To spot check or monitor Oxygen saturation of arterial hemoglobin (SpO2%) and pulse rate.
To analyze the pulse waveform (Photoelectrical Plethysmography or PP) provided by the oximeter. It only provides mathematical analyses of the input of the SpO2 measurement.
To analyze the basic rhythms of the NN or RR intervals in heart rate, both in the time domain and in the frequency domain (short time 5 minutes). It only provides mathematical analyses of the input of the heart rate variability.
The mathematical analysis of Photoelectrical Plethysmography and HRV are not intended use for diagnosis.
The software provides a visual alarm for the values of the heart rate and/or SpO2 percent out of the normal range and for the bad quality signal transmission.
The data are stored in PC in the Backup system of the ESO software.
The device is intended use only for adult subjects (> 20 years old)
This Oximeter is intended to be used in spot-checking (5 minutes)
The device is intended use in licensed practitioner's office
This device is no intended to be used at home, in hospital or out-of-hospital transport
The device is not intended use in support life and not for continuously monitoring
The system will be use by practitioner.

Device Description

USB plug and play hardware device including an electronic box and reusable Adult SpO2 probe
Software installed on a computer.
Description of the features
Displays SpO2%, pulse rate value and vertical bar graph pulse amplitude.
Mathematical analysis of the pulse waveform (photoelectrical Plethysmograph' feature).
Mathematical analysis of the Heart Rate Variability (HRV 'feature).

AI/ML Overview

The provided 510(k) submission for the Electro Sensor Oxi (E.S.O) does not contain detailed acceptance criteria or a study proving that the device meets specific performance criteria related to accuracy of SpO2, pulse rate, or the mathematical analyses for Photoelectrical Plethysmography (PP) and Heart Rate Variability (HRV).

Instead, the submission largely focuses on establishing substantial equivalence to a predicate device (Electro Sensor Teck Model PEMS, K083229) by demonstrating similar intended use, technological characteristics, and safety/effectiveness, with the main new characteristic being the derivation of heart rate from oximeter waveform analysis rather than an EKG device.

Here's an analysis of the provided information based on your requested points:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria	Reported Device Performance
No explicit numerical acceptance criteria for SpO2 accuracy, pulse rate accuracy, or the mathematical analyses (PP, HRV) are provided in this document.	- Pulse Oximeter Functions (SpO2, Pulse Rate): The submission states that the OEM subcontractor provided the oximeter, sensor, cable connections and software code source, and "they were cleared for use together." It does not provide specific accuracy data for SpO2 or pulse rate against a reference standard or a specified range of acceptance.
	- Photoelectrical Plethysmography (PP) Analysis & Heart Rate Variability (HRV) Analysis: These are described as "only mathematical analyses" and are "not intended use for diagnosis." The document states "no clinical validation is required for E.S.O." for these features. It further mentions "peer reviews for the photoelectrical plethysmography mathematical analysis" and "comparative testing between EKG RR intervals (from predicate device) and SP02 RR intervals (from E.S.O) in one hand, and in second hand, comparative HRV analysis results from the predicate device and E.S.O." However, no quantitative performance metrics or acceptance criteria for these comparisons are provided.
General Safety & Effectiveness: Device is substantially equivalent to the predicate device in terms of performance, technology, safety, and efficacy.	- General Safety: "The fact to remove the EKG PCB does not change the general safety to the legally marketed predicate device as shown in the laboratory tests reports of the E.S.O. system (IEC 60601-1-2 and IEC 60601-1-1)." (This implies meeting these general safety standards, but these are not performance criteria for diagnostic accuracy).

2. Sample Size Used for the Test Set and Data Provenance

Test Set Sample Size: Not specified for any performance evaluation.
Data Provenance:
- The document mentions "input data from the MIT-BIH database" for "Software algorithms tests." This suggests a retrospective dataset, likely from North America (MIT-BIH is a US-based database). However, it's not explicitly stated if this database was used for the "test set" in the context of device performance, but rather for software verification.
- For the comparative testing of RR intervals and HRV, no details about where this data came from are provided.
- The document references "published clinical investigations" for interpretation of PP and HRV results, stating these investigations "had been made with materials using the same technology (Pulse oximeter) and the same anatomical site (fingertip)." This implies reliance on existing literature rather than new clinical data from the E.S.O. itself. There is no information on the country of origin or whether these studies were retrospective or prospective, as they are external references not directly part of the E.S.O.'s submission data.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

Not Applicable / Not Specified. The document does not describe a process of establishing ground truth for a test set using experts for performance evaluation of the E.S.O. device.
"Peer reviews" are mentioned for the mathematical analyses of PP and HRV, but the number or qualifications of these reviewers are not detailed, nor is it explicitly stated that they established a "ground truth" for a test set. Their role seems to be more about assessing the mathematical soundness of the algorithms.

