep 2, 2015 · Ophthalmic
Device Facts
Record ID
K151783
Device Name
COMPACT INTUITIV Multiple-Use Pack
Applicant
Abbott Medical Optics, Inc.
Product Code
HQC · Ophthalmic
Decision Date
Sep 2, 2015
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 886.4670
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The OPO85 is used with the COMPACT INTUITIV System. The OPO85 is sterilized using Ethylene Oxide and is designed for use up to 20 times. Following the first use, the user then follows cleaning and sterilization instructions specified below for up to 19 additional cleaning/sterilization cycles for a total of 20 uses when used according to the Instructions for Use.
Device Story
Reusable phacoemulsification fluidics pack; accessory for COMPACT INTUITIV System. Provides fluid path for irrigation and aspiration during cataract surgery. Consists of housing manifold, irrigation/aspiration tubing, inlet connector, and drain pump connection. Used in surgical setting by ophthalmologists. Supports peristaltic aspiration via tubing interface and molded cartridge to generate fluid outflow from eye. Reusable up to 20 times (initial use plus 19 reprocessing cycles). Facilitates lens removal; improves surgical efficiency through reusable design. Healthcare providers use system controls to manage fluidics; output is controlled aspiration/irrigation flow.
Clinical Evidence
No clinical data. Bench testing only. Verification and validation included parametric measurements and irrigation/aspiration testing. Biocompatibility, sterilization, and reprocessing/re-sterilization evaluations performed per ISO 10993, ISO 11135, ISO 14937, and ANSI/AAMI standards.
Technological Characteristics
Reusable phacoemulsification fluidics pack. Components: housing manifold, irrigation/aspiration tubing, inlet connector, drain pump connection. Peristaltic aspiration mechanism. Materials validated for 20-cycle reuse. Sterilization: Ethylene Oxide (initial) and steam/moist heat (reprocessing). Standards: ISO 14971, ISO 10993 series, ISO 11135, ISO 11979-5, ANSI/AAMI ST79, ISO 14937, ANSI/AAMI ST72, ANSI/AAMI ST81, ISO 11737-2, ISO 17665-1.
Indications for Use
Indicated for use with the COMPACT INTUITIV System by ophthalmologists experienced in phacoemulsification for the emulsification and removal of cataractous lenses during anterior segment ophthalmic surgery.
Regulatory Classification
Identification
A phacofragmentation system is an AC-powered device with a fragmenting needle intended for use in cataract surgery to disrupt a cataract with ultrasound and extract the cataract.
Sovereign Reusable Tubing Pack, Model OPO55 (K981116)
Reference Devices
COMPACT INTUITIV Phacoemulsification System (K133115)
Sovereign Cataract Extraction Phacoemulsification System (K981116)
Sovereign Compact Phacoemulsification System (K111446)
Sovereign Compact Disposable Tubing Set, Model OPO61 (K981116)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 2, 2015
Abbott Medical Optics, Inc. Priya Viswanathan, RAC Sr. Specialist, Regulatory Affairs 1700 East Saint Andrew Place Santa Ana, CA 92705
Re: K151783
Trade/Device Name: COMPACT INTUITIV Multiple-Use Pack, Model OP085 Regulation Number: 21 CFR 886.4670 Regulation Name: Phacofragmentation system Regulatory Class: Class II Product Code: HQC Dated: June 29, 2015 Received: July 1, 2015
Dear Ms. Viswanathan:
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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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 contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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 Industry and Consumer Education 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.
Sincerely vours.
# Kesia Y. Alexander -A
for Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known)
Device Name
COMPACT INTUITIV Multiple-Use Pack, Model OPO85
Indications for Use (Describe)
The OPO85 is used with the COMPACT INTUITIV System. The OPO85 is sterilized using Ethylene Oxide and is designed for use up to 20 times. Following the first use, the user then follows cleaning and sterilization instructions specified below for up to 19 additional cleaning/sterilization cycles for a total of 20 uses when used according to the Instructions for Use.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------------------------|---------------------------------------------|
| <span style="text-decoration: underline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
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#### 510(K) SUMMARY 6
### 6.1 APPLICANT INFORMATION
Abbott Medical Optics Inc. (AMO) is submitting an Abbreviated 510(k) premarket notification for the Multiple-Use Pack, Model OPO85, which is an accessory to the COMPACT INTUITIV Phacoemulsification System cleared under the premarket notification. K133115. This 510(k) Summary is being submitted in accordance with the Medical Device Amendments of 1976, the requirements of the Safe Medical Devices Act (SMDA) of 1990 and 21 CFR 807.92.
