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510(k) Data Aggregation

    K Number
    K132042
    Manufacturer
    Date Cleared
    2014-04-28

    (300 days)

    Product Code
    Regulation Number
    886.4750
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    X6D, LTD.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Amblyz™ System is an electronic shutter module intended to provide occlusions of the eye in an intermittent fashion.

    Device Description

    The Amblyz™ device is an optical eyewear using a Liquid Crystal lens and electronics technology that acts as an intermittent shutter. The shutter incorporated in the optical lens performs an occlusion of the sound eye in an intermittent mode by changing the lens from a clear to an opaque state via electronic control. The system incorporates the following components: Spectacle Frame, Liquid Crystal Shutter (LCS), Earpieces, Nose Piece, Clip to Hold Refractive Lens, Micro-USB Connector, LED Indicator, ON/OFF Switch, Programming Button, Amblyz™ onboard Software, Amblyz™ Technician Software.

    AI/ML Overview

    The Amblyz™ system is an electronic shutter module intended to provide occlusions of the eye in an intermittent fashion. The provided document details several performance tests for the Amblyz™ system, but it does not specify explicit acceptance criteria for each test in a quantitative manner. Instead, it describes the results of the tests, implying that these results meet unstated acceptance criteria.

    1. Table of Acceptance Criteria and Reported Device Performance

    Test DescriptionAcceptance Criteria (Implied)Reported Device Performance
    Operation time without chargeOver 48 hours (based on predicate comparison)Over 48 hours
    Charging timeLess than 2 hours (based on predicate comparison)Less than 2 hours
    Lens transparency40% (based on predicate comparison)40%
    Contrast ratioOver 400 (based on predicate comparison)Over 400
    Electrical Characteristics TestAll tests passed successfully and meet acceptance criteriaAll tests passed successfully and meet acceptance criteria
    Lens Impact Resistance/Drop BallLenses should not shatter into pieces when crackedThe lenses cracked but did not shatter into pieces and therefore comply with standard requirements
    Destructive TestLaminated films should hold glass pieces and no glass residuesThe LC lens glass was cracked and the liquid crystal was spread across the glass. Nevertheless, the laminated films completely held the LCM glass pieces. No change in the overall package and no glass residues were found. Test was performed on four lenses, all resulting in same findings
    Charge/Discharge TestSufficient operating time with the batteryTests show, that glasses have more than enough operating time with the used battery.
    Charging Time TestAll 10 test cases comply with acceptance criteriaAll ten (10) test cases comply with the acceptance criteria
    Climatic TestingSamples sustain specified environmental testing without damageThe samples sustained the specified environmental testing, no damage was noted.
    Unpacked Drop TestAll samples pass visual and operational checks after dropAll samples have passed all visual and operating/performance checks after the drop
    Cosmetic ResistanceNo visual change on tested samples after the testNo visual change on tested samples after the test was completed.
    Sweat ResistanceNo visual change on tested surfacesNo visual change observed on tested surfaces in all tested samples
    Cleaning ResistanceNo visual change on tested surfacesNo visual change observed on tested surfaces in all tested samples
    Thermal ShockAll samples pass visual and operational checks after the testAll samples have passed all visual and operating/performance checks after the test
    Fall Test - Master PackagingFunctional and cosmetic inspections pass successfullyFunctional and cosmetic inspections have passed successfully.
    Fall Test - Retail PackagingAll samples pass and meet acceptance criteriaAll samples passed and meet acceptance criteria
    Transportation Vibration TestUnits pass functionality check with no problemsAfter the completion of Transportation Vibration Test, units inside the carton box were subjected to functionality check. All test units passed the functionality check with no functionality and cosmetic problem.
    Bump TestUnits pass functionality check with no problemsAfter the completion of Bump Test, units inside the carton box were subjected to functionality check. All test units passed the functionality check with no functionality and cosmetic problem.
    Biocompatibility Testing (ISO 10993-5)No in vitro cytotoxicity observed (implies)Cytotoxicity testing was conducted on all components in direct contact with the patient (Spectacle Nosepiece, Front frame, Amblyz™ Insert left & right part of the handle), based on ISO 10993-5. (Results are not explicitly stated, but the conclusion implies compliance).
    Electrical safety & EMC (IEC 60601-1, 60601-1-2)Compliance with standard requirementsThe Amblyz™ has found to comply with the requirements of these standards. (Certificate of Compliance attached to submission).
    Software V&VSoftware verifies and validates (implies)Software verification and validation testing performed. (No specific results beyond "performed" are given, but the overall conclusion states acceptable safety and performance).
    Hazard Analysis (ISO 14971:2012)Hazard analysis performed with risk level and solutions (implies)Hazard analysis including risk level and solutions performed in compliance with ISO 14971:2012 for the entire system and for the software. (No specific results beyond "performed" and "in compliance" are given).

