K Number
K180331
Date Cleared
2018-06-22

(136 days)

Product Code
Regulation Number
882.5890
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The device is designed to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities(arm) and lower extremities (leg) due to strain from exercise or normal household work activities. And to be used for the symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

Device Description

The Wireless Pain Relieve Device includes TENS mode. Transcutaneous Electrical Nerve Stimulation (TENS) is a noninvasive, drug free method of controlling pain. TENS uses tiny electrical impulses sent through the skin to nerves to modify your pain perception. TENS does not cure any physiological problem; it only helps control the pain, this activates the underlying sensory nerves. For Transcutaneous Electrical Nerve Stimulation (TENS) Self-adhesive electrodes are placed on the skin close to the area of pain. The user can choose 23 pre-set TENS programs. In each program, the intensity can be adjusted. The Wireless Pain Relieve Device is controlled by means of an APP on a mobile device (phone or table) or remote control. The communication is done via Bluetooth Low Energy. The APP operates on iOS or Android platforms (iOS 8.0 or greater, Android 5.0 or greater).

AI/ML Overview

This document is a 510(k) summary for the Wireless Pain Relieve Device, Model LT5011C, seeking substantial equivalence to a predicate device (Wireless Pain Relieve Device LT5018C). It does not contain information about a clinical study with acceptance criteria and device performance in the manner typically seen for clinical trials. Instead, it focuses on demonstrating substantial equivalence through comparison of technological characteristics and compliance with electrical safety, EMC, and software standards.

Therefore, many of the requested items (acceptance criteria, device performance from a clinical study, sample sizes, data provenance, expert ground truth, adjudication, MRMC study, standalone performance, and ground truth for training) cannot be extracted because this document describes a premarket notification for a Class II medical device based on substantial equivalence, not a detailed clinical study demonstrating new efficacy or performance.

However, I can extract information related to the technical performance and standards compliance tests performed to demonstrate safety and effectiveness for this type of device.

Here's a summary of the available information:

1. Table of acceptance criteria and the reported device performance (based on technical specifications and safety/EMC standards):

Acceptance Criteria (based on standards/predicate)Reported Device Performance (LT5011C)
Electrical Safety (IEC 60601-1, IEC 60601-1-11, IEC 60601-2-10):Compliant
Patient Leakage Current (Normal Condition)0 uA (Same as predicate)
Patient Leakage Current (Single Fault Condition)2.0 uA (Same as predicate)
Average DC current through electrodes (device on, no pulses)0 (Same as predicate)
Method of Channel IsolationBy Electrical Circuit and Software (Evaluated and passed IEC60601-1)
Automatic Overload TripYes (Same as predicate)
Automatic No Load contact TripYes (Same as predicate)
Automatic Shut offYes (Same as predicate)
Electromagnetic Compatibility (EMC) (IEC 60601-1-2, FCC Part 15 Subpart C):Compliant
Output Waveform Specifications (IEC 60601-2-10):Verified via oscilloscope tracing diagrams to meet specifications
Max Output Voltage (V) ±20% (at 500Ω)30.5V (Similar to predicate 31V, evaluated and passed IEC60601-2-10)
Max Output Voltage (V) ±20% (at 2kΩ)65V (Similar to predicate 66V, evaluated and passed IEC60601-2-10)
Max Output Voltage (V) ±20% (at 10kΩ)65V (Similar to predicate 66V, evaluated and passed IEC60601-2-10)
Pulse Duration (µsec)100200us (Similar to predicate 150250us, evaluated and passed IEC60601-2-10)
Frequency (Hz)2~100Hz (Same as predicate)
Maximum Phase Charge (uC) 500Ω24 uC (Similar to predicate 31 uC, evaluated and passed IEC60601-2-10)
Maximum Current Density 500Ω0.295mA/cm² (Similar to predicate 0.48mA/cm², evaluated and passed IEC60601-2-10)
Maximum Average Current (average absolute value), mA, 500Ω1.2mA (Same as predicate)
Maximum Average Power Density, (mW/cm²).500Ω1.74 mW/cm² (Similar to predicate 2.88 mW/cm², evaluated and passed IEC60601-2-10)
Biocompatibility (ISO10993-5/10):The materials (electrodes, enclosure) are the same as the predicate device (K173462), which already received 510(k) clearance and was presumably tested for biocompatibility. No new biocompatibility testing was performed for LT5011C.
Software Verification and Validation (IEC 62304, FDA Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices"):Compliant; Software considered "Moderate" level of concern. Verification and validation testing conducted and documentation provided.

