Fingertip Pulse Oximeter C101H1 is a non-invasive device intended for spot checking of function of arterial hemoglobin (SpO2) and pulse rate (PR). This portable device is indicated for use in adult patients in hospitals.

Device Description

SpO2 is based on the absorption of pulse blood oxygen to red and infrared light by means of finger sensor and SpO2 measuring unit. The light-electronic transducer in finger sensor converts the pulse red and infrared light modulated by pulse blood oxygen into electrical signal is processed by hardware and software of the unit. The PLETH curve and numeral value of SpO2 will be obtained.

The pulse oximeter, C101H1, is designed for spot checking of the pulse oxygen saturation and pulse rate for adults in a clinic environment. This medical device can be reused. Not for continuously monitoring. The device is not for life-supporting or life-sustaining, not for implant.

The device is not provided sterile and is NOT a reprocessed single-use device.

The device is a spot-check pulse oximeter and does not include alarms.

The device does not support the measurement in the condition of low perfusion.

The device is not intended for life-supporting or life-sustaining.

The device is reusable and does not need sterilization.

AI/ML Overview

Here's an analysis of the provided information, describing the acceptance criteria and the study that proves the device meets them:

1. Table of Acceptance Criteria and Reported Device Performance

Performance Metric	Acceptance Criteria (Predicate Device)	Reported Device Performance (C101H1)
SpO2 Measuring Range	0%-100%	0%-100%
SpO2 Resolution	1%	1%
SpO2 Accuracy (70-100%)	±3%	A_rms = 2.12% (within 70-100% range)
SpO2 Accuracy (0-69%)	Unspecified	Unspecified
PR Measuring Range	30-235 BPM	30-240 BPM
PR Resolution	1 bpm	1 bpm
PR Accuracy (30-99 bpm)	±2 bpm	±1 bpm or ±1%, whichever is greater
PR Accuracy (100-235 bpm)	±1%	±1 bpm or ±1%, whichever is greater
Biocompatibility	ISO 10993-5 and ISO 10993-10	Complies (Cytotoxicity, Sensitization, Irritation)
Electrical Safety	IEC 60601-1, IEC 60601-1-11	Complies (IEC 60601-1:2005/A1:2012, IEC 60601-1-11:2015, ISO 80601-2-61:2011)
EMC	IEC 60601-1-2	Complies (IEC 60601-1-2:2014)
Software Level of Concern	(Implied "moderate" for predicate)	Moderate

Note: The acceptance criteria for the C101H1 are largely established by demonstrating substantial equivalence to the predicate device (Fingertip Pulse Oximeter A310/ K153021) and adherence to relevant international standards. The performance metrics listed for the predicate device serve as the de facto acceptance criteria for the C101H1 in terms of comparable specifications.

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

Sample Size for Clinical Test Set (SpO2 accuracy): 12 healthy adult volunteer subjects.
Data Provenance: The study was conducted on a volunteer population, implying a prospective study. The location is not explicitly stated, but given the manufacturer's location in Shenzhen, China (as indicated in the 510(k) summary), it is highly likely that the study was conducted there, or at least with subjects geographically accessible to the company or its clinical partners.

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

The document describes the ground truth for SpO2 accuracy as being established by arterial blood CO-Oximetry. This method itself is the "expert" or gold standard. There isn't information provided about individual experts, such as physicians or lab technicians, establishing the ground truth; rather, it relies on the accuracy of the CO-Oximetry device and its operation. It states "Arterial blood samples were drawn during simultaneous data collection from the test devices. The blood was immediately analyzed on reference CO-Oximetry providing functional SaO2 for the SpO2 accuracy comparison."

4. Adjudication Method for the Test Set

Not applicable for this type of test. The ground truth (SaO2 from CO-Oximetry) is an objective measurement, not a subjective interpretation requiring adjudication among multiple experts. The device's reading is compared directly to this objective ground truth.

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

No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This device is a Pulse Oximeter, which provides a direct physiological measurement (SpO2 and PR). It does not involve human readers interpreting images or data where AI assistance would be relevant.

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

Yes, the performance study for SpO2 accuracy is a standalone performance evaluation of the device's algorithm. The "C101H1 Pulse Oximeter" itself, without human interpretation influencing the measurement output, was evaluated against the gold standard CO-Oximetry. While humans operate the device, the core "performance" reported (A_rms) directly reflects the device's measurement accuracy.

