K123494 · Convergent Dental, Inc. · GEX · Feb 11, 2013 · General, Plastic Surgery
Device Facts
Record ID
K123494
Device Name
SOLEA
Applicant
Convergent Dental, Inc.
Product Code
GEX · General, Plastic Surgery
Decision Date
Feb 11, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Solea system is indicated for the following: . Incision . . Excision . . Vaporization . . Coagulation . Hemostasis . of soft tissue in the oral cavity.
Device Story
Solea is a mobile, cart-based CO2 laser system (9.25μm wavelength) for dental soft tissue surgery. Operated by dentists/specialists, it delivers pulsed laser energy via an articulating arm to perform incision, excision, vaporization, coagulation, and hemostasis. The device provides precise tissue interaction, replacing traditional scalpels or electrosurgery tools. Clinicians use the laser to manage soft tissue pathologies, improving procedural efficiency and patient outcomes through controlled ablation. The system includes software for operational control and safety monitoring.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, including electrical safety, EMC, laser safety, sterilization validation, and comparative soft tissue performance analysis (depth, width, length of cuts, and histological assessment).
Technological Characteristics
Class 4 CO2 laser; 9.25μm wavelength; 1.13J/mm² fluence; 112.80W/mm² irradiance. Beam delivery via articulating arm. Sterilization via steam autoclave. Complies with CISPR 11, IEC 61000-3-2, and IEC 61000-3-3. Software-controlled operation.
Indications for Use
Indicated for incision, excision, vaporization, coagulation, and hemostasis of soft tissue in the oral cavity for patients requiring dental surgical procedures.
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
Lutronic Corporation Spectra DENTA II Laser System (K091320)
Submission Summary (Full Text)
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K123 494 1/4
# 510(k) Summary
## 1. Submission Sponsor
# FEB 1 1 2013
Convergent Dental, Inc. 2 Vision Drive Natick, MA 01760 USA Phone: (508) 500-5656 Contact: Jon Quillard, VP of Regulatory Affairs
## 2. Submission Correspondent
Emergo Group 611 West 5th Street, Third Floor Austin, TX 78701 Cell Phone: (720) 838.4113 Office Phone: (512) 327 9997 Fax: (512) 327.9998 Contact: Carrie Hetrick, Senior Consultant Email: project.management@emergogroup.com
## 3. Date Prepared
23 October 2012
### 4. Device Identification
| Trade/Proprietary Name: | Solea |
|----------------------------|----------------------------------------------------------------------------------|
| Common/Usual Name: | CO2 laser |
| Classification Name: | Laser surgical instrument for use in general and plastic surgery and dermatology |
| Classification Regulation: | 878.4810 |
| Product Code: | GEX |
| Device Class: | Class II |
| Classification Panel: | General and Plastic Surgery |
### 5. Predicate Devices
Lutronic Corporation Spectra DENTA II Laser System, 510(k) Number: K091320
## 6. Device Description
The Solea system is a mobile, cart-based dental treatment system that uses pulsed laser energy to cut soft tissue in the oral cavity. The Solea system utilizes advanced CO2 laser technology with a wavelength of 9.25μm to safely and effectively perform incision, excision, vaporization, coagulation, and hemostasis.
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## 7. Intended Use
The Solea system is indicated for the following:
- . Incision
- . Excision
- . Vaporization
- . Coagulation
- Hemostasis
of soft tissue in the oral cavity.
## 8. Comparison of Technological Characteristics
The following table compares the Solea to the predicate device with respect to the intended use, technological characteristics, and principles of operation, providing more detailed information regarding the basis for the determination of substantial equivalence.
| | Convergent Dental, Inc. | Lutronic Corporation |
|--------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | Solea | Spectra DENTA II |
| 510(k)<br>Number | Pending | K091320 |
| Common<br>Name | CO2 Laser | CO2 Laser |
| Classification<br>Names (FDA) | Powered Laser Surgical Instrument | Powered Laser Surgical Instrument |
| FDA<br>Classification<br>Codes | GEX | GEX |
| Predicates<br>cited | K091320 | K050254, K030147, K935563, K963229,<br>K991297, K021508, K081181 |
| Target User | General practitioner dentists and<br>specialists | General practitioner dentists and specialists |
| Indications<br>for use | The Solea system is indicated for the<br>following:<br>• Incision<br>• Excision<br>• Vaporization<br>• Coagulation<br>• Hemostasis<br>of soft tissue in the oral cavity. | The Spectra DENTA II Laser System is<br>indicated for use in soft tissue dental<br>indications including periodontic procedures<br>such as, but not limited to, removal of<br>diseased or inflamed soft tissue in the<br>periodontal pocket (sulcular debridement),<br>vaporization, gingivectomy-removal of<br>hyperplasias, gingivoplasty, papillectomy,<br>vestibuloplasty, fibroma (nonmalignant<br>tumor, mucosa, tongue), epulis, incision and<br>excision, removal of soft tissue, cysts, and<br>tumors, and laser assisted new attachment<br>procedure (cementum mediated periodontal<br>ligament new attachment to the root surface<br>in the absence of long junctional epithelium);<br>Oral surgery such as frenectomy, frenum<br>release, drainage (abscess), flap surgery,<br>incisional and excisional biopsy, incision and |
Table 5A – Comparison of Characteristics
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| | Convergent Dental, Inc. | Lutronic Corporation |
|--------------------------------------------------|----------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | Solea | Spectra DENTA II |
| | | excision of aphthous ulcers, incision of infection when used with antibiotic therapy, excision and ablation of benign and malignant lesions, oral cavity tumors and hemangiomas, salivary gland pathologies, preprosthetic gum preparation, leukoplakia; partial glossectomy, periodontal gum resection, homeostasis, operculectomy, and crown lengthening. |
