K Number
K162416
Device Name
IRIDEX Cyclo G6 Laser System, G-Probe Illuminate
Manufacturer
Date Cleared
2016-09-29

(30 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Family of IRIDEX® IQ Laser Systems (IQ 532 [532nm], IQ 630-670 [630nm-670mm], IQ 810 [810mm] [IRIDEX Cyclo G6 Laser System]) and the hand pieces & accessories that are used with them to deliver laser energy in either CW-pulse, MicroPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, excision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows: 810nm (The IRIDEX Cyclo G6 Laser System) Ophthalmology: The IRIDEX® Cyclo G6™ Laser System and Probe Delivery Devices (G-Probe Illuminate, & MicroPulse® P3) are used to deliver laser energy in either CW-Pulse (CW) or MicroPulse (uP) treatment mode and indicated for the treatment of Glaucoma: MicroPulse P3 Device: For the treatment of Glaucoma including: • Primary Open-Angle • Closed-Angle • Refractory. Treatment (Intended Use): Transscleral Cyclophotocoagulation (TSCPC) of the ciliary processes. Mode: μP G-Probe & G-Probe Illuminate: For the treatment of Glaucoma including: • Primary Open-Angle • Closed-Angle • Refractory. Treatment (Intended Use): Transscleral cyclophotocoagulation (TSCPC) of the ciliary processes. Mode: CW
Device Description
The Iridex Cyclo G6 is an 810nm (diode) ophthalmic laser comprised of the following main components: - Main console containing the major electrical components, including: - Control Panel including control knobs (power, interval, duration or software assigned function), treat/standby button, and display; - Two delivery device fiber-optic connector ports (only one active at a time); - LIO illumination connection; - Smart key port for detecting/operating safety filters and/or accessory identification; - Emergency stop switch; - Key switch; - Connector ports for the footswitch, remote control, and power cord; - A treatment Footswitch (either wired, wireless, or wireless with PowerAdjust); - A Wired Remote Control that duplicates the control panel; - Delivery Accessories including G-Probe and MicroPulse P3 probe Handpieces, and the G-Probe Illuminate - Optional Cart/Stand The laser system automatically enters the "Standby" mode after it is turned on and completes its internal "selftest". Laser emission is not possible until the user attaches the proper delivery device, selects the desired treatment settings, verifies eye safety filter status, places the system into "Ready", and depresses the footswitch. The system has a primary display screen (power, interval, duration, pulse mode, aiming beam brightness, illumination brightness, treatment/standby toggle, counter reset) and additional screens for ancillary options (system volume, display contrast/brightness, preset selection (user defined/generated), aiming beam settings). The user may adjust power, treatment duration, treatment interval, type of laser output mode (CW-pulse, MicroPulse), aiming beam brightness, illumination brightness, and reset the laser shot counter. Additionally, for some delivery devices the user may optionally select the on/off operation of the countdown timer on the display screen as well as the on/off function of the voice countdown. The G-Probe Illuminate that is the subject of this 510(k) is a handheld fiber optic delivery device. It is intended to be used to perform transscleral cyclophotocoagulation of the ciliary processes. It is differentiated from the G-Probe described in earlier submissions by the incorporation of two additional optical fibers to provide white light transillumination of the optic globe. Such transillumination can aid probe placement by revealing the location of internal ocular structures such as the ciliary processes. The incorporation of this transillumination function into a multifunction probe offers the user similar functionality as a separate handheld transilluminator, with a more convenient setup that requires fewer hands or assistants to operate. It is provided as a sterile, single-use device.
More Information

Not Found

No
The document describes a laser system with various control parameters and delivery devices. There is no mention of AI, ML, image processing, or any data-driven decision-making or analysis within the device's functionality. The changes described relate to hardware modifications (illumination fibers) and standard performance testing.

Yes
The device is described as a laser system used for medical treatments in ophthalmology, specifically for glaucoma, which indicates its therapeutic purpose.

No

The device is a therapeutic laser system used for treatment (incision, excision, coagulation, vaporization, ablation, and hemostasis of tissue, specifically for glaucoma treatment), not for diagnostic purposes. While it aids in probe placement by revealing internal ocular structures, this is a procedural aid, not a diagnosis.

No

The device is a laser system with multiple hardware components including a main console, footswitch, remote control, and delivery accessories (handpieces and probes). While it has a control panel and display which likely involve software, the core function and components are hardware-based. The submission also details hardware testing (sterilization, biocompatibility, illumination, shelf life, transit testing).

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly describes a surgical laser system used for treating glaucoma by applying laser energy to the ciliary processes. This is a therapeutic procedure performed directly on the patient's body.
  • Device Description: The device description details a laser system, handpieces, and accessories used to deliver laser energy. It does not mention any components or processes related to testing samples of human origin (like blood, urine, tissue, etc.) in vitro (outside the body) to provide diagnostic information.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples.
    • Providing diagnostic information about a patient's health status.
    • Using reagents or assays.
    • Measuring analytes in a sample.

