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510(k) Data Aggregation

    K Number
    K251594
    Device Name
    truFlex
    Date Cleared
    2025-08-28

    (93 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Rajasthan 342012
    India

    Re: K251594
    Trade/Device Name: truFlex
    Regulation Number: 21 CFR 890.5850
    Name | Stimulator, Muscle, Powered, For Muscle Conditioning |
    | Classification Regulation | 21 CFR 890.5850
    Limited) | Mettler / Lutronic Corporation | BTL Industries, Inc. | NA |
    | Regulation Number | 21 CFR 890.5850
    | 21 CFR 890.5850 | 21 CFR 890.5850 | 21 CFR 890.5850 | Subject device is identical to all Predicate

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

    truFlex is indicated to be used for:

    • Improvement of abdominal tone, for strengthening of the abdominal muscles, for development of firmer abdomen.
    • Strengthening, toning and firming of arms, buttocks, thighs, and calves
    • Relaxation of muscle spasms
    • Prevention or retardation of disuse atrophy
    • Increasing local blood circulation
    • Muscle re-education
    • Maintaining or increasing range of motion
    • Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
    • Stimulation of neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes
    • To be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions
    Device Description

    truFlex is an electrical muscle stimulator, which generates electrical impulses that are delivered through electrodes on the skin in direct proximity to the muscles to be stimulated. The device contracts muscles rhythmically to achieve the intended use.

    truFlex consists of a console with a touchscreen control panel and eight handpiece pairs. All system functions are controlled through the console. During a treatment session, one or more handpiece pairs are secured to the patient using disposable hydrogel pads and transparent silicone belts, and electrical stimulation is delivered to the treatment area at the selected treatment mode and intensity.

    The fundamental scientific technology has not changed in the modified device. Changes are solely considered for addition of indication for use. The modified device generates the same stimulation to contract the muscles rhythmically to achieve the intended use.

    The clinician can increase or decrease the intensity as per the desired stimulation. While modified device, complete care and considerable measures have been taken to retain its safety and effectiveness. The truFlex device complies with voluntary standards.

    The modified device, as described in this submission, have only addition of the indication for use and name the device

    The device has two treatment types:

    • Classic - In Classic mode, the treatment duration is 45 minutes.
    • flex+ - In flex+ mode, the treatment duration is 15 minutes.

    For ease of use and operation for the clinicians, we have 3 modes (suggestive):

    • PREP mode creates a twisting motion to warm up and stretch the muscles and to slowly build a tolerance to muscle contractions. PREP mode is available for Classic treatments only.
    • TONE mode contracts the muscles, holds it, and then relaxes to increase strength and muscle endurance. TONE mode is available for Classic and flex+ treatments.
    • SCULPT mode uses fast, sequential contractions of the muscles which lead to toning and firming. SCULPT mode is available for Classic and flex+ treatments
    AI/ML Overview

    Based on the provided FDA 510(k) Clearance Letter for the truFlex Muscle Stimulator, it's important to clarify that this document primarily focuses on demonstrating substantial equivalence to predicate devices rather than proving specific clinical efficacy or performance through a traditional clinical study with defined acceptance criteria for de novo AI/ML devices.

    The truFlex device is a Powered Muscle Stimulator, classified as Class II, and uses electrical muscle stimulation (EMS). Its clearance is based on the premise that its safety and effectiveness are "demonstrated by performance data and a comparison of technical characteristics between the modified device and the predicate device," as stated on Page 4 and Page 9. This means the acceptance criteria are largely met by showing the device performs similarly to or within the established safety and performance parameters of already cleared, similar devices (predicates).

    Therefore, the requested information points (1-9) about acceptance criteria, test sets, expert ground truth, MRMC studies, etc., typically apply to the rigorous clinical validation studies for novel medical devices, especially AI-driven ones where performance metrics like sensitivity, specificity, or AUC are critical. For a 510(k) based on substantial equivalence to predicate muscle stimulators, the "study" is often a combination of non-clinical bench testing, electrical safety testing, electromagnetic compatibility (EMC) testing, and comparison of technical specifications to demonstrate that the new device is as safe and effective as the predicate.

    Given this context, I will address your points as best as possible based on the provided document, acknowledging where the information is not directly applicable or explicitly stated as it would be for a typical AI/ML clinical validation study.


    Acceptance Criteria and Study for truFlex Muscle Stimulator

    The acceptance criteria for the truFlex Muscle Stimulator, as described in this 510(k) submission, are primarily centered around demonstrating substantial equivalence to existing legally marketed predicate devices. This is achieved by showing that the truFlex device has the same intended use, similar technological characteristics, and meets recognized safety and performance standards as its predicates, without raising new questions of safety or effectiveness.

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

    Since this is a substantial equivalence submission for a traditional medical device (not an AI/ML diagnostic/therapeutic device), the "acceptance criteria" are generally that the device performs within the established safety and effectiveness profiles of the predicates. The "reported device performance" is demonstrated through compliance with voluntary standards and direct comparison of specifications.

