K Number
K230122
Device Name
IPL Hair Removal Device, Model(s): UI04 SD, UI04 DG
Date Cleared
2023-04-10

(83 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.
Device Description
IPL Hair Removal Device (Model: UI04 SD, UI04 DG), is an over-the-counter, home-use and personal device for hair reduction by using Intense Pulsed Light (IPL). It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain. The device is only powered by the external power adapter and its IPL emission activation is by finger switch. This product adopts irreplaceable treatment window and the spot size is 3.3cm² that is suitable for multiple hair removal areas. It contains a skin sensor to detect appropriate skin contact, if the device is not in full contact with the skin, the device cannot emit the treatment light pulses. Besides, the device has the cooling function that will be activated throughout the whole hair removal process to provide users with a more comfortable experience. IPL Hair Removal Device, model: UI04 SD, UI04 DG have the same indication for use, performance, structure design and operation, the only deference is their enclosure color (UI04 SD is Star White and UI04 DG is Dark Green).
More Information

No
The summary does not mention AI or ML, and the device description focuses on basic sensor and light emission technology.

No.
The device is indicated for hair removal and permanent reduction in hair regrowth, which are cosmetic purposes rather than for treating a disease or condition.

No

The device is an IPL hair removal device intended for the removal and permanent reduction of unwanted hair, not for diagnosing any medical condition.

No

The device description clearly states it is a hardware device that uses Intense Pulsed Light (IPL) and includes physical components like an external power adapter, finger switch, treatment window, skin sensor, and cooling function. While it mentions software verification and validation, this is for the control and operation of the hardware, not a standalone software medical device.

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

Here's why:

  • Intended Use: The intended use is for hair removal and permanent reduction in hair regrowth. This is a physical treatment applied to the body, not a diagnostic test performed on samples taken from the body (like blood, urine, or tissue).
  • Device Description: The description details a device that emits light to affect hair follicles. It does not describe any components or processes related to analyzing biological samples.
  • Lack of Diagnostic Function: The device's function is to treat, not to diagnose a condition or provide information about a patient's health status based on in vitro analysis.

IVD devices are specifically designed to examine specimens derived from the human body to provide information for diagnostic, monitoring, or screening purposes. This IPL hair removal device does not fit that description.

N/A

Intended Use / Indications for Use

IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

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

OHT

Device Description

IPL Hair Removal Device (Model: UI04 SD, UI04 DG), is an over-the-counter, home-use and personal device for hair reduction by using Intense Pulsed Light (IPL). It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain.

The device is only powered by the external power adapter and its IPL emission activation is by finger switch. This product adopts irreplaceable treatment window and the spot size is 3.3cm² that is suitable for multiple hair removal areas. It contains a skin sensor to detect appropriate skin contact, if the device is not in full contact with the skin, the device cannot emit the treatment light pulses. Besides, the device has the cooling function that will be activated throughout the whole hair removal process to provide users with a more comfortable experience.

IPL Hair Removal Device, model: UI04 SD, UI04 DG have the same indication for use, performance, structure design and operation, the only deference is their enclosure color (UI04 SD is Star White and UI04 DG is Dark Green).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Intense Pulsed Light

Anatomical Site

large areas (e.g. arms, legs, chest) and small areas (e.g. lip)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Over-The-Counter Use; home-use and personal device

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)

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

  1. Biocompatibility Testing: The biocompatibility evaluation for the body-contacting components of the IPL Hair Removal Device was conducted in accordance with the "Use of International Standard ISO 10993-1, 'Biological Evaluation of Medical Devices -Part 1: Evaluation and Testing Within a Risk Management Process, Document Issued on September 4, 2020", as recognized by FDA. The following testing was performed to, and passed, including:
  • ISO 10993-5:2009, Biological Evaluation of Medical Devices -Par t 5: Tests for In Vitro Cytotoxicity
  • ISO 10993-10:2010, Biological Evaluation of Medical Devices -Par t 10: Tests for Irritation and Skin Sensitization
  1. Electrical Safety and EMC: Electrical safety and EMC testing was performed to, and passed, as per the following standards:
  • ANSI AAMI ES60601-1 Medical electrical equipment Part 1: General requirements for basic safety and essential performance
  • IEC 60601-1-2 Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances -Requirements and tests
  • IEC 60601-1-11 Medical Electrical Equipment -Part 1-11: General Requirements for Basic Safety and Essential Performance -Collateral Standard: Requirements for Medical Electrical Equipment and Medical Electrical Systems Used in the Home Healthcare Environment
  • IEC 60601-2-57 Medical electrical equipment -Part 2-57: Particular requirements for the basic safety and essential performance of non-laser source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use
  • IEC 60601-2-83 Medical electrical equipment Part 2-83: Particular requirements for the basic safety and essential performance of home light therapy equipment
  1. Eye Safety:
  • IEC 62471 Photobiological safety of lamps and lamp systems
  1. Software Verification and Validation: Software documentation consistent with moderate level of concern was submitted in this 510(k). System validation testing presented in this 510(k) demonstrated that all software requirement specifications are met and all software hazards have been mitigated to acceptable risk levels.