4. Adjudication Method for the Test Set

Not Applicable / Not Specified. No formal adjudication method is mentioned as a test set for performance evaluation by human experts was not described.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance

Not Applicable. This device is a pulse oximeter with mathematical analysis features, not an AI-assisted diagnostic tool that human readers would use to improve their performance with or without AI. Therefore, an MRMC study and effect size of human improvement with AI assistance are not relevant to this submission.

6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

Partially Applicable, but with no detailed results. The "Software algorithms tests with input data from the MIT-BIH database" could be considered a form of standalone testing. The "comparative testing between EKG RR intervals (from predicate device) and SP02 RR intervals (from E.S.O)" and "comparative HRV analysis results from the predicate device and E.S.O." also suggest standalone comparison of the algorithm's output to a reference, but no specific performance metrics like accuracy, sensitivity, or specificity are provided. The document explicitly states that the PP and HRV analyses "are not intended use for diagnosis" and "no clinical validation is required for E.S.O" for these features.

7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

For Software Algorithms Tests: The use of the "MIT-BIH database" implies that the ground truth for software verification would be derived from the annotations and established physiological parameters within that database (e.g., expert-annotated heartbeats, rhythm classifications from EKG).
For RR Intervals and HRV Comparisons: The ground truth or reference standard used for the comparative testing between EKG RR intervals and SpO2 RR intervals would have been the EKG RR intervals from the predicate device. For HRV, the comparison was against HRV analysis results from the predicate device. This essentially uses an existing, cleared device as the reference standard.
For SpO2/Pulse Rate: No explicit ground truth method is described for verifying the accuracy of the SpO2 and pulse rate measurements. Reliance seems to be on the OEM subcontractor's clearance and general safety standards rather than detailed clinical accuracy studies within this submission.

8. The Sample Size for the Training Set

Not Specified. The document does not mention a training set or its sample size. The device relies on established algorithms for oximetry and mathematical analyses, rather than a machine learning model that would typically require a training set. The "Software algorithms tests with input data from the MIT-BIH database" is referred to for verification, not training.

9. How the Ground Truth for the Training Set Was Established

Not Applicable. As no specific training set for a machine learning model is mentioned, the method for establishing its ground truth is also not applicable.

Summary

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K102442 Pg. 1 of 1

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L.D Technology LLC.

510(k) Premarket Notification Number: Preparation date: July, 02 2010

510(k) Summary Electro Sensor Oxi / E.S.O

Name of the device: Electro Sensor Oxi Common name: E.S.O Pulse oximeter/Photoelectrical Plethysmograph/Heart Rate variability Regulation number: 21 CFR 870 2700 Product Codc: DQA Classification: Class II Classification Advisory: Cardiovascular/Anesthesiology

This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of 21 CFR §807.92

1. Submitter's Identification:

Manufacturer: L.D TECHNOLOGY Owner of LD Technology: MAAREK Albert Address: L.D Technology 100 N.Biscayne Blvd, Suite 500 . Miami, FL, 33132, USA Tel: 305-379-9900 E mail: albert.ldteck@gmail.com

2. Device Name / Classification

Electro Sensor Oxi System components : 21 CFR 870 2700 Product Code: DQA Classification: Class II Classification Panel: Cardiovascular /Anesthesiology

3. Predicate legally marketed device

Fredicate regally marketed avile
Electro Sensor Teck (Model PEMS) K083229 Applicant: LD Technology LLC Product code MW. 4. Device Description
Device Description

USB plug and play hardware device including an electronic box and reusable Adult SpO2 probe ●
Software installed on a computer.

