The miraDry System MD4000 is indicated for use in the treatment of primary axillary hyperhidrosis plus unwanted underarm hair removal, and permanent reduction of underarm hair of all colors for Fitzpatrick skin types I - IV.

Permanent hair reduction is defined as long-term, stable reduction in the number of hairs reasured at 6. 9 and 12 months after the completion of a treatment regime.

Device Description

The miraDry System MD4000 is a microwave device designed to heat tissue located at the dermal- hypodermal interface where the axillary sweat glands and hair bulbs reside using a surface contact applicator. The miraDry System MD4000 consists of: the MD4000-MC Console; the MD4000-HP miraDry Handpiece; and a disposable, sterile MD4000-BT miraDry bioTip that snaps onto the Handpiece to provide a sterile protective cover.

As described in K131162, the miraDry System MD4000 also includes Class I components/accessories. The MD4000-TS template system is a required component for the miraDry treatment as well as the MD4000-PK priming kit. The MD4000-PK priming kit is required when the system is initially set up at a user facility. Optional accessories include an armrest and disposable ice packs.

The MD4000-MC Console is a software-driven device which contains circuit boards, a microwave generator, integrated vacuum and cooling systems, and an integrated touch-screen user interface.

The non-invasive miraDry Handpiece is specifically designed to deliver microwave energy to the skin at specified frequency and power levels. The proximal end of the Handpiece has a cable bundle and a console connector that supplies the energy and cooling to the Handpiece. The distal end has a sterile, disposable barrier, the miraDry bioTip, which contacts the patient.

AI/ML Overview

Here's an analysis of the acceptance criteria and study detailed in the provided document, restructured to address your specific points:

The document describes the Miramar Labs miraDry System MD4000, which has an expanded indication for underarm hair removal in addition to primary axillary hyperhidrosis treatment. The information below focuses on the hair removal aspect.

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria	Reported Device Performance (Hair Reduction)
Primary Endpoint: >30% reduction (baseline to 3 months, measured by hair counts) in >50% of subjects.	88.1% (37/42) of subjects showed >30% hair reduction at 3 months (lower 95% CL: 76.6%). This met the criterion.
Secondary Endpoint: >30% reduction (comparing baseline to 12 months photos) to make a claim for permanent axillary hair reduction.	95.5% (42/44) of subjects showed >30% hair reduction at 12 months (lower 95% CL: 86.4%). This met the criterion.
	Average Reduction:
	- 3 months: 66% (± 30%)
	- 6 months: 72% (± 29%)
	- 9 months: 75% (± 28%)
	- 12 months: 75% (± 27%)
	Side-by-side axilla review:
	- 3 months: 74% of pairs had at least 26-50% reduction
	- 6 months: 78% of pairs had at least 26-50% reduction
	- 9 months: 78% of pairs had at least 26-50% reduction
	- 12 months: 89% of pairs had at least 26-50% reduction
	Patient satisfaction with hair reduction (rating "very satisfied" or "somewhat satisfied"):
	- 3 months: 81%
	- 6 months: 70%
	- 9 months: 68%
	- 12 months: 70%

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

Sample Size: 56 subjects were enrolled.
- For the primary endpoint (3-month hair count): 42 subjects were assessable.
- For the secondary endpoint (12-month hair count): 44 subjects were assessable.
Data Provenance: The study was conducted at three private dermatology clinics in the United States. It was a prospective clinical trial, initiated in September 2012.

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

The document states that an "independent physician reviewer" conducted a blinded comparison of baseline to follow-up full-axilla photos to score hair reduction.
The specific number of independent physician reviewers is not explicitly stated (e.g., "an independent physician reviewer" could imply one, or a panel reviewed by one lead).
The qualifications of the independent physician reviewer(s) are not detailed beyond "physician."

4. Adjudication Method for the Test Set

The document primarily mentions a "blinded comparison of baseline to follow-up full-axilla photos by an independent physician reviewer," implying a single reviewer's assessment for photo-based evaluation.
For hair counts, the method of counting and potential adjudication is not explicitly described. Given it's a quantitative measure, it might rely on standardized methods rather than expert adjudication in the same way image review would.

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 study evaluates the device's direct performance in hair reduction, not the influence of AI on human reader performance. The device itself is the treatment, not an AI diagnostic aid.

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

Yes, this was a standalone performance study of the device/treatment itself. The device, the miraDry System MD4000, is a therapeutic device that physically reduces hair. The study assesses the effectiveness of this physical treatment in a clinical setting, without any AI algorithm involved in the treatment delivery or primary assessment.
The "performance" described is the direct clinical outcome from using the miraDry system.