  2. Usability: The product usability has been evaluated and verified according to the following standard and FDA guidance

  • IEC 60601-1-6 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
  • Applying Human Factors and Usability Engineering to Medical Devices, issued on FEBRUARY 2016

Summary: Based on the above performance as documented in this application, IPL Hair Removal Device was found to have a safety and effectiveness profile that is similar to the predicate device and reference devices.

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.

K160968, K173813

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.

K212318

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 date April 10, 2023. The date is written in a simple, clear font. The text is centered and takes up a small portion of the image.

Image /page/0/Picture/1 description: The image contains 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" stacked on top of each other.

Shenzhen Ulike Smart Electronics Co., Ltd % Riley Chen Registration Engineer Feiying Drug & Medical Consulting Technical Service Group Rm 2401 Zhenye International Business Center, No. 3101-90, Qianhai Road Shenzhen, Guangdong 518052 China

Re: K230122

Trade/Device Name: IPL Hair Removal Device, Model(s): UI04 SD, UI04 DG 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: OHT Dated: January 15, 2023 Received: January 17, 2023

Dear Riley Chen:

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 medical devices and radiation-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.

Colin K. Chen -S

for

Jianting Wang Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K230122

Device Name IPL Hair Removal Device Model(s): UI04 SD, UI04 DG

Indications for Use (Describe)

IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

"510(k) Summary" as required by 21 CFR Part 807.92.

I. Submitter

Shenzhen Ulike Smart Electronics Co.,Ltd.

No.8, Keyuan Road, Yuehai Sub-district, Nanshan District, Shenzhen, Guangdong, China Post code: 518000 Tel.: +86 18600825411

Shane Xie Registration Director Tel: +86 18600825411 Email: Shane@ulikebeauty.com

II. Device

Name of Device: IPL Hair Removal Device Model(s): UI04 SD, UI04 DG Common or Usual Name: Light Based Over-The-Counter Hair Removal Regulation Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Regulatory Class: II Product Code: OHT Regulation Number: 21 CFR 878.4810

III. Predicate Device

Primary predicate device:

ManufacturerPredicate Device510(k) NumberApproval Date
CyDen Limited.iPulse SmoothSkin Gold
Hair Removal SystemK160968Apr.14, 2016

Predicate device:

ManufacturerReference Device510(k) NumberApproval Date
Shen Zhen CosBeauty Co., LtdIPL Hair Removal Device
Joy Version, CB-027K173813Sept. 07, 2018

Reference device:

ManufacturerReference Device510(k) NumberApproval Date
Dongguan Define Beauty
Electronic Technology Co.
LtdIPL HAIR REMOVAL SG-
8025K212318Jan.14, 2022

4

IV. Device Description

IPL Hair Removal Device (Model: UI04 SD, UI04 DG), is an over-the-counter, home-use and personal device for hair reduction by using Intense Pulsed Light (IPL). It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain.

The device is only powered by the external power adapter and its IPL emission activation is by finger switch. This product adopts irreplaceable treatment window and the spot size is 3.3cm² that is suitable for multiple hair removal areas. It contains a skin sensor to detect appropriate skin contact, if the device is not in full contact with the skin, the device cannot emit the treatment light pulses. Besides, the device has the cooling function that will be activated throughout the whole hair removal process to provide users with a more comfortable experience.

IPL Hair Removal Device, model: UI04 SD, UI04 DG have the same indication for use, performance, structure design and operation, the only deference is their enclosure color (UI04 SD is Star White and UI04 DG is Dark Green).

V. Indications for Use

IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

VI. Materials

| Component

nameMaterial of ComponentBody Contact CategoryContact Duration
IPL Hair Removal
Device (Enclosure
and treatment
window)ABS, PC,
Crystal applicationSurface-contacting
device: Intact skinLess than 24 hours

We have tested the device for biocompatibility by a reliable third-party lab. For details, please refer to "Biocompatibility Discussion".