    Acceptance Criterion (Implicit for Substantial Equivalence)Reported Device Performance (Summary from Submission)Reference Pages
    Safety: Compliance with recognized electrical safety standards (e.g., patient leakage, isolation).Measured Patient Leakage:
    • Normal Condition: Less than 100µA (Predicate 1,2:
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    K Number
    K251706
    Date Cleared
    2025-07-30

    (57 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    China

    Re: K251706
    Trade/Device Name: TENS and EMS Unit
    Regulation Number: 21 CFR 890.5850

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

    The device of this submission is designed to temporarily relieve muscle soreness and pain in the shoulder, waist, back, neck, upper extremities (arm), lower extremities (leg), abdomen and bottom caused by exercise or normal household activities. Also used to stimulate healthy muscles to improve muscle performance.

    Device Description

    Not Found

    AI/ML Overview

    The provided text is an FDA clearance letter for a medical device: "TENS and EMS Unit." This letter indicates that the device has been found substantially equivalent to a legally marketed predicate device.

    Crucially, this document does NOT contain information about acceptance criteria or a study proving the device meets those criteria, as typically found in a clinical study report or a 510(k) summary.

    The letter is a regulatory document stating market clearance and does not detail the technical performance or supporting studies for the device. Instead, it refers to the device's "Indications for Use" and mentions regulatory compliance.

    Therefore, I cannot provide the requested information from the given text.

    To answer your questions, I would need access to the 510(k) summary or the full 510(k) submission for K251706, which would typically contain the performance data and details of any studies conducted.

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    K Number
    K251378
    Device Name
    CoolTone
    Date Cleared
    2025-07-14

    (73 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Stow, Massachusetts 01775

    Re: K251378
    Trade/Device Name: CoolTone
    Regulation Number: 21 CFR 890.5850
    Stimulator, Muscle, Powered, For Muscle Conditioning

    DEVICE CLASSIFICATION: Class II, 21 CFR §890.5850
    MedizinSyteme GmbH CoolTone (K220601) |
    |---|---|---|
    | Product Code and Regulation | Physical Medicine 21 CFR 890.5850
    NGX – Stimulator Muscle, Powered, Muscle Conditioning | Physical Medicine 21 CFR 890.5850 NGX – Stimulator

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

    CoolTone is indicated to be used for:

    • Improvement of abdominal tone, strengthening of the abdominal muscles, development for firmer abdomen.
    • Strengthening, Toning and Firming of buttocks and thighs.
    Device Description

    The CoolTone is a non-invasive therapeutic device. The device produces an electromagnetic field that interacts with the tissues of the human body. By muscle stimulation, the CoolTone helps to strengthen, tone and firm abdomen, buttocks and thighs.

    The device housing protects the patient from electrical shock and mechanical injuries. The device is a mobile standalone equipment with four wheels.

    Two large applicators are connected to the control unit and can be used simultaneously depending on the treatment. The device is a medical equipment that generates a magnetic field by applying a strong current to an applicator. The CoolTone is equipped with the securement system which is designed to maintain applicator position throughout treatment.

    A large color touch screen facilitates the use of the device. The on-screen information guides the user step-by-step through the entire treatment process. The treatment is operated through parameters such as frequency, time and intensity. Three pre-set treatment options are available for users to choose from: Abdomen, buttocks and thighs.

    AI/ML Overview

    The provided FDA 510(k) clearance letter pertains to the CoolTone device (K251378). It states that this device is substantially equivalent to a previously cleared CoolTone device (K220601).

    Crucially, the document explicitly states: "No clinical testing was required for this change." This means that for the K251378 submission, no new studies were performed to prove the device meets acceptance criteria. Instead, the clearance relies on its substantial equivalence to the predicate device, which presumably had clinical data supporting its initial clearance.

    Therefore, many of the requested information points regarding acceptance criteria and study details cannot be directly extracted from this specific 510(k) clearance letter. The information below reflects what can be inferred or directly cited from the provided text about K251378, with an acknowledgement that the core "proof" resides within the documentation for the predicate device (K220601).


    1. Table of Acceptance Criteria and Reported Device Performance

    As stated, no new clinical study was conducted for this specific 510(k) submission (K251378). Therefore, there are no new acceptance criteria or reported device performance for this updated device. The clearance is based on the identical technological characteristics and indications for use to the predicate device (K220601). The "acceptance criteria" for K251378 are implicitly met by demonstrating substantial equivalence to the predicate device, meaning it performs as safely and effectively for the stated indications.

    Acceptance Criteria (Inferred from Predicate Device's Clearance)Reported Device Performance (Inherited from Predicate)
    Improvement of abdominal toneExpected to provide improved abdominal tone
    Strengthening of abdominal musclesExpected to provide strengthened abdominal muscles
    Development of firmer abdomenExpected to provide a firmer abdomen
    Strengthening of buttocks and thighsExpected to provide strengthened buttocks and thighs
    Toning of buttocks and thighsExpected to provide toned buttocks and thighs
    Firming of buttocks and thighsExpected to provide firmer buttocks and thighs

    2. Sample size used for the test set and the data provenance

    Not applicable for K251378 as no new clinical testing was performed for this submission. The substantial equivalence argument relies on prior data for the predicate device (K220601).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable for K251378 as no new clinical testing was performed for this submission.

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

    Not applicable for K251378 as no new clinical testing was performed for this submission.

    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 for K251378. The CoolTone device is a powered muscle stimulator, not an AI-assisted diagnostic or imaging device that would typically involve human readers or MRMC studies.

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

    Not applicable for K251378. The CoolTone is a physical device for muscle stimulation.

