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510(k) Data Aggregation

    Why did this record match?
    Applicant Name (Manufacturer) :

    Gigaalaser Company Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Medical Diode Laser Systems, include model: VELASⅡ-30A, GBOX-15AB, GBOX-20B, CHEESEⅡ-10B are intended to emit energy in the infrared spectrum to provide topical heating for the purpose of elevating tissue temperature for temporary relief of minor muscle and joint pain, muscle spasm, pain and stiffness associated with minor arthritis, promoting relaxation of muscle tissue, and to temporarily increase local blood circulation.

    The Medical Diode Laser Systems, model: VELASⅡ-30B is intended to emit energy in the infrared spectrum to provide topical heating for the purpose of elevating tissue temperature for temporary relief of minor muscle and joint pain, muscle spasm, pain and stiffness associated with minor arthritis, promoting relaxation of muscle tissue, and to temporarily increase local blood circulation.

    The Medical Diode Laser Systems, model: VELASⅡ-30B is also indicated for use for the temporary increase of clear nail in patients with onychomycosis (e.g., dermatophytes Trichophyton rubrum and T. mentagrophytes, and/or yeasts Candida albicans, etc.).

    Device Description

    The "Medical Diode Laser Systems", include model: VELASⅡ-30B, VELASⅡ-30A, GBOX-15AB, GBOX-20B, CHEESEⅡ-10B which consist of three main components: Main device; Foot switch; Accessories.

    Diode laser is a kind of laser with semiconductor as working material. It consists of working material, cavity resonator and power source.

    The diode laser for this unit is GaAlAs diode bar, and the wavelength is 810nm and/or 980nm+/-10nm (pilot beam: 650nm+/-10nm). It features impact structure, high efficiency and long lifetime. Generally, the beam shall be emitted as the big beam divergence of the laser from the diode. With the unique fiber-coupling technology, the laser beam can be coupled efficiently into the fiber.

    MCU (Micro Controller Unit) is the control center of system. MCU controls the drive board and temperature system by changing operating current. The operating power supply is the power source of the whole system. It supplies power for MCU, diode laser module by DC-DC conversion module and temp system by temp-control circuit. MCU controls the drive current of diode laser module by adjusting the DC-DC module and current-control circuit. The MCU has three external input sources: footswitch, remote interlock connector and information input from the touch units, it has one external output unit: display terminal. The diode laser module provides laser power output by fiber with optical fiber coupling system.

    AI/ML Overview

    The provided FDA 510(k) clearance letter for the Gigaalaser Medical Diode Laser Systems does not contain a study that proves the device meets specific acceptance criteria related to its clinical efficacy. Instead, it demonstrates substantial equivalence to legally marketed predicate devices based on technological characteristics and safety standards.

    The document focuses on non-clinical performance data (electrical safety, EMC, software V&V, mechanical/acoustic, animal, and clinical studies are noted as "not applicable" for this submission type) to argue that the proposed device is as safe and effective as its predicates.

    Therefore, I cannot directly provide a table of acceptance criteria and reported device performance in the context of a clinical efficacy study, as such a study is explicitly stated as "not applicable" in this 510(k) submission. Similarly, details about sample size, expert ground truth, adjudication methods, MRMC studies, or standalone performance are not present because clinical efficacy testing was not required for this type of submission.

    However, I can interpret the acceptance criteria in the context of a 510(k) submission as the requirements for demonstrating substantial equivalence to predicates, particularly regarding safety and technological characteristics. The "performance" reported is the demonstration that these criteria are met through compliance with recognized standards.

    Here's an interpretation based on the provided document:


    Overview of "Acceptance Criteria" for Substantial Equivalence and Device Performance (as demonstrated in the 510(k))

    Within the context of a 510(k) submission, "acceptance criteria" are primarily established through demonstrating compliance with recognized performance standards and substantial equivalence to legally marketed predicate devices. The "study" proving this involves a comprehensive technical comparison and non-clinical testing.

    The document explicitly states that clinical studies are "not applicable" for this 510(k) submission, meaning the acceptance criteria are focused on non-clinical performance and technological equivalence rather than empirical clinical efficacy data from a human trial.

