K151333 · Led Intellectual Properties, LLC · ILY · Aug 21, 2015 · Physical Medicine
Device Facts
Record ID
K151333
Device Name
LightStim for Pain LED Belt
Applicant
Led Intellectual Properties, LLC
Product Code
ILY · Physical Medicine
Decision Date
Aug 21, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The LightStim for Pain LED Belt is an Over-The-Counter device intended to emit energy in the visible and near infrared spectrum to provide topical heating for the purpose of elevating tissue temperature for a temporary relief of minor muscle and joint pain and stiffness, minor arthritis pain or muscle spasm, the temporary increase in local blood circulation, and the temporary relaxation of muscles.
Device Story
Portable LED-based therapeutic heating device; consists of 1-4 LED pods attached to an adjustable elastic Velcro belt. Each pod contains 52 LEDs emitting 630nm, 865nm, and 940nm wavelengths. Powered by external 12V AC/DC supply; features manual on/off switch and 30-minute automatic shut-off timer. Used by consumers in home settings for topical heating. Device elevates skin temperature to 40-41.8°C to provide temporary relief of minor muscle/joint pain, stiffness, arthritis, and muscle spasms, and to increase local blood circulation. User applies belt to target areas (e.g., ankles, torso, legs).
Clinical Evidence
Bench testing only. Electrical safety and performance tested per IEC 60601-1 and IEC 60601-1-2. Temperature testing on 3 individuals confirmed skin warming to 40-41.8°C. Usability study (n=33, ages 20-79) demonstrated 100% correct self-selection and 97% comprehension of instructions and device operation.
Technological Characteristics
Infrared therapeutic heating lamp (21 CFR 890.5500). Emits visible/near-infrared light (630nm, 865nm, 940nm). Output: 60mW/cm2. 1-4 pods, 52 LEDs per pod. Powered by 12V AC/DC supply. Elastic belt form factor with Velcro. Tested to IEC 60601-1 and IEC 60601-1-2 standards.
Indications for Use
Indicated for OTC use by adults for temporary relief of minor muscle/joint pain and stiffness, minor arthritis pain, muscle spasm, temporary increase in local blood circulation, and temporary muscle relaxation.
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.
Predicate Devices
LightStim Professional 2-Panel Light System #2 (K150098)
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August 21, 2015
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
LED Intellectual Properties LLC Mr. Steve Marchese Chief Executive Officer 16552 Von Karman Avenue Irvine, California 92606
Re: K151333
Trade/Device Name: LightStim for Pain LED Belt Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared lamp Regulatory Class: Class II Product Code: ILY Dated: May 17, 2015 Received: May 27, 2015
Dear Mr. Marchese:
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 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
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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 contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
For
Sincerelv vours.
Joshua C. Nipper -S
Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K151333
Device Name LightStim for Pain LED Belt
#### Indications for Use (Describe)
The LightStim for Pain LED Belt is an Over-The-Counter device intended to emit energy in the visible and near infrared spectrum to provide topical heating for the purpose of elevating tissue temperature for a temporary relief of minor muscle and joint pain and stiