K Number
K191865
Device Name
SmartLite Pro Modular LED Curing Light
Manufacturer
Date Cleared
2019-11-20

(131 days)

Product Code
Regulation Number
872.6070
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
-For light activated polymerization of dental materials such as composites, luting cements. and sealants using visible light. -For intraoral illumination used upon initial examination of the dental transillumination to help locate crown fractures, posterior and anterior caries, and for use as an auxiliary light source for endodontic procedures.
Device Description
The proposed SmartLite®Pro Modular LED Curing Light is a cordless pen-style, LED light polymerization and illumination device for use by dental professionals in dental offices or dental laboratories.
More Information

No
The summary describes a standard LED curing light and transilluminator with no mention of AI, ML, image processing, or any data processing that would suggest the use of such technologies. The performance studies focus on light output, depth of cure, and electrical/usability standards.

Yes
The device is used for light-activated polymerization of dental materials, which is a therapeutic intervention, and also for illumination to help locate dental issues like crown fractures and caries, aiding in diagnosis and treatment.

No

The device is primarily a polymerization tool, but it also has an "Intended Use" for "intraoral illumination used upon initial examination of the dental transillumination to help locate crown fractures, posterior and anterior caries". This function is diagnostic as it aids in identifying dental pathologies.

No

The device description explicitly states it is a "cordless pen-style, LED light polymerization and illumination device," indicating it is a hardware device with integrated software, not a software-only device. The performance studies also detail testing of hardware components like output power and depth of cure.

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

Here's why:

  • Intended Use/Indications for Use: The intended uses are for light-activated polymerization of dental materials and for intraoral illumination for examination and procedures. These are direct interactions with the patient's body or materials being applied to the patient's body, not testing of samples taken from the body.
  • Device Description: It's described as a light polymerization and illumination device for use by dental professionals. This aligns with a therapeutic or diagnostic imaging/illumination device, not an IVD.
  • Lack of IVD Characteristics: There is no mention of analyzing samples (blood, tissue, etc.), detecting analytes, or providing diagnostic information based on laboratory testing.
  • Performance Studies: The performance studies focus on light output, depth of cure, irradiance, electrical safety, usability, and biocompatibility. These are typical performance metrics for a medical device used in a clinical setting, not for an IVD which would focus on analytical and clinical performance related to sample testing.
  • Predicate Devices: The predicate devices are other dental curing lights and transilluminators, which are not IVDs.

In summary, the device's function, intended use, and the nature of the performance testing all indicate that it is a medical device used directly in the dental setting for treatment and examination, not an in vitro diagnostic device used for testing samples outside the body.

N/A

Intended Use / Indications for Use

-For light activated polymerization of dental materials such as composites, luting cements. and sealants using visible light.
-For intraoral illumination used upon initial examination of the dental patient and dental transillumination to help locate crown fractures, posterior and anterior caries, and for use as an auxiliary light source for endodontic procedures.

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

EBZ, NTK

Device Description

The proposed SmartLite®Pro Modular LED Curing Light is a cordless pen-style, LED light polymerization and illumination device for use by dental professionals in dental offices or dental laboratories.
The proposed SmartLite®Pro Modular LED Curing Light is characterized by:

  • · Small size and lightweight ergonomic design.
  • Compact cordless design with convenient handling features and exchangeable battery pack.
  • Individually adjustable LED tips, rotatable by 360°.
  • · LED tip design providing excellent intra-oral access.
  • · Polymerization area (optic effective cross-sectional area) of 10 mm in diameter.
  • Up to 10 seconds curing time per activation with audible signal at start and end of cycle.
  • · Advanced heat management system limiting LED tiptemperature.
  • Exchangeable tips for:
    • curing of CQ initiated materials.
    • curing of materials with initiators absorbing in the violetrange.
    • intraoral illumination and dental transillumination.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

intraoral

Indicated Patient Age Range

Not Found

Intended User / Care Setting

dental professionals in dental offices or dental laboratories.

