K241407 · Bios S.R.L. · GEX · Jun 14, 2024 · General, Plastic Surgery
Device Facts
Record ID
K241407
Device Name
Splendor X (Alex, Alex2, Nd:YAG, Alex+Nd:YAG)
Applicant
Bios S.R.L.
Product Code
GEX · General, Plastic Surgery
Decision Date
Jun 14, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic, 3rd-Party Reviewed
Indications for Use
The Nd:YAG 1064 Laser is intended for: - Removal of unwanted hair, for stable long term or permanent hair reduction and for treatment of Pseudofolliculitis barbae (PFB). 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. The lasers are indicated on all skin types, such as Fitzpatrick I-VI, including tanned skin. - Photocoagulation and hemostasis of benign pigmented and vascular lesions such as, but not limited to, port-wine stains, hemangioma, warts, telangiectasia, rosacea, venus lake, leg veins and spider veins. - Coagulation and hemostasis of soft tissue. - Treatment of benign pigmented lesions such as, but not limited to, lentigos (age spots), solar lentigos (sunspots), café au lait macules, seborrheic keratosis, nevi, chloasma, verrucae, skin tags, keratosis, tattoos (significant reduction in the intensity of black and/or blue-black tattoos) and plaques. The laser is indicated for benign pigmented lesion size, for patients with benign lesions that would potentially benefit from aggressive treatment, and for patients with benign lesions that have not responded to other laser treatments. - Reduction of red pigmentation in hypertrophic and keloid scars where vascularity is an integral part of the scar. - Treatment of wrinkles. - Temporary increase of clear nail in patients with onychomycosis (e.g., dermatophytes, Trichophyton rubrum and T. mentagrophytes, and for yeast Candida Albicans, etc.). The Alexandrite 755 laser is intended for: - Temporary hair reduction. - Stable long-term or permanent hair reduction through selective targeting of melanin in hair follicles. 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. On all skin types, such as Fitzpatrick I - VI, including tanned skin. - Treatment of benign pigmented lesions. - Treatment of wrinkles. - Photocoagulation of dermatological benign vascular lesions (such as port-wine stains, hemangiomas, telangiectasias).
Device Story
Splendor X is a solid-state laser system utilizing Alexandrite (755nm) and/or Nd:YAG (1064nm) sources. Device configurations include single or dual-source setups. In BlendX mode, device delivers sequential pulses of both wavelengths without temporal overlap. System includes energy check port for output verification. Used in clinical settings by trained professionals for dermatological procedures. Device transforms electrical energy into laser radiation; output is controlled via user interface. Benefits include permanent hair reduction, lesion treatment, and tissue coagulation. Healthcare providers use output to perform targeted dermatological interventions; clinical decision-making is guided by patient skin type and lesion characteristics.
Clinical Evidence
No clinical data provided. Substantial equivalence supported by bench testing, including biocompatibility (ISO 10993-1), electrical safety (IEC 60601-1, 60601-2-22), EMC (IEC 60601-1-2), laser safety (IEC 60825-1), software verification/validation (IEC 62304), and usability engineering (IEC 62366-1).
Technological Characteristics
Solid-state laser (Alexandrite 755nm, Nd:YAG 1064nm). Class 4 laser. Features include energy check port, square/round spot sizes (2mm-30mm), cooling system, and user interface. Compliant with IEC 60601-1, 60601-1-2, 60601-2-22, 60825-1. Biocompatibility per ISO 10993-1 (surface device, intact skin, limited contact).
Indications for Use
Indicated for patients of all skin types (Fitzpatrick I-VI, including tanned) for hair reduction, treatment of benign pigmented/vascular lesions, soft tissue coagulation/hemostasis, scar pigmentation reduction, wrinkle treatment, and onychomycosis-related clear nail increase.
Regulatory Classification
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.
Predicate Devices
Family of Square Epil (Alex, Alex2, Nd:YAG, Alex+Nd:YAG) (K161632)
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left side of the logo is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
June 14, 2024
Bios S.r.l. % Prithul Bom Most Responsible Person Regulatory Technology Services, LLC 1000 Westgate Drive, Suite 510k Saint Paul, Minnesota 55114
Re: K241407
Trade/Device Name: Splendor X (Alex, Alex2, Nd:YAG, Alex+Nd:YAG) 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: GEX Dated: May 17, 2024 Received: May 17, 2024
Dear Prithul Bom:
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 (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 available at https://www.accessdata.fda.gov/scripts/cdrb/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
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Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn).