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

    Not applicable for K251378 as no new clinical testing was performed. For the predicate device (K220601), clinical trials would likely have used objective measurements (e.g., imaging to assess muscle thickness, physical measurements for circumference changes, or patient/physician reported outcomes on tone/firmness) to establish the ground truth for muscle strengthening, toning, and firming.

    8. The sample size for the training set

    Not applicable for K251378 as no new clinical testing or algorithm training was performed for this submission.

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

    Not applicable for K251378 as no new clinical testing or algorithm training was performed for this submission.

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    K Number
    K251746
    Device Name
    Pure Impact
    Date Cleared
    2025-07-02

    (26 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Pennsylvania 19103

    Re: K251746
    Trade/Device Name: Pure Impact
    Regulation Number: 21 CFR 890.5850
    Name):
    Pure Impact

    Common Name:

    Electrical Muscle Stimulator

    Classification Name:

    21 CFR 890.5850
    muscle stimulator | Same |
    | Product Code | NGX | NGX | Same |
    | Regulation Number | 21 CFR 890.5850
    | 21 CFR 890.5850 | Same |
    | Panel | Physical Medicine | Physical Medicine | Same |
    | Class

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

    Pure Impact is indicated to be used for:

    • Improvement of abdominal tone, for strengthening of the abdominal muscles, for development of firmer abdomen.
    • Improvement of muscle tone and firmness, for strengthening muscles in arms, thighs and buttocks areas.
    • The Pure Impact is intended to stimulate healthy muscles in order to improve or facilitate muscle performance. The Pure Impact is not intended to be used in conjunction with therapy or treatment of medical diseases or medical conditions of any kind. The various types of muscle work that the Pure Impact can impose on the stimulated muscles are able to improve or facilitate muscle performance. The Pure Impact may therefore be considered a technique of muscle training.
    Device Description

    Pure Impact device provides both training and physical therapy using Electrical Muscle Stimulation (EMS). The EMS is provided through electrodes that are controlled by the Touch Control Module.

    The system includes:

    • Touch Control Module
    • Pure Impact™ Wireless Stimulation Modules
    • Pure Impact™ Electrode Pads
    • Pure Impact™ Charging Station

    The Touch Control Module runs the Pure Impact™ program and displays the user interface, which provides the full range of controls to identify the patient and the required treatment. The Pure Impact™ Wireless Stimulation Modules provide EMS to selected body locations on the patient and communicate to the Touch Control Module through Bluetooth Low Energy (BLE). Each Stimulation Module contains a main stimulation unit and several stimulation subunits, each of which is attached to a Pure Impact™ Electrode Pad placed on the patient. The Pure Impact™ Electrode Pads are disposable and intended for single patient, single use only. They contain a hydrogel adhesive to attach to the selected body locations on the patient and magnetic connectors to attach to the Stimulation Modules. The Pure Impact™ Charging Station charges the Stimulation Modules.

    AI/ML Overview

    This FDA 510(k) clearance letter pertains to the Pure Impact device, a powered muscle stimulator. The clearance is based on demonstrating substantial equivalence to a predicate device, the Pure Impact Module of the SofWave System (K250146).

    The document states that the Pure Impact device is a modification of the predicate, with the only changes being related to the standalone PC, GUI, and software updates. It explicitly states that no changes were made to the Pure Impact Charging Station Unit, Pure Impact Wireless Stimulation Modules, or Pure Impact Electrode Pads. Furthermore, the change does not affect the treatment protocols, stimulation parameters, or energy delivery.

    Therefore, the performance data and acceptance criteria for electrical muscle stimulators (EMS) typically revolve around safety and technical specifications, rather than clinical efficacy or diagnostic accuracy, which would involve more complex studies like MRMC or ground truth assessment from expert consensus or pathology. This is because EMS devices, particularly those for muscle conditioning, are often cleared based on demonstrating that their technical characteristics (e.g., waveform, output, safety features) are equivalent to a legally marketed predicate device, and that these characteristics do not raise new questions of safety or effectiveness.

    Given the information provided, which heavily emphasizes direct technical comparison and safety testing (electrical safety, EMC, software V&V), the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are primarily framed around these technical and safety aspects, and the device's functional equivalence to its predicate. There is no mention of a clinical study assessing improvement in muscle tone or firmness with quantified metrics from human subjects, or any study involving human readers/experts for performance evaluation, as would be common for diagnostic AI/ML devices.

    Here's a breakdown of the requested information based solely on the provided FDA 510(k) clearance letter:


    1. Table of Acceptance Criteria and Reported Device Performance

    For this device, the "acceptance criteria" are predominantly framed as mirroring the technical specifications and safety standards met by the predicate device, and ensuring the modified device continues to meet these.

    CriterionAcceptance Criteria (Predicate's Specifications)Reported Device Performance (Subject Device)Conclusion
    Regulation Number21 CFR 890.585021 CFR 890.5850Meets (Same)
    Classification NamePowered Muscle StimulatorPowered Muscle StimulatorMeets (Same)
    Product CodeNGXNGXMeets (Same)
    PanelPhysical MedicinePhysical MedicineMeets (Same)
    ClassClass IIClass IIMeets (Same)
    Indications for UseIdentical to predicateIdentical to predicateMeets (Same)
    Power SourceConsole: 100-240AC, 50/60Hz; Battery: 3.7V, 600mAConsole: 100-240AC, 50/60Hz; Battery: 3.7V, 600mAMeets (Same)
    Patient Leakage Current (Normal)
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    K Number
    K250759
    Device Name
    3 in 1 TENS UNIT
    Date Cleared
    2025-06-13

    (92 days)

    Product Code
    Regulation Number
    N/A
    Reference & Predicate Devices
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Jersey 07436

    Re: K250759
    Trade/Device Name: 3 in 1 TENS UNIT
    Regulation Number: 21 CFR 890.5850
    Jersey 07436

    Re: K250759
    Trade/Device Name: 3 in 1 TENS UNIT
    Regulation Number: 21 CFR 890.5850

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

    1) TENS
    The device is designed to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, neck, upper extremities (arm), lower extremities (leg), abdomen and bottom due to strain from exercise or normal household work activities.