7. The Type of Ground Truth Used

The ground truth used for the SpO2 accuracy test was objective measurement from a gold-standard device: arterial blood CO-Oximetry, which provides functional SaO2.

8. The Sample Size for the Training Set

The document does not specify a separate training set for the clinical performance evaluation. The clinical trial described focused on validation of the device's accuracy against a reference standard using 12 healthy volunteers. Pulse oximeters typically use fixed algorithms based on known light absorption properties of oxygenated and deoxygenated hemoglobin, rather than machine learning algorithms requiring a distinct training phase on clinical data. Performance testing (e.g., pulse rate accuracy, cleaning/disinfection) does not typically involve "training data" in the AI sense.

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

As no explicit training set is mentioned in the context of device performance in this document, this question is not applicable. The underlying physics and algorithms are generally developed based on a foundational understanding of spectroscopy and validated through engineering tests and subsequent clinical trials like the one described.

Summary

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Shenzhen IMDK Medical Technology Co., Ltd. % Kevin Wang Consultant Chonconn Medical Device Consulting Co., Ltd. 22A, Haijing Square No. 18, Taizi Road Nanshan District, Shenzhen, 518067 Cn

Re: K173123

Trade/Device Name: Pulse Oximeter Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DOA Dated: July 12, 2018 Received: July 12, 2018

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/cfpmp/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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/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 D. Courtney -S

for Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K173123

Device Name Pulse Oximeter

Indications for Use (Describe)

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)	☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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510(K) Summary

Prepared in accordance with the requirements of 21 CFR Part 807.92

Prepared Date: 2017/09/20

1. Submission sponsor

Name: Shenzhen IMDK Medical Technology Co., Ltd.

Address: C Zone, 10F, Building 16, Yuanshan Industrial B Area, Gongming Street, Guangming

District, Shenzhen, Guangdong, P.R. China

Contact person: Xia Yuan

Title: Administration Director

E-mail: vicky@estne.org

Tel: +86 755 33637905

2. Submission correspondent

Name: Chonconn Medical Device Consulting Co., Ltd.

Address: 22A, Haijing Square, No. 18, Taizi Road, Nanshan District, Shenzhen, P.R. China 518067 Contact person: Kevin Wang E-mail: kevin@chonconn.com

Tel: +86-755 33941160

Trade/Device Name	Pulse Oximeter
Model	C101H1
Common Name	Pulse Oximeter
Regulatory Class	Class II
Classification	21CFR 870.2700 / Oximeter / DQA
Submission type	Traditional 510(K)

3. Subject Device Information

4. Predicate Device

AMEMO Inc. Fingertip Pulse Oximeter A310/ K153021.

The subject device has same intended use, same target patient population, and same performance effectiveness as the predicate device and there are no different questions of effectiveness and safety. So, the conclusion is that the subject device is substantial equivalent to the predicate.

5. Device Description

The pulse oximeter, C101H1, is designed for spot checking of the pulse oxygen saturation and pulse rate

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for adults in a clinic environment. This medical device can be reused. Not for continuously monitoring. The device is not for life-supporting or life-sustaining, not for implant.

The device is not provided sterile and is NOT a reprocessed single-use device.

The device is a spot-check pulse oximeter and does not include alarms.

The device does not support the measurement in the condition of low perfusion.

The device is not intended for life-supporting or life-sustaining.

The device is reusable and does not need sterilization.

6. Intended use & Indication for use

Fingertip Pulse Oximeter C101H1 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 hospitals.

7. Predicate Device Comparison

The subject devices share the same characteristics in all items with the predicate device, concluding from using the same technology and principle. All the technological differences existed between the subject and predicate devices are only some performance parameters improvement, detailed substantial equivalence discussion is included in the following tables.

Comparison Items	Proposed device: C101H1	Predicate device: A310(K153021)
Intended use/ Indicationsfor use	Fingertip Pulse Oximeter C101H1is a non-invasive device intendedfor spot checking of functionaloxygen saturation of arterialhemoglobin (SpO2) and pulse rate(PR). This portable device isindicated for use in adult patientsin hospitals.	Fingertip Pulse Oximeter A310 isa non-invasive device intended forspot checking of functionaloxygen saturation of arterialhemoglobin (SpO2) and pulse rate(PR). This portable device isindicated for use in adult patientsin hospitals
Principle	The device displays numericalvalues for functional oxygensaturation of arterial hemoglobin(SpO2) and pulse rate bymeasuring the absorption of redand infrared (IR) light passingthrough perfused tissue. Changesin the absorption caused by thepulsation of blood in the vascular	The device displays numericalvalues for functional oxygensaturation of arterial hemoglobin(SpO2) and pulse rate bymeasuring the absorption of redand infrared (IR) light passingthrough perfused tissue. Changesin the absorption caused by thepulsation of blood in the vascular