    1. Table of "Acceptance Criteria" (Substantial Equivalence) and "Reported Device Performance" (Demonstrated Compliance)

    Acceptance Criteria (Demonstration of Equivalence to Predicate)Reported Device Performance (as summarized in the document)
    Similar Indications for UseIdentical or Covered: All proposed device models (VELASⅡ-30A, GBOX-15AB, GBOX-20B, CHEESEⅡ-10B) share identical indications for general topical heating relief as their respective predicates. The VELASⅡ-30B also shares the onychomycosis indication with a co-predicate.
    Similar Technological Characteristics (General)Identical Diode Laser Technology: All models use the same diode laser technology (e.g., 980nm, 810nm, or combinations) as their respective predicates.
    Similar Output Parameters (within clinical needs)Within Predicate Scope: While some proposed device models show slight differences in output power, energy density, power density, spot diameter, operation mode (CW vs. pulse), pulse width, pulse repetition rate, transmission system, and aiming beam compared to their specific predicates, these differences are argued to be "slight" and "do not raise new types of questions regarding the safety and effectiveness" and are "within the scope of what predicate device claims" or "meet clinical needs."
    Compliance with Electrical Safety StandardsVerified Conformity: Demonstrated compliance with IEC 60601-1:2005/AMD1:2012/AMD2:2020.
    Compliance with Electromagnetic Compatibility (EMC) StandardsVerified Conformity: Demonstrated compliance with IEC 60601-1-2:2014+A1:2020.
    Compliance with Laser Safety StandardsVerified Conformity: Demonstrated compliance with IEC 60825-1:2014.
    Compliance with Usability StandardsVerified Conformity: Demonstrated compliance with IEC 60601-1-6:2010/AMD1:2013/AMD2:2020.
    Compliance with Medical Laser Equipment Specific StandardsVerified Performance: Demonstrated compliance with IEC 60601-2-22:2019.
    Software Verification & ValidationConducted and Documented: Software testing conducted as per FDA guidance, with the software deemed a "moderate" level of concern.

    2. Sample Size Used for the Test Set and Data Provenance

    This document does not describe a "test set" in the context of clinical data for efficacy. The "testing" referred to is primarily bench testing and compliance validation with international safety and performance standards. Therefore, concepts like sample size for a patient test set and data provenance (country of origin, retrospective/prospective) are not applicable as no clinical study for efficacy was performed or presented.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    Not applicable. As no clinical efficacy test set was used, there was no need for experts to establish ground truth on patient outcomes/diagnoses. The "ground truth" for the substantial equivalence argument relies on comparison to the published specifications and regulatory clearances of the predicate devices.

    4. Adjudication Method for the Test Set

    Not applicable, as no clinical test set requiring adjudication was used.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No. The document explicitly states "Clinical Studies: It is not applicable." Therefore, no MRMC study for human reader improvement with AI assistance was conducted or reported.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    No. This device is a laser system hardware, not an AI algorithm. Its performance is inherent to its physical output characteristics, not an algorithm's classification or detection performance.

    7. The Type of Ground Truth Used

    The "ground truth" for this 510(k) submission is primarily:

    • Predicate Device Specifications: The established technical parameters and indications for use of the legally marketed predicate devices (K142078, K150138, K121363, K230047).
    • Industry Standards: The requirements laid out in the cited IEC and other international standards for medical electrical equipment and laser safety.

    8. The Sample Size for the Training Set

    Not applicable. This is a hardware device, not a machine learning model that requires a training set of data.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable, as there is no training set for this type of device.

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    K Number
    K250018
    Date Cleared
    2025-04-01

    (88 days)

    Product Code
    Regulation Number
    878.4810
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Gigaalaser Company Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The THEIA808 is intended for hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type 1-VI), including tanned skin.

    Permanent hair reduction is 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

    The Diode laser is a kind of laser with semiconductor as working material. It consists of working material, cavity resonator and power source.

    The diode laser for this unit is GaAlAs diode bar, and the wavelength is 808nm. It features impact structure, high efficiency and long lifetime. Generally the beam shall be emitted as the big beam divergence of the laser from the diode. With the unique fiber-coupling technology, the laser beam can be coupled efficiently into the handpiece.

    When the THEIA808 works, the thermoelectric cooler cools the light outlet, and the main device measures the working temperature of the light outlet through the NTC temperature measuring resistor.

    When the temperature reaches the minimum temperature, the TEC is controlled to stop working. The heat generated by thermoelectric cooler is conducted away by the water flow in the cooling module.

