K Number
K180423
Device Name
Empower H65
Manufacturer
Date Cleared
2018-03-15

(27 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Empower H65 laser system and its fiber optic delivery system are in surgical procedures using open, laparoscopic and endoscopic incision, resection, ablation, vaporization, coagulation and haemostasis of soft tissue in use in medical specialties including: Urinary Lithotripsy, Gastroenterology, Arthroscopy, Discectomy, Gynaecology, ENT and General Surgery.
Device Description
The Empower H65 laser system and its fiber optic delivery system. The device is a modified version of the Litho 60 (K172025) with some technical modifications.
More Information

Litho 60 (K172025), Lumenis Pulse 120h (K140388)

Not Found

No
The summary describes a laser system for surgical procedures and does not mention any AI or ML capabilities. The technical modifications are not described as involving AI/ML.

Yes

The device is used for surgical procedures like ablation, vaporization, and coagulation of soft tissue, which are therapeutic interventions.

No
The "Intended Use / Indications for Use" section explicitly states that the device is used for surgical procedures such as "incision, resection, ablation, vaporization, coagulation and haemostasis of soft tissue," which are treatment-oriented actions, not diagnostic ones.

No

The device description explicitly states it is a "laser system and its fiber optic delivery system," which are hardware components. The performance studies also mention testing related to electrical and laser safety standards (IEC 60601 series and IEC 60825-1), further indicating a hardware device.

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

Here's why:

  • Intended Use: The intended use clearly describes the device as a surgical laser system used for procedures like incision, resection, ablation, vaporization, coagulation, and haemostasis of soft tissue. These are all direct surgical interventions on the body.
  • Device Description: The description confirms it's a laser system and fiber optic delivery system, used for surgical procedures.
  • Lack of IVD Characteristics: An IVD device is used to examine specimens derived from the human body (like blood, urine, tissue samples) to provide information for diagnosis, monitoring, or screening. This device does not perform any such analysis of specimens.

The device is a therapeutic surgical device, not a diagnostic one.

N/A

Intended Use / Indications for Use

The Empower H65 laser system and its fiber optic delivery system are in surgical procedures using open, laparoscopic and endoscopic incision, resection, ablation, vaporization, coagulation and haemostasis of soft tissue in use in medical specialties including: Urinary Lithotripsy, Gastroenterology, Arthroscopy, Discectomy, Gynaecology, ENT and General Surgery.

Urology
Open and endoscopic surgery (incision, excision, resection, ablation, vaporization, coagulation and haemostasis) including:

  • · Urethral Strictures
  • · Bladder Neck Incisions (BNI)
  • · Ablation and resection of Bladder Tumors, Uretheral Tumors and Ureteral Tumors,
  • · Ablation of Benign Prostatic Hypertrophy (BPH),
  • · Transurethral incision of the prostate (TUIP)
  • · Holmium Laser Resection of the Prostrate (HoLRP)
  • · Holmium Laser Enucleation of the Prostate (HoLEP)
  • · Holmium laser Ablation of the Prostate (HoLAP)
  • Condylomas
  • · Lesions of external genitalia

Lithotripsy and Percutaneous Urinary Lithotripsy
· Endoscopic fragmentation of ureteral, bladder and renal calculi including cystine, calcium oxalate,

  • monohydrate and calcium oxalate
  • · dehvdrate stones.
  • · Endoscopic fragmentation of kidney calculi
  • · Treatment of distal impacted fragments of steinstrasse when guide wire cannot be passed.