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
Not applicable. This submission relies on technical testing and comparisons to a predicate device, not a clinical study involving patients or a test set of data in the sense of AI/ML evaluation.

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 establishment by experts for a test set is mentioned. The assessment is based on compliance with established engineering and safety standards.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable. No adjudication method for a test set is mentioned.

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 Transcutaneous Electrical Nerve Stimulator (TENS) for pain relief, not an AI-assisted diagnostic or interpretive system. Therefore, no MRMC study or AI assistance is relevant.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
Not applicable. This is not an AI/algorithm-only device. Its performance is assessed through its electrical output characteristics and safety features.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
Not applicable. The "ground truth" here is adherence to engineering specifications and international safety standards (IEC 60601 series, ISO 10993).

8. The sample size for the training set:
Not applicable. There is no training set in the context of an AI/ML device.

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

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

June 22, 2018

Shenzhen Dongdixin Technology Co.,Ltd. Siping Yuan R.A. Specialist No. 3 Building Xiliba imang Xusheng Industrial Estate Nansha Shenzhen, China 518108

Re: K180331

Trade/Device Name: Wireless Pain Relieve Device, Model LT5011C Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator For Pain Relief Regulatory Class: Class II Product Code: NYN, NUH Dated: May 15, 2018 Received: May 21, 2018

Dear Siping Yuan:

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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820):

{1}------------------------------------------------

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 medical devices and radiation-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,

Pamela D. Scott -S

for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

Indications for Use

510(k) Number (if known) K180331

Device Name Wireless Pain Relieve Device Model: LT5011C

Indications for Use (Describe)

The device is designed to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities(arm) and lower extremities (leg) due to strain from exercise or normal household work activities. And to be used for the symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 201.5 Labeling) Over-The-Counter Use (21 CFR 201.5 Labeling)
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

_ | Prescription Use (Part 21 CFR 801 Subpart D)

|X Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

Image /page/3/Picture/0 description: The image is a logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is composed of the company name in a bold, sans-serif font, with the "X" in "DIXIN" stylized with an orange line. To the right of the English name is the company name in Chinese characters.

005_510 (k) Summary Version: 1.1

510(k) SUMMARY

as required by section 21 CFR 807.92

Wireless Pain Relieve Device

Date of Submission:02/01/2018
Submitter's Name:Shenzhen Dongdixin Technology Co., Ltd
Address:No. 3 Building, Xilibaimang Xusheng Industrial Estate Nanshan, Shenzhen, CHINA 518108
E-mail:ra@dundex.com
Tel:+86(755) 27652471
FAX:+86(755) 27652674
Contact:Siping Yuan

{4}------------------------------------------------

005 510 (k) Summary Version: 1.1

TECHNOLOGY CO., LTD.

1. Proposed Device:
---------------------------

Device Name: Wireless Pain Relieve Device

Model: LT5011C

Device classification Name:Stimulator, Nerve, Transcutaneous, Over-The-Counter
Regulation Description:Transcutaneous electrical nerve stimulator for pain relief
Regulation Medical Specialty:Neurology
Review Panel:Neurology
Regulation Number:882.5890
Product Code:NUH
Device Class:II
Device classification Name:Stimulator, Electrical, Transcutaneous, For Arthritis
Regulation Description:Transcutaneous electrical nerve stimulator for pain relief
Regulation Medical Specialty:Neurology
Review Panel:Neurology
Regulation Number:882.5890
Product Code:NYN
Device Class:II

2. Predicate Device:

Legally Marketed Device:Wireless Pain Relieve Device LT5018C
510(k) Number:K173462
Manufacturer:Shenzhen Dondixin Technology Co., Ltd

3. Description of Proposed Device:

LT5011C is designed to be used at home, by adults of all genders.