    The energy of the laser is preferentially absorbed by the melanin in the hair, so that the hair follicle produces high heat. Thereby destroying the structure of the hair follicle, making the hair lose the ability to regenerate, and achieving the purpose of hair removal. The light outlet (treatment head) adopts a uniquely designed dynamic cooling device.

    During the hair removal process, it can ensure that the epidermis will not be burned, so that the laser heat is limited to damage the hair follicles, while allowing the heat to diffuse from the epidermis, so that the epidermis can be anesthetized in a short time. The skin will not reach the damage threshold and can be protected from heat damage, thus ensuring a painless, fast and permanent hair removal effect.

    AI/ML Overview

    This document is a 510(k) clearance letter for the Medical Diode Laser Systems (THEIA808). It does not contain any information about acceptance criteria or a study proving the device meets acceptance criteria related to AI or algorithm performance.

    The document specifically states:

    • "No clinical study is included in this submission." This means there are no clinical trials proving efficacy or performance based on patient outcomes related to hair removal or reduction using this specific device.
    • The clearance is based on "Substantial Equivalence" to a predicate device (K162659 Diode Laser Hair Removal System). This means the FDA determined the new device is as safe and effective as a legally marketed predicate device, primarily through non-clinical testing and comparison of specifications (e.g., wavelength, power, cooling methods).
    • The non-clinical tests conducted verified compliance with electrical safety, EMC, laser safety, and biocompatibility standards. These are not performance metrics for hair removal efficacy or AI assistance.

    Therefore, I cannot provide the requested information regarding acceptance criteria and study details for AI or algorithm performance because the provided text does not contain any such details. The device itself is a laser system, not an AI or algorithmic diagnostic/assistive device.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Gigaalaser Company Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    (1) The Medical Diode Laser Systems, model: GBOX-6H, VELAS II-6H is indicated for use in surgical applications requiring the vaporization, excision, ablation, cutting and hemostasis, or coaqulation of soft tissue in conjunction with endoscopic equipment for medical specialist including: Urology, Thoracic Surgery, Plastic Surgery and Dermatology, General Surgery, Ophthalmology, Orthopedics, Podiatry, Arthroscopy, Spinal Surgery, Gynecology, Pulmonary Surgery, Neurosurgery, Gastroenterology, Head/neck/ENT and Radiology, Oral Surgery and Dental procedures. The output wavelength of model GBOX-6H and VELAS II -6H is 1940nm.

    (2) The Medical Diode Laser Systems, model: GBOX-10D, GBOX-12D is indicated for use in surgical applications requiring the vaporization, excision, ablation, cutting and hemostasis, or coagulation of soft tissue in conjunction with endloscopic equipment for medical specialist including: Urology, Thoracic Surgery, Plastic Surgery and Dermatology, General Surgery, Ophthalmology, Orthopedics, Podiatry, Arthroscopy, Spinal Surgery, Gynecology, Pulmonary Surgery, Neurosurgery, Gastroenterology, Head/neck/ENT and Radiology, Oral Surgery and Dental procedures. The output wavelength of model GBOX-10D and GBOX-12D is 1470nm.

    (3) The Medical Diode Laser Systems, model: GBOX-15D, VELAS II -15D is indicated for use in endovenous occlusion of the greater saphenous vein in patients with superficial vein reflux. The GBOX-15D, VELAS II - 15D is further indicated for laser assisted lipolysis. The output wavelength of model GBOX-15D and VELAS II -15D is 1470nm.

    (4) The Medical Diode Laser Systems, model: VELAS Pro-30B15D is indicated for use in surgical applications requiring the vaporization, incision, ablation, cutting and hemostasis, or coagulation of soft tissue in conjunction with endoscopic equipment for medical specialist including: Urology, Thoracic Surgery, Plastic Surgery and Dermatology, General Surgery, Ophthalmology, Orthopedics, Podiatry, Arthroscopy, Spinal Surgery, Gynecology, Pulmonary Surgery, Neurosurgery, Gastroenterology, Head/neck/ENT and Radiology, Oral Surgery and Dental procedures, Endovascular coagulation and endovenous occlusion of the greater saphenous vein in patients with superficial vein reflux. Medical Diode Laser Systems, model: VELAS Pro-30B15D is further indicated for laser assisted lipolysis. The output wavelength of model VELAS Pro-30B15D is 980nm or 1470nm.

