K Number
K181588
Device Name
POPS! one Blood Glucose Monitoring System
Date Cleared
2018-11-30

(168 days)

Product Code
Regulation Number
862.1345
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The POPS!® one Blood Glucose Monitoring System is comprised of the POPS!® one blood glucose meter, the POPS!® one blood glucose sensor modules, and the POPS!® mobile application as the display component. The POPS!® one Blood Glucose Monitoring System is intended for use outside the body (in vitro diagnostic use) in the quantitative measurement of glucose in fresh capillary whole blood taken from the finger. It is intended to be used by people with diabetes mellitus at home as an aid in monitoring the effectiveness of a diabetes control program. The POPS!® one Blood Glucose Monitoring System is intended to be used by a single patient and should not be shared. It is not intended for the diagnosis of, or screening of diabetes. It is not intended for use on neonates.
Device Description
The POPS!® one Blood Glucose Monitoring System is designed to make blood glucose testing and diabetes management easier and more convenient. The traditional test kit is replaced by a low-profile meter that contains everything needed for testing and requires no assembly. The meter pairs with a mobile app installed on the user's phone via Bluetooth, allowing the meter to perform glucose testing and send the results to the app where they are communicated to the user and automatically stored. The POPS!® one Blood Glucose Monitoring System contains the following: - . POPS!® one blood glucose meter works directly with the POPS!® app installed on the user's mobile phone. The meter performs a blood glucose test and sends the result to the POPS!" app. - . POPS!® one blood glucose sensor module is individually packed and sterile. It contains 3 test sites with separate foil covers; each containing a lancet and test strip. The user inserts the sensor module in the meter and replaces a used sensor module with a new once all 3 test sites have been used. The sensor module not only provides all components for performing a glucose test to the user in a convenient, self-contained format but it also provides a new lancet for each test; preventing lancet re-use. - . POPS!® mobile application acts as the primary interface with users; enabling them to test, communicating blood glucose results and messages, and allowing them to monitor trends on their phone.
More Information

Not Found

No
The summary describes a standard blood glucose monitoring system with a meter, sensor modules, and a mobile app for display and data storage. There is no mention of AI or ML being used for data analysis, prediction, or any other function beyond basic glucose measurement and trend display.

No
This device is an in vitro diagnostic (IVD) system used for quantitative measurement of glucose in blood, intended to aid in monitoring diabetes, not to provide therapy.

No

The text explicitly states: "It is not intended for the diagnosis of, or screening of diabetes." It is intended as an aid in monitoring the effectiveness of a diabetes control program.

No

The device description explicitly states that the system includes a blood glucose meter and sensor modules, which are hardware components, in addition to the mobile application.

Yes, this device is an IVD (In Vitro Diagnostic).

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section explicitly states: "The POPS!® one Blood Glucose Monitoring System is intended for use outside the body (in vitro diagnostic use)..."
  • Nature of the Test: The device measures glucose in fresh capillary whole blood. This is a test performed on a biological sample taken from the body, which is the definition of an in vitro diagnostic test.
  • Purpose: The purpose is to aid in monitoring the effectiveness of a diabetes control program, which is a diagnostic purpose related to a medical condition.

N/A

Intended Use / Indications for Use

The POPS!® one Blood Glucose Monitoring System is comprised of the POPS!® one blood glucose meter, the POPS!® one blood glucose sensor modules, and the POPS!® mobile application as the display component.

The POPS!® one Blood Glucose Monitoring System is intended for use outside the body (in vitro diagnostic use) in the quantitative measurement of glucose in fresh capillary whole blood taken from the finger. It is intended to be used by people with diabetes mellitus at home as an aid in monitoring the effectiveness of a diabetes control program.

The POPS!® one Blood Glucose Monitoring System is intended to be used by a single patient and should not be shared. It is not intended for the diagnosis of, or screening of diabetes. It is not intended for use on neonates.

Product codes

NBW

Device Description

The POPS!® one Blood Glucose Monitoring System is designed to make blood glucose testing and diabetes management easier and more convenient. The traditional test kit is replaced by a low-profile meter that contains everything needed for testing and requires no assembly. The meter pairs with a mobile app installed on the user's phone via Bluetooth, allowing the meter to perform glucose testing and send the results to the app where they are communicated to the user and automatically stored.

The POPS!® one Blood Glucose Monitoring System contains the following:

  • . POPS!® one blood glucose meter works directly with the POPS!® app installed on the user's mobile phone. The meter performs a blood glucose test and sends the result to the POPS!" app.