Gastroenterology
Open and endoscopic Gastroenterology surgery (incision, excision, resection, ablation, vaporization, coagulation and haemostasis) including:

  • · Appendectomy
  • Polyps
  • Biopsy
  • · Gall Bladder calculi
  • Biliary/Bile duct calculi
  • Ulcers
  • · Gastric ulcers
  • · Duodenal ulcers

• Non Bleeding Ulcers

  • Pancreatitas
  • Haemorrhoids
  • · Cholecystectomy
  • Benign and Malignant Neoplasm
  • · Angiodysplasia
  • Colorectal cancer
  • · Telangiectasias
  • · Telangiectasias of the Osler-Weber-Renu disease
  • Vascular Malformation
  • · Gastritis
  • Esophagitis
  • Esophageal ulcers
  • · Varices
  • · Colitis
  • · Mallory-Weiss tear
  • · Gastric Erosions

Arthroscopy
Arthroscopy/Orthopaedic surgery (excision, ablation and coagulation of soft and cartilaginous tissue) in small and large joints of the body, excluding the spine but including:

  • Ligament and tendon Release
  • Contouring and sculpting of articular surfaces
  • · Capsulectomy in the Knee
  • · Chondreplasty in the Knee
  • · Debridement of inflamed synovial tissue
  • Chondromalacia Ablation
  • Chondromalacia and tears
  • · Plica Removal
  • · Meniscectomy
  • Loose Body Debridement
  • Lateral retinecular release

Ablation of soft, cartilaginous and bony tissue in Minimal Invasive Spinal Surgery including
· Percutaneous Laser Disc Decompression/Discectomy of the L4-5 and L5-SI lumbar discs, including Foraminoplasty Percutaneous Cervical Disc Decompression/Discectomy

  • Percutaneous Thoracic Disc Decompression/Discectomy

Gynaecology
Open and laparoscopic gynaecological surgery (incision, excision, ablation, vaporization, coagulation and haemostasis) of soft tissue

ENT
Endoscopic endonasal surgery (incision, excision, ablation, vaporization, coagulation and haemostasis of soft tissue and cartilage) including:

  • · Endonasal/sinus Surgery
  • · Partial turbinectomy
  • · Polypectomy
  • Dacryocystorhinostomy

• Frontal Sinusotomy

  • · Ethmoidectomy
  • Maxillary antrostomy
  • · Functional endoscopic sinus surgery

General Surgery
Open, laparoscopic and endoscopic surgery (incision, resection, ablation, vaporization, coagulation and haemostasis) including:

  • Appendectomy
  • · Skin incision
  • · Excision of external and internal lesions
  • · Complete of partial resection of internal organs, tumors and lesions
  • Bionsv

Product codes (comma separated list FDA assigned to the subject device)

GEX

Device Description

The Empower H65 is a laser system and its fiber optic delivery system. It is a modified version of the Litho 60 (K172025) device, with technical modifications. It has the same intended use as the unmodified device and is based on Holmium laser sources.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Urological: Urethral, Bladder, Uretheral, Ureteral, Prostate, External genitalia, Urethral, Ureteral, Bladder, Renal, Kidney.
Gastroenterological: Appendectomy, Gall Bladder, Biliary/Bile duct, Gastric, Duodenal, Pancreas, Colon, Rectum, Esophageal, Gastric.
Arthroscopy/Orthopaedic: Small and large joints of the body (excluding the spine), Knee, Spinal (L4-5, L5-SI lumbar discs, Cervical, Thoracic).
Gynaecological: Soft tissue.
ENT: Endonasal/sinus, Turbinates, Nasal polyps, Lacrimal sac/nasal cavity, Frontal Sinus, Ethmoid, Maxillary antra.
General Surgery: Skin, Internal organs, tumors, lesions.

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)

Performance testing in accordance with the following recognized consensus standards related to electromagnetic compatibility, electrical safety and performances:

  • IEC 60601-1:2012, ed 3.1, Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance
  • IEC 60601-1-2 Edition 4: 2014, Medical Electrical Equipment - Part 1-2: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility -Requirements And Tests.
  • IEC 60601-2-22: 2012-10 ed 3.1, Medical Electrical Equipment - Part 2-22: Particular Requirements For Basic Safety And Essential Performance Of Surgical, Cosmetic, Therapeutic And Diagnostic Laser Equipment
  • IEC 60825-1 Ed. 3.0 (2014) Safety of laser products – Part 1: Equipment classification and requirements
  • 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".