Submitter Information:
Contact Person:
6
Abbott Medical Optics Inc. 1700 E. St. Andrew Place Santa Ana, CA 92799-5162, USA
Priya Viswanathan, RAC Sr. Specialist, Regulatory Affairs 1700 East St. Andrew Place Santa Ana, CA 92705 Tel: (714) 247-8670 Fax: (714) 566-3785 Email: Priya. Viswanathan@abbott.com
Priya
Date of 510(k) Summary Preparation:
June 29, 2015.
### 6.2 SUBJECT DEVICE
Trade/Proprietary Name: Multiple-Use Pack - OPO85 Phacoemulsification Pack, Fluidics Pack Common Name: Classification Name: Phacofragmentation System per 21 CFR 886.4670 Product Code: HQC Requlatory Class: 11
### 6.3 SUBSTANTIAL EQUIVALENCE SUMMARY
The Multiple-Use Pack, Model OPO85, is a new optional phacoemulsification fluidics pack designed to facilitate anterior segment ophthalmic surgical procedures. The device is an optional accessory for use with the COMPACT INTUITIV Phacoemulsification System (K133115), which is designed for use in the surgical setting for ophthalmologists with experience as phacoemulsification surgeons in the emulsification and removal of a cataractous lens from the eye.
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The OP085 Pack is claimed to be substantially equivalent to the following predicates:
- A Primary predicate: Single-Use Fluidics Pack, Model OPO80 cleared on February 27, 2014 (K133115), designed for use with the COMPACT INTUITIV Phacoemulsification System (K133115).
- Sovereign Reusable Tubing Pack, Model OPO55 A Secondary predicate: cleared on May 19, 1998, designed for use with the Sovereign Cataract Extraction Phacoemulsification System (K981116).
COMPACT INTUITIV System and its components were shown to be substantially equivalent to the Sovereign Compact Phacoemulsification System (K111446) and the Sovereign Compact Disposable Tubing Set, Model OPO61 (K981116) in the Premarket Notification, K133115.
The two predicate fluidics packs are both designed for use in phacoemulsification procedures to provide all the tubing required for irrigation and share similarities in design, technology and functionality. The predicate devices to which substantial equivalence of the Multiple-Use Pack, Model OP085 is claimed are listed below.
| 510(k) Number | Date of FDA<br>Clearance | Predicate<br>Device/Accessory<br>Name | 510(k) Holder |
|---------------|--------------------------|-------------------------------------------------------|-------------------------------|
| K133115 | February 27, 2014 | Primary Predicate<br>Single-Use Pack,<br>OPO80 | Abbott Medical<br>Optics Inc. |
| K981116 | May 19, 1998 | Secondary Predicate<br>Reusable Tubing Pack,<br>OPO55 | Abbott Medical<br>Optics Inc. |
# Predicate Devices to which Substantial Equivalence is claimed for the Multiple-Use Pack, Model OP085
# 6.4 DEVICE DESCRIPTION
The Multiple-Use Pack, Model OPO85 is a reusable phacoemulsification pack that is an optional accessory for use with the COMPACT INTUITIV Phacoemulsification System (K133115), which is used to facilitate the emulsification and removal of a cataractous lens. The primary predicate device, the Single-Use Fluidics Pack, Model OPO80, is cleared for use with the COMPACT INTUITIV System and the secondary predicate device, the Sovereign Reusable Pack, Model OPO55, is cleared for use with the Sovereign Phacoemulsification System. Both the predicates share the same technology, intended use, and performance specifications as the subject device. The Multiple-Use Pack, Model OPO85, consists of a housing manifold, irrigation and aspiration tubing, irrigation inlet tubing connector, and a drain pump tubing connection. Like the secondary predicate device, Model OPO55, the OPO85 Pack is designed for reuse up to 19 times, for a total of 20 uses.
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#### TECHNOLOGICAL CHARACTERISTICS OF THE DEVICE 6.5
Similar to the predicate devices, the Multiple-Use Pack, Model OPO85 supports peristaltic aspiration by means of a tubing interface in combination with a molded cartridge designed to generate fluid outflow from a patient's eye through an aspiration tubing line. The main technological characteristics in which the Multiple-Use Pack, Model OP085, is involved include irrigation and aspiration. All performance functions of the OP085 Pack are identical to those of the primary predicate device, OP080 (K133115). The performance functions for the reusability is identical to the secondary predicate device, OPO55 (K981116).
The basic scientific concepts, energy source, design, intended use and FDA-recognized consensus standards used for performance testing of the Multiple-Use Pack, Model OP085, are identical to those of the primary predicate, Single-Use Fluidics Pack, Model OP080 (K133115). The intended use of the Multiple-Use Pack, Model OP085 is anterior seqment ophthalmic surgery, which is the same intended use as both predicate devices.