    Device Description

    The "Medical Diode Laser Systems", include model: GBOX-6H, VELAS II -6H, GBOX-10D, GBOX-12D, GBOX-15D, VELAS II-15D, VELAS Pro-30B15D which consist of three main components: Main device; Foot switch; Accessories. Diode laser is a kind of laser with semiconductor as working material. It consists of working material, cavity resonator and power source. The diode laser for this unit is GaAlAs diode bar, and the wavelength is 1940nm for GBOX-6H, VELAS II -6H; 1470nm for GBOX-10D, GBOX-12D, GBOX-15D, VELAS III-15D; 980nm or 1470nm for VELAS Pro-30B15D. It features impact structure, high efficiency and long lifetime. Generally, the beam shall be emitted as the big beam divergence of the laser from the diode. With the unique fiber-coupling technology, the laser beam can be coupled efficiently into the fiber. MCU (Micro Controller Unit) is the control center of system. MCU controls the drive board and temperature system by changing operating current. The operating power supply is the power source of the whole system. It supplies power for MCU, diode laser module by DC-DC conversion module and temp system by temp-control circuit. MCU controls the drive current of diode laser module by adjusting the DC-DC module and current-control circuit. The MCU has three external input sources: footswitch, remote interlock connector and information input from the touch units, it has one external output unit: display terminal. The diode laser module provides laser power output by fiber with optical fiber coupling system.

    AI/ML Overview

    The provided document is a 510(k) summary for Medical Diode Laser Systems. It focuses on establishing substantial equivalence to predicate devices rather than providing detailed acceptance criteria and a study demonstrating the device meets those criteria in terms of clinical performance. The document primarily discusses the similarity of the proposed device to predicate devices. Therefore, much of the requested information cannot be extracted directly from this type of regulatory submission.

    Here's a breakdown of what can be inferred or explicitly stated:

    1. A table of acceptance criteria and the reported device performance

    The document does not present explicit acceptance criteria for clinical performance (e.g., specific efficacy rates or safety profiles) for the proposed device, nor does it report its performance against such criteria. Instead, it compares the technological characteristics of the proposed device to predicate devices. The "acceptance criteria" here are implicitly meeting the performance characteristics of the predicate devices to prove substantial equivalence.

