The WELL-LIFE OTC Abdomen System / Model WL-2412 is the electrical muscle stimulator intended for the following indication for use:
• Strengthening, toning and firming of the abdomen region.

Device Description

The Well-Life OTC ABDOMEN SYSTEM model WL-2412 is battery-operated programmable muscle stimulator intended to improve or facilitate muscle performance by applying an electrical current to electrodes, which are attached on abdomen.

Well-Life OTC ABDOMEN SYSTEM model WL-2412, consists mainly of three parts: the stimulator , electrodes, and support belts fitting for special parts of body. The stimulator generates the output current specified as the input of controller. The output port transmits the output current to the electrode, which is attached to the specified region, so as to transmit this stimulus current to the region of abdomen for the following intended purposes:

Strengthening, toning and firming of the abdomen region.

To adequately locate the stimulation on the intended treatment area, the following support belt is provided together with the stimulator:

· The abdomen belt, which is capable of connecting to the both two output channels of stimulator.

The stimulation mode for Well- Life OTC ABDOMEN SYSTEM includes several different operation modes as mentioned on the comparison table. These operation modes are generated from the software control by using the microprocessor as its main control unit.

AI/ML Overview

Here's a breakdown of the acceptance criteria and study information for the Well-Life OTC Abdomen System (model WL-2412) based on the provided 510(k) summary:

This device is a Powered Muscle Stimulator, which typically focuses on electrical and functional safety, and comparisons to predicate devices for substantial equivalence. It does not involve AI or complex diagnostic accuracy studies.

Device Acceptance Criteria and Performance

Acceptance Criteria Category	Specific Criteria/Test	Reported Device Performance
Safety	Compliance to voluntary standards	ANSI/AAMI NS4-1985 (likely for electrical safety and performance of powered muscle stimulators)
	Compliance to voluntary standards	EN 60601-1 (Medical electrical equipment - Part 1: General requirements for basic safety and essential performance)
	Compliance to voluntary standards	EN 60601-1-1 (Collateral standard for safety requirements for medical electrical systems - likely specific to the combination of the stimulator and accessories)
	Compliance to voluntary standards	EN 60601-1-2 (Collateral standard for electromagnetic compatibility - requirements and tests)
	Software verification	Carried out according to FDA software guidance
Effectiveness	Maintenance of intended use	The differences in the submitted model do not "affect the intended use," which is "Strengthening, toning and firming of the abdomen region."
	Maintenance of fundamental scientific technology	The differences in the submitted model do not "alter the fundamental scientific technology of the device," implying it operates on the same principle as the predicate device.
	Verification & Validation Tests (Overall Equivalence)	"Verification and validation tests contained in this submission demonstrate that the difference in the submitted demonstrate that the difference in the submitted model could maintain the same safety and effectiveness as that of cleared device." (Details of these tests beyond standard compliance are not provided in the summary).
Functional Equivalence	Comparison to Predicate Device (Slendertone Flex K010335)	The device "has the same intended use and technological characteristics as the cleared device," and engineering differences do not affect intended use or fundamental scientific technology.

Study Information

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The 510(k) summary does not mention a specific "test set" in the context of clinical data or patient outcomes for this type of device. The evaluation appears to be based on:
* Engineering and Performance Testing: Compliance with recognized electrical and safety standards (ANSI/AAMI, EN 60601 series). These tests likely involve laboratory settings and instrumentation, not human subjects or patient data.
* Software Verification: Done according to FDA guidance.
* Comparison to Predicate Device: Evaluation of technological characteristics.
No information regarding country of origin, retrospective/prospective nature, or sample size for patient data is provided because such studies were not deemed necessary for this type of device and submission.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. No "ground truth" was established by experts in a clinical or diagnostic context for this type of device or submission. The evaluation relies on engineering standards, software validation, and a comparison of technical specifications to a predicate.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No clinical test set or adjudication process of the type described was utilized.

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
Not applicable. This device is a powered muscle stimulator, not an AI-assisted diagnostic tool.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a muscle stimulator, not an algorithm, and its intended use does not involve human-in-the-loop performance in a diagnostic or AI context.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device's safety and effectiveness is largely based on adherence to recognized electrical and medical device safety standards (ANSI/AAMI, EN 60601 series) and demonstrated functional equivalence to a legally marketed predicate device (K010335). There isn't a complex clinical "ground truth" in the diagnostic sense.