The device is a therapeutic medical device used for surgical intervention.

N/A

Intended Use / Indications for Use

The Family of IRIDEX® IQ Laser Systems (IQ 532 [532nm], IQ 630-670 [630nm-670mm], IQ 810 [810mm] [IRIDEX Cyclo G6 Laser System]) and the hand pieces & accessories that are used with them to deliver laser energy in either CW-pulse, MicroPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, excision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows:

810nm (The IRIDEX Cyclo G6 Laser System)

Ophthalmology:

The IRIDEX® Cyclo G6™ Laser System and Probe Delivery Devices (G-Probe Illuminate, & MicroPulse® P3) are used to deliver laser energy in either CW-Pulse (CW) or MicroPulse (uP) treatment mode and indicated for the treatment of Glaucoma:

MicroPulse P3 Device: For the treatment of Glaucoma including: • Primary Open-Angle • Closed-Angle • Refractory. Treatment (Intended Use): Transscleral Cyclophotocoagulation (TSCPC) of the ciliary processes. CW/μP: μP

G-Probe & G-Probe Illuminate: For the treatment of Glaucoma including: • Primary Open-Angle • Closed-Angle • Refractory. Treatment (Intended Use): Transscleral cyclophotocoagulation (TSCPC) of the ciliary processes. CW/μP: CW

Product codes

GEX

Device Description

The Iridex Cyclo G6 is an 810nm (diode) ophthalmic laser comprised of the following main components:

  • . Main console containing the major electrical components, including:
    • Control Panel including control knobs (power, interval, duration or software assigned ● function), treat/standby button, and display;
    • Two delivery device fiber-optic connector ports (only one active at a time); ●
    • . LIO illumination connection;
    • Smart key port for detecting/operating safety filters and/or accessory identification; ●
    • Emergency stop switch;
    • Key switch; ●
    • Connector ports for the footswitch, remote control, and power cord;
    • A treatment Footswitch (either wired, wireless, or wireless with PowerAdjust); ●
    • A Wired Remote Control that duplicates the control panel;
    • Delivery Accessories including G-Probe and MicroPulse P3 probe Handpieces, and the ● G-Probe Illuminate
    • Optional Cart/Stand

The laser system automatically enters the "Standby" mode after it is turned on and completes its internal "selftest". Laser emission is not possible until the user attaches the proper delivery device, selects the desired treatment settings, verifies eye safety filter status, places the system into "Ready", and depresses the footswitch.

The system has a primary display screen (power, interval, duration, pulse mode, aiming beam brightness, illumination brightness, treatment/standby toggle, counter reset) and additional screens for ancillary options (system volume, display contrast/brightness, preset selection (user defined/generated), aiming beam settings).

The user may adjust power, treatment duration, treatment interval, type of laser output mode (CW-pulse, MicroPulse), aiming beam brightness, illumination brightness, and reset the laser shot counter. Additionally, for some delivery devices the user may optionally select the on/off operation of the countdown timer on the display screen as well as the on/off function of the voice countdown.

The G-Probe Illuminate that is the subject of this 510(k) is a handheld fiber optic delivery device. It is intended to be used to perform transscleral cyclophotocoagulation of the ciliary processes. It is differentiated from the G-Probe described in earlier submissions by the incorporation of two additional optical fibers to provide white light transillumination of the optic globe. Such transillumination can aid probe placement by revealing the location of internal ocular structures such as the ciliary processes. The incorporation of this transillumination function into a multifunction probe offers the user similar functionality as a separate handheld transilluminator, with a more convenient setup that requires fewer hands or assistants to operate. It is provided as a sterile, single-use device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

ciliary processes (of the eye)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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)

Clinical trial data was not required for this product change. This product change did not require any additional EMC (electromagnetic compatibility) or IEC 60601 safety testing. There were no software changes to the product.

The product change did require the following tests, which were successfully completed to the relevant standards:

Sterilization:
ISO 11135: 2014 Sterilization of health-care products -- Ethylene oxide -- Requirements for the development, validation and routine control of a sterilization process for medical devices

Biocompatibility:
ISO 10993-1: 2009 Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process

ISO 10993-5: 2009 Biological evaluation of medical devices -- Part 5: Tests for In Vitro Cytotoxicity

ISO 10993-10: 2010 Biological evaluation of medical devices -- Part 10: Tests for Irritation and Skin Sensitization

Illumination:
ISO 15004-2:2007 Ophthalmic Instruments -Fundamental Requirements and Test Methods - Part 2: Light Hazard Protection

Shelf Life:
ASTM F1980-07:2011 Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices

Transit Testing:
ASTM D4169-14 Standard Practice for Performance Testing of Shipping Containers and Systems

ASTM D4332-14 Standard Practice for Conditioning Containers, Packages, or Packing Components for Testing

ASTM F2096-11 Standard Test Method for Detecting Gross Leaks in Medical Packaging by Internal Pressurization (Bubble Test)

BS EN ISO 11607-1: 2009 Packaging for Terminally Sterilized Medical Devices – Part 1: Requirements for Materials, Sterile Barrier Systems and Packaging Systems

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K143154

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 878.4810 Laser surgical instrument for use in general and plastic surgery and in dermatology.

