K032816 · Stargate International, Inc. · NHN · Mar 26, 2004 · Physical Medicine
Device Facts
Record ID
K032816
Device Name
QUANTUM LIGHT THERAPY SYSTEM
Applicant
Stargate International, Inc.
Product Code
NHN · Physical Medicine
Decision Date
Mar 26, 2004
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Quantum Light Therapy System is a non-heating lamp, infrared as described under the provisions of 21 CFR §890.5500 and is indicated for: - A- Adjunctive use in providing temporary relief of minor chronic neck and shoulder paint of musculoskeletal origin using the QS-2; QS-4; and/or the QS-L applicator heads.
Device Story
Quantum Light Therapy System is a hand-held, battery-operated, non-invasive pain therapy device. It utilizes interchangeable applicator heads containing laser diodes and light-emitting diodes (LEDs) to deliver non-heating, visible photonic energy to tissue. The system is operated by a clinician to provide therapeutic light treatment. The device transforms electrical power into specific wavelengths of light (609-645nm range) to provide temporary relief of minor chronic musculoskeletal pain. The system is compact and portable. Clinical benefit is derived from the application of light therapy to the affected area, consistent with established therapeutic regimens for similar light therapy systems. The device is intended for adjunctive use in pain management.
Clinical Evidence
Bench testing only. The device underwent functional performance, software, firmware, electrical safety, and component specification testing conducted by an independent laboratory. Compliance with standards including FCC 47CFR Part 15B, IEC 60825-1, IEC 60601-2-22, and IEC 60601-1-2 was verified.
Technological Characteristics
Hand-held, battery-operated control unit with interchangeable applicator heads. Emits light via laser diodes and LEDs. Wavelengths: 609-645nm. Laser output: <5mW (Class IIIa). LED output: non-coherent diffuse light. Standards: FCC 47CFR Part 15B, UL approved components, 21CFR Part 1040 (Class IIIa laser), IEC 60825-1, IEC 60601-2-22, IEC 60601-1-2.
Indications for Use
Indicated for adjunctive use in providing temporary relief of minor chronic neck and shoulder pain of musculoskeletal origin in patients.
Regulatory Classification
Identification
An infrared lamp is a device intended for medical purposes that emits energy at infrared frequencies (approximately 700 nanometers to 50,000 nanometers) to provide topical heating.
Special Controls
*Classification.* Class II (special controls). The device, when it is an infrared therapeutic heating lamp, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.
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Image /page/0/Picture/0 description: The image shows the word "Stargate" in bold, black letters. Above the word is a thin, black oval shape. To the right of the oval is a black star shape.
MAR 2 6 2004
# Final 510(k) Summary For Application #K032816 Dated March 23, 2004
(as required per 21CFR; §807.92)
Quantum Light Therapy System
The following modified 510k summary is in response to the issues indicated by the Food and Drug Administration in a phone conversation on March 22, 2004. This represents Stargate's Final Amended Summary.
| I. Applicant | Stargate International, Inc. |
|-------------------|------------------------------|
| | 10235 South Progress Way #7 |
| | Parker, CO 80134 |
| | Phone: 303-840-8206 |
| | Fax: 303-840-8320 |
| II. Contact Name: | Robert H. Walker; CEO |
III. Device Name
| Proprietary Name | Quantum Light Therapy System |
|----------------------|------------------------------------------------------------|
| Common/Usual Name(s) | Low Level Laser Therapy (LLLT)<br>Therapeutic Light System |
| Classification Name | Infrared Lamp; (21CFR; §890.5500) |
| Product Code(s) | NHN |
rwalker@stargateinternational.com
### IV. Predicate Device/Substantial Equivalency
The Quantum Light Therapy System is substantially equivalent to other pulsed low level therapeutic lasers and light therapy systems currently in commercial distribution. The Quantum Light Therapy System has the same intended use and similar technological characteristics to predicate devices. It combines the clinically accepted therapeutic uses of previously FDA 510(k) approved light therapy systems currently in commercial distribution into one complete, compact, and cost-effective system.
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The technological equivalence to the predicate devices is substantiated by the wavelengths and power outputs generated by the individual Quantum System applicator heads. Depending on the applicator head chosen by the clinician, the Quantum System will provide the same treatment benefits and regimens for conditions already approved by the Food and Drug Administration.