Results: Empower H65 passed all the required testing and is in compliance will all applicable sections of the abovementioned performance standards.

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.

Litho 60 (K172025), Lumenis Pulse 120h (K140388)

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/0 description: The image shows 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.

March 15, 2018

quanta system spa Francesco Dell'antonio Vice President Regulatory Affairs and QA via Acquedotto 109 Samarate (Va), 21017 It

Re: K180423

Trade/Device Name: Empower H65 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: February 12, 2018 Received: February 16, 2018

Dear Francesco Dell'antonio:

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, 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 the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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.

Jennifer R. Stevenson -S3

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

2

Indications for Use

510(k) Number (if known) K180423

Device Name Empower H65

The Empower H65 laser system and its fiber optic delivery system are in surgical procedures using open, laparoscopic and endoscopic incision, resection, ablation, vaporization, coagulation and haemostasis of soft tissue in use in medical specialties including: Urinary Lithotripsy, Gastroenterology, Arthroscopy, Discectomy, Gynaecology, ENT and General Surgery.

Urology

Open and endoscopic surgery (incision, excision, resection, ablation,

vaporization, coagulation and haemostasis) including:

  • · Urethral Strictures
  • · Bladder Neck Incisions (BNI)
  • · Ablation and resection of Bladder Tumors, Uretheral Tumors and Ureteral Tumors,
  • · Ablation of Benign Prostatic Hypertrophy (BPH),
  • · Transurethral incision of the prostate (TUIP)
  • · Holmium Laser Resection of the Prostrate (HoLRP)
  • · Holmium Laser Enucleation of the Prostate (HoLEP)
  • · Holmium laser Ablation of the Prostate (HoLAP)
  • Condylomas
  • · Lesions of external genitalia

Lithotripsy and Percutaneous Urinary Lithotripsy

· Endoscopic fragmentation of ureteral, bladder and renal calculi including cystine, calcium oxalate,

  • monohydrate and calcium oxalate
  • · dehvdrate stones.
  • · Endoscopic fragmentation of kidney calculi
  • · Treatment of distal impacted fragments of steinstrasse when guide wire cannot be passed.

Gastroenterology

Open and endoscopic Gastroenterology surgery (incision, excision, resection, ablation, vaporization, coagulation and haemostasis) including:

  • · Appendectomy
  • Polyps
  • Biopsy
  • · Gall Bladder calculi
  • Biliary/Bile duct calculi
  • Ulcers
  • · Gastric ulcers
  • · Duodenal ulcers

3

• Non Bleeding Ulcers

  • Pancreatitas
  • Haemorrhoids
  • · Cholecystectomy
  • Benign and Malignant Neoplasm
  • · Angiodysplasia
  • Colorectal cancer
  • · Telangiectasias
  • · Telangiectasias of the Osler-Weber-Renu disease
  • Vascular Malformation
  • · Gastritis
  • Esophagitis
  • Esophageal ulcers
  • · Varices
  • · Colitis
  • · Mallory-Weiss tear
  • · Gastric Erosions

Arthroscopy

Arthroscopy/Orthopaedic surgery (excision, ablation and coagulation of soft and cartilaginous tissue) in small and large joints of the body, excluding the spine but including:

  • Ligament and tendon Release
  • Contouring and sculpting of articular surfaces
  • · Capsulectomy in the Knee
  • · Chondreplasty in the Knee
  • · Debridement of inflamed synovial tissue
  • Chondromalacia Ablation
  • Chondromalacia and tears
  • · Plica Removal
  • · Meniscectomy
  • Loose Body Debridement
  • Lateral retinecular release

Ablation of soft, cartilaginous and bony tissue in Minimal Invasive Spinal Surgery including

· Percutaneous Laser Disc Decompression/Discectomy of the L4-5 and L5-SI lumbar discs, including Foraminoplasty Percutaneous Cervical Disc Decompression/Discectomy