    2) EMS
    The device is designed to be used to stimulate healthy muscles in order to improve and facilitate muscle performance.

    Device Description

    Not Found

    AI/ML Overview

    The provided FDA 510(k) Clearance Letter for the "3 in 1 TENS UNIT" (K250759) does not contain any information about acceptance criteria or a study that proves the device meets specific performance criteria related to AI/algorithm-based medical devices.

    This document is a standard FDA clearance letter for a Class II medical device (Powered Muscle Stimulator, TENS/EMS unit). It confirms that the device is substantially equivalent to legally marketed predicate devices and is subject to general controls and other regulations like the Quality System (QS) regulation.

    Specifically, the letter does not mention:

    • Any AI or algorithmic components of the device.
    • Specific performance metrics (e.g., sensitivity, specificity, AUC) that would require a clinical study with acceptance criteria.
    • Test sets, training sets, ground truth establishment, expert readers, or MRMC studies.

    Therefore, I cannot fulfill your request to describe the acceptance criteria and the study proving the device meets them based solely on the provided text. The information required for your request (1-9) is typical for AI/ML-based medical devices that require performance validation, which is not described in this standard 510(k) clearance letter for a TENS/EMS unit.

    This device, being a "Powered Muscle Stimulator" (TENS/EMS unit), typically undergoes electrical safety, electromagnetic compatibility (EMC), and performance testing related to its electrical output, waveform, and ability to deliver stimulation as intended, rather than AI-driven diagnostic or treatment algorithms.

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    K Number
    K242704
    Date Cleared
    2025-06-05

    (269 days)

    Product Code
    Regulation Number
    882.5810
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Classification Regulation(s) | 21 CFR 882.5810 | 21 CFR 882.5810 | 21 CFR 890.5850 | Same.

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

    The Synchrony (20-3000) is an electrical stimulation device indicated for the following uses:

    Functional Electrical Stimulation (FES).

    • Improvement of hand function and active range of motion in patients with hemiplegia due to stroke or upper limb paralysis due to C5 spinal cord injury.

    NeuroMuscular Electrical Stimulation (NMES).

    • Maintenance and/or increase of hand range of motion.
    • Prevention and/or retardation of disuse atrophy.
    • Increase in local blood circulation.
    • Reduction of muscle spasm.
    • Re-education of muscles.
    Device Description

    The Synchrony (20-3000) system is a functional electrical stimulation (FES) device and a powered muscle stimulator. It is specifically designed to enhance hand functionality in patients with arm paresis through a range of customizable therapies. The system integrates five major components: the Stimulator, Sensor, Patient Interface (electrodes), Motor Point Probe, and Clinician App. The therapies are directed and programmed by a clinician through an iOS based application and then the patient may apply the therapy at their home with the Stimulator and Sensor.

    The Synchrony system supports three primary therapeutic modes: Contralaterally Controlled Electrical Stimulation (CCFES), cyclical Neuromuscular Electrical Stimulation (CNMES), and Functional Task Practice (FTP). The CCFES mode uses sensor data from the patient's unimpaired side to control the timing, intensity, and movement of the paretic hand/arm, synchronizing stimulation with natural motor patterns. The cyclical NMES mode delivers repetitive stimulation to targeted muscles, aiding in muscle re-training, as described in the systematic review of research studies using cyclic NMES. The FTP mode allows for direct control of hand movements during task-oriented exercises, using real-time sensor feedback and stimulator output.

    Stimulation is delivered through up to four electrodes placed on identified motor points, using symmetric balanced biphasic pulses. The system offers preset stimulation amplitudes of 20mA, 40mA, and 60mA, with a pulse width adjustable between 1-250 µsec, providing high precision with 1 µsec resolution. The device's enclosure is constructed from biocompatible ABS Cycoloy, ensuring durability and patient safety, and is rated IP22 for ingress protection.

    The stimulator can operate independently or in conjunction with the Synchrony Sensor, depending on the therapy mode selected. The Sensor, which communicates wirelessly with the Stimulator via Bluetooth Low Energy (BLE), uses a Class I laser that is compliant with 21 CFR 1040.10 and 21 CFR 1040.11 to measure hand opening and closure distances, enabling accurate therapeutic adjustments. Both the Stimulator and Sensor are wirelessly charged using an FCC Part 15 compliant charging pad, enhancing ease of use and handling.

    The Synchrony system is engineered for ease of use with user-friendly control interfaces for both patients and clinicians. It incorporates a range of safety mechanisms to ensure effective and safe operation, making it a versatile and reliable tool for improving hand functionality through personalized therapeutic interventions.