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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-devices/deviceadvice-comprehensive-regulatory-assistance/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.
Tanisha L. Digitally signed by Hithe -S - Date: 2024.06.1
Tanisha Hithe Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Submission Number (if known)
K241407
Device Name
Splendor X (Alex, Alex2, Nd:YAG, Alex+Nd:YAG)
ndications for Use (Describe)
The Nd:YAG 1064 Laser is intended for:
- Removal of unwanted hair, for stable long term or permanent hair reduction and for treatment of Pseudofolliculitis barbae (PFB). 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. The lasers are indicated on all skin types, such as Fitzpatrick I-VI, including tanned skin.
- Photocoagulation and hemostasis of benign pigmented and vascular lesions such as, but not limited to, port-wine stains, hemangioma, warts, telangiectasia, rosacea, venus lake, leg veins and spider veins.
- Coagulation and hemostasis of soft tissue.
- Treatment of benign pigmented lesions such as, but not limited to, lentigos (age spots), solar lentigos (sunspots), café au lait macules, seborrheic keratosis, nevi, chloasma, verrucae, skin tags, keratosis, tattoos (significant reduction in the intensity of black and/or blue-black tattoos) and plaques. The laser is indicated for benign pigmented lesion size, for patients with benign lesions that would potentially benefit from aggressive treatment, and for patients with benign lesions that have not responded to other laser treatments.
- Reduction of red pigmentation in hypertrophic and keloid scars where vascularity is an integral part of the scar.
- Treatment of wrinkles.
- Temporary increase of clear nail in patients with onychomycosis (e.g., dermatophytes,
Trichophyton rubrum and T. mentagrophytes, and for yeast Candida Albicans, etc.).
The Alexandrite 755 laser is intended for:
- Temporary hair reduction.
- Stable long-term or permanent hair reduction through selective targeting of melanin in hair follicles. 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. On all skin types, such as Fitzpatrick I - VI, including tanned skin.
- Treatment of benign pigmented lesions.
- Treatment of wrinkles.
- Photocoagulation of dermatological benign vascular lesions (such as port-wine stains,
hemangiomas, telangiectasias).
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
er-The-Counter Use (21 CFR 801 Subpart C)
# CONTINUE ON A SEPARATE PAGE IF NEEDED.
Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.
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Image /page/4/Picture/1 description: The image shows the logo for "bios, A LUMENIS COMPANY". The word "bios" is written in a simple, sans-serif font, with the letters in a dark blue color. Below the word "bios", in a smaller font size, is the text "A LUMENIS COMPANY", also in dark blue. The logo is clean and modern in appearance.
# Electronic Submission Template And Resource (eSTAR)
510kSummary - K241407
Complying with 21 CFR 807.92
# I. Submitter
Bios S.r.l. Via Guido Rossa 10/12 20055 Vimodrone (MI) – Italy
Phone: +39 02 27304275 Mobile: +39 391 7461002 Fax: +39 02 27304276 Email: m.deiturbe@biosgroup.eu
Contact Person: Dr. Martina De Iturbe Date prepared: 11th June 2024
#### ll. Device
| Device Proprietary Name: | Splendor X (Alex, Alex², Nd: YAG, Alex + Nd: YAG) |
|--------------------------|----------------------------------------------------------------------------------------------------------|
| Device Common Name: | Powered laser surgical instrument |
| Classification Name: | Laser surgical instrument for use in general and plastic surgery and<br>in dermatology (21 CFR 878.4810) |
| Regulatory Class: | II |
| Product Code: | GEX |
#### III. Predicate/Reference Device
The substantial equivalence is based on the following Predicate Device:
| Trade Name | Product Code and<br>classification regulation | Manufacturer | 510(k) Number |
|-------------------------------------------------------------|-----------------------------------------------|--------------|---------------|
| Family of Square Epil (Alex, Alex2,<br>Nd:YAG, Alex+Nd:YAG) | GEX<br>21 CFR 878.4810 | Bios S.r.l. | K161632 |
The Predicate device has been evaluated by the manufacturer as adequate for the equivalence comparison purposes and it has been detected using the best practices for selecting the predicate device. The predicate device has been firstly identified on the basis of the same intended use and the regulatory framework and basic administrative information (classification, medical device class, product code, and applicable federal regulation etc..) that are the same as the subject device. Secondary, a predicate device identifying well-established safety and performance testing has been preferred to others with lower information availability. The predicate device is currently marketed in
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Image /page/5/Picture/1 description: The image shows the logo for "bios, A LUMENIS COMPANY". The word "bios" is written in a lowercase, sans-serif font with rounded edges, and the letters are connected. The color of the word is a dark blue. Below the word "bios" is the text "A LUMENIS COMPANY" in a smaller, sans-serif font, also in dark blue.
the US and all the documentation is available to support the equivalence since Bios is the manufacturer of the predicate device as well.