VII.Comparison of Technological Characteristics With the Predicate Device

The IPL Hair Removal Device has the same intended use, mode of action and similar operational characteristics as the predicate device and reference devices. Any minor differences between the subject device and the listed predicate devices and reference device do no raise any issues of safety or efficacy. Performance data supports that the device is safe and as effective as the predicate devices and reference device for its intended use. Therefore, the IPL Hair Removal Device may be found substantially equivalent to its predicate devices and reference device.

IPL Hair Removal Device is compared with the following Predicate Devices and Reference Device in terms of intended use, design, specifications and performance:

5

| Comparison

ElementsSubject DevicePrimary DevicePredicate DeviceReference DeviceRemark
510(k)
NumberPendingK160968K173813K212318/
Trade nameIPL Hair Removal
DeviceiPulse SmoothSkin
Gold Hair Removal
SystemIPL Hair Removal
Device Joy Version, CB-
027IPL HAIR
REMOVAL SG-
8025/
ManufacturerShenzhen Ulike
Smart Electronics
Co.,Ltd.Cyden Limited.Shen Zhen CosBeauty
Co., LtdDongguan Define
Beauty Electronic
Technology Co.
Ltd/
Regulation
number21 CFR 878.481021 CFR 878.481021 CFR 878.481021 CFR 878.4810Same
Product codeOHTOHT, GEXOHTOHTSame
Device
classificationClass IIClass IIClass IIClass IISame
Indication for
use/ Intended
useIPL Hair Removal
Device is indicated
for the removal of
unwanted hair. The
device is also
indicated for the
permanent reduction
in hair regrowth,
defined as the long-
term, stable reduction
in the number of hairs
regrowing when
measured at 6, 9 and
12 months after the
completion of a
treatment regime.The
iPulse SmoothSkin
Gold Hair Removal System
is indicated for the
removal of unwanted
hair. The iPulse
Smoothskin Gold is
also indicated for the
permanent reduction
in hair regrowth,
defined as the long-
term, stable reduction
in the number of hairs
regrowing when
measured at 6, 9 and
12 months after the
completion of a
treatment regime.The IPL Hair Removal
Device Joy Version is
indicated for the
removal of unwanted
hair. The device is also
indicated for the
permanent reduction in
hair regrowth, defined
as the long-term, stable
reduction in the number
of hairs regrowing when
measured at 6, 9 and 12
months after the
completion of a
treatment regime. The
device is used for adults
with Fitzpatrick skin
types I - IV.The IPL Hair
Removal (Model:
SG-8025) is an
over the Counter
device intended for
the removal of
unwanted body
and/or facial hair
in adults. It is also
intended for
permanent
reduction in
unwanted hair.
Permanent hair
reduction is
defined as the
long-term stable
reduction in the
number of hairs re-
growing when
measured at 6. 9.
and 12 months
after the
completion of a
treatment regimen.Same,
only wording
difference
Prescription
or OTCOTCOTCOTCOTCSame
ApplicableFitzpatrick
SkinUnknownFitzpatrick skin types I -UnknownDifferent
Comparison
ElementsSubject DevicePrimary DevicePredicate DeviceReference DeviceRemark
skinTypes I-VIV
Treatment
arealarge areas (e.g. arms,
legs, chest) and small
areas (e.g. lip)UnknownLarge areas (legs, arms,
back and abdomen), face
(upper lip, chin and
sideburns)Body and faceSimilar
Device design
Source
energySupplied by external
adapterExternal Power
supplySupplied by external
adapterSupplied by
external adapterSame
Power supply100~240V, 50/60Hz110V or 230V,
50/60Hz100-240 VAC, 50/60HzUnknownSame
Dimension60mm x
38mm x
170mmUnknown12678200mm2057656mm
(HWD)Different
SterilizationNot requiredNot requiredNot requiredNot requiredSame
Output specification
Light sourceIntense Pulsed LightIntense Pulsed LightIntense Pulsed LightIntense Pulsed
LightSame
Energy
mediumXenon Arc FlashlampXenon Arc FlashlampXenon Arc FlashlampXenon lampSame
Wavelength
range560-1200nm510-1100nm510-1200nm530nmSimilar
Energy
density2.4-7.2J/cm23-6J/cm21.8~5.1J/cm22.5J/cm2 MaxSimilar
Output
energy9.9~19.8J9~18JBody
lamp
cartridge11.77~22.21J
510-1200nmLevel 1: 7.5J
Level 2: 8.5J
Level 3: 9.5J
Level 4: 11J
Level 5: 12JSimilar
Facial
lamp
cartridge3.65~7.04J
512-1197nm
Bikini
lamp
cartridge3.84~7.22J
511-1200nm
Spot size3.3cm23cm2 (3cm by 1cm)Body: 4.2cm2
Bikini and face: 2.0cm23.0cm2Similar
Pulse
duration1.15-6.2ms2ms to 10ms9.2~11.2ms1msDifferent
Pulsing
controlFinger switchFinger switchFinger switchFinger switchSame
Delivery
deviceDirect illumination to
tissueDirect illumination to
tissueDirect illumination to
tissueDirect illumination
to tissueSame
Output
intensity level5Unknown55Same
Comparison
ElementsSubject DevicePrimary
Predicate
DevicePredicate DeviceReference DeviceRemark
Software/
Firmware/
Microprocess
or Control?YesYesYesYesSame
Additional features
Electrical
safetyANSI
ES60601-1
IEC 60601-1-2
IEC 60601-1-11
IEC 60601-2-57
IEC 60601-2-83AAMI
IEC 60601-1
IEC 60601-1-2
IEC 60601-2-57IEC 60601-1
IEC 60601-1-2
IEC 60601-2-57IEC 60601-1
IEC 60601-1-2
IEC 60601-1-11
IEC 60601-2-57Similar
Eye safetyIEC 62471IEC 62471UnknownIEC 62471Same
Biocompatibi
lityISO 10993-5
ISO 10993-10ISO 10993-5
ISO 10993-10ISO 10993-5
ISO 10993-10ISO 10993-5
ISO 10993-10Same