    AI/ML Overview

    The provided FDA 510(k) clearance letter for the Synchrony (20-3000) device does not contain information about acceptance criteria or a specific study proving the device meets those criteria.

    The letter primarily focuses on establishing substantial equivalence to predicate devices, referencing adherence to recognized standards, and outlining performance differences between the new device and the predicates without providing specific acceptance criteria or study details.

    However, based on the information provided, we can infer some details and highlight the missing information:

    Key Takeaways from the document relevant to performance and safety:

    • Substantial Equivalence: The primary method for demonstrating safety and effectiveness is through substantial equivalence to predicate devices (K123636 and K960457).
    • Standards Compliance: The device claims compliance with numerous IEC, ISO, ASTM, and ANSI standards related to safety, essential performance, usability, electromagnetic compatibility, software lifecycle, risk management, biological evaluation, laser safety, battery testing, shipping, cleaning processes, wireless coexistence, and cybersecurity. These standards inherently contain their own acceptance criteria that the device must meet.
    • Performance Differences: The comparison tables highlight differences in technical characteristics and output specifications. The rationale for these differences consistently asserts "No impact on safety and effectiveness."
    • Clinical Data: The document explicitly states: "No clinical data were reviewed in this submission in support of the subject device." This is a crucial piece of information indicating that clinical trials were not part of this 510(k) submission for performance validation against specific clinical outcomes or acceptance criteria.

    Inferred and Missing Information:

    Since dedicated acceptance criteria and a study proving the device meets them are not explicitly detailed in the provided text, the table below will reflect what is implied by the substantial equivalence and standards compliance, and explicitly state where information is missing.

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

    Acceptance Criteria (Inferred from Standards & Equivalence)Reported Device Performance
    Safety:
    IEC 60601-1 Basic Safety & Essential Performance CompliantCompliant
    IEC 60601-1-2 Electromagnetic Disturbances CompliantCompliant
    IEC 60601-1-6 Usability CompliantCompliant
    IEC 60601-1-11 Home Healthcare Environment CompliantCompliant
    IEC 60601-2-10 Nerve and Muscle Stimulators CompliantCompliant
    IEC 60825-1 Safety of Laser Products (Class I laser) CompliantCompliant
    ISO 10993-1 Biological Evaluation CompliantCompliant
    ISO 10993-5 Cytotoxicity CompliantCompliant
    ISO 10993-10 Sensitization CompliantCompliant
    ISO 10993-23 Irritation CompliantCompliant
    Patient Leakage Current below 100 microamperes (normal) & 500 microamperes (single fault)Within acceptable limits (Implied by "No impact on Safety and Effectiveness" and compliance with IEC 60601-1)
    Max Current Density 2x2" electrodes: 0.34 mA/cm²2x4" electrodes: 0.17 mA/cm²MPP: 1.33 mA/cm² (All comply with
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    K Number
    K241433
    Manufacturer
    Date Cleared
    2025-06-04

    (379 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Korea, South

    Re: K241433
    Trade/Device Name: EVE Synergy (EVE-20M)
    Regulation Number: 21 CFR 890.5850
    Range** | 0-60 [minutes] | 0-60 [minutes] | 0-60 [minutes] | Identical |
    | **Compliance with 21 CFR 890.5850

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

    EMS is used for:

    • Relaxation of muscle spasms
    • Prevention or retardation of disuse atrophy
    • Increasing local blood circulation
    • Muscle re-education
    • Maintaining or increasing range of motion
    • Immediate postsurgical stimulation of calf muscles to prevent venous thrombosis

    TENS is used for:

    • Symptomatic relief and management of chronic, intractable pain
    • Post-surgical acute pain
    • Post-trauma acute pain
    Device Description

    EVE Synergy has Synergy handpiece (1EA), Pro handpiece (2EA), Micro cable, Tip (Ball type, T type, COMB type) and Power adaptor & cable.

    EVE Synergy has Synergy mode and Pro mode.

    Synergy mode has radio frequency and low frequency functions using a synergy handpiece. The Synergy handpiece has a temperature sensor, so the output is automatically turned off when the skin surface temperature exceeds 43℃.

    Pro mode has low frequency function that uses the Pro handpiece with tip.

    It should be noted that the device has radio frequency (RF Mode) indicated for relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation. This RF mode was previously reviewed by the FDA under K212253 and was cleared under regulation 21 CFR 878.4400 (Product code PBX). In the subject submission, there are no changes being proposed related to the RF Mode, and, hence, the review of the RF Mode is not within the scope of the subject 510(k) submission.

    AI/ML Overview

    The provided text is a 510(k) clearance letter and an accompanying 510(k) summary for the EVE Synergy (EVE-20M) device. This document focuses on demonstrating substantial equivalence to previously cleared predicate devices, rather than proving the device meets specific acceptance criteria through a comparative effectiveness study involving AI assistance or human-in-the-loop performance.

    Therefore, many of the requested details regarding acceptance criteria for AI performance, specific study designs (MRMC, standalone), ground truth establishment for AI training/test sets, and sample sizes for these, are not present in this type of regulatory submission. This document primarily describes the physical and electrical characteristics of the device and compares them to predicate devices, along with standard electrical safety, EMC, and software validation testing.

    Here's a breakdown of the requested information based on the provided text, highlighting what is present and what is not:


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

    The document does not present "acceptance criteria" in the traditional sense of a specific performance metric (like accuracy, sensitivity, specificity) for a clinical outcome or an AI model's performance. Instead, it demonstrates compliance with safety and performance standards and similarity to predicate devices.