In the end, a predicate device with a negligible rate of serious malfunctions/serious injuries/deaths, without unmitigated safety issues and no recalls has been chosen.
Furthermore, the following Reference Device has been identified to support the difference in the technological characteristics between the subject device and the selected predicate device.
| Trade Name | Product Code and<br>classification regulation | Manufacturer | 510(k) Number |
|--------------------|-----------------------------------------------|------------------------|---------------|
| GentleMax Pro Plus | GEX<br>21 CFR 878.4810 | Candela<br>Corporation | K201111 |
# IV. Device Description
The Splendor X (Alex, Alex , Nd:YAG, Alex + Nd: YAG), hereinafter referred to as "Splendor X", is a laser equipped with one or two solid-state laser sources.
The 4 configurations differ for the internal crystals of the sources, that can be Alexandrite and/or Nd:YAG. The emitted laser radiation has a wavelength of 755nm, respectively, and 1064nm:
- Alex configuration has only one source and one wavelength available (755 nm).
- . Alex configuration has two sources of the same wavelength (755 nm), in order to increase the maximum power available.
- Nd:YAG configuration has only one source and one wavelength available (1064 nm).
- . In the Alex+Nd:YAG configuration has both the two wavelengths available (755 nm and 1064 nm). In this configuration the two wavelengths can act only individually, simultaneous operations are not allowed. This configuration works with three different modes: only with Alex source, only with Nd:YAG source or in the BlendX mode. With the BlendX mode, an initial pulse with Alexandrite source is followed automatically, without overlapping in time, by another pulse of the Nd:YAG source.
This device is intended for medical use only.
# V. Indications for Use
The Nd:YAG 1064 Laser is intended for:
- । Removal of unwanted hair, for stable long term or permanent hair reduction and for treatment of Pseudofolliculitis barbae (PFB). 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. The lasers are indicated on all skin types, such as Fitzpatrick I-VI, including tanned skin.
- -Photocoagulation and hemostasis of benign pigmented and vascular lesions such as, but not limited to, port-wine stains, hemangioma, warts, telangiectasia, rosacea, venus lake, leg veins and spider veins.
- -Coagulation and hemostasis of soft tissue.
- -Treatment of benign pigmented lesions such as, but not limited to, lentigos (age spots), solar lentigos (sun spots), cafè au lait macules, seborrheic keratosis, nevi, chloasma, verrucae, skin tags,
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Image /page/6/Picture/1 description: The image shows the logo for "bios A LUMENIS COMPANY". The word "bios" is written in a sans-serif font, with the letters in lowercase and connected. Below the word "bios" is the text "A LUMENIS COMPANY" in a smaller, sans-serif font. The logo is simple and modern, with a clean design.
keratosis, tattoos (significant reduction in the intensity of black and/or blue-black tattoos) and plaques.
The laser is indicated for benign pigmented lesions to reduce lesion size, for patients with benign lesions that would potentially benefit from aggressive treatment, and for patients with benign lesions that have not responded to other laser treatments.
- -Reduction of red pigmentation in hypertrophic and keloid scars where vascularity is an integral part of the scar.
- -Treatment of wrinkles.
- -Temporary increase of clear nail in patients with onychomycosis (e.g., dermatophytes, Trichophyton rubrum and T. mentagrophytes, and for yeast Candida Albicans, etc.).
The Alexandrite 755 laser is intended for:
- -Temporary hair reduction.
- -Stable long-term or permanent hair reduction through selective targeting of melanin in hair follicles. 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. On all skin types, such as Fitzpatrick I – VI, including tanned skin.
- -Treatment of benign pigmented lesions.
- Treatment of wrinkles. -
- -Photocoagulation of dermatological benign vascular lesions (such as port-wine stains, hemangiomas, telangiectasias).
