K Number
K214008
Device Name
Dental diode laser
Date Cleared
2022-05-10

(139 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Intra- and extra-oral surgery including incision, excision, hemostasis, coagulation and vaporization of soft tissue; marginal and interdental gingival and epithelial lining of free gingiva; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/ partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of diseased, inflamed and necrosed soft tissue in the periodontal pocket to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment loss and tooth inability); pulpotomy; pulpotomy as adjunct to root canal therapy; Fibroma removal; Gingival incision; Treatment of canker sores; herpetic ulcers of the oral mucosa: Laser soft tissue curettage: Reduction of gingival hypertrophy:.
Device Description
The semiconductor laser diode is excited by the generation power supply to generate the laser, which is effectively transmitted to the treatment site through the optical fiber tip. It is composed of laser host (including internal power system, laser drive system, optical path system, LCD screen, emergency stop button, laser) and optic fiber tip. The device mainframe not supplied sterile and do not require sterilization prior to use. The consumable component (Fiber optic tip) not supplied sterile but require sterilization prior to use.
More Information

Not Found

No
The device description and performance studies focus on the laser technology and its physical components, with no mention of AI or ML.

Yes
The "Intended Use / Indications for Use" section lists numerous applications for treating diseases, injuries, and conditions (e.g., "removal of diseased, inflamed and necrosed soft tissue," "treatment of aphthous ulcers," "incisions and draining of abscesses"), which aligns with the definition of a therapeutic device.

No

The device description and intended use outline various surgical and therapeutic procedures (e.g., incision, excision, hemostasis, removal of tissues, treatment of ulcers), but none of these functions are for the purpose of diagnosing a medical condition.

No

The device description explicitly states it is composed of a "laser host" and "optic fiber tip," which are hardware components.

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

Here's why:

  • IVDs are used to examine specimens from the human body. The intended use and device description clearly indicate that this device is a laser used for surgical procedures directly on soft tissue within and outside the mouth. It does not involve the analysis of biological samples like blood, urine, or tissue biopsies in vitro (outside the body).
  • The device description focuses on the laser technology and its application to tissue. It describes how the laser is generated and delivered to the treatment site, which is consistent with a surgical device, not a diagnostic one.
  • The performance studies mentioned are related to safety and effectiveness standards for medical devices (IEC standards), not diagnostic performance metrics. There are no mentions of sensitivity, specificity, or other metrics typically associated with diagnostic tests.

Therefore, this device is a surgical laser intended for therapeutic procedures, not an IVD.

N/A

Intended Use / Indications for Use

Intra- and extra-oral surgery including incision, excision, hemostasis, coagulation and vaporization of soft tissue; marginal and interdental gingival and epithelial lining of free gingiva; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/ partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of diseased, inflamed and necrosed soft tissue in the periodontal pocket to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment loss and tooth inability); pulpotomy; pulpotomy as adjunct to root canal therapy; Fibroma removal; Gingival incision; Treatment of canker sores; herpetic ulcers of the oral mucosa: Laser soft tissue curettage: Reduction of gingival hypertrophy:.

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

NVK, GEX

Device Description

Principle: The semiconductor laser diode is excited by the generation power supply to generate the laser, which is effectively transmitted to the treatment site through the optical fiber tip.

Intended operator: Dental surgeon.

Component part: It is composed of laser host (including internal power system, laser drive system, optical path system, LCD screen, emergency stop button, laser) and optic fiber tip.

Sterile: The device mainframe not supplied sterile and do not require sterilization prior to use. The consumable component (Fiber optic tip) not supplied sterile but require sterilization prior to use.

Sterilization condition: 121℃ (250°F), 30min

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Intra- and extra-oral

Indicated Patient Age Range

For use in all patients

Intended User / Care Setting

Dental surgeon; Hospital, clinic, and medical office setting

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 Test:
Clinical testing was not performed for SOGALaser (Model: ILaser I) as part of the submission.

Non-Clinical Tests:
The subject device was tested/analyzed according to the following standards in order to ensure its effectiveness and safety:
Electrical Safety: IEC 60601-1 Medical electrical equipment Part 1: General requirements for basic safety and essential performance
Electromagnetic Compatibility: IEC 60601-1-2 Medical Electrical Equipment - Part 1-2: General Requirements For Basic Safety And Essential Performance – Collateral Standard: Electromagnetic Compatibility - Requirements And Tests
Performance Safety and Effectiveness: IEC 60825-1 Safety of laser products - Part 1: Equipment classification, and requirements
Performance Safety and Effectiveness: IEC 60601-2-22 Medical electrical equipment - Part 2-22: Particular requirements for basic safety and essential performance of surgical, cosmetic, therapeutic and diagnostic laser equipment

Key Results: "The safety and essential effectiveness of the subject device have been evaluated according to the FDA recognized 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.