(a)
Identification. (1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
(b)
Classification. (1) Class II.(2) Class I for special laser gas mixtures used as a lasing medium for this class of lasers. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 878.9.

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles three human profiles facing to the right, with a stylized design that suggests flowing hair or water beneath the profiles.

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

September 29, 2016

Iridex Corporation Ms. Kathy Maynor Acting VP of Regulatory/Quality 1212 Terra Bella Avenue Mountain View, CA 94043

Re: K162416

Trade/Device Name: Iridex Cyclo G6 Laser System, G-Probe Illuminate Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument for Use in General and Plastic Surgery and in Dermatology Regulatory Class: Class II Product Code: GEX Dated: August 27, 2016 Received: August 30, 2016

Dear Ms. Maynor:

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

1

related adverse events) (21 CFR 803); 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.

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" (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 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,

Kesia Alexander

for Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose, and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K162416

Device Name

Cyclo G6 Laser System with Illumination

Indications for Use (Describe)

The Family of IRIDEX® IQ Laser Systems (IQ 532 [532nm], IQ 630-670 [630nm-670mm], IQ 810 [810mm] [IRIDEX Cyclo G6 Laser System]) and the hand pieces & accessories that are used with them to deliver laser energy in either CW-pulse, MicroPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, excision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows:

810nm (The IRIDEX Cyclo G6 Laser System)

Ophthalmology:

The IRIDEX® Cyclo G6™ Laser System and Probe Delivery Devices (G-Probe Illuminate, & MicroPulse® P3) are used to deliver laser energy in either CW-Pulse (CW) or MicroPulse (uP) treatment mode and indicated for the treatment of Glaucoma:

Condition (IndicatedTreatment (Intended Use)CW/μP
MicroPulse P3
DeviceFor the treatment of
Glaucoma including:
• Primary Open-Angle
• Closed-Angle
• RefractoryTransscleral Cyclophotocoagulation
(TSCPC) of the ciliary processesμP
G-Probe &
G-Probe IlluminateFor the treatment of
Glaucoma including:
• Primary Open-Angle
• Closed-Angle
• RefractoryTransscleral
cyclophotocoagulation
(TSCPC) of the ciliary
processesCW

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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3

Section 8 - Special 510(k) Summary

I. General Information

Submitter:

Iridex Corporation 1212 Terra Bella Avenue Mountain View, CA 94043

Contact Person: Kathy Maynor kmaynor@iridex.com 352-586-3113

Summary Preparation Date: September 28, 2016

II. Names

Device Name(s): Cyclo G6 Laser System with Illumination

Primary Classification Name(s): Electrosurgical cutting and coagulation device and accessories

Predicate Devices III.

K143154 -Iridex Cyclo G6 Laser System

IV. Product Description

The Iridex Cyclo G6 is an 810nm (diode) ophthalmic laser comprised of the following main components:

  • . Main console containing the major electrical components, including:
    • Control Panel including control knobs (power, interval, duration or software assigned ● function), treat/standby button, and display;
    • Two delivery device fiber-optic connector ports (only one active at a time); ●
    • . LIO illumination connection;
    • Smart key port for detecting/operating safety filters and/or accessory identification; ●
    • Emergency stop switch;
    • Key switch; ●
    • Connector ports for the footswitch, remote control, and power cord;
    • A treatment Footswitch (either wired, wireless, or wireless with PowerAdjust); ●
    • A Wired Remote Control that duplicates the control panel;
    • Delivery Accessories including G-Probe and MicroPulse P3 probe Handpieces, and the ● G-Probe Illuminate
    • Optional Cart/Stand

4

The laser system automatically enters the "Standby" mode after it is turned on and completes its internal "selftest". Laser emission is not possible until the user attaches the proper delivery device, selects the desired treatment settings, verifies eye safety filter status, places the system into "Ready", and depresses the footswitch.

The system has a primary display screen (power, interval, duration, pulse mode, aiming beam brightness, illumination brightness, treatment/standby toggle, counter reset) and additional screens for ancillary options (system volume, display contrast/brightness, preset selection (user defined/generated), aiming beam settings).