7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

The ground truth was established using a combination of:

Quantitative Measurement: Hair counts (primary method).
Expert Review: Blinded comparison of baseline and follow-up photos by an independent physician reviewer.
Patient-Reported Outcomes: Subject assessment of overall satisfaction, odor rating, and sweat ratings (though sweat and odor are related to the hyperhidrosis indication, they were collected).
Clinical Observation: Assessment of adverse events.

8. The Sample Size for the Training Set

The document describes a clinical trial (performance study) for the expanded indication. It does not mention a "training set" in the context of an AI algorithm or a machine learning model.
Therefore, N/A (Not Applicable) as this is not an AI/ML device.

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

N/A (Not Applicable) as there was no training set mentioned in the context of an AI/ML device.

Summary

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

June 19, 2015

Miramar Labs Incorporated Dr. Kathy O'Shaughnessy, Ph.D. Vice President, Clinical/Regulatory/Quality Assurance 2790 Walsh Avenue Santa Clara, California 95051

Re: K150419

Trade/Device Name: MiraDry System MD4000 Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: OUB, NEY, MWY Dated: May 5, 2015 Received: May 6, 2015

Dear Dr. O'Shaughnessy:

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. 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 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

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Page 2 - Ms. Kathy O'Shaughnessy, Ph.D.

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 contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Jennifer R. Stevenson -S

For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K150419

Device Name miraDry System MD4000

Indications for Use (Describe)

Permanent hair reduction is defined as long-term, stable reduction in the number of hairs reasured at 6. 9 and 12 months after the completion of a treatment regime.

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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5. 510(k) Summary
GENERAL INFORMATION
Classification:	Class II (special controls)
Classification No.:	21 CFR 878.4400
Classification Name:	Electrosurgical cutting and coagulationdevice and accessories.
Product Code(s):	OUB, NEY, MWY
Common Name:	Instrument for Treatment of HyperhidrosisSystem, Ablation, Microwave AndAccessories
Trade Name:	System, Microwave, Hair RemovalmiraDry System MD4000
Submitter:	Miramar Labs, Inc.2790 Walsh AvenueSanta Clara, CA 95051USATel: 408-940-8700Fax: 408-940-8795FDA Registration No.: 3008082710
Contact:	Kathy O'Shaughnessy, PhDVP, Clinical/Regulatory/Quality
Date prepared:	06/16/15

INTENDED USE

Permanent hair reduction is defined as long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

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PREDICATE DEVICES

The miraDry System MD4000 (K131162).

REFERENCE DEVICE

The Microwave Delivery System Model MMC-330 (K991456).

DEVICE DESCRIPTION

The MD4000-MC Console is a software-driven device which contains circuit boards, a microwave generator, integrated vacuum and cooling systems, and an integrated touch-screen user interface.

SUMMARY OF SUBSTANTIAL EQUIVALENCE

The miraDry System MD4000 with the revised, expanded indication to include underarm hair removal is substantially equivalent to the miraDry System MD4000 as previously cleared for sweat reduction. The subject and predicate device have the same fundamental technology, design, and method of usage. A comparison of the two devices is shown in Table 1 below.

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Characteristics	Predicate DevicemiraDry MD4000	Subject DevicemiraDry MD4000
510(k)	K131162	K150419
Device Class	II	II
Energy Type	Microwave	Microwave
Mode of Action	generation of localized heat	generation of localized heat
Product Code	NEY, OUB	NEY, OUB, MWY
Indications for Use	The miraDry System is indicated foruse in the treatment of primaryaxillary hyperhidrosis.Note: The miraDry System is notindicated for use in the treatment ofhyperhidrosis related to other bodyareas or generalized hyperhidrosis.	The miraDry System MD4000 isindicated for use in the treatment ofprimary axillary hyperhidrosis plusunwanted underarm hair removal,and permanent reduction ofunderarm hair of all colors forFitzpatrick skin types I - IV.Permanent hair reduction is definedas long-term, stable reduction inthe number of hairs regrowingwhen measured at 6, 9 and 12months after the completion of atreatment regime.
Function	Heat absorption by tissue located atthe dermal- hypodermal interfacewhere the axillary sweat glandsreside	Heat absorption by tissue locatedat the dermal- hypodermal interfacewhere the axillary sweat glandsand hair bulbs reside
Overall Systemstructure	microwave source/amplifier, coolantsupply system, operator interface,and microwave, electrical andcoolant lines that connect to theapplicator	microwave source/amplifier,coolant supply system, operatorinterface, and microwave, electricaland coolant lines that connect tothe applicator
Key Components	Console, handpiece, disposableapplicator tip	Console, handpiece, disposableapplicator tip
Console ControlMechanism	electronic user interface	electronic user interface
Coolant usage	Delivers cooling to the skin surface	Delivers cooling to the skin surface

	Table 1. Substantial Equivalence Comparison Table.