K103753

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). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" followed by the words "U.S. Food & Drug Administration".

May 10, 2022

Shenzhen Soga Technology Co., Ltd. Tse Adrian Quality Manager D906, Yinxing Technology Building No. 1301, Sightseeing Road Xinlan Community, Guanlan Street, Longhua District Shenzhen, Guangdong 518110 CHINA

Re: K214008

Trade/Device Name: Dental diode laser 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: NVK, GEX Dated: March 11, 2022 Received: March 11, 2022

Dear Tse Adrian:

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.

1

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) 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 (QS) 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.

Michael E. Adjodha, M.ChE. Assistant Director DHT1B: Division of Dental and ENT 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)

K214008

Device Name Dental Diode Laser

Indications for Use (Describe)

Intra- and extra-oral surgery including incision, excision, hemostasis, coagulation and vaporization of soft tissue; marginal and interdental gingival and epithelial lining of free gingiva; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/ partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of diseased, inflamed and necrosed soft tissue in the periodontal pocket to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment loss and tooth inability); pulpotomy; pulpotomy as adjunct to root canal therapy; Fibroma removal; Gingival incision; Treatment of canker sores; herpetic ulcers of the oral mucosa: Laser soft tissue curettage: Reduction of gingival hypertrophy:.

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

Image /page/3/Picture/1 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letter A having a green triangle in the middle. Below the logo is the company name in Chinese.

005_510(k) Summary

5.1 Submitter Information

  • Company: Shenzhen Soga technology Co., Ltd.
  • Address: D906, Yinxing Technology Building No. 1301, Sightseeing Road, Xinlan Community, Guanlan Street, Longhua District, Shenzhen, Guangdong, China.
  • Phone: +086-15915873605
  • Contact: Tse Adrian, Quality Manager
  • Mail box: 15915873605@Soga12.com
  • Website: www.soga12.com

5.2 Device Information

  • Trade/Device Name: Dental diode laser ●
  • Model: ILaser I
  • Common Name: Dental diode laser
  • Classification regulation: Regulation number: 21 CFR 878.4810 Requlation Description: Manual surgical instrument for general use. Regulation Medical Specialty: General & Plastic Surgery
  • Review Panel: General & Plastic Surgery
  • Product Code: Primary product code: NVK; Secondary product code: GEX ●
  • Regulation Number: 21 CFR 878.4810 ●
  • Device Class: Class II

5.3 Predicate Device Information

Predicate Device: SIROLaser Advance (Model: FonaLaser)

Manufacturer: Sirona Dental Systems GmbH

510(k) number: K103753

Indication of use:

Intra- and extra-oral surgery including incision, excision, hemostasis, coagulation and vaporization of soft tissue; marginal and interdental

4

Image /page/4/Picture/1 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letter A in green. Below the logo is the company name in Chinese characters.

gingival and epithelial lining of free gingiva; frenectomy; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingivoplasty; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, infected, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of diseased, infected, inflamed and necrosed soft tissue in the periodontal pocket to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment loss and tooth inability); pulpotomy; pulpotomy as adjunct to root canal therapy; Fibroma removal; Gingival incision and excision; Treatment of canker sores; herpetic ulcers of the oral mucosa; Laser soft tissue curettage; Reduction of gingival hypertrophy;.

5.4 Device Description

Principle: The semiconductor laser diode is excited by the generation power supply to generate the laser, which is effectively transmitted to the treatment site through the optical fiber tip.

Intended operator: Dental surgeon.

Component part: It is composed of laser host (including internal power system, laser drive system, optical path system, LCD screen, emergency stop button, laser) and optic fiber tip.

Sterile: The device mainframe not supplied sterile and do not require sterilization prior to use. The consumable component (Fiber optic tip) not supplied sterile but require sterilization prior to use.

Sterilization condition: 121℃ (250°F), 30min

5.5 Indications for Use

5

Image /page/5/Picture/1 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letter A having a green triangle in the middle. Below the logo is the company name in Chinese, which is 索感科技.