#### 6.6 INDICATIONS FOR USE
The Indications for Use statement of the Multiple-Use Pack, Model OPO85 is the following:
The OP085 is used with the COMPACT INTUITIV System. The OP085 is sterilized using Ethylene Oxide and is designed for use up to 20 times. Following the first use, the user then follows cleaning and sterilization instructions specified below for up to 19 additional cleaning/sterilization cycles for a total of 20 uses when used according to the Instructions for Use.
#### 6.7 SUMMARY OF PERFORMANCE DATA
The Multiple-Use Pack, Model OPO85 has undergone design verification and validation testing, which include parametric measurements testing and irrigation and aspiration testing. The test results demonstrate that the subject device, the Multiple-Use Pack, Model OPO85, performs as safely and as effectively as the predicate device, the Single-Use Pack, Model OPO80. During performance testing, all anterior segment ophthalmic surgery modes that require the OPO85 functionality, including irrigation/aspiration, were conducted; all tests passed and all acceptance criteria were met.
Components of the Multiple-Use Pack, Model OPO85, have indirect contact with the patient by providing a fluid path for sterile Balanced Salt Solution (BSS) to enter the eye during surgery. Verification and validation testing was completed and all acceptance criteria were met, demonstrating that the OPO85 Pack has a similar safety, effectiveness and performance profile as the predicate device. Biocompatibility, sterilization, and reprocessing/re-sterilization evaluations of the materials that comprise the patient-contacting fluid path were performed to the following standards:
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| Standard Number | Standard Title |
|----------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ISO 14971:2007 | Medical devices – Application of risk management to<br>medical devices |
| ISO 10993-1:2009 | Biological evaluation of medical devices – Part 1:<br>Evaluation and testing within a risk management<br>process |
| AAMI/ANSI/ISO 10993-5:2009 | Biological evaluation of medical devices – Part 5:<br>Tests for in vitro cytotoxicity |
| ISO 10993-7:2008 | Biological evaluation of medical devices – Part 7:<br>Ethylene oxide sterilization residuals |
| ISO 10993-10:2010 | Biological evaluation of medical devices – Part 10:<br>Tests for irritation and skin sensitization |
| ISO 10993-12:2012 | Biological evaluation of medical devices – Part 12:<br>Sample preparation and reference materials |
| ISO 11135:2014 | Sterilization of health care products – Ethylene Oxide<br>– Requirements for development, validation and<br>routine control of a sterilization process for medical<br>devices |
| ISO 11979-5:2006 | Ophthalmic implants - intraocular lenses – Part 5:<br>Biocompatibility |
| ANSI/AAMI ST79-2010 | Comprehensive guide to steam sterilization and<br>sterility assurance for health care facilities. |
| ISO 14937:2009 | Sterilization of health care products - general<br>requirements for characterization of a sterilizing agent<br>and the development, validation and routine control of<br>a sterilization process for medical devices. |
| ANSI/AAMI ST72:2002 | Bacterial endotoxins – Tests methodologies, routine<br>monitoring and alternatives to batch testing |
| ANSI/AAMI ST81:2004/2010 | Sterilization of medical devices– Information to be<br>provided by the manufacturer for the processing of<br>resterilizable medical devices |
| ANSI/AAMI/ISO 11737-2:2009 | Sterilization Of Medical Devices - Microbiological<br>Methods - Part 2: Tests Of Sterility Performed In The<br>Definition, Validation And Maintenance Of A<br>Sterilization Process. |
| ANSI/AAMI/ISO 17665-1:2006 | Sterilization Of Health Care Products -- Moist Heat --<br>Part 1: Requirements For The Development,<br>Validation, And Routine Control Of A Sterilization<br>Process For Medical Devices |
All additional accessories required to use the OPO85 in the surgical setting, which include the Administration Set (P/N OM2505191) and Drain Bag (P/N OPO56), are the same as those used with the secondary predicate device, the Reusable Tubing Pack, Model OPO55, and have been cleared in previous 510(k) filings and are not within the scope of this premarket notification.
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# 6.8 SUMMARY OF CLINICAL TESTS
No clinical studies were deemed necessary to determine the safety and effectiveness of the Multiple-Use Pack - OPO85.
# 6.9 CONCLUSIONS
The technological characteristics that determine the functionality and performance of the Multiple-Use Pack, Model OP085, are believed to be substantially equivalent to those for the cleared Single-Use Pack, Model OPO80 primary predicate device (K133115) and Reusable Tubing Pack, Model OPO55 secondary predicate device (K981116). The Multiple-Use Pack, Model OPO85, will be manufactured in compliance with FDA and ISO quality system requirements. The data from the non-clinical tests demonstrate that the device is as safe and as effective and performs as safely and as effectively as the legally marketed predicate devices. Verification and validation testing demonstrate that the functional requirements and system specifications will be met prior to commercial release.
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.