NON-CLINICAL TESTING

There was no additional non-clinical testing that was completed, as the device being used is the same as the cleared device (miraDry System MD4000, cleared under K131162).

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CLINICAL TESTING

The safety and effectiveness of the clinical application of the miraDry System MD4000 for sweat reduction was demonstrated in prior clinical studies. The performance for underarm hair reduction was demonstrated in a clinical trial of 56 subjects.

The primary objective of this study was to quantify hair reduction in the axillae after treatment(s) with the miraDry System MD4000. The study device was used in the same manner as the commercially available technique cleared by the FDA for the treatment of primary axillary hyperhidrosis, as described in the User Manual.

The study was conducted at three private dermatology clinics in the United States. The study was initiated at the first site in September of 2012. Adult subjects seeking hair reduction in the axillae were considered for enrollment. Subjects were treated with the miraDry System MD4000 using the standard miraDry procedure in one or two treatment sessions 3 months apart.

Fifty-six subjects were enrolled in the study. The mean age was 33 years; 80% of the subjects were female and 88% were Caucasian. The majority of the subjects were of Fitzpatrick skin type I-IV. 23% (13/56) of the subjects completed only one treatment session; 5 of these 13 subjects declined a second session due to adverse events. The primary endpoint of this study was to show >30% reduction (baseline to 3 month, measured by hair counts) in >50% of subjects. There were 42 subjects assessable for this endpoint. The secondary endpoint was to show >30% reduction (comparing baseline to 12 months photos) to make a claim for permanent axillary hair reduction. Additional analyses used a blinded comparison of baseline to follow-up full-axilla photos by an independent physician reviewer to correctly identify which photo had more hair and score hair reduction at follow-up. Also, a subject assessment of overall satisfaction, odor rating and sweat ratings was determined at the follow-up visits. A summary of the results is presented in Table 2 below.

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Efficacy measure	Follow-up visit time from the last treatment session
	3 months	6 month	9 month	12 month
Hair count:% of subjects with >30%reduction [lower 95% CL]	Primary:88.1% (37/42)[76.6%]	97.5% (39/40)[88.7%]	92.1% (35/38)[80.8%]	Secondary:95.5% (42/44)[86.4%]
Hair count:Average reduction [std]Light hair subgroup (n)	66% [± 30%]66% (n=12)	72% [± 29%]	75% [± 28%]	75% [± 27%]72% (n=13)
Side-by-side axilla review:% of pairs having at least26-50% reduction	74% (63/85)	78% (65/83)	78% (66/85)	89% (83/93)
Patient satisfaction with hairreduction: % of subjectsrating "very satisfied" or"somewhat satisfied"	81%(38/47)	70%(31/44)	68%(30/44)	70%(33/47)
Odor self-assessment, Meanreduction 10pt scale	2.6 ± 3.0	2.8 ± 2.8	2.5 ± 2.8	2.4 ± 2.7
% of subjects with HDSSreduction to score of 1 or 2	92%(23/25)	96%(25/26)	96%(24/25)	89%(25/28)

2: Summary of Efficacy Results

Both the primary and secondary endpoints were met, since the percentage of patients with hair reduction of at least 30% was significantly higher than 50% at all follow-up timepoints.

All subjects experienced at least one (1) treatment-related adverse event (AE), 99% (324/326) of all AE's were rated as mild in severity. Many subjects experienced the expected mild transient post-treatment effects; the most common were localized edema (55%), tingling or numbness in the treatment area (30%), vacuum acquisition marks (29%), bumps or lumps under the skin (29%) or discomfort or tenderness in the treatment area (26%). Other rarer treatment effects affecting more than the treatment area were noted in 18% of subjects (10/56), 75% of which were rated as mild. These included numbness or tingling in the arms (n=6 events); more extensive swelling in the adjacent area (e.g. arms) (n=4 events); and bruising outside the treatment area (n=2 events). One patient experienced unilateral ulnar neuropathy that was improving but not completely resolved at study exit. The types, rates and severity of the reported AE's are substantially equivalent to those from the predicate device (MD4000-MC with the hyperhidrosis indication, K131162).

The modification to the Indications for Use statement has not altered the fundamental technology of the miraDry System MD4000.

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CONCLUSION

As described in this 510(k) Summary, Miramar Labs Inc. considers the miraDry System MD4000 to be substantially equivalent to the predicate device.

Regulation Number and Section

§ 878.4400 Electrosurgical cutting and coagulation device and accessories.

(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.