  • . POPS!® one blood glucose sensor module is individually packed and sterile. It contains 3 test sites with separate foil covers; each containing a lancet and test strip. The user inserts the sensor module in the meter and replaces a used sensor module with a new once all 3 test sites have been used. The sensor module not only provides all components for performing a glucose test to the user in a convenient, self-contained format but it also provides a new lancet for each test; preventing lancet re-use.

  • . POPS!® mobile application acts as the primary interface with users; enabling them to test, communicating blood glucose results and messages, and allowing them to monitor trends on their phone.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

fresh capillary whole blood taken from the finger.

Indicated Patient Age Range

Not intended for use on neonates.

Intended User / Care Setting

people with diabetes mellitus at home

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical and clinical studies were conducted to test, verify and validate the performance of the proposed device according to FDA Guidance issued on October 11, 2016: Self-Monitoring Blood Glucose Test Systems for Over-the-Counter Use. Results from these studies show that all performance criteria were met.

Non-Clinical Testing Summary: Design verification and validation testing was performed to ensure that the POPS!® one System met design specifications and requirements. Testing activities included electrical/mechanical safety tests, functional performance tests (precision, linearity, interference, flex studies) as well as disinfection, cleaning, robustness, sterilization, shelf life and transit studies. Software validation was performed for this moderate level of concern device per FDA Guidance Content of Premarket Submissions for Software Contained in Medical Devices.

Clinical Testing Summary: A user evaluation confirmed the system accuracy, operation according to design, and ease of use to support the intended use as described in the proposed labeling.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K100322

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 862.1345 Glucose test system.

(a)
Identification. A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.(b)
Classification. Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.

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November 30, 2018

TaiDoc Technology Corporation Anne Kuo Regulatory Affairs Senior Specialist 6F. No.127. Wugong 2nd Rd., Wugu District New Taipei City, 24888 Taiwan

Re: K181588

Trade/Device Name: POPS! one Blood Glucose Monitoring System Regulation Number: 21 CFR 862.1345 Regulation Name: Glucose test system Regulatory Class: Class II Product Code: NBW Dated: October 26, 2018 Received: October 31, 2018

Dear Anne Kuo:

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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's

1

requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801 and Part 809); 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.html; good manufacturing practice requirements as set forth in the quality systems (OS) 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.

Kellie B. Kelm -S

for Courtney H. Lias, Ph.D. Director Division of Chemistry and Toxicology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K181588

Device Name

POPS!® one Blood Glucose Monitoring System

Indications for Use (Describe)

The POPS!® one Blood Glucose Monitoring System is comprised of the POPS!® one blood glucose meter, the POPS!® one blood glucose sensor modules, and the POPS!® mobile application as the display component.

The POPS!® one Blood Glucose Monitoring System is intended for use outside the body (in vitro diagnostic use) in the quantitative measurement of glucose in fresh capillary whole blood taken from the finger. It is intended to be used by people with diabetes mellitus at home as an aid in monitoring the effectiveness of a diabetes control program.

The POPS!® one Blood Glucose Monitoring System is intended to be used by a single patient and should not be shared. It is not intended for the diagnosis of, or screening of diabetes. It is not intended for use on neonates.

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

Assigned 510(k) number: K181588

In accordance with the requirements of 21 CFR 807.92, this summary is being provided to serve as basis for the substantial equivalence determination.

Submitter information

ManufacturerTaiDoc Technology Corporation
Address6F, No. 127, Wugong 2nd Rd. Wugu Dist.
New Taipei City, Taiwan 24888
Establishment Registration No.3004145393
Date PreparedNovember 30, 2018
CorrespondentTaiDoc Technology Corporation
Correspondent ContactAnne Kuo
TitleRegulatory Affairs Senior Specialist
Phone+886-2-6625-8188 #1195
E-mailra.cert@taidoc.com.tw
anne.kuo@taidoc.com.tw
CorrespondentPOPS! Diabetes Care, Inc.
Correspondent ContactJennifer Englund
TitleVice President, Clinical, Regulatory & Quality
Phone612-802-7606
E-mailjennifer.englund@popsdiabetes.com

Proposed Device Information

Proprietary namePOPS!® one Blood Glucose Monitoring System
Common nameBlood Glucose Monitoring System
Product codeNBW, Blood Glucose Test System, Over-the-Counter
Classification panelClinical chemistry
ClassificationClass II
Regulation citation21 CFR §862.1345, Glucose test system

CONFIDENTIAL

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Image /page/4/Picture/0 description: The image shows the logo for TaiDoc. The logo consists of the word "TaiDoc" in gray letters, followed by three red hearts. Below the hearts is the website address "www.taidoc.com" in white letters on a gray background. The logo is simple and clean, with the hearts adding a touch of warmth and care.