    The "acceptance criteria" are implicitly met by showing:

    • Compliance with various IEC standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, IEC 62304) for electrical safety, EMC, and software.
    • The device's technical specifications (e.g., output voltage, current, pulse width, frequency, power density) are comparable to or within the safe limits established by the predicate devices.

    Table of Performance (extracted from comparison tables):

    CharacteristicAcceptance Criteria (Implied by Predicate & Standards)EVE Synergy (EVE-20M) Reported Performance
    General ComplianceCompliance with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, ISO 14971, IEC 60601-1-6, IEC 62304Passed all testing in accordance with internal requirements, national standards, and international standards.
    Device ConfigurationSimilar design, components, and method of current isolation to predicates.Consists of AC/DC power supply, controller, LCD touch screen; Supports Synergy and Pro handpieces; Independent transformer isolation; Type BF Electrical Type.
    Electrical SafetyPatient Leakage Current – Normal Condition:
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    K Number
    K242926
    Manufacturer
    Date Cleared
    2025-05-30

    (248 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    05738

    Re: K242926
    Trade/Device Name: XBody Go USA, XBody Pro USA
    Regulation Number: 21 CFR 890.5850
    Muscle Conditioning
    Regulation Name: Powered Muscle Stimulator
    Regulation Number: 21 CFR 890.5850
    Medicine | Physical Medicine | Same |
    | Regulated voltage | Yes | Yes | Same |
    | Regulation Name | 21 CFR 890.5850
    | 21 CFR 890.5850 | Same |
    | Type of use | Prescription Use | Prescription Use | Same |
    | Indications

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

    The XBODY Go USA and XBODY Pro USA are machines with electronic muscle stimulation based on EMS technology. The devices are specifically designed as an addition to other sports and for training muscles. They must be used only for healthy muscles and clients, not for rehabilitation purposes.

    Both models are intended to stimulate healthy muscles in order to improve or facilitate muscle performance. Neither model is intended to be used in conjunction with therapy or treatment of medical diseases or medical conditions of any kind. None of the XBODY Go USA or XBODY Pro USA training programs are designed for injured or ailing muscles and its use on such muscles is contraindicated.

    For both models, electrical impulses allow the triggering of action potentials on motoneurons of motor nerves (excitations). These excitations of motoneurons are transmitted to the muscle fibers via the motor endplate where they generate mechanical muscle fiber responses that correspond to muscle work. Depending on the parameters of the electrical impulses (pulse frequency, duration of contraction, duration of rest, total session duration), different types of muscle work can be imposed on the stimulated muscles.

    The various types of muscle work that the XBODY Go USA and XBODY Pro USA can impose on the stimulated muscles are able to improve or facilitate muscle performance. Both models may therefore be considered a technique of muscle training.

    Device Description

    The XBody Go USA and the XBody Pro USA generate electronic muscle stimulation based on electrical muscle stimulation (EMS) technology. The devices are designed as additions to other sports and for training muscles. They are not intended to be used in conjunction with therapy or treatment of medical diseases or medical conditions of any kind. They are intended for use only by persons with healthy muscles, not for rehabilitation purposes.

    AI/ML Overview

    Based on the provided FDA 510(k) Clearance Letter and Submission Summary, here's a description of the acceptance criteria and the study that proves the device meets them:

    Important Note: The provided document is a 510(k) submission summary, primarily focused on establishing substantial equivalence to a predicate device. It details the similarities and minor differences between the new device and the predicate. For devices like the XBody Go USA and XBody Pro USA, which are "Powered Muscle Stimulators," the primary "performance" and "acceptance criteria" revolve around demonstrating equivalence in electrical safety, electromagnetic compatibility, and fundamental stimulation characteristics, rather than a clinical study measuring a specific physiological outcome (like muscle strength improvement). The document explicitly states, "Any differences that exist between the subject and predicate devices do not affect safety or performance." This implies that the acceptance criteria are largely met by demonstrating adherence to recognized safety and performance standards and showing that any changes do not negatively impact these.

    Therefore, the "proof" described is not a typical clinical trial demonstrating superiority or non-inferiority in effectiveness, but rather a demonstration of continued safety and equivalent performance to a device already deemed safe and effective.


    Acceptance Criteria and Device Performance Study

    The acceptance criteria for the XBody Go USA and XBody Pro USA, as implied by the 510(k) submission, are primarily centered around demonstrating essential safety and equivalent performance to their predicate devices, particularly regarding electrical muscle stimulation parameters and the introduction of new accessories (the XBody DrySuit and DryWear). Since this is a 510(k) for a powered muscle stimulator, the "performance" proved is not a clinical outcome like muscle strength gain, but rather the device's ability to safely and effectively deliver electrical impulses as intended, consistent with the predicate.

    1. Table of Acceptance Criteria and Reported Device Performance

    Given the nature of this 510(k) (substantial equivalence for a powered muscle stimulator), the "acceptance criteria" are predominantly related to compliance with recognized standards and maintaining equivalent technical specifications and safety profiles. The "device performance" is therefore demonstrated by meeting these standards and showing that the subject device's operation is not adversely affected by the minor changes.