  • Percutaneous Thoracic Disc Decompression/Discectomy

Gynaecology

Open and laparoscopic gynaecological surgery (incision, excision, ablation, vaporization, coagulation and haemostasis) of soft tissue

ENT

Endoscopic endonasal surgery (incision, excision, ablation, vaporization, coagulation and haemostasis of soft tissue and cartilage) including:

  • · Endonasal/sinus Surgery
  • · Partial turbinectomy
  • · Polypectomy
  • Dacryocystorhinostomy

4

• Frontal Sinusotomy

  • · Ethmoidectomy
  • Maxillary antrostomy
  • · Functional endoscopic sinus surgery

General Surgery

Open, laparoscopic and endoscopic surgery (incision, resection, ablation, vaporization, coagulation and haemostasis) including:

  • Appendectomy
  • · Skin incision
  • · Excision of external and internal lesions
  • · Complete of partial resection of internal organs, tumors and lesions
  • Bionsv

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

2 Prescription Use (Part 21 CFR 801 Subpart D)

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

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

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5

5. 510(K) SUMMARY

| Applicant /
Manufacturer
Name and Address: | Quanta System SPA
Via Acquedotto, 109
Samarate (VA)
Italy, 21017 |
|--------------------------------------------------|-------------------------------------------------------------------------------------------------|
| 510(k) Contact Person: | Francesco Dell'Antonio
Vice President Regulatory Affairs and QA
Quanta System SPA |
| | Email: francesco.dellantonio@quantasystem.com
Phone: +39-0331-376797
Fax: +39-0331-367815 |
| Date Prepared: | February 12th 2018 |
| Device Name: | Empower H65 |
| Classification: | Class II |
| Classification Name: | Laser surgical instrument for use in general and plastic surgery
and in dermatology. |
| Regulation Number: | 21 CFR 878.4810 |
| Product Code: | GEX |
| Basis for Submission: | Device modifications |
| Legally Marketed Device | Litho 60 (K172025) – Quanta System SPA
Lumenis Pulse 120h (K140388) – Lumenis LTD |

The modified device Empower H65 is derived from the legally marketed (unmodified) device Litho 60 (K172025).

Performance Standards:

There are no mandatory performance standards for this device.

6

Description of the modifications:

This Special 510(k) of Empower H65 is submitted due to Device Modifications of the already cleared device Litho 60 (K172025) due to some technical modifications.

The modified device has the same intended use of the unmodified device. Moreover, the the intended use of the modified device, as described in its labeling, has not changed as a result of the modifications.

Based on the nature of the changes implemented, the device underwent and successfully passed performance testing and software verifications and validation according to the relevant standards.

Intended Use/Indications for Use

Empower H65 has the same intended use of the unmodified device, as follows:

The Empower H65 laser system and its fiber optic delivery system are intended for use in surgical procedures using open, laparoscopic and endoscopic incision, resection, ablation, vaporization, coagulation and haemostasis of soft tissue in use in medical specialties including: Urology, Urinary Lithotripsy, Gastroenterology, Arthroscopy, Discectomy, Gynaecology, ENT and General Surgery.

Urology

Open and endoscopic surgery (incision, excision, resection, ablation,

  • vaporization, coagulation and haemostasis) including:
    • Urethral Strictures
    • Bladder Neck Incisions (BNI)
    • Ablation and resection of Bladder Tumors, Uretheral Tumors and Ureteral Tumors,
    • Ablation of Benign Prostatic Hypertrophy (BPH),
    • Transurethral incision of the prostate (TUIP)
    • Holmium Laser Resection of the Prostrate (HoLRP)
    • Holmium Laser Enucleation of the Prostate (HoLEP)
    • Holmium laser Ablation of the Prostate (HoLAP) ●
    • Condylomas
    • . Lesions of external genitalia

Lithotripsy and Percutaneous Urinary Lithotripsy

  • Endoscopic fragmentation of urethral, ureteral, bladder and renal calculi including cystine, calcium oxalate, monohydrate and calcium oxalate
  • dehydrate stones.
  • Endoscopic fragmentation of kidney calculi
  • Treatment of distal impacted fragments of steinstrasse when guide wire cannot be passed.