Explanation of how the device functions:

The Wireless Pain Relieve Device includes TENS mode. Transcutaneous Electrical Nerve Stimulation (TENS) is a noninvasive, drug free method of controlling pain.

Scientific concepts that from the basis for the device:

TENS uses tiny electrical impulses sent through the skin to nerves to modify your pain perception. TENS does not cure any physiological problem; it only helps control the pain, this activates the underlying sensory nerves.

For Transcutaneous Electrical Nerve Stimulation (TENS) Self-adhesive electrodes are placed on the skin close to the area of pain. The user can choose 23 pre-set TENS programs. In each program, the intensity can be adjusted.

{5}------------------------------------------------

Image /page/5/Picture/0 description: The image shows the logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is composed of the company name in a bold, sans-serif font, with the letters 'X' stylized in orange. To the right of the English name, the company name is also written in Chinese characters.

The Wireless Pain Relieve Device is controlled by means of an APP on a mobile device (phone or table) or remote control. The communication is done via Bluetooth Low Energy. The APP operates on iOS or Android platforms (iOS 8.0 or greater, Android 5.0 or greater).

4. Description of All Device Modification(s)

Compared with the existing device (LT5018C), the following main parts of Wireless Pain Reliever LT5018C have changed:

    1. Change the dimensional specification and change the hardware based on the new dimension of enclosure. But the fundamental scientific technology does not change.
    1. Remove the EMS program and indications for use of EMS mode.
    1. Remove the neck program and indications for use of neck pain.
  • Split the cycle program of unmodified device into four programs for users to choose their 4) comfortable programs and add custom program for users to choose their comfortable programs.

Based on the 21CFR820.30 requirement, this is belong to design change and shall have been evaluated according to the standard IEC60601-2-10, and IEC 60601-1-2. We have conducted these standard test and the results is Passed.

5. Proposed Device Intended for Use Statement:

Device Name: Wireless Pain Relieve Device, Model: LT5011C

Indications for Use:

The device is designed to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities(arm) and lower extremities (leg) due to strain from exercise or normal household work activities. And to be used for the symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

{6}------------------------------------------------

Image /page/6/Picture/0 description: The image shows the logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is in blue and yellow. The text "DONGDIXIN" is in large, bold letters, with the "X" in "DIXIN" being yellow. Below "DONGDIXIN" is the text "TECHNOLOGY CO., LTD." in smaller letters, also in blue. To the right of the English text is the company name in Chinese.

6. Technological Characteristics and Substantial Equivalence

Both the IT5011C and Predicate Device utilize the application of electrodes placed on the skin for pain control. The impulses are generated by the device and delivered through electrodes on the skin in direct proximity to the (painful) muscles to be stimulated. Basic technological characteristics, new device vs. Predicate device