    Acceptance Criteria (Inferred from Predicate Equivalence)Reported Device Performance (as compared to Predicate)
    Indications for Use (GBOX-6H, VELAS II-6H): Surgical applications requiring vaporization, incision, excision, ablation, cutting, hemostasis, or coagulation of soft tissue in conjunction with endoscopic equipment for various medical specialists.Substantially Equivalent (Same indications as K222701, covered by K193656)
    Indications for Use (GBOX-10D, GBOX-12D): Surgical applications requiring vaporization, incision, excision, ablation, cutting, hemostasis, or coagulation of soft tissue in conjunction with endoscopic equipment for various medical specialists.Substantially Equivalent (Same indications as K222701, covered by K160952)
    Indications for Use (GBOX-15D, VELAS II-15D): Endovenous occlusion of the greater saphenous vein in patients with superficial vein reflux; laser assisted lipolysis.Substantially Equivalent (Same indications as K160952, covered by K222701)
    Indications for Use (VELAS Pro-30B15D): Surgical applications requiring vaporization, incision, excision, ablation, cutting, hemostasis, or coagulation of soft tissue in conjunction with endoscopic equipment for various medical specialists; endovascular coagulation and endovenous occlusion of the greater saphenous vein in patients with superficial vein reflux; laser assisted lipolysis.Identical to K240747
    Laser Type: Diode laserIdentical (Diode laser)
    Wavelength (GBOX-6H, VELAS II-6H): 1940nmIdentical (1940nm)
    Wavelength (GBOX-10D, GBOX-12D, GBOX-15D, VELAS II-15D): 1470nmIdentical (1470nm)
    Wavelength (VELAS Pro-30B15D): 980nm or 1470nmIdentical (980nm or 1470nm)
    Output Power (GBOX-6H, VELAS II-6H): 1-6WSimilar (Predicate K222701 at 5W, Predicate K193656 up to 7.5W)
    Output Power (GBOX-10D, GBOX-12D, GBOX-15D): GBOX-10D: 1-10W; GBOX-12D: 1-12W; GBOX-15D: 1-15WSimilar (Within scope of Predicate K222701: Max. 12W and Predicate K160952: Max. 15W)
    Output Power (VELAS Pro-30B15D): 980nm: 30W; 1470nm: 15WIdentical (Same as K240747)
    Pulse Width (GBOX-6H, VELAS II-6H): 10ms-10sSimilar (Predicate K222701: 10ms-30s; Predicate K193656: 10ms-10s)
    Pulse Width (GBOX-10D, GBOX-12D, GBOX-15D, VELAS II-15D): 10ms-10sSimilar (Predicate K222701: 10ms-30s; Predicate K160952: 10-990ms)
    Pulse Width (VELAS Pro-30B15D): 10ms-1sIdentical (Same as K240747)
    Operation Mode: CW, single pulse, repeat pulseIdentical (CW, pulsed, single pulse; Continuous wave, single pulse, pulsed)
    Operation Interface: Color LCD touch screenIdentical (Color touch screen; Touch screen control; LCD touch screen)
    Repetition Rate (GBOX-6H, VELAS II-6H): 0.05Hz-50HzSimilar (Predicate K222701: 0.02-50Hz; Predicate K193656: CW or up to 100Hz)
    Repetition Rate (GBOX-10D, GBOX-12D, GBOX-15D, VELAS II-15D): 0.05Hz-50HzSimilar (Predicate K222701: 0.02-50Hz; Predicate K160952: CW or up to 100Hz)
    Aiming Beam: Specifications varying by modelSubstantially Equivalent
    Laser Class: 4Identical
    Electrical Safety and EMC: Conformity to IEC 60601-1, IEC 60601-1-2, IEC 60825-1, IEC 60601-2-22, IEC 60601-1-6Verified.
    Software Verification and Validation: Conformity to FDA Guidance, "moderate" level of concern.Documentation provided.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document explicitly states: "Animal Study - It is not applicable." and "Clinical Studies - It is not applicable." This indicates that no clinical "test set" (i.e., patient data for direct performance evaluation) was used for this 510(k) submission. The data provenance is therefore not relevant in this context.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    Since no clinical studies or test sets with patient data were conducted for this submission, there were no experts used to establish ground truth for such a test set. The submission relies on establishing equivalence to legally marketed predicate devices, implying their established safety and efficacy.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable, as no clinical test set was used.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This device is a laser system, not an AI-powered diagnostic tool, and no MRMC studies were mentioned.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is a hardware medical device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    Not applicable, as no clinical studies requiring a ground truth for performance evaluation were conducted. The "ground truth" in this context is the safety and efficacy profiles of the predicate devices as legally marketed.

    8. The sample size for the training set

    Not applicable, as this is a hardware medical device, not an AI/ML algorithm requiring a training set.

    9. How the ground truth for the training set was established

    Not applicable, as this is a hardware medical device.

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    K Number
    K230047
    Date Cleared
    2024-03-04

    (423 days)

    Product Code
    Regulation Number
    878.4810
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Gigaalaser Company Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Medical Diode Laser Systems are intended for intra- and extra-oral surgery including incision, excision, hemostasis, coagulation and vaporization of soft tissue including marginal and epithelial lining of free gingiva and are indicated for: frenectomy; frenotomy; biopsy; operculectomy; implant recovery; gingivoplasty; gingivoplasty; gingival troughing; crown lengthening; hemostasis of donor site; removal of granulation tissue; laser assisted flap surgery;debridement of diseased epithelial lining; incisions and draining of abscesses; tissue retraction for impressions;papillectorny; 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 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.

    Whitening: Medical Diode Laser Systems are indicated for light activation materials for teeth whitening and for laser-assisted whitening/bleaching of teeth.

    Low Level Laser Therapy: Medical Diode Laser Systems are intended to provide topical heating for the purpose of elevating tissue temperature for the temporary relief of minor muscle and joint pain and stiffins pain, or muscle spasm, and for the temporary increase in local blood circulation and/or temporary relaxation of muscles.