8. The sample size for the training set
Not applicable. This device is not an AI/machine learning device that requires a training set.

9. How the ground truth for the training set was established
Not applicable.

Summary

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510(K) SUMMARY

K072168

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

The assigned 510(k) number is:

Submitter's Identifications: Well-Life Healthcare Ltd. 1 Fl., No. 16, Lane 454, Jungjeng Rd., Yunghe City, Taipei County, Taiwan, R.O.C.

Contact: Ms. Jenny Hsieh General Manager

DEC 1 9 2007

Date of Summary Preparation: November 23, 2007.

1. Name of the Device:

Trade name:	Well-Life OTC Abdomen System; model WL-2412
Common name:	Powered Muscle Stimulator
Classification name:	Stimulator, Muscle, Powered
Product Code:	NGX

1. Information of the 510(k) Cleared Device (Predicate Device):
  For this 510(k) submission, we compared our models to the following FDA cleared OTC devices:
K010335: Slendertone Flex, made by Bio-Medical Research Ltd.
1. Device Description:
  The Well-Life OTC ABDOMEN SYSTEM model WL-2412 is battery-operated programmable muscle stimulator intended to improve or facilitate muscle performance by applying an electrical current to electrodes, which are attached on abdomen.

Strengthening, toning and firming of the abdomen region.

To adequately locate the stimulation on the intended treatment area, the following support belt is provided together with the stimulator:

· The abdomen belt, which is capable of connecting to the both two output channels of stimulator.
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5. Intended Use:

Basically the indication for use is defined clearly as the description of the following table:

Model Name	Statement of “indication for use”	Intended for
WL-2412	The electrical muscle stimulator intended for the following indication for use:• Strengthening, toning and firming of the abdomen region.	OTC

6. Discussion of Non-Clinical Tests Performed Determination of Substantial Equivalence are as follows:

Compliance to applicable voluntary standards includes ANSI/AAMI, NS4-1985, as well as EN 60601-1, EN 60601-1-1, and EN 60601-1-2 requirement.

In addition to the compliance of voluntary standards, the software verification has been carried out according to the FDA software guidance.

7. Conclusions

The Well Life OTC ABDOMEN SYSTEM, model WL-2412, has the same intended use and technological characteristics as the cleared device of Slendertone Flex (K010335). Moreover, verification and validation tests contained in this submission demonstrate that the difference in the submitted demonstrate that the difference in the submitted model could maintain the same safety and effectiveness as that of cleared device.

ln the other words, those engineering difference do not: (1) affect the intended use or (2) alter the fundamental scientific technology of the device. Therefore, the Well Life OTC ABDOMEN SYSTEM, model WL-2412, is substantial equivalent to the chosen predicate model.

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Image /page/2/Picture/1 description: The image shows the seal of the U.S. Department of Health & Human Services. The seal features the department's name in a circular arrangement around a stylized symbol. The symbol consists of a series of three parallel, curved lines that resemble a caduceus without the snake, representing health and well-being. The text reads "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA".

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

DEC 1 9 2007

Well-Life Healthcard Ltd. % Ms. Jenny Hsieh General Manager 1 Fl., No. 16, Lane 454 Jungjeng Rd., Yunghe City Taipei County, Taiwan, R.O.C.

K072168 Re:

Trade/Device Name: Well-Life OTC Abdomen System, Model WL-2412 Regulation Number: 21 CFR 890.5850 Regulation Name: Powered muscle stimulator Regulatory Class: Class II Product Code: NGX Dated: November 23, 2007 Received: November 26, 2007

Dear Ms. Hsieh:

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 such 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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); 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.

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Page 2 - Ms. Jenny Hsieh

This letter will allow you to begin marketing vour device as described in your Section 510/k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours.

Mark N. Millman

Mark N. Melkerson Director Division of General, Restorative and Neurological 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: OTC Abdomen System / Model: WL-2412.

Indications For Use:

The WELL-LIFE OTC Abdomen System / Model WL-2412 is the electrical muscle stimulator intended for the following indication for use:

Strengthening, toning and firming of the abdomen region.
Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off)
Division of General, Restorative, and Neurological Devices	Page 1 of 1
510(k) Number	K072168

Regulation Number and Section

§ 890.5850 Powered muscle stimulator.

(a)
Identification. A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.(b)
Classification. Class II (performance standards).