REACTION SYSTEM

K090221 · Viora , Ltd. · NUV · Jul 1, 2009 · General, Plastic Surgery

Device Facts

• Record ID: K090221
• Device Name: REACTION SYSTEM
• Applicant: Viora , Ltd.
• Product Code: NUV · General, Plastic Surgery
• Decision Date: Jul 1, 2009
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.4810
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Reaction™ system is intended for the treatment of the following medical conditions, using the B-contour and F-contour applicators for delivering non thermal RF combined with massage: - relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and - temporary reduction in the appearance of cellulite. Using the ST applicator for delivering RF, the Reaction™ system is intended for the treatment of relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation.

Device Story

Reaction™ System combines CORE™ (Channeling Optimized RF Energy) technology with mechanical vacuum massage. System comprises console (power supply, vacuum pump, RF generator, CPU, display) and three applicators (B-Contour, F-Contour, ST). Operator adjusts RF power and vacuum intensity via handpiece or applicator panels. Used in clinical settings by trained operators. RF energy provides heating/therapeutic effects; vacuum massage aids circulation and tissue manipulation. Output is thermal/mechanical energy delivered to skin/muscle to alleviate pain, spasms, and improve circulation; cellulite reduction achieved via combined RF/massage. Benefits include non-invasive symptom relief and aesthetic improvement.

Clinical Evidence

No clinical data provided; bench testing only.

Technological Characteristics

System utilizes CORE™ (Channeling Optimized RF Energy) and mechanical vacuum massage. Includes console, handpiece, and three applicators (B-Contour, F-Contour, ST). Energy source: RF generator and vacuum pump. Connectivity: manual adjustment via operator panels on handpiece/applicators. Software: embedded control for RF power and vacuum intensity.

Indications for Use

Indicated for patients requiring relief of minor muscle aches/pain, relief of muscle spasms, temporary improvement of local blood circulation, and temporary reduction in the appearance of cellulite.

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

• VelaShape (K071872)
• VelaSmooth, Shaper (K050397)
• LPG Therapeutic Massager (K990445)
• Cutera CMMCD (K080300)
• Intelect® SWD 100/ Senior Solutions (K083433)
• Auto*Therm® 390, Model ME 390 (K042554)

Submission Summary (Full Text)

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K090221

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# 510(k) Summary:

Reaction™ System

Company Name: Viora Ltd.

Contact Person: Omri Kessler

COO

Telephone: [phone] [phone] Fax: E-mail: [e-mail]

## Authorized US Agent:

Josef Luzon - CEO Viora Inc. 30 Montgomery Street, Suite 660 Jersey City, NJ 07302

Telephone: [phone] Fax: [phone] E-mail: josef(@vioramed.com

Date prepared: January 23, 2009

Trade Name: Reaction™ System

Classification name: Laser surgical instrument for use in-general and plastic surgery and in dermatology

Common/usual name: Massager, vacuum, light induced heating

Product Code: NUV, ISA

Regulation No.: 878.4810

Class: II

Panel identification: General and Plastic Surgery Panel.

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090221

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## Predicate Device:

VelaShape from Syneron Medical Ltd, Yokneam Elite, Israel, cleared under 510(k) # K071872;

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VelaSmooth, Shaper from Syneron Medical Ltd, Yokneam Elite, Israel, cleared under 510(k) # K050397;

LPG Therapeutic Massager from LPG USA Inc, Fort Lauderdale, Fl, USA, cleared under 510(k) # K990445 and

### Description of the device:

The Reaction™ system combines CORE™ (Channeling Optimized RF Energy) technology with mechanical vacuum massage of the skin. The Reaction™ treatment is indicated for the treatment of selected medical conditions such as relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation, temporary reduction in the appearance of cellulite

The Reaction™ system provides the treatments using 3 specially-designed applicators that treat various areas of the body, including large and small areas.

The system includes five core modules: the Console, the hand piece, and 3 treatment applicators: B-Contour, F-Contour and ST.

The Reaction™ console houses the following components:

- Power supply
- Hand piece
- Vacuum pump
- RF Generator
- Main CPU
- Display unit

The hand piece allows the operator to adjust the treatment parameters of the RF power and intensity of mechanical vacuum massage.

The applicators incorporate operator panels and are used to adjust the treatment parameters of the RF power and mechanical vacuum manipulation.

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### Indications for Use:

The Reaction™ system is intended for the treatment of the fellowing medical conditions. using the B-contour and F-contour applicators for delivering non thermal RF combined with massage:

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- relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and

- temporary reduction in the appearance of cellulite.

Using the ST applicator for delivering RF, the Reaction™ system is intended for the treatment of relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation.

#### Substantial Equivalence:

The Reaction 130 System using the B-contour and the F-contour applicators, has the same intended use and the same performance characteristics as the fotlowing predicate devices: VelaShape from Syneron Medical Ltd, Yokneam Elite, Israel, cleared under 510(k) # K071872; VelaSmooth, Shaper from Syneron Medical Ltd, Yokneam Elite, Israel, cleared under 510(k) # K050397 and LPG Therapeutic Massager from LPG USA Inc, Fort Lauderdale, Fl, USA, cleared under 510(k) # K990445.

When using the ST applicator, the Reaction 130 System has the same intended use and the same performance characteristics as the RF application of Cutera CMMCD from Cutera Inc in Brisbane, CA, USA, cleared under 510(k) # K080300 and the following predicate devices: Intelect® SWD 100/ Senior Solutions from Chattanooga Group in Hixson, TN. USA, cleared under 510(k) # K083433 and Auto*Therm® 390, Model ME 390 from Mettler Electronics Corp in Anaheim, CA, USA, cleared under 510(k) # K042554.

The Reaction TM System is therefore substantially equivalent to those devices for each of the intended applications.

#### Conclusion -

The evaluation of the Reaction " System does not raise any additional concerns regarding safety and effectiveness and may therefore be considered substantially equivalent to the predicate device.

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## DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS). The seal features a stylized eagle with its wings spread, symbolizing protection and strength. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES. USA" are arranged in a circular pattern around the eagle.

#### Public Health Service

JUL - 1 2009

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Viora Ltd. % Viora Inc. Mr. Josef Luzon Chief Executive Officer 30 Montgomery Street, Suite 660 Jersey City, New Jersey 07302

Re: K090221

Trade/Device Name: Reaction™ System Regulation Number: 21 CFR 878.4810 Regulation Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Regulatory Class: II Product Code: NUV, ISA, ILY Dated: June 18, 2009 Received: June 19, 2009

Dear Mr. Luzon:

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 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); medical device reporting (reporting of medical

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Page 2 - Mr. Josef Luzon

device-related adverse events) (21 CFR 803); 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,

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/cdrh/mdr/ for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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 [phone] or [phone] or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours.

fren Nillson

Mark N.Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## INDICATIONS FOR USE

510(k) Number (if known):

K090221

Device Name:

Reaction™ System

Indications for Use:

The Reaction™ system is intended for the treatment of the following medical conditions, using the B-contour and F-contour applicators for delivering non thermal RF combined with massage: - relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and - temporary reduction in the appearance of cellulite.

Using the ST applicator for delivering RF, the Reaction™ system is intended for the treatment of relief of minor musele aches and pain, relief of muscle spasm, temporary improvement of local blood circulation.

Prescription Use X ાર (Part 21 CFR 801 Subpart D)

Over the Counter Use (21 CFR 801 Subpart C)

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Concurrence of CDRH, Office of Device Evaluation (ODE)

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(Division Sign-Off)

Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K090221