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 of the SmartLite®Pro Modular LED Curing Light was conducted and included in this premarket notification. The results of the performance testing support substantial equivalence. The exchangeable tip used in the test is identified.
The following testing was conducted using the exchangeable tip as identified within the testing, as applicable:

  • Testing to verify Output Power (Cure Tip). Internal test method and . acceptance criteria.
  • Testing to verify Output Power (PolyCure Tip). Internal test method ● and acceptance criteria.
  • Testing to verify Output Power (Illuminate Tip). Internal test method . and acceptance criteria.
  • Testing to compare Depth of Cure of Cure Tip, PolyCure Tip, and ● primary predicate (K061341) per ISO 4049: (Dentist - Polymerbased restorative materials).
  • . Testing to compare Irradiance over Distance of Cure Tip, PolyCure Tip, and primary predicate (K061341). Internal test method and acceptance criteria.
  • . Testing to verify the conformity of the proposed SmartLite®Pro Modular LED Curing Light with the requirements of IEC 60601-1: (Medical electrical equipment Part 1: General requirements for basic safety and essential performance).
  • Testing to verify the conformity of the proposed SmartLite®Pro ● Modular LED Curing Light with the requirements of IEC 60601-1-2: (Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance. Collateral Standard: Electromagnetic compatibility).
  • Testing to verify the conformity of the proposed SmartLite®Pro ● Modular LED Curing Light with the requirements of IEC 80601-2-60: (Medical electrical equipment Part 2: Particular requirements for basic safety and essential performance of dentalequipment).
  • Testing to verify the conformity of the proposed SmartLite®Pro ● Modular LED Curing Light with the requirements of IEC 60601-1-6: (Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance. Collateral Standard: Usability).
  • Usability study conducted in conformity with IEC 62366 (Medical . devices - Application of usability engineering to medicaldevices).
  • Biocompatibility assessment of patient contacting components of the . proposed SmartLite®Pro Modular LED Curing Light according the requirements of ISO 10993-5 (Biological evaluation of medical devices Part 5: Tests for cytotoxicity).
  • Validation of the devices' software in conformity with IEC 62304 . (Medical device software - Software lifecycle processes).
    The performance of SmartLite®Pro Modular LED Curing Light satisfactorily met the requirements of the non-clinical bench testing conducted to support substantial equivalence.

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.

K061341, K062961

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.

K110756

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

§ 872.6070 Ultraviolet activator for polymerization.

(a)
Identification. An ultraviolet activator for polymerization is a device that produces ultraviolet radiation intended to polymerize (set) resinous dental pit and fissure sealants or restorative materials by transmission of light through a rod.(b)
Classification. Class II.

0

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

November 20, 2019

Dentsply Sirona Karl Nittinger Vice President, Corporate Regulatory Affairs 221 West Philadelphia Street, Suite 60W York, Pennsylvania 17401

Re: K191865

Trade/Device Name: SmartLite Pro Modular LED Curing Light Regulation Number: 21 CFR 872.6070 Regulation Name: Ultraviolet Activator For Polymerization Regulatory Class: Class II Product Code: EBZ, NTK Dated: July 31, 2019 Received: August 1, 2019

Dear Karl Nittinger:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

for Srinivas Nandkumar, Ph.D. Acting Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K191865

Device Name SmartLite® Pro Modular LED Curing Light

Indications for Use (Describe)

-For light activated polymerization of dental materials such as composites, luting cements. and sealants using visible light.

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)

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

Indications for Use

510(k) Number (if known) K191865

Device Name SmartLite® Pro Modular LED Curing Light

Indications for Use (Describe)

-For intraoral illumination used upon initial examination of the dental transillumination to help locate crown fractures, posterior and anterior caries, and for use as an auxiliary light source for endodontic procedures.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

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."

4

Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401

Image /page/4/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized leaf-like shape on the left, followed by the words "Dentsply" and "Sirona" stacked on top of each other on the right. The text and the leaf are in a dark gray color. The logo is simple and modern.

K191865 - 510(k) SUMMARY

for

SmartLite®Pro Modular LED Curing Light

Submitter Information:

Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401

Contact Person:Karl Nittinger
Telephone Number:717-849-4424
Fax Number:717-849-4343

Date Prepared:

18-November-2019

Device Name:

.

• Proprietary Name:SmartLite®Pro Modular LED Curing Light
• Classification Name:Ultraviolet Activator for Polymerization
  • Ultraviolet Activator for Polymerization Classification Name: Laser Fluorescence Caries Detection Device
CFR Number:872.6070
872.1745
  • Device Class: Class II ●
  • Product Code: EBZ, NTK .

Primary Predicate Devices:

| Primary Predicate

Devices510(k)Company Name
Palmlight 10K061341CAO Group, Incorporated
Microlux TransilluminatorK062961AdDent, Incorporated

Reference Device:

Reference Device510(k)Company Name
Bluephase® StyleK110756Ivoclar Vivadent,
Incorporated

5

Description of Device:

Dentsply Sirona intends to market the proposed SmartLite®Pro Modular LED Curing Light with an indications for use as a dental curing light as well as a dental illuminator.