7

Gastroenterology

Open and endoscopic Gastroenterology surgery (incision, excision, resection, ablation, vaporization, coagulation and haemostasis) including:

  • Appendectomy
  • Polyps
  • Biopsy
  • . Gall Bladder calculi
  • Biliary/Bile duct calculi ●
  • Ulcers
  • Gastric ulcers
  • Duodenal ulcers
  • Non Bleeding Ulcers
  • Pancreatitas
  • Haemorrhoids
  • Cholecystectomy
  • Benign and Malignant Neoplasm
  • Angiodysplasia
  • Colorectal cancer
  • Telangiectasias
  • Telangiectasias of the Osler-Weber-Renu disease
  • Vascular Malformation
  • Gastritis
  • Esophagitis
  • Esophageal ulcers
  • Varices
  • Colitis
  • Mallory-Weiss tear
  • Gastric Erosions ●

Arthroscopy

Arthroscopy/Orthopaedic surgery (excision, ablation and coagulation of soft and cartilaginous tissue) in small and large joints of the body, excluding the spine but including:

  • Ligament and tendon Release
  • Contouring and sculpting of articular surfaces
  • Capsulectomy in the Knee
  • Chondreplasty in the Knee
  • Debridement of inflamed synovial tissue
  • Chondromalacia Ablation

8

  • Chondromalacia and tears
  • Plica Removal
  • Meniscectomy
  • Loose Body Debridement
  • Lateral retinecular release

Ablation of soft, cartilaginous and bony tissue in Minimal Invasive Spinal Surgery including

  • Percutaneous Laser Disc Decompression/Discectomy of the L4-5 and L5-SI lumbar discs, . including Foraminoplasty Percutaneous Cervical Disc Decompression/Discectomy Percutaneous Thoracic Disc Decompression/Discectomy

Gynaecology

Open and laparoscopic gynaecological surgery (incision, resection, ablation, vaporization, coagulation and haemostasis) of soft tissue

ENT

Endoscopic endonasal surgery (incision, excision, resection, ablation, vaporization, coagulation and haemostasis of soft tissue and cartilage) including:

  • Endonasal/sinus Surgery
  • Partial turbinectomy
  • Polypectomy
  • Dacryocystorhinostomy
  • Frontal Sinusotomy
  • Ethmoidectomy
  • Maxillary antrostomy
  • . Functional endoscopic sinus surgery

General Surgery

Open, laparoscopic and endoscopic surgery (incision, excision, ablation, vaporization, coagulation and haemostasis) including:

  • Appendectomy
  • Skin incision
  • Excision of external and internal lesions
  • Complete of partial resection of internal organs, tumors and lesions ●
  • . Biopsy

9

Performace testing

Empower H65 was subjected to performance testing in accordance with the following recognized consensus standards related to electromagnetic compatibility, electrical safety and performances:

  • । IEC 60601-1:2012, ed 3.1, Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance
  • -IEC 60601-1-2 Edition 4: 2014, Medical Electrical Equipment - Part 1-2: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility -Requirements And Tests.
  • . IEC 60601-2-22: 2012-10 ed 3.1, Medical Electrical Equipment - Part 2-22: Particular Requirements For Basic Safety And Essential Performance Of Surgical, Cosmetic, Therapeutic And Diagnostic Laser Equipment
  • -IEC 60825-1 Ed. 3.0 (2014) Safety of laser products – Part 1: Equipment classification and requirements
  • -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".

Empower H65 passed all the required testing and is in compliance will all applicable sections of the abovementioned performance standards.

Comparison with predicate device:

The subject and unmodified devices have intended use and the same fundamental scientific technology, based on Holmium laser sources.

Summary

The modified device Empower H65 is substantially equivalent to its identified predicate device.