New devicePredicate deviceS.E. Discussion
1510K#To be assignedK173462N/A
2Device Name andModelWireless Pain Relieve deviceMode: LT5011CWireless Pain Relieve deviceMode: LT5018CN/A
3ManufacturerShenzhen Dongdixin Technology Co., LtdShenzhen Dongdixin Technology Co., LtdSame
4Intended for useTENS: The device is designed to be used fortemporary relief of pain associated withsore and aching muscles in the shoulder,waist, back , upper extremities (arm) andlower extremities (leg) due to strain fromexercise or normal household workactivities. And to be used for thesymptomatic relief and management ofchronic, intractable pain and relief of painassociated with arthritis.TENS: The device is designed to be usedfor temporary relief of pain associatedwith sore and aching muscles in theshoulder, waist, back, neck, upperextremities (arm) and lower extremities(leg) due to strain from exercise or normalhousehold work activities. And to be usedfor the symptomatic relief andmanagement of chronic, intractable painand relief of pain associated with arthritis.EMS: The device is designed to be usedfor stimulate healthy muscles in order toimprove and facilitate muscleperformance.Similar, the intended use ofLT5011C is fallen within theintended use of predicatedevice.
5Power SourceDC 3.7V Li-ion Battery(main device)DC 3.0V, 2 x AAA Batteries (Remote control)DC 3.7V Li-ion Battery(main device)DC 3.0V, 2 x AAA Batteries (Remotecontrol)Same
-Method ofcurrent isolationN/AN/ASame
- Patient LeakageCurrent (μΑ)Same
-Normal condition0uA0uA
-Single faultcondition2.0uA2.0uA
6Average DC current through electrodes when device is on but no pulses are being applied (µA)00Same
7Number of Output Modes1 (TENS)2 (TENS/EMS(including MASSAGE))Different, LT5011C only has TENS mode and LT5011C remove indications for use of EMS mode accordingly.
8Number of Output Channels
Synchronous or Alternating?AlternatingN/ADifferent, LT5011C has two channels and have been evaluated and passed the test according to the requirement of IEC60601-2-10.
Method of Channel IsolationBy Electrical Circuit and SoftwareN/ADifferent, LT5011C has two channels and have been evaluated and passed the test according to the requirement of IEC60601-1.
9Regulated Current or Regulated Voltage?Current controlCurrent controlSame
10Software/Firmware/Micro processor Control?YesYesSame
11Automatic Overload TripYesYesSame
12Automatic No Load contact TripYesYesSame
13Automatic Shut offYesYesSame
14User Override Control?YesPower on/off button on the devicePower on/off on the remote controlPower on/off in the APP softwareYesPower on/off button on the devicePower on/off on the remote controlPower on/off in the APP softwareSame
15Indicator Display:
On/Off Status?YesYesSame
Low Battery?YesYesSame
Voltage/ CurrentLevel?YesYesSame
16Timer Range (minutes)5-90 minutes30 minutesDifferent, new device have beenevaluated and passed the testaccording to the requirement ofIEC60601-2-10.User can set the treatment timeaccording their needs.
17Weight (grams.)33grams (Main device)55 grams (Remote control)36grams (Main device)65 grams (Remote control)Different, the new device havebeen evaluated and passed thetesting according to therequirement of IEC60601-1.
18Dimensions (cm.) H*W *L80.5(L)x45(W)x13.5(H)mm (Main device)127(L)x48.7(W)x24.2(H)mm (Remote control)360(L)x59(W)x11.5(H)mm (Main device)115(L)x53(W)x25(H)mm (Remote control)
19Housing Materials &ConstructionABSABSSame
20Compliance with 21 CFR898YesYesSame
21Compliance withVoluntary Standards?IEC 60601-1,IEC 60601-1-2,IEC 60601-2-10,IEC 60601-1-11ISO10993-5/10IEC 60601-1,IEC 60601-1-2,IEC 60601-2-10,IEC 60601-1-11ISO10993-5/10Same
New devicePredicate deviceS.E. Discussion
1510K#To be assignedK173462N/A
2Device Name orProgram NameWireless Pain Relief DeviceMode:LT5011CWireless Pain Relief DeviceMode:LT5018CN/A
3ManufacturerShenzhen Dongdixin Technology Co., LtdShenzhen Dongdixin Technology Co., LtdSame
4WaveformBiphasicBiphasicSame
5ShapeRectangularRectangularSame
6Max Output Voltage (V) ±20%
7500Ω30.531Similar, the new device havebeen evaluated and passedthe test according to therequirement of IEC60601-2-10
82kΩ6566
910kΩ6566
10Pulse Duration(µsec)100~200us150~250us
11Frequency (Hz)2~100Hz2~100HzSame
12Maximum PhaseCharge (uC) 500Ω2431Similar, the new device havebeen evaluated and passedthe test according to therequirement ofIEC60601-2-10.
13Maximum CurrentDensity 500Ω0.295mA/cm²0.48mA/cm²
14Maximum AverageCurrent (averageabsolute value),mA, 500Ω1.21.2
15Maximum AveragePower Density,(mW/cm²).500Ω1.742.88

Table 1: Substantial Equivalence Comparison Table

{7}------------------------------------------------

Image /page/7/Picture/0 description: The image shows the logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is in blue and yellow. The text "TECHNOLOGY CO., LTD." is in a smaller font size than the company name. There are also three Chinese characters to the right of the company name.