The user may adjust power, treatment duration, treatment interval, type of laser output mode (CW-pulse, MicroPulse), aiming beam brightness, illumination brightness, and reset the laser shot counter. Additionally, for some delivery devices the user may optionally select the on/off operation of the countdown timer on the display screen as well as the on/off function of the voice countdown.

The G-Probe Illuminate that is the subject of this 510(k) is a handheld fiber optic delivery device. It is intended to be used to perform transscleral cyclophotocoagulation of the ciliary processes. It is differentiated from the G-Probe described in earlier submissions by the incorporation of two additional optical fibers to provide white light transillumination of the optic globe. Such transillumination can aid probe placement by revealing the location of internal ocular structures such as the ciliary processes. The incorporation of this transillumination function into a multifunction probe offers the user similar functionality as a separate handheld transilluminator, with a more convenient setup that requires fewer hands or assistants to operate. It is provided as a sterile, single-use device.

V. Indications for Use

The Family of IRIDEX® IQ Laser Systems (IQ 532 [532nm], IQ 577 [577nm], IQ 630-670 [630nm-670nm], IQ 810 [810nm] [IRIDEX Cyclo G6 Laser System]) and the hand pieces, delivery devices & accessories that are used with them to deliver laser energy in either CW-pulse, MicroPulse™ or LongPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, excision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows:

810nm (The IRIDEX Cyclo G6 Laser System)

Ophthalmology:

The IRIDEX® Cyclo G6™ Laser System and Probe Delivery Devices (G-Probe, G-Probe Illuminate, & MicroPulse® P3) are used to deliver laser energy in either CW-Pulse (CW) or MicroPulse (uP) treatment mode and indicated for the treatment of Glaucoma:

5

Condition (Indicated for)Treatment (Intended Use)CW/μP
MicroPulse P3
DeviceFor the treatment of
Glaucoma including:
• Primary Open-Angle
• Closed-Angle
• RefractoryTransscleral
cyclophotocoagulation
(TSCPC) of the ciliary
processesμP
G-Probe &
G-Probe IlluminateFor the treatment of
Glaucoma including:
• Primary Open-Angle
• Closed-Angle
• RefractoryTransscleral
cyclophotocoagulation
(TSCPC) of the ciliary
processesCW

VI. Performance Testing

Clinical trial data was not required for this product change. This product change did not require any additional EMC (electromagnetic compatibility) or IEC 60601 safety testing. There were no software changes to the product.

The product change did require the following tests, which were successfully completed to the relevant standards:

Sterilization:

ISO 11135: 2014 Sterilization of health-care products -- Ethylene oxide -- Requirements for the development, validation and routine control of a sterilization process for medical devices

Biocompatibility:

ISO 10993-1: 2009 Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process

ISO 10993-5: 2009 Biological evaluation of medical devices -- Part 5: Tests for In Vitro Cytotoxicity

ISO 10993-10: 2010 Biological evaluation of medical devices -- Part 10: Tests for Irritation and Skin Sensitization

Illumination:

ISO 15004-2:2007 Ophthalmic Instruments -Fundamental Requirements and Test Methods - Part 2: Light Hazard Protection

Shelf Life:

ASTM F1980-07:2011 Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices

Transit Testing:

ASTM D4169-14 Standard Practice for Performance Testing of Shipping Containers

6

and Systems

ASTM D4332-14 Standard Practice for Conditioning Containers, Packages, or Packing Components for Testing

ASTM F2096-11 Standard Test Method for Detecting Gross Leaks in Medical Packaging by Internal Pressurization (Bubble Test)

BS EN ISO 11607-1: 2009 Packaging for Terminally Sterilized Medical Devices – Part 1: Requirements for Materials, Sterile Barrier Systems and Packaging Systems

7

VII. Summary of Technological Characteristics

The technological characteristics of the Iridex Cyclo G6 laser are substantially equivalent to those of the predicate device.

K143154
Charact
eristicIridex Cyclo G6 Laser
SystemIridex Cyclo G6 Laser System
Product
CodeGeneral & Plastic
SurgeryGeneral & Plastic Surgery
Regulation• GEX, 21 CFR 878.4810• GEX, 21 CFR 878.4810
Intended
UseIntended for use for the
treatment of Glaucoma
including:
• Primary Open-Angle
• Closed-Angle
• Refractory
(see section V above)Intended for use for the
treatment of Glaucoma
including:
• Primary Open-Angle
• Closed-Angle
• Refractory
(see section V above)
Indications for
UseTransscleral
cyclophotocoagulation
(TSCPC) of the ciliary
processesTransscleral
cyclophotocoagulation
(TSCPC) of the ciliary
processes
Wavelength810nm - Infrared (IR) Diode810nm – Infrared (IR) Diode
Aiming
beam630-670 nm – red
(nominal) – variable
intensity from 0 to