    Acceptance Criteria (Implied)Reported Device Performance (as demonstrated)
    Electrical Safety (IEC 60601-1, 60601-2-10)Validated through independent testing. Product meets max output voltage, current, phase charge, current density, power density, net charge, waveform shape specifications, and incorporates safety circuits (overload, no-load trip, battery monitoring, watchdog).
    Electromagnetic Compatibility (IEC 60601-1-2)Validated through independent testing. Device is compliant.
    Usability (IEC 60601-1-6, IEC 62366-1)User interface is described as "large and easily controllable" with clear stimulation parameters and channel identification. Operator training and certification are required. Updated control units maintain ease of use.
    Software Life Cycle (IEC 62304)Software differences are minor, aiming to enhance user interface without impacting safety/effectiveness. Compliance with IEC 62304 is stated.
    Biocompatibility (ISO 10993-1, -5, -10)Cotton underwear is "biocompatibility certified." New DryWear and DrySuit materials are implied to be compliant through risk management and biocompatibility standards.
    Maintaining Intended Use & Indications for UseDevices have "same in indication for use, intended use performance, design, dimensions, and materials as the predicate devices." The new DrySuit is stated to have "acceptable similarity in intended use."
    Equivalent Output SpecificationsOutput voltage, current, phase charge, current density, power density, net charge, waveform, burst mode parameters, output frequency, and pulse widths are all "Same" as the predicate.
    Equivalent Portability/Environment of Use"Portable with ease," "indoors," "home healthcare environment." Same as predicate.
    Safe Use of New Accessories (DrySuit/DryWear)Performance testing of the XBody DrySuit demonstrated "acceptable similarity in intended use." Instructions for use (e.g., wearing undergarments) ensure safe conductivity.

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

    The document does not specify a "sample size" in the context of a data-driven test set for complex performance metrics like accuracy or sensitivity/specificity for an AI/ML device. For this type of device, the "test set" is more conceptual, referring to the various configurations and conditions under which the device's electrical safety, EMC, and fundamental performance characteristics were validated through bench testing.

    • Sample Size: Not applicable in the typical sense for a clinical data set. The validation is based on engineering tests performed on production units or prototypes.
    • Data Provenance: The data comes from "independent testing" of the XBody Actiwear G2 main unit, the control unit, the XBody Training Suit 2.1, the XBody Training Suit 3.0, and the new XBody DrySuit. This implies lab-based testing. The country of origin of the data/testing is not specified, but the manufacturer is XBody Hungary Kft. The testing would be considered prospective in the sense that it's conducted to demonstrate compliance for the submission, rather than retrospective analysis of existing clinical data.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    Not applicable. For a powered muscle stimulator's safety and performance testing, "ground truth" is established by calibrated instruments and adherence to engineering standards (e.g., peak voltage, current, waveform shape, and safety circuit functionality). There is no "expert consensus" on an image or clinical finding that requires adjudication.

    4. Adjudication Method for the Test Set

    Not applicable. There is no human interpretation or subjective assessment of data requiring adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    Not applicable. This is not an AI/ML diagnostic or image-based device that would typically undergo an MRMC study to assess human reader improvement with AI assistance. The device's function is direct electrical muscle stimulation, not assisting in interpretation.

    6. Standalone (Algorithm Only) Performance Study

    Not applicable. This device is a physical electromedical device, not a standalone algorithm. Its performance is intrinsically linked to its hardware and software working together to deliver electrical impulses.

    7. Type of Ground Truth Used

    The "ground truth" is based on:

    • Engineering specifications and standards: Adherence to output parameters (voltage, current, frequency, pulse width) as defined by electrical engineering principles and the device's design.
    • Safety standards: Compliance with IEC 60601 series standards for electrical safety and electromagnetic compatibility.
    • Predicate device characteristics: The predicate device itself effectively serves as a "ground truth" or benchmark for acceptable performance and safety, as the submission aims to demonstrate substantial equivalence.

    8. Sample Size for the Training Set

    Not applicable. This is not an AI/ML device that learns from a "training set" of data in the typical sense of machine learning. The device's behavior is deterministic, based on its programmed logic and hardware design.

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

    Not applicable, as there is no "training set" for this type of device. The ground truth for the device's design and functionality is rooted in established electrical engineering principles, medical device safety standards, and the performance characteristics of the legally marketed predicate device.

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    K Number
    K250038
    Date Cleared
    2025-05-19

    (131 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Re: K250038
    Trade/Device Name: Muscle Stimulator Device (PZ-100)
    Regulation Number: 21 CFR 890.5850
    Conditioning
    Classification: II
    Product Code: NGX

    Page 6

    510(k) Summary

    Regulation Number: 21 CFR 890.5850
    --------------------------|---------|
    | Product Code | NGX | NGX | SAME |
    | Regulation No. | 21 CFR 890.5850
    | 21 CFR 890.5850 | SAME |
    | Classification | II | II | SAME |
    | Regulation Name | Stimulator, Muscle

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

    The Muscle Stimulator Device is indicated to be used for:

    • Improvement of abdominal tone, strengthening of the abdominal muscles, development of firmer abdomen.
    • Strengthening, Toning and Firming of buttocks, thighs and calves.
    • Improvement of muscle tone and firmness, for strengthening muscles in arms.
    Device Description

    The Muscle Stimulator Device (model PZ-100) is a non-invasive therapeutic device. The device produces electromagnetic field that interacts with the tissues of the human body. The device has four outputs, and two applicators perform simultaneous treatment.