The predicate devices the Quantum System establishes equivalence to include the following:
| Predicate Device | 510(k) # | Manufacturer |
|----------------------|----------|---------------------------|
| Tuco Erchonia PL3000 | K012580 | Tuco Innovations |
| Super Nova; Accubeam | K001179 | Light Force Therapy, Inc. |
| MedX 100 Series | K020017 | MedX Electronics, Inc. |
### V. Intended Use of the Device
The Quantum Light Therapy System is a non-heating lamp, infrared as described under the provisions of 21 CFR §890.5500 and is indicated for:
- A- Adjunctive use in providing temporary relief of minor chronic neck and shoulder paint of musculoskeletal origin using the QS-2; QS-4; and/or the QS-L applicator heads.
### VI. Description of the Device
The Quantum Light Therapy System is a hand-held, non-invasive, pain therapy system which utilizes non-heating lamps consisting of both laser and light emitting diodes(LED) in three optional applicator heads. It combines the clinically accepted therapentic treatment of numerous predicate light therapy callor itsacs: It commercial distribution and 510(k) approved into one complete, compact, and costeffective system.
The system consists of a basic hand-held, battery operated control unit and three optional (one-LED; two-laser) and interchangeable applicator heads which can only be used with the Quantum Light Therapy System control unit.
The three distinct applicator heads produce wavelengths that range between 609-645mm which falls within the spectrum as defined by 21 CFR §890.5500.
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The two laser applicator heads produce an output power of <Smw prom-convergent beam and I he two laser apprication neads produced wavelength of 635mm 11% and ontinued of themse are classified as Class IIIa lastis. Bour operate and included on tortly in 21CFR Part 1040. Stargeton tional, Inc. has filed as a registered laser manufacturer with the Food and Drug Administration.
The distinct LED applicator head produces a non coherent diffuse light source. This applicator head operates at a measured wavelength of 628mm ±3%.
# VII. Summary of Technical Characteristics of the Device To Referenced Predicate Devices
The Quantum Light Therapy System and the aforementioned predicate devices use diodes to emit I he Qualium Light Included in the intended use of the Quantum Light Therapy System is visible photomic energy to numal ussue. The Stargate applicator head chosen by the clinician.
### VIII. System Testing
The testing of the Quantum Light Therapy System includes functional performance, software, firmware, electrical safety, and component specification. This includes four-staged manufactiffinate, electrical salety, and component specifications by an outside independent laboratory.
The Quantum Light Therapy System is manufactured, performs, is labeled, and is tested to comply with the following standards:
- FCC Standard 47CFR Part 15B せ
- All Electrical Components Utilized Are UL® Approved ◆
- Class IIIa Laser 21CFR Part 1040. .
- IEC60825-1, Amendment 2 해
- IEC 60601-2-22 ャ
- EMC: IEC 60601-1-2 .
#### IX. Conclusions
In accordance with testing and comparison to the predicate devices, and pursuant to 21CFR; 5890.500, the Quantum Light Therapy System has the same intended uses, with similar functional and performance characteristics.
The device meets or excceds the design, testing, and labeling standards required by law. The Quantum Light Therapy System is manufactured and performs as intended and does not raise any new regulatory, safety, and/or clinical efficacy issues.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird-like figure with three wing-like shapes.
Public Health Service
MAR 2 6 2004
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. Robert H. Walker CEO Stargate International, Inc. 10235 South Progress Way, #7 Parker, Colorado 80134
Re: K032816
Trade/Device Name: Quantum Light Therapy System Regulation Number: 21 CFR 890.5500 Regulation Name: Lamp, non-heating for adjunctive use in pain therapy Regulatory Class: II Product Code: NHN Dated: December 23, 2003 Received: December 29, 2003
Dear Mr. Walker:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 - Mr. Robert H. Walker
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Miriam C. Provost
Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications For Use
### 510(k) Number (if known): K032816
Device Name: Quantum Light Therapy System
The Quantum Light Therapy System is a non-heating lamp, infrared as described Indications For Use: under the provisions of 21 CFR §890.5500 and is indicated for:
> Adjunctive use in providing temporary relief of minor chronic neck and shoulder pain of musculoskeletal origin using the QS-2; QS-4; and/or the QS-L applicator heads.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Miriam C. Provost
(Division Sign-Off) Division of General, Restorative, and Neurological Devices
Page 1 of
**510(k) Number** K132816
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
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.