| Laser<br>classification | Class 4 (IV) Laser Product | Class 4 (IV) Laser Product |
| Type of Laser | CO₂ (Carbon Dioxide) | CO₂ (Carbon Dioxide) |
| Wavelength | 9.25µm (9250 nm) | 10.6µm (10600 nm) |
| Fluence:<br>Energy per<br>mm² | 1.13J/mm² | 1.08J/mm² |
| Irradiance:<br>Power per<br>mm² | 112.80W/mm² | 194.80W/mm² |
| Operating<br>Modes | Ablation laser: Pulsed<br>Aiming laser: Continuous | Ablation laser: Pulsed<br>Aiming laser: Continuous |
| Beam<br>Delivery | Articulating Arm (Free Space) | Articulating Arm (Free Space) |
| Sterilization<br>Methods | Steam Autoclave | Steam Autoclave |
| RF emissions | CISPR 11 Group 1 | CISPR 11 Group 1 |
| EMC<br>compliance | CISPR 11 Class A | CISPR 11 Class A |
| Harmonic<br>emissions | IEC 61000-3-2 Class A | IEC 61000-3-2 Class A |
| Voltage<br>fluctuations/<br>flicker<br>emissions | IEC 61000-3-3 | IEC 61000-3-3 Class A |
### 9. Non-Clinical Performance Data
The Solea system meets all the requirements for overall design, sterilization, biocompatibility, and electrical safety. The results of the non-clinical testing confirm the output meets the design inputs and specifications. Bench testing was performed to demonstrate substantial equivalence to the predicate device in terms of safety and performance. The following non-clinical testing was performed:
### . Electrical Safety Testing:
The system passed electrical safety testing in accordance with requirements for medical electrical equipment.
### Electromagnetic Compatibility: .
The system passed electromagnetic compatibility (EMC) testing to meet requirements for medical electrical equipment.
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### Laser Safety: .
The system passed particular requirements for the safety of diagnostic and therapeutic laser equipment.
### . Cleaning and Sterilization:
The handpieces of the Solea system passed cleaning and sterilization validations for reusable medical devices.
### . Software:
Verification testing was conducted on the Solea software. All tests were completed successfully with respect to stated pass/fail criteria thereby deeming the device and software appropriate for its intended use.
### . Usability:
Usability testing was conducted on the Solea system. Based on the participant feedback and ratings of usability of the Solea system, all of the acceptance criteria for the user design validation have been met for the intended use.
### . Bench Testing: Solea Soft Tissue Testing:
Performance data was collected using the Solea system and the predicate device. A quantitative analysis was conducted evaluating the depth, width and length of cuts, a histological assessment of changes in sample tissue, and effect on tissue surrounding the incision areas. The results show substantially equivalent results for both systems.
## 10. Clinical Testing
There was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. These types of devices, including the predicate devices, have been on the market for many years with proven safety and efficacy for the use of the device. The nonclinical testing detailed in this submission supports the substantial equivalence of the device.
## 11. Statement of Substantial Equivalence
By definition, a device is substantially equivalent to a predicate device when the device has the same intended use and the same technological characteristics as the previously cleared predicate device. The Solea device has the same intended use and different technological characteristics that can be demonstrated that the device is substantially equivalent to the predicate device and that the new device does not raise different questions regarding its safety and effectiveness as compared to the predicate device.
It has been shown in this 510(k) submission that the difference between the Solea system and the predicate devices do not raise any questions regarding its safety and effectiveness. Performance testing and compliance with voluntary standards, demonstrate that the Solea system is substantially equivalent to the relevant aspects of the predicate devices in terms of design, components, materials, principals of operation, sterilization, biocompatibility, performance characteristics, and intended use. Solea, as designed and manufactured, is determined to be substantially equivalent to the referenced predicate devices.
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## DEPARTMENT OF HEALTH & HUMAN SERVICES
### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
Convergent Dental, Incorporated % Emergo Group. Incorporated Ms. Carrie Hetrick Senior Regulatory Consultant 611 West 5th Street Third Floor Austin, Texas 78701
February 11, 2013
Re: K123494
Trade/Device Name: Solea 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: November 05, 2012 Received: November 13, 2012
Dear Mr. Hetrick:
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 or any Federal statutes and regulations administered by other Federal agencies. You must
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Page 2 - Ms. Carrie Hetrick
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 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/ReportaProblem/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 Di 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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# Indications for Use Statement
510(k) Number (if known): K123494
Device Name: Solea
Indications for Use:
The Solea system is indicated for the following:
- Incision .
- . Excision
- . Vaporization
- . Coagulation
- Hemostasis .
of soft tissue in the oral cavity.
Prescription Use ×
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(Part 21 CFR 801 Subpart D)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Neil R Ogden 2013.02.11 ,1 3:12:15 -05'00'
. .
(Division Sign-Off) for MXM Division of Surgical Devices 510(k) Number ________________________________________________________________________________________________________________________________________________________________ K123494
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.