Based upon the FDA Guidance, "Bundling Multiple Devices or Multiple Indications in a Single Submission Guidance for Industry and Food and Drug Administration Staff Document", issued on June 22, 2007, bundling, as found in the case of the proposed devices, is acceptable, because one of the bundled devices is an accessory to the other. In the proposed bundled device, two attachments utilize the same handpiece in order to function.

The proposed SmartLite®Pro Modular LED Curing Light is a cordless pen-style, LED light polymerization and illumination device for use by dental professionals in dental offices or dental laboratories.

The proposed SmartLite®Pro Modular LED Curing Light is characterized by:

  • · Small size and lightweight ergonomic design.
  • Compact cordless design with convenient handling features and exchangeable battery pack.
  • Individually adjustable LED tips, rotatable by 360°.
  • · LED tip design providing excellent intra-oral access.
  • · Polymerization area (optic effective cross-sectional area) of 10 mm indiameter.
  • Up to 10 seconds curing time per activation with audible signal at start and end of cycle.
  • · Advanced heat management system limiting LED tiptemperature.
  • Exchangeable tips for:
    • curing of CQ initiated materials.
    • curing of materials with initiators absorbing in the violetrange.
    • intraoral illumination and dental transillumination.

Indications for Use:

  • For light activated polymerization of dental materials such as composites, luting cements, and sealants using visible light.
  • For intraoral illumination used upon initial examination of the dental patient and dental transillumination to help locate crown fractures, posterior and anterior caries, and for use as an auxiliary light source for endodontic procedures.

Substantial Equivalence:

Technological Characteristics

Table 5.1 compares the proposed device with the primary predicate device, Palmlight 10(K061341).

6

Table 5.1
Proposed Device
SmartLite®Pro Modular
LED Curing Light
(K191865)Primary
Predicate Device
Palmlight 10
(K061341)Differences
Indications for UseIndications for Use:
For light activated
polymerization of dental
materials such as
composites, luting cements,
and sealants using visible
light.For light activated
polymerization of dental
materials such as composites,
luting cements, adhesives, and
sealants using visible and
near-UV light.Narrowing for the indications for use
of the proposed device. With the
proposed device, polymerization of
dental materials if performed using
visible light only where the primary
predicate uses visible and near-UV
light.
Proposed device does not include
dental adhesives.
Features:Features:Differences
Cordless design with
exchangeable battery pack.
The exchangeable battery
packs can be charged on a
charging base.Option to be used cordless
(battery powered) or corded
(connected to mains)
Rechargable lithium ion
batteries for the charging base
so the charging base may be
used un-cordedThe proposed device does not offer
corded back up. The proposed
device can only be powered using
the exchangeable battery pack. The
proposed device's charging base can
only be used while connected to the
mains.
Individually removable and
rotatable LED tips360° rotating LED tipBoth the proposed device and
primary predicate device LED
tips can be rotated. The primary
predicate device tip cannot be
removed.
Up to 10 seconds curing time
per activation with audible
signal at start and end of
cycle- Adjustable timer (5, 10, 15,
20 sec) with countdown
display
  • Audible signals confirm
    button presses to select the
    mode and time, and every 5
    sec during the curing process | The proposed device does not offer
    multiple options for curing cycle
    duration. |
    | Software limits LED tip
    temperature. Provides
    audible warnings when
    device tip reaches critical
    temperature and turns off. | Software monitors the
    temperature of the unit and the
    unit turns off when the
    temperature at the wand tip
    reaches 48°C to minimize
    exposure of personnel and
    patients to excessive
    temperatures | The proposed device has audible
    warnings when the device reaches
    the maximum temperature compared
    to the primary predicate which just
    turns off. |
    | Wide spectral output range
    from 405-480 nm | Wide spectral output range
    from 400-460 nm | The proposed device has a higher
    maximum wavelength than its
    primary predicate Palmlight 10. |
    | Proposed Device | Reference Device | Reason for Reference Device |
    | SmartLite®Pro Modular
    LED Curing Light
    (K191865) | Bluephase® Style
    (K110756) | |
    | Wide spectral output
    range from 405-480 nm | Wide spectral output
    range from 430-490 nm. | To address the wider spectral
    output generated by the proposed
    SmartLite®Pro Modular LED
    Curing Light, in comparison to its
    primary predicate Palmlight 10,
    reference device, Bluephase®
    Style was added. |

7

Table 5.2 compares the proposed device with the primary predicate device, Microlux Transilluminator (K062961).