    Device Description

    The Medical Diode Laser System is a compact, air-cooled unit. It is a complete self-contained instrument, which includes a high efficiency power supply, a microprocessor controlled, adjustable light output with automatic power stabilization, (fan cooled), as well as a switch panel and LCD screen display panel designed to be user friendly. The system includes high power lasers, safety features and an SMA fiber output connector. The system includes a Lithium battery, it can work 1hour when not external power input at maximum power output in pulse or CW but intermittent mode. The diodes are made from GaAlAs semiconductor material for high output and superior reliability. The diode lasers are enclosed in a rugged, factory-aligned, replaceable, environmentally protective module. High-capacity fans eliminate the need for water-cooling, and assure low maintenance and reliable laser operation. The diodes convert electric energy into coherent laser radiation with a wavelength of 810nm or 980nm+/-10nm (pilot beam: 650nm+/-10nm).

    AI/ML Overview

    This document is a 510(k) premarket notification for a medical device (Medical Diode Laser Systems) and explicitly states that no clinical testing was performed. Therefore, the request for "acceptance criteria and the study that proves the device meets the acceptance criteria" cannot be fully answered as it pertains to clinical performance and AI integration.

    The provided document focuses on demonstrating substantial equivalence to predicate devices primarily through non-clinical testing (electrical safety, EMC, laser safety standards, and software verification). There is no mention of AI/ML, human-in-the-loop performance studies, or ground truth establishment based on expert consensus, pathology, or outcomes data, which are typical requirements for AI/ML device clearances.

    Based on the provided text, here's what can be inferred/extracted and what cannot be answered:

    1. Table of acceptance criteria and the reported device performance:

    Since no clinical or AI performance study was presented, the "acceptance criteria" here refer to conformance with established safety and performance standards for laser medical devices.

    Acceptance Criteria (from Non-Clinical Tests)Reported Device Performance (Compliance)
    Conformity to IEC 60601-1 (Medical electrical equipment Part 1: General requirements for basic safety and essential performance)Verified
    Conformity to IEC 60601-1-2 (Medical electrical equipment Part 1-2: General requirements for basic safety and essential performance Collateral Standard: Electromagnetic compatibility)Verified
    Conformity to IEC 60825-1 (Safety of laser products - Part 1: Equipment classification and requirements)Verified
    Performance according to IEC 60601-2-22 (Medical electrical equipment Part 2: Particular Requirements for basic safety and essential performance of surgical, cosmetic, therapeutic, and diagnostic laser equipment).Verified
    Software Verification and Validation (for "moderate" level of concern) as per FDA guidance "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."Conducted and documentation provided.
    Device Specifications (Comparison to predicate, serving as a form of "performance" for equivalence)(All stated as "Identical" or "Substantial Equivalence" to predicate/reference devices)
    Product Code (NVK, GEX, ILY)Identical (to predicate K210367)
    Regulation Number (21 CFR 878.4810)Identical
    Classification (Class II)Identical
    Indications for UseSubstantial Equivalence (Proposed device's intended use is same as predicate; reference device does not have light activation for bleaching materials for teeth whitening, but this difference does not affect safety and effectiveness based on the submission.)
    Application (Dental Laser)Identical
    Laser Classification (Class IV)Substantial Equivalence (Predicate states 976nm and 450nm: Class IV, 650nm: Class II; Reference states Class IV). The document implies this is an acceptable difference for substantial equivalence.
    Type of Laser (Diode Laser)Identical
    Wavelength (810 ± 10nm; 980 ± 10nm)Substantial Equivalence (Predicate: 976nm, 650nm, 450nm; Reference: 810nm, 980nm). Stated that modification (different wavelengths) does not adversely affect safety and effectiveness.
    Average Power (Range specific to models)Similar to predicate/reference device. Example: Proposed DEN7A/DEN7B: 0.1W-7W vs. Predicate D-Laser Blue 976nm: 0.2W-4W (CW), 7W (peak). Reference: 0.1-2W, 20W (peak). The ranges for the proposed device generally align with or explain differences within the scope of the predicate devices.
    Operation Mode (Continuous Wave; Pulse)Identical to the predicate.
    Pulse width (e.g., 1ms-1000ms for DEN models)Similar (Predicate: 5 µsec. to 0.9 sec.; Reference: Variable).
    Pulse repetition rate (e.g., 0.5Hz-500Hz for DEN models)Similar (Predicate: 1 Hz—20 kHz; Reference: 50Hz).
    Aiming Beam (650±10 nm, 5mw (max))Substantial Equivalence (Predicate: 650±20 nm, Pmax
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