6

7

Shenzhen Ulike Smart Electronics Co.,Ltd. 510(k)s -Section 8. 510(k) Summary

Performance Data VIII.

The following performance data were provided in support of the substantial equivalence determination.

1) Biocompatibility Testing

The biocompatibility evaluation for the body-contacting components of the IPL Hair Removal Device was conducted in accordance with the "Use of International Standard ISO 10993-1, 'Biological Evaluation of Medical Devices -Part 1: Evaluation and Testing Within a Risk Management Process, Document Issued on September 4, 2020", as recognized by FDA. The following testing was performed to, and passed, including:

  • ISO 10993-5:2009, Biological Evaluation of Medical Devices -Par t 5: Tests for In Vitro Cytotoxicity

  • ISO 10993-10:2010, Biological Evaluation of Medical Devices -Par t 10: Tests for Irritation and Skin Sensitization

2) Electrical Safety and EMC

Electrical safety and EMC testing was performed to, and passed, as per the following standards:

  • ANSI AAMI ES60601-1 Medical electrical equipment Part 1: General requirements for basic safety and essential performance

  • IEC 60601-1-2 Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances -Requirements and tests

8

  • IEC 60601-1-11 Medical Electrical Equipment -Part 1-11: General Requirements for Basic Safety and Essential Performance -Collateral Standard: Requirements for Medical Electrical Equipment and Medical Electrical Systems Used in the Home Healthcare Environment

  • IEC 60601-2-57 Medical electrical equipment -Part 2-57: Particular requirements for the basic safety and essential performance of non-laser source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use

  • IEC 60601-2-83 Medical electrical equipment Part 2-83: Particular requirements for the basic safety and essential performance of home light therapy equipment

3) Eye Safety

  • IEC 62471 Photobiological safety of lamps and lamp systems

4) Software Verification and Validation

Software documentation consistent with moderate level of concern was submitted in this 510(k). System validation testing presented in this 510(k) demonstrated that all software requirement specifications are met and all software hazards have been mitigated to acceptable risk levels.

5) Usability

The product usability has been evaluated and verified according to the following standard and FDA guidance

IEC 60601-1-6 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability

Applying Human Factors and Usability Engineering to Medical Devices, issued on FEBRUARY 2016

Summary

Based on the above performance as documented in this application, IPL Hair Removal Device was found to have a safety and effectiveness profile that is similar to the predicate device and reference devices.

IX. Conclusions

Based on the above analysis and non-clinical tests performed, it can be concluded that the subject device IPL Hair Removal Device is as safe, as effective, and performs as well as the legally marketed predicate device and reference devices.