Table 5.2
Proposed DevicePrimary Predicate DeviceDifferences
SmartLite®Pro Modular
LED Curing LightMicrolux Transilluminator
(K062961)
Indications for UseIndications for Use:
For intraoral illumination used
upon initial examination of
the dental patient and dental
transillumination to help
locate crown fractures,
posterior and anterior caries,
and for use as an auxiliary
light source for endodontic
procedures.The Microlux Transilluminator
is a device used upon initial
examination of the dental
patient to help locate crown
fractures, posterior and
anterior caries.
The microlux Transilluminator
is a screening device used to
help locate caries and crown
fractures. It also functions as
an auxiliary light source to aid
in operative procedures and
preventive dentistry.The intraoral illumination of
endodontic access and root canal
orifices in the indications for use of
the subject device are proposed as a
more narrowly scoped use which is
within the cleared indications for use
of the primary predicate device as an
"auxiliary light source to aid in
operative procedures and preventive
dentistry".
Features:Features:Differences
Cordless design with
exchangeable battery pack.
The exchangeable battery
packs can be charged on a
charging base.Option to be used cordless
(battery powered) or corded
(connected to mains)
Rechargeable lithium ion
batteries for the charging base
so the charging base may be
used up-cordedThe proposed device does not offer
corded back up. The proposed
device can only be powered using
the exchangeable battery pack. The
proposed device's charging base can
only be used while connected to the
mains.

8

Table 5.2 (continued)
Proposed Device
SmartLite®Pro Modular
LED Curing LightPrimary Predicate Device
Microlux Transilluminator
(K062961)Differences
Features:Features:Differences
LED tip with 1.5 mm output
diameterAvailable glass light guides
with 2 mm and 3 mm
output diameter.The proposed device has a tip with a
single output diameter.
Two output powers to
visualize anterior or posterior
dental anatomySingle output power to
visualize dental anatomyThe proposed device has the option
for use of two output powers.

Non-Clinical Performance Data.

Performance testing of the SmartLite®Pro Modular LED Curing Light was conducted and included in this premarket notification. The results of the performance testing support substantial equivalence. The exchangeable tip used in the test is identified.

The following testing was conducted using the exchangeable tip as identified within the testing, as applicable:

  • Testing to verify Output Power (Cure Tip). Internal test method and . acceptance criteria.
  • Testing to verify Output Power (PolyCure Tip). Internal test method ● and acceptance criteria.
  • Testing to verify Output Power (Illuminate Tip). Internal test method . and acceptance criteria.
  • Testing to compare Depth of Cure of Cure Tip, PolyCure Tip, and ● primary predicate (K061341) per ISO 4049: (Dentist - Polymerbased restorative materials).
  • . Testing to compare Irradiance over Distance of Cure Tip, PolyCure Tip, and primary predicate (K061341). Internal test method and acceptance criteria.
  • . Testing to verify the conformity of the proposed SmartLite®Pro Modular LED Curing Light with the requirements of IEC 60601-1: (Medical electrical equipment Part 1: General requirements for basic safety and essential performance).
  • Testing to verify the conformity of the proposed SmartLite®Pro ● Modular LED Curing Light with the requirements of IEC 60601-1-2: (Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance. Collateral Standard: Electromagnetic compatibility).
  • Testing to verify the conformity of the proposed SmartLite®Pro ● Modular LED Curing Light with the requirements of IEC 80601-2-60: (Medical electrical equipment Part 2: Particular requirements for basic safety and essential performance of dentalequipment).

9

  • Testing to verify the conformity of the proposed SmartLite®Pro ● Modular LED Curing Light with the requirements of IEC 60601-1-6: (Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance. Collateral Standard: Usability).
  • Usability study conducted in conformity with IEC 62366 (Medical . devices - Application of usability engineering to medicaldevices).
  • Biocompatibility assessment of patient contacting components of the . proposed SmartLite®Pro Modular LED Curing Light according the requirements of ISO 10993-5 (Biological evaluation of medical devices Part 5: Tests for cytotoxicity).
  • Validation of the devices' software in conformity with IEC 62304 . (Medical device software - Software lifecycle processes).

The performance of SmartLite®Pro Modular LED Curing Light satisfactorily met the requirements of the non-clinical bench testing conducted to support substantial equivalence.

Clinical Performance Data.

No data from human clinical studies has been included to support the substantial equivalence of the SmartLite® Pro Modular LED Curing Light.

Conclusion Regarding Substantial Equivalence

The SmartLite® Pro Modular LED Curing Light is a light polymerization and illumination device for use by dental professionals. The SmartLite® Pro Modular LED Curing Light has the same intended use, incorporates the same fundamental technology, and has similar indications for use as the primary predicate Palmlight 10 cleared under premarket notification K061341 and the primary predicate Microlux Transilluminator cleared under premarket notification K062961.

The results of the performance testing, combined with the design and intended use comparison with the primary predicate devices, support substantial equivalence.