{8}------------------------------------------------

Image /page/8/Picture/0 description: The image shows the logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is in blue and yellow. The text "DONGDIXIN" is in large, bold, blue letters, with a yellow "X" in the middle. Below the company name is the text "TECHNOLOGY CO., LTD." in smaller, blue letters. To the right of the company name are three Chinese characters in blue.

{9}------------------------------------------------

Image /page/9/Picture/0 description: The image shows the logo for DONGDIXIN Technology Co., LTD. The logo features the company name in a bold, sans-serif font, with the "X" in "DIXIN" stylized in orange. To the right of the English name is the company name in Chinese characters.

Table 2: Output Specification TENS mode

{10}------------------------------------------------

Image /page/10/Picture/0 description: The image shows the logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is composed of the company name in a bold, sans-serif font, with the "X" in "DIXIN" stylized in orange. To the right of the English name is the company name in Chinese characters. The overall design is clean and modern.

Discussion:

The number of output modes, number of output channels, timer range, weight and dimension of the new device are different from the predicate devices, but the new devices are evaluated and passed the testing according to IEC60601-1 and IEC60601-2-10, this difference does not pose any new questions of safety.

The Max Output Voltage/Current, Pulse Duration, Maximum Phase Charge, Maximum Current Density and Maximum Average Power Density are similar with the predicate devices, but the new devices are evaluated and passed the testing according to IEC60601-2-10, this difference doesn't pose any new questions of safety and effectiveness.

7. Performance Data:

The following performance data are provided in support of the substantial equivalence determination:

7.1 Biocompatibility testing

Compared with unmodified device, the material of electrodes for the new product LT5011C is the same material of predicate device (K173462) that got the 510(k) clearance on 2017. The material of enclosure is ABS, and it is the same as the material of predicate device (K173462) that got the 510(k) clearance on 2017. These materials have the same product process and injection process.

7.2 Electrical safety and electromagnetic compatibility (EMC)

Electrical safety and EMC testing were conducted on the LT5011C. The system complies with the IEC 60601-1, IEC 60601-1-11 and IEC 60601-2-10 standards for safety and the IEC 60601-1-2 standard for EMC.

For FCC part 15 RADIO FREQUENCY DEVICES, Subpart C—Intentional Radiators.

7.3 Software Verification and Validation Testing

Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "Moderate" level of concern. IEC 62304 was followed.

7.4 Output waveform Testing

For each program, oscilloscope tracing diagrams describing the electrical output waveform was provided to verify the output specifications of the device according to IEC 60601-2-10.

8. Conclusions

The LT5011C has the similar intended use and technological characteristics as the predicate device Wireless Pain Relieve Device LT5018C. Moreover, bench testing and safety report supplied in this submission demonstrates that the difference in the submitted models could

{11}------------------------------------------------

Image /page/11/Picture/0 description: The image shows the logo for DONGDIXIN TECHNOLOGY CO., LTD. The logo is in blue, except for a yellow line that crosses the "X" in "DIXIN". To the right of the English text is the company name in Chinese.

005_510 (k) Summary Version: 1.1

maintain the same safety and effectiveness as that of predicate device. In the other words, those engineering difference do not affect the intended use or alter the fundamental scientific technology of the device. Thus, LT5011C is substantially equivalent to the predicate device.

§ 882.5890 Transcutaneous electrical nerve stimulator for pain relief.

(a)
Identification. A transcutaneous electrical nerve stimulator for pain relief is a device used to apply an electrical current to electrodes on a patient's skin to treat pain.(b)
Classification. Class II (performance standards).