    Regarding the study that proves the device meets the acceptance criteria:

    The provided document describes a series of safety and performance tests conducted for the Amblyz™ device. These are primarily bench testing (in vitro) and engineering verification/validation activities, rather than a clinical study involving human patients to assess therapeutic efficacy. The intent of these tests is to demonstrate the physical, electrical, and material safety and performance of the device itself, and its compliance with relevant standards.

    Here's a breakdown of the specific information requested, based on the provided text:

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    • Sample Size for Test Set:
      • Destructive Test: 4 lenses.
      • Charging Time Test: 10 test cases (presumably 10 devices or instances of testing).
      • Climatic Testing: "The samples" (specific number not given).
      • Unpacked Drop Test: "All samples" (specific number not given).
      • Cosmetic Resistance: "tested samples" (specific number not given).
      • Sweat Resistance: "all tested samples" (specific number not given).
      • Cleaning Resistance: "all tested samples" (specific number not given).
      • Thermal Shock: "All samples" (specific number not given).
      • Fall Test - Retail Packaging: "All samples" (specific number not given).
      • Transportation Vibration Test & Bump Test: "units inside the carton box" (specific number not given).
    • Data Provenance: Not explicitly stated. These appear to be internal engineering and lab tests, so the "country of origin of the data" would likely be Cyprus (where the applicant is located) or the location of the testing laboratories. The tests are prospective in nature, as they were conducted to evaluate the device prior to submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • This question is not applicable to the type of testing described. The tests are primarily for device performance, safety, and material properties, which are evaluated against engineering specifications and industry standards, not against "ground truth" established by clinical experts in the sense of diagnosis or treatment outcomes. The "ground truth" for these tests would be the physical properties, electrical outputs, or material integrity, as measured by standard laboratory equipment and procedures, and interpreted by qualified engineers/technicians in the testing facilities.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    • This question is not applicable as the tests are for objective device performance and safety, not for subjective interpretation by multiple readers/experts. The evaluation relied on compliance with predetermined technical specifications and standards.

    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, an MRMC comparative effectiveness study was NOT done. This device is an ophthalmic eye shield for amblyopia treatment, not an AI-powered diagnostic or assistive tool for human readers. The submission focuses on the safety and functional equivalence to a predicate device.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

    • Not applicable in the context of AI/algorithm performance. The "standalone" performance refers to the device's operational characteristics (e.g., battery life, lens transparency, shutter function) which are extensively tested and reported as per the table above. There is no AI algorithm being evaluated for performance on its own.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

    • For the physical and electrical performance tests, the "ground truth" is defined by engineering specifications, industry standards (e.g., IEC 60601-1, ISO 10993-5, ISO 14971), and objective physical measurements. For example, the "ground truth" for charging time is the measured time compared to the specified limit; for impact resistance, it's the observation of shattering vs. non-shattering.
    • For biocompatibility, the ground truth is established by the results of in vitro cytotoxicity tests according to ISO 10993-5.

    8. The sample size for the training set:

    • Not applicable. This device is a hardware product with embedded firmware, not a machine learning or AI model that requires a "training set" in the conventional sense. The "Amblyz™ onboard Software (firmware)" is programmed, not trained.

    9. How the ground truth for the training set was established:

    • Not applicable. As there is no "training set" for an AI or machine learning model, this question does not apply. The firmware's correctness would be established through software verification and validation against its design specifications.
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