    The Muscle Stimulator Device is equipped with a large color touch screen with wide view angle that significantly facilitates the use of the device. The on-screen information guides the user step-by-step through the entire therapy procedure. The therapeutic parameters are easily set using the touch screen of the device. During the therapy the device keeps information about the applied therapy type, remaining therapy time and main therapy parameters on the screen.

    The Muscle Stimulator Device is composed of control display panel module, main control module, temperature module, treatment handle module, and fan cooling module.

    The proposed device can simultaneously apply multiple treatment handles to patients, and the handles are held in place by bandages.

    AI/ML Overview

    This document is a 510(k) clearance letter for the Muscle Stimulator Device (PZ-100). It focuses heavily on demonstrating substantial equivalence to a predicate device through non-clinical testing and comparison of specifications.

    Crucially, there is ABSOLUTELY NO MENTION of acceptance criteria related to a study proving performance, sample sizes, expert involvement, ground truth, or MRMC studies.

    The document explicitly states:

    • "No clinical study is included in this submission." This means there was no study to prove the device met acceptance criteria in a clinical setting with human subjects.
    • The clearance is based on "non clinical tests" to verify that the proposed device met design specifications and was substantially equivalent to the predicate device. These typically involve engineering tests, electrical safety, EMC, and biocompatibility, as listed in the "Non-Clinical Test Conclusion" section.

    Therefore, I cannot provide the requested information regarding acceptance criteria and study details for proving the device meets those criteria because this information is not present in the provided document.

    The document describes regulatory compliance and equivalency based on technical specifications and non-clinical testing, not on a clinical performance study with human subjects, which would typically involve the criteria you asked about (sample size, expert ground truth, MRMC, etc.).

    In summary, based on the provided text, the device was NOT proven to meet acceptance criteria through a clinical performance study. Its clearance is based on demonstrating substantial equivalence to a predicate device through non-clinical testing.

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    K Number
    K243165
    Manufacturer
    Date Cleared
    2025-05-15

    (227 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    |---|---|
    | Common Name | Limfa® System |
    | Regulation Number and Regulation Name | 21 CFR§890.5850
    |
    | Premarket Notification | K151834 |
    | Regulation Number and Classification Name | 21 CFR§890.5850
    Product Code** | NGX | NGX | Equivalent
    The product code is the same |
    | Regulation | 21 CFR 890.5850
    | 21 CFR 890.5850 | Equivalent
    The regulation is the same |

    Page 8

    | | **Subject Device
    LIMFA
    | 21 CFR 890.5850 | Equivalent
    The regulation is the same |
    | Indications for Use | To temporarily

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

    The indications for the Limfa Therapy System are to temporarily increase blood circulation in healthy leg muscles and to stimulate healthy muscles in order to improve and facilitate muscle performance.

    Device Description

    The Limfa® Therapy System is a medical device, intended for stimulation with extremely low frequencies (ELF), pulsed, and low frequency (ELF 3-300 Hz) magnetic fields, which generates pulsed, bipolar and variable electromagnetic fields, at very low and variable intensity and frequency using complex waveforms (sinusoidal, triangular and rectangular), thus obtaining multiple signals within a frequency spectrum composed of base waves from 2 to 80 Hz plus the harmonics that are produced by the hardware component.

    The manufacturer presets base wave frequencies and the harmonics are generated by the DM hardware. The therapy is based on the generation of a pulsed magnetic field with a very low and variable frequency and variable intensity.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary for the Limfa Therapy System (K243165) do not describe a study involving "acceptance criteria and the study that proves the device meets the acceptance criteria" in the context of an AI/ML-driven medical device performance study, which is implied by the detailed questions about sample sizes, expert ground truth, MRMC studies, and training sets.

    Instead, this submission focuses on demonstrating substantial equivalence to predicate devices (Bemer Classic Set, K151834 and K210174) based on:

    • Indications for Use: Identical.
    • Technological Characteristics: Similar primary mode of action (non-invasive tissue stimulation via magnetic field induction), comparable frequency and intensity ranges (ELF PEMF), and compliance with the same safety standards. Differences in waveform shape, pulse duration, and treatment timing are argued to be equivalent without raising new safety or effectiveness concerns.
    • Safety and Performance Testing: Compliance with relevant electrical safety (IEC 60601-1, -1-2, -1-6, -1-11), software (EN 62304, EN 62366), quality/risk management (EN ISO 14971), and labeling standards (EN ISO 15223-1, IEC TR 60601-4-2).

    The document explicitly states:

    • "No animal testing of the subject device was necessary. The performance tests are sufficient."
    • "No clinical testing of the subject device was necessary. The performance tests are sufficient."

    This type of 510(k) submission, common for devices deemed substantially equivalent to existing, cleared devices, generally does not require new de novo clinical studies demonstrating effectiveness, especially if the device operates on the same principles and within similar parameters as its predicates. The "performance tests" mentioned refer to engineering and electrical safety testing, not clinical performance studies with patient outcomes or expert reviews.

    Therefore, I cannot extract the information requested about acceptance criteria, test set details, expert ground truth, MRMC studies, standalone performance, or training set specifics from this document because such studies were not required or performed for this specific 510(k) clearance. The device is cleared based on its substantial equivalence to previously cleared devices through technical comparisons and compliance with relevant safety and performance standards.

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