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Description of the features

Displays SpO2%, pulse rate value and vertical bar graph pulse amplitude. .
Mathematical analysis of the pulse waveform (photoelectrical Plethysmograph' feature). .
Mathematical analysis of the Heart Rate Variability (HRV 'feature). .

5. Intended use and indications for use

To spot check or monitor Oxygen saturation of arterial hemoglobin (SpO2%) and pulse rate. .
To analyze the pulse waveform (Photoelectrical Plethysmography or PP) provided by the . oximeter. It only provides mathematical analyses of the input of the SpO2 measurement.
To analyze the basic rhythms of the NN or RR intervals in heart rate, both in the time . domain and in the frequency domain (short time 5 minutes). It only provides mathematical analyses of the input of the heart rate variability.

The mathematical analysis of Photoelectrical Plethysmography and HRV ARE NOT intended use for diagnosis.

The software provides a visual alarm for the values of the heart rate and/or SpO2 percent out of the normal range and for the bad quality signal transmission.

The data are stored in PC in the Backup system of the ES Teck software.

The device is intended use only for adult subjects (> 20 years old)

This Oximeter is intended to be used in spot-checking (2 minutes)

The device is intended use in licensed practitioner's office

This device is no intended to be used at home, in hospital or out-of-hospital transport The device is not intended use in support life and not for continuously monitoring The system will be use by practitioner.

The system will be use by practitioner.

6. Performances, specifications and materials

Technical specifications I.e. Device description

Software specifications

The system carries out the following operations:

Image /page/1/Figure/20 description: The image shows a block diagram of a system. The diagram includes blocks labeled "HARDWARE", "PROTOCOL COMMUNICATION", "SpO2 %", "Pulse wave", "Photoelectrical plethysmography analysis", "Heart rate", "Heart rate variability analysis", and "BACK UP". Arrows connect the blocks to show the flow of information.

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7. Contra-indications

Patients undergoing external defibrillation .
Patients connected to electronic life support devices, or any implanted electronic device. .
Do not use this device in the presence of magnetic resonance imaging (MR or MRI) . equipment. MRI equipment may cause induced current to the SpO2 sensor resulting in patient injury.
This device should not be used on pregnant women. The effects on the fetus, as well as . accuracy of readings are unknown.
. When using the finger probe, utilize the arm not in use for blood pressures, arterial lines, or having an AV fistula or pressure dressing.
Dyes introduced into the bloodstream, such as methylene blue, indocyanine green, indigo . carmine, and fluorescein
Significant levels of dysfunctional hemoglobins, such as carboxyhemoglogin or . methhemoglobin, will affect the accuracy of the SpO2 measurement.
Any condition that restricts blood flow, such as use of a blood pressure cuff or extremes . in systemic vascular resistance, may cause an inability to determine accurate pulse rate and SpO2 readings
Operation of this device may be adversely affected in the presence of strong . electromagnetic sources, such as electro surgery equipment.
Operation of this device may be adversely affected in the presence of computed . tomography (CT) equipment.
Do not use this device in the presence of flammable anaesthetics; a spark hazard exists . which may result in explosion.
Fingernail polish or false fingernails: Fingernail polish or false fingernails may cause . inaccurate SpO2 readings.

8. Undesirable side effects:

Side effects or adverse reactions are none known to date.

9. Substantial equivalence

Predicate legally marketed device

Freureate regaily mai Reted device
Electro Sensor Teck (Model PEMS) K083229 Applicant: LD Technology LLC. Product code MWI

Similarities:

Substantial equivalence
- Same intended use
- Same technological characteristics as the predicate device
- √ Same safety and effectiveness

New characteristic:

V The Heart rate detection comes from the oximeter wave form analysis (a/a from SDPTG) and not from the EKG device.
I . . .

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11. Performances and Effectiveness

Calibration tests (simulator oximeter)
The OEM subcontractor provided the oximeter, sensor, cable connections and software code source and they were cleared for use together.

16102442 Pa 4 of 5

Software verification (SRS/SDS/STD/STR/ Software algorithms tests with input data from the MIT-BIH database)
Peer reviews for the photoelectrical plethysmography mathematical analysis.
Peer review reference for the heart rate variability mathematical analysis.

Discussion of Clinical Test performed for the E.S.O:

Since the ES Teck do not required clinical tests.