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	Comparison Items	Proposed device: C101H1	Predicate device: A310(K153021)
		bed are used to determine oxygensaturation and pulse rate.	bed are used to determine oxygensaturation and pulse rate.
ecificati	LED wavelength	Red= 660 nm; Infrared=904nm	Red= 660 nm; Infrared=905nm
	Power source	2 AAA alkaline batteries.	2 AAA alkaline batteries.
	Display data	SpO2%; PR	SpO2%; PR
	SpO2 MeasuringRange	0%-100%	0%-100%
	SpO2 Resolution	1%	1%
	SpO2 Accuracy	70~100%, ±3%;	70~100%, ±3%;
			0-69%, unspecified;
	PR MeasuringRange	30-240BPM.	30-235BPM.
	PR Resolution	1 bpm	1 bpm
	PR Accuracy	±1 bpm or ±1%, whichever is	±2 bpm (30-99bmp)
		greater	±1% (100-235bmp)
	Biocompatibility	ISO 10993-5 and ISO 10993-10	ISO 10993-5 and ISO 10993-10
'esting	Electrical Safety	IEC 60601-1	IEC 60601-1
		IEC 60601-1-11	IEC 60601-1-11
	ElectromagneticCompatibility	IEC 60601-1-2	IEC 60601-1-2
	Performance	ISO 80601-2-61	ISO 80601-2-61

8. Performance Data

The following performance data were provided in support of the substantial equivalence determination. Biocompatibility evaluation:

The biocompatibility evaluation for the Pulse Oximeter C101H1 were conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA. The testing included the following tests:

Cytotoxicity
Sensitization
Irritation

The subject devices are made up of enclosure, button and finger clip. The finger clip will contact with patient skin. According to ISO 10993-1, the contacting classification is surface contacting and the

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duration is intact skin contact less than 24 hours.

Electrical safety and electromagnetic compatibility (EMC):

Electrical safety and EMC testing were conducted on the Pulse Oximeter C101H1, consisting of all the modules and accessories in the system. The system complies with the IEC 60601-1:2005/A1: 2012, IEC 60601-1-11: 2015 and ISO 80601-2-61: 2011 standards for electrical safety and the IEC 60601-1-2:2014 standard for EMC.

Software Verification and Validation Testing

Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "moderate" level of concern, since a failure or latent flaw in the software could directly result in serious injury or death to the patient or operator.

Performance Testing

Pulse rate accuracy test
Cleaning and disinfection cycle test

Clinical data:

The clinical trial was performed according to Clause 201.12.1.101.2 and Annex EE.2 of ISO 80601-2-61:2011 Procedure for invasive laboratory testing on healthy volunteers.

The purpose of the clinical trial was to evaluate the SpO2 accuracy performance of the C101H1 Pulse Oximeter during stationary (non-motion) conditions over a wide range of arterial blood oxygen saturation levels as compared to arterial blood CO-Oximetry. 12 healthy adult volunteer subjects (ages 22-27yr, with light to dark pigmentation) were included in the study conducted to evaluate the SpO2 accuracy performance of proposed devices. Each system was evaluated during steady state/non-motion conditions with various levels of induced hypoxia resulting in stable oxygen saturation levels between 100% and 70% SaO2. Arterial blood samples were drawn during simultaneous data collection from the test devices. The blood was immediately analyzed on reference CO-Oximetry providing functional SaO2 for the SpO2 accuracy comparison. The SpO2 accuracy performance results showed the fingertip pulse oximeter to have an Arms of 2.12 during steady state conditions over the range of 70-100%.

Summary:

Based on the non-clinical and clinical performance as documented in the system development, the subject devices were found to substantially equivalent to the predicate device.

9. Conclusion

The non-clinical data support the substantial equivalence of the device and the hardware and software verification and validation demonstrate that the subject device should perform as intended in the specified use conditions. The clinical data demonstrate that the subject device performs comparably to the predicate

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device that is currently marketed for the same intended use.

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).