Intra- and extra-oral surgery including incision, excision, hemostasis, coagulation and vaporization of soft tissue; marginal and interdental gingival and epithelial lining of free gingiva; frenectomy; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingivoplasty; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, infected, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of diseased, infected, inflamed and necrosed soft tissue in the periodontal pocket to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment loss and tooth inability); pulpotomy; pulpotomy as adjunct to root canal therapy; Fibroma removal; Gingival incision and excision; Treatment of canker sores; herpetic ulcers of the oral mucosa; Laser soft tissue curettage; Reduction of gingival hypertrophy;.

| Comparison
Items | Subject Device:
SOGALaser
(Model: ILaser I) | Predicate Device:
SIROLaser Advance
Model: FONALaser
(K103753) |
|-------------------------------|-------------------------------------------------------------------------------|-------------------------------------------------------------------------------|
| Classification & Intended Use | | |
| Classification | GEX, NVK
Class II
21 CFR 878.4810 | GEX
Class II
21 CFR 878.4810 |
| Intended use | Intra- and extra-oral
surgery including incision,
excision, hemostasis, | Intra- and extra-oral
surgery including incision,
excision, hemostasis, |

5.6 Comparison of Technological Characteristics with the Predicate Device

6

Image /page/6/Picture/0 description: The image shows the text "Shenzhen Soga technology Co. Ltd." in a clear, sans-serif font. The text is horizontally aligned and appears to be the name of a company. The background is plain white, providing a clean and professional look to the text.

Image /page/6/Picture/1 description: The image shows the logo for SOGA, a technology company. The logo is in a dark gray color, with the letter 'A' in the logo having a green triangle in the middle. Below the logo, there are Chinese characters, and a black line is present at the bottom of the image.

coagulation and vaporization of soft tissue; marginal and interdental gingival and epithelial lining of free gingiva; frenectomy; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingivoplasty; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, infected, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of diseased,

coagulation and vaporization of soft tissue; marginal and interdental gingival and epithelial lining of free gingiva; frenectomy; frenotomy; biopsy; operculectomy; Implant recovery; gingivectomy; gingivoplasty; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery; debridement of deseased epithelial lining ; incisions and draining of abscesses; tissue retraction for impressions; papillectomy; vestibuloplasty; excision of lesions ; exposure of unerupted/partially erupted teeth; removal of hyperplastic tissues; treatment of aphthous ulcers; leukoplakia; Laser removal of diseased, infected, inflamed and necrosed soft tissue within the periodontal pocket; Sulcular debridement (removal of

7

Image /page/7/Picture/0 description: The image shows the text "Shenzhen Soga technology Co. Ltd." in bold, black font. The text appears to be a company name. The background is plain white, providing a clear contrast for the text to stand out. There is a black line underneath the text.

Image /page/7/Picture/1 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letters "SOGA" in a stylized font. Below the letters is the company name in Chinese characters, which translates to "Suo Gan Technology". The "A" in SOGA has a green triangle in the middle.

infected, inflamed anddiseased, infected,
necrosed soft tissue in the
periodontal pocket to
improve clinical indices
including gingival index,
gingival bleeding index,
probe depth, attachment
loss and tooth inability);
pulpotomy; pulpotomy as
adjunct to root canal
therapy; Fibroma removal;
Gingival incision and
excision; Treatment of
canker sores; herpetic
ulcers of the oral mucosa;
Laser soft tissue curettage;
Reduction of gingival
hypertrophy;.inflamed and necrosed
soft tissue in the
periodontal pocket to
improve clinical indices
including gingival index,
gingival bleeding index,
probe depth, attachment
loss and tooth inability);
pulpotomy; pulpotomy as
adjunct to root canal
therapy; Fibroma removal;
Gingival incision and
excision; Treatment of
canker sores; herpetic
ulcers of the oral mucosa;
Laser soft tissue
curettage; Reduction of
gingival hypertrophy;.
Patient PopulationFor use in all patientsFor use in all patients
Environment of
UseFor Dental surgeonPrescription Use - For
professional
Patient PopulationNo restriction on the
applicable populationAll Population
Comparison
StatementThe subject device enjoys the same classification and
intended use with the predicate device.
Technological Characteristics
Principle / Method
of OperationThe semiconductor laser
diode is excited by the
generation power supply to
generate the laser, which is
effectively transmitted toIt is generated by a laser
diode in the control unit
and is guided through a
quartz fiber to the
treatment area. The laser
the treatment site through
the fiber optic tip.radiation is absorbed by
the tissue and converted
into heat for cutting,
solidification, bacteria
reduction and
desensitization.
Environment
of
UseHospital, clinic, and medical
office settingHospital, clinic, and
medical office setting
Size18cm x 16cm x 26cm182 x 197 x 189 mm
Shipping listThe product is composed
of:
● Mainframe
● Fiber optic tip
● Charging adaptor
● Fiber optic cleaner
● Fiber bender
● Laser area symbol
● Protection glasses● FONALaser mainframe
including A control
unit including a
handpiece with a
manual switch
● Handpiece cover
● Fiber head pack
(including 1 x 200 μm
and 4 x 320 μm)
● Fiber cutter
● Disposable operation
head (including a
bending tool)
● Protection glasses
● Switch power supply
SoftwareMCU softwareMCU software
Laser ClassIV (4)IV (4)
Wavelength980nm ±20nm970 nm ± 15nm
Frequency1Hz to 100Hz1Hz to 100Hz
Output Power4.0 W Max CW / 8.0 W4.0 W Max CW / 7.0 W
Peak Power (Pulse Mode)Peak Power (Pulse Mode)
Pulse modeContinuousContinuous
Aiming BeamLaser diode, 5 mW,
680nm±20nm, Class 1Laser diode, max 1 mW,
635-650nm, Class 1
N.O.H.D.3.03 meters1.5 meters
Comparison
statementThe subject device has almost the same technological
characteristics with the predicate device, and their slight
difference in Size, Aiming Beam, Wavelength and
N.O.H.D. will not affect the core usage of the devices or
validated by relevant standard evaluation or not
bringing new safety and effectiveness concerns, thus
will not affecting the substantial equivalence
comparison. their differences are not affecting the core
usage of the devices
The difference in Wavelength had verified the safety
characteristics by IEC 60825-1 and IEC 60601-2-22, and
the efficiency of subject device is better than predicate
device. It could be found in literature referred.[1]
Material Characteristics
Application partFiber optic tipFiber
EnclosureABSNot know
Hand piece CoverSilica gelelasto-plastic
Safety & Effectiveness
Patient-Contacting
MaterialsFiber optic tipFiber
Electrical SafetyVerified according IEC
60601-1Not know
EMCVerified according IEC
60601-1-2Not know
Performance SafetyVerified according IEC 60825-1 and IEC 60601-2-22Not know
Comparison statementThe safety and essential effectiveness of the subject device have been evaluated according to the FDA recognized standards.