#### Comparison of technological characteristics with the predicate and reference devices VI.
The Splendor X device and its predicate device are based on the same technological principle of two solid-state laser emission (Alexandrite and Nd:YAG). The two laser sources wavelength are intended for the same indications for use.
The subject and predicate devices are based on the following same technological elements, such as, same laser sources, wavelengths, delivery system, power supply, cooling system, optic, user interfaces and display screen. Both the subject device and the predicate share operating principles, such as energy, repetition rate, available spot sizes.
The subject device includes an energy check port that was not included in the predicate device. For this reason, a reference device is selected to support the full equivalence comparison. Any other difference does not raise any new or modified safety and/or effectiveness questions due to the similarities to the predicate device.
| Item for comparison | Splendor X<br>(Alex, Alex2, Nd:YAG, Alex+Nd:YAG)<br>Subject device | Family of Square Epil<br>(Alex, Alex2, Nd:YAG, Alex+Nd:YAG)<br>Predicate device K161632 |
|---------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| General/Regulatory Information | | |
| Manufacturer | Bios S.r.l. | Bios S.r.l. |
| 510(k) number | Subject of this submission | K161632 |
| | Splendor X | Family of Square Epil |
| Item for comparison | (Alex, Alex², Nd:YAG, Alex+Nd:YAG)<br>Subject device | (Alex, Alex², Nd:YAG, Alex+Nd:YAG)<br>Predicate device K161632 |
| Device Classification<br>Name | Powered laser surgical instrument | Powered laser surgical instrument |
| Regulation number | 21 CFR 878.4810 | 21 CFR 878.4810 |
| Product Code | GEX | GEX |
| Regulation Medical<br>Specialty | General & Plastic Surgery | General & Plastic Surgery |
| Regulation Name | Laser surgical instrument for use in<br>general and plastic surgery and in<br>dermatology. | Laser surgical instrument for use in<br>general and plastic surgery and in<br>dermatology. |
| Review Panel | General & Plastic Surgery | General & Plastic Surgery |
| Classification | Class II | Class II |
| Indications for Use | The Nd:YAG 1064 Laser is intended for:<br>• Removal of unwanted hair, for stable<br>long term or permanent hair reduction<br>and for treatment of Pseudofolliculitis<br>barbae (PFB). Permanent hair reduction<br>is defined as the long-term, stable<br>reduction in the number of hairs<br>regrowing when measured at 6, 9, and<br>12 months after the completion of a<br>treatment regime. The lasers are<br>indicated on all skin types, such as<br>Fitzpatrick I-VI, including tanned skin.<br>• Photocoagulation and hemostasis of<br>benign pigmented and vascular lesions<br>such as but not limited to port-wine<br>stains, hemangioma, warts,<br>telangiectasia, rosacea, venus lake, leg<br>veins and spider veins.<br>• Coagulation and hemostasis of soft<br>tissue.<br>• Treatment of benign pigmented lesions<br>such as, but not limited to, lentigos (age<br>spots), solar lentigos (sun spots), cafè au<br>lait macules, seborrheic keratosis, nevi,<br>chloasma, verrucae, skin tags, keratosis,<br>tattoos (significant reduction in the<br>intensity of black and/or blue-black<br>tattoos) and plaques. The laser is<br>indicated for benign pigmented lesions<br>to reduce lesion size, for patients with<br>benign lesions that would potentially<br>benefit from aggressive treatment, and<br>for patients with benign lesions that<br>have not responded to other laser<br>treatments.<br>• Reduction of red pigmentation in<br>hypertrophic and keloid scars where<br>vascularity is an integral part of the scar. | The Nd:YAG 1064 Laser is intended for:<br>• Removal of unwanted hair, for stable<br>long term or permanent hair reduction<br>and for treatment of Pseudofolliculitis<br>barbae (PFB). Permanent hair reduction<br>is defined as the long-term, stable<br>reduction in the number of hairs<br>regrowing when measured at 6, 9, and<br>12 months after the completion of a<br>treatment regime. The lasers are<br>indicated on all skin types Fitzpatrick I-VI<br>including tanned skin.<br>• Photocoagulation and hemostasis of<br>benign pigmented and vascular lesions<br>such as but not limited to port wine<br>stains, hemangioma, warts,<br>telangiectasia, rosacea, venus lake, leg<br>veins and spider veins.<br>• Coagulation and hemostasis of soft<br>tissue.