泰博科技股份有限公司 TaiDoc Technology Corp. 新北市24888五股區五工二路127號6樓 6F., No.127, Wugong 2nd Rd., Wugu Dist., New Taipei City 24888. Taiwan

Predicate Device Information

ManufacturerTaiDoc Technology Corporation
Proprietary NameTD-4277 Blood Glucose Monitoring System
Common NameBlood Glucose Monitoring System
510(k) NumberK100322

Intended use

The POPS!" one Blood Glucose Monitoring System is comprised of the POPS!" one blood glucose meter, the POPS!® one blood glucose sensor modules, and the POPS!® mobile application as the display component.

The POPS!" one Blood Glucose Monitoring System is intended for use outside the body (in vitro diagnostic use) in the quantitative measurement of glucose in fresh capillary whole blood taken from the finger. It is intended to be used by people with diabetes mellitus at home as an aid in monitoring the effectiveness of a diabetes control program.

The POPS!® one Blood Glucose Monitoring System is intended to be used by a single patient and should not be shared. It is not intended for the diagnosis of, or screening of diabetes. It is not intended for use on neonates.

Device Description

The POPS!® one Blood Glucose Monitoring System is designed to make blood glucose testing and diabetes management easier and more convenient. The traditional test kit is replaced by a low-profile meter that contains everything needed for testing and requires no assembly. The meter pairs with a mobile app installed on the user's phone via Bluetooth, allowing the meter to perform glucose testing and send the results to the app where they are communicated to the user and automatically stored.

The POPS!® one Blood Glucose Monitoring System contains the following:

  • . POPS!® one blood glucose meter works directly with the POPS!® app installed on the user's mobile phone. The meter performs a blood glucose test and sends the result to the POPS!" app.
  • . POPS!® one blood glucose sensor module is individually packed and sterile. It contains 3 test sites with separate foil covers; each containing a lancet and test strip. The user inserts the sensor module in the meter and replaces a used sensor module with a new once all 3 test sites have

5

Image /page/5/Picture/0 description: The image shows the logo for TaiDoc. The logo consists of the word "TaiDoc" in gray letters, with three red hearts below it. Below the hearts is the website address "www.taidoc.com" in white letters on a gray background.

been used. The sensor module not only provides all components for performing a glucose test to the user in a convenient, self-contained format but it also provides a new lancet for each test; preventing lancet re-use.

  • . POPS!® mobile application acts as the primary interface with users; enabling them to test, communicating blood glucose results and messages, and allowing them to monitor trends on their phone.

Test principle

The blood glucose testing is based on the measurement of electrical current generated by the reaction of glucose with the reagent of the strip within the Sensor Module. The system measures the current, calculates the blood glucose level, and displays the result. The strength of the current produced by the reaction depends on the amount of glucose in the blood sample.

Summary of Technological Characteristics and Comparison to the Predicate

The POPS!" one Blood Glucose Monitoring System is substantially equivalent to the predicate device, both in terms of intended use and technological characteristics. The primary differences between the proposed and predicate device are design changes to simplify the glucose testing experience and allow communication of results and messages to the user to occur via the POPS!® app.

The similarities and differences between the predicate and proposed devices are summarized in Table 1 and 2 below.

| Characteristic | Predicate device
TD-4277 | Proposed device
POPS!® one |
|---------------------|--------------------------------------|--------------------------------------|
| Operation principle | Electrochemical biosensor technology | Electrochemical biosensor technology |
| Detection method | Amperometric glucose biosensor | Amperometric glucose biosensor |
| Code calibration | No coding required | No coding required |
| Enzyme | Glucose dehydrogenase | Glucose dehydrogenase |
| Strip reaction time | 6 seconds | 6 seconds |
| Sample volume | 0.5 µL | 0.5 µL |

Table 1: Similarities between the Predicate and Proposed Devices

CONFIDENTIAL

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泰博科技股份有限公司 TaiDoc Technology Corp.

新北市24888五股區五工二路127號6樓 6F., No.127, Wugong 2nd Rd., Wugu Dist., New Taipei City 24888, Taiwan

Tel : +886-2-6625-8188 Fax : +886-2-6625-0288

www.taidoc.com

| Characteristic | Predicate device
TD-4277 | Proposed device
POPS!® one |
|--------------------------------------------|-------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------|
| Measurement range | 20600 mg/dL | 20600 mg/dL |
| Hematocrit range | 2060% | 2060% |
| Measurement unit | mg/dL | mg/dL |
| Measurement modes | Test Mode
AC (before meal)
PC (after meal)
Gen (not specified)
QC (quality control) | Test Mode
AC (before meal)
PC (after meal)
Gen (not specified)
QC (quality control) |
| Strip indication light | Yes | Yes |
| Meter storage/
transportation condition | -4 °F to 140°F,