8

Image /page/8/Picture/0 description: The image shows the logo for SOGA. The logo is in dark gray, with the letter A in the logo having a green triangle in the middle. Below the logo is the company name in Chinese characters. There is a horizontal line above and below the Chinese characters.

9

Image /page/9/Picture/0 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letter A having a green triangle in the middle. Below the logo is the company name in Chinese characters.

10

Image /page/10/Picture/0 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letter A having a green triangle in the middle. Underneath the logo is the company name in Chinese characters, with a line on either side of the name.

5.6.1 Comparison summary

First, the subject device (Model: ILaser I) enjoys identical classification and intended use with the predicate device, which forms the foundation of their substantial equivalence.

Secondly, the most technological characteristics have substantial equivalence difference is below:

Difference item
Shipping list
Size
Wavelength
Aiming Beam
Frequency
Output power
N.O.H.D.
Enclosure material
Handpiece cover material

5.7 Discussion of Tests Performed

11

Image /page/11/Picture/1 description: The image shows the logo for SOGA. The logo is in a dark gray color, with the letter A in the logo having a green triangle in the middle. Below the logo is the company name in Chinese.

5.7.1 Clinical Test

Clinical testing was not performed for SOGALaser (Model: ILaser I) as part of the submission.

5.7.2 Non-Clinical Tests

The subject device was tested/analyzed according to the following standards in order to ensure its effectiveness and safety:

| | Standard
Designation
Number | Title of Standard |
|--------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Electrical Safety | IEC 60601-1 | Medical electrical
equipment Part 1:
General requirements
for basic safety and
essential performance |
| Electromagnetic
Compatibility | IEC 60601-1-2 | Medical Electrical
Equipment - Part 1-2:
General Requirements
For Basic Safety And
Essential Performance
– Collateral Standard:
Electromagnetic
Compatibility -
Requirements And
Tests |
| Performance
Safety and
Effectiveness | IEC 60825-1 | Safety of laser
products - Part 1:
Equipment
classification, and
requirements |
| | IEC 60601-2-22 | Medical electrical
equipment - Part 2-22: |
| | Particular
requirements for basic
safety and essential
performance of
surgical, cosmetic,
therapeutic and
diagnostic laser
equipment | |

12

Image /page/12/Picture/0 description: The image shows the logo for SOGA. The logo is in a dark gray color, except for a small green triangle in the upper right corner of the A. Below the logo is the company name in Chinese characters.

5.8 Conclusion

From the above analysis, it is proper to conclude that the subject device (Model: ILaser I) will be as safe and effective for usage as the listed predicate devices that have already been on the U.S. market.

5.9 Release date

Apr. 11, 2022