<br>• Treatment of benign pigmented lesions<br>such as, but not limited to, lentigos (age<br>spots), solar lentigos (sun spots), cafè au<br>lait macules, seborrheic keratosis, nevi,<br>chloasma, verrucae, skin tags, keratosis,<br>tattoos (significant reduction in the<br>intensity of black and/or blue-black<br>tattoos) and plaques. The laser is<br>indicated for benign pigmented lesions<br>to reduce lesion size, for patients with<br>benign lesions that would potentially<br>benefit from aggressive treatment, and<br>for patients with benign lesions that<br>have not responded to other laser<br>treatments.<br>• Reduction of red pigmentation in<br>hypertrophic and keloid scars where<br>vascularity is an integral part of the scar. |
| | Splendor X<br>(Alex, Alex², Nd:YAG, Alex+Nd:YAG)<br>Subject device | Family of Square Epil<br>(Alex, Alex², Nd:YAG, Alex+Nd:YAG)<br>Predicate device K161632 |
| Item for comparison | Temporary increase of clear nail in patients with onychomycosis (e.g., dermatophytes, Trichophyton rubrum and T. mentagrophytes, and for yeast Candida Albicans, etc.) The Alexandrite 755 laser is intended for: Temporary hair reduction. Stable long-term or permanent hair reduction through selective targeting of melanin in hair follicles. 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. On all skin types, such as Fitzpatrick I – VI, including tanned skin. Treatment of benign pigmented lesions. Treatment of wrinkles. Photocoagulation of dermatological benign vascular lesions (such as port-wine stains, hemangiomas, telangiectasias). | Temporary increase of clear nail in patients with onychomycosis (e.g., dermatophytes, Trichophyton rubrum and T. mentagrophytes, and for yeast Candida Albicans, etc.) The Alexandrite 755 laser is intended for: Temporary hair reduction. Stable long-term or permanent hair reduction through selective targeting of melanin in hair follicles. 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. On all skin types (Fitzpatrick I – VI) including tanned skin. Treatment of benign pigmented lesions. Treatment of wrinkles. Photocoagulation of dermatological benign vascular lesions (such as port-wine stains, hemangiomas, telangiectasias). |
| Laser Class | 4 | 4 |
| Laser source | Alexandrite (Alex)<br>Nd:YAG | Alexandrite (Alex)<br>Nd:YAG |
| Spot size | Square: 2mm, 3mm, 5 mm, 10mm,<br>14mm, 18mm, 20mm, 24mm,<br>27mm;<br><br>Round: 2mm, 3mm, 5 mm, 10mm,<br>14mm, 18mm, 20mm, 24mm,<br>26mm, 30 mm | Square: 2mm, 3mm, 5 mm, 10mm,<br>14mm, 18mm, 20mm, 24mm,<br>27mm;<br><br>Round: 2mm, 3mm, 5 mm, 10mm,<br>14mm, 18mm, 20mm, 24mm,<br>26mm, 30 mm |
Table 1: Predicate Device SE comparison
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Image /page/7/Picture/1 description: The image shows the logo for "bios, a Lumenis company". The word "bios" is written in a sans-serif font, with the letters in a dark blue color. Below the word "bios" is the text "A LUMENIS COMPANY" in a smaller, sans-serif font, also in dark blue. The logo is simple and modern, with a focus on the company name.
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Image /page/8/Picture/1 description: The image shows the logo for "bios, a Lumenis company". The word "bios" is written in a simple, sans-serif font, with the letters connected in a flowing, cursive-like style. The color of the text is a dark blue. Below the word "bios", in a smaller font size, is the text "A LUMENIS COMPANY", also in dark blue.
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Image /page/9/Picture/1 description: The image shows the logo for "bios A LUMENIS COMPANY". The word "bios" is written in a lowercase sans-serif font, with the letters "b", "i", "o", and "s" connected. The color of the word is a dark blue. Below the word "bios" is the text "A LUMENIS COMPANY" in a smaller, sans-serif font, also in dark blue.
The subject device has the same technical features of the predicate excepting for the energy check port that was not introduced at the time of the predicate submission. This difference is supported by the equivalence with the reference device.
The Splendor X and the GentleMax Pro Plus share the same regulatory classification, similar indications for use and technological characteristics included the handpiece power port access.
Table 2: Reference Device SE comparison
| Item for comparison | Splendor X<br>(Alex, Alex2, Nd:YAG, Alex+Nd:YAG)<br>Subject device…
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Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.