K121920 · Sunetics International Marketing Group, LLC · OAP · Jun 27, 2013 · Physical Medicine
Device Facts
Record ID
K121920
Device Name
LASERBRUSH
Applicant
Sunetics International Marketing Group, LLC
Product Code
OAP · Physical Medicine
Decision Date
Jun 27, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Sunetics LaserBrush is indicated to treat Androgenetic Alopecia, promote hair growth and prevent further hair loss in males who have Norwood Hamilton Classifications of IIa to V and Fitzpatrick Skin Types I to IV & also in females who have Ludwig (Savin) I-4, II-1, II-2, or frontal patterns of hair loss & Fitzpatrick Skin Types I to IV.
Device Story
Handheld low-level laser device; utilizes 7, 9, or 12 collimated 650 nm laser modules (<5 mW); integrated brush bristles part hair to ensure scalp exposure; intended for home use by patients; promotes hair growth and prevents hair loss in Androgenetic Alopecia patients; provides distributed laser light to scalp.
Clinical Evidence
No clinical data provided. Substantial equivalence is based on bench testing comparing laser wavelength, average/peak power levels, laser treatment field, and energy delivery to the predicate device.
Technological Characteristics
Handheld device; 650 nm laser modules (<5 mW); 7, 9, or 12 module configurations; integrated brush bristles for scalp parting; battery/power supply; non-invasive; no software or algorithmic components.
Indications for Use
Indicated for males (Norwood Hamilton IIa-V) and females (Ludwig/Savin I-4, II-1, II-2, or frontal patterns) with Androgenetic Alopecia and Fitzpatrick Skin Types I-IV to promote hair growth and prevent further hair loss.
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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K121920
Sunetics International Marketing Group LLC
510(k) Submission Sunetics LaserBrush
## ATTACHMENT 2
# 510(k) SUMMARY
JUN 2 7 2013
| 510(k) Owner: | Sunetics International Marketing Group LLC<br>892 Steger Towne Rd Suite # 44<br>Rockwall, TX 75032<br>Contact:<br>John Carullo<br>Phone:<br>214-683-0724 | |
|-----------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|
| Date Summary<br>Prepared: | June 21, 2012 | |
| Device: | Trade Name: | Sunetics LaserBrush |
| | Common/Classification Name: | Laser, Comb, Hair<br>Product Code OAP |
| | | 21 C.F.R. § 890.5500 (Infrared lamp) |
| | Classification: | Class II |
| Predicate<br>Device: | HairMax LaserCombs - models: Advanced 7, Lux 9, Professional 12<br>Lexington International, LLC<br>K110233, K103368, Κ112524 | |
| Device<br>Description: | The Sunetics LaserBrush consists of a handheld low-level laser device<br>intended to promote hair growth. Depending upon the Sunetics LaserBrush<br>model, the device provides distributed laser light using seven (7), nine (9), or<br>twelve (12), collimated, 650 nm, <5 mW laser modules, while brush bristles<br>simultaneously part the user's hair to ensure that the laser light reaches the<br>user's scalp. | |
| Intended Use: | The Sunetics LaserBrush is indicated to treat Androgenetic Alopecia,<br>promote hair growth and prevent further hair loss in males who have<br>Norwood Hamilton Classifications of IIa to V and Fitzpatrick Skin Types I to<br>IV & also in females who have Ludwig (Savin) I-4, II-1, II-2, or frontal<br>patterns of hair loss & Fitzpatrick Skin Types I to IV. | |
| Technological<br>Characteristics: | The Sunetics LaserBrush has the same intended power, wavelength, energy<br>source, laser beam pattern, laser treatment field, consumer usage focal point,<br>energy delivery, power supply, treatment time, indication for use, and target<br>population as the Hairmax LaserComb.<br>Not applicable. | |
| Biocompatibility<br>Data: | | |
| Performance<br>Data: | The laser wayeth length, average and peak power levels, laser treatment field<br>and energy delivery of the Sunetics LaserBrush and the Lexington Hairmax<br>LaserComb were substantially equivalent. | |
| Conclusions: | The performance data discussed above demonstrate that the Sunetics<br>LaserBrush device is as safe and effective as the predicate device. | |
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Image /page/1/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of an eagle with its wings spread.
#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002
Sunetics International Marketing Group, LLC % Mr. John Carullo 892 Steger Towne Road, Suite 44 Rockwall, Texas 75032
Re: K121920
Trade/Device Name: Sunetics LaserBrush Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared lamp Regulatory Class: Class II Product Code: OAP Dated: June 05, 2013 Received: June 11, 2013
June 27, 2013
Dear Mr. Carullo:
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. 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 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 that I DA has made a coulations 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. John Carullo
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/MedicalDevices/Safety/ReportalProblem/default.htm 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 (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
FOR
Peter D. Rumm -S
Mark N. Melkerson Acting Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Sunetics International Marketing Group LLC
510(k) Submission Sunetics LaserBrush
### ATTACHMENT 1
#### Indications for Use
510(k) Number (if known):
. K121920
Device Name:
Sunetics LaserBrush models: LHB 7, LHB 9, LHB 12
Indications for Use:
The Sunetics LaserBrush is indicated to treat Androgenetic Alpopecia and promote hair growth in males who have Norwood Hamilton Classifications of Ila to V and Fitzpatrick Skin Types I to IV.
The Sunetics LaserBrush is indicated to treat Androgenetic Alpopecia and promote hair growth in females who have Ludwig (Savin) I-4, 11-1, II-2, or frontal patterns of hair loss and Fitzpatrick Skin Types I to IV.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use X (21 CFR801 Subpart C)
PLEASE DO NOT WRITE BELOW TIDS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED
Concurrence of CDRH, Office of Device Evaluation (ODE)
Neil R Ogden Nell R Ogden
2013.06.24 17:36:30 -04'00'
(Division Sign-Off) for MXM
Division of Surgical Devices
510(k) Number K121920
June 28, 2012
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.