The HRV and photoelectrical plethysmography analysis are only mathematical analysis and have not been approved by FDA for a specific clinical diagnosis in any device, so that is for reference only, therefore, no clinical validation is required for E.S.O.

Use of the published clinical investigations of the photoelectrical plethysmography and HRV mathematical analysis:

For interpretation of the results we use some published clinical investigations. These clinical investigations had been made with materials using the same technology (Pulse oximeter) and the same anatomical site (fingertip).

The fact to detect the heart rate from the oximeter wave form analysis and not from the EKG module does not affect the performances and the effectiveness of the E.S.O as shown by the peer review and comparative testing between EKG RR intervals (from predicate device) and SP02 RR intervals (from E.S.O) in one hand, and in second hand, comparative HRV analysis results from the predicate device and E.S.O.

General Safety Concerns

The fact to remove the EKG PCB does not change the general safety to the legally marketed predicate device as shown in the laboratory tests reports of the E.S.O. system (IEC 60601-1-2 and IEC 60601-1-1).

13. Standards

AAMI EC57-1998(R) 2003 Testing and Reporting Performance Results of Cardiac Rhythm and ST-Segment Measurement Algorithms

IEC60601-1-1 Issued: 2000/12/14 Ed: 2 Part 1-1: General requirements for safety -Collateral standard: Safety requirements for medical electrical systems

Conateral standard. Daret Todaller. 2 Medical Electrical Equipment Part 1-2: General IDC 00001 P D Issued. Doollateral Standard: Electromagnetic Compatibility - Req. and Tests - Including Section 6 manual review

ISO9919 (From OEM subcontractor) Issued: 2005/03/15 Ed: 2 Medical electrical 1309717 (1 rom OBM sabellings for the basic safety and essential performance of pulse oximeter equipment for medical use

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Conclusions

E.S.O is equivalent in performances, technology, safety and efficacy to the legally marketed predicate device.

Signature:

Image /page/4/Picture/4 description: The image shows a black and white photograph of what appears to be a field or landscape. There are several rows of what could be crops or plants, and they are arranged in a linear fashion. The image quality is not very clear, and the details are difficult to discern.

Albert MAAREK

Premarket notification [510K] Number: K102442

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three stripes representing the department's mission. The eagle is positioned within a circular border. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the border of the circle.

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

L.D. Technology, Inc. c/o Mr. Mark Job Regulatory Technology Services, LLC Responsible Third Party Official 1394 25th Street, NW Buffalo, Minnesota 55313

SEP 1 0 2010

K102442 Re:

Trade/Device Name: E.S.O. (Electro Sensor Oxi) Regulatory Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: II (two) Product Code: 74 DQA, MWI Dated: August 25, 2010 Received: August 26, 2010

Dear Mr. Job:

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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

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Page 2 - Mr. Mark Job

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

WMad

Bram D. Zuckerman, M.D. Director

Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number: Klo 2442

Device Name: E.S.O (Electro Sensor Oxi)

Indications for Use:

To spot check or monitor Oxygen saturation of arterial hemoglobin (SpO2%) and pulse rate. ...
SEP 1 0 2010
To analyze the pulse waveform (Photoelectrical Plethysmography or PP) provided . by the oximeter. It only provides mathematical analyses of the input of the SpO2 measurement.
To analyze the basic rhythms of the NN or RR intervals in heart rate, both in the ● time domain and in the frequency domain (short time 5 minutes). It only provides mathematical analyses of the input of the heart rate variability.

The mathematical analysis of Photoelectrical Plethysmography and HRV are not intended use for diagnosis.

The software provides a visual alarm for the values of the heart rate and/or SpO2 percent out of the normal range and for the bad quality signal transmission.

The data are stored in PC in the Backup system of the ESO software.

The device is intended use only for adult subjects (> 20 years old)

This Oximeter is intended to be used in spot-checking (5 minutes)

The device is intended use in licensed practitioner's office

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Page	1 of 1
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Concurrence of CDRH, Office of Device Evaluation (ODE)

signature

(Division Sign-Off)
Division of Cardiovascular Devices
510(k) Number	K102442

Regulation Number and Section

§ 870.2700 Oximeter.

(a)
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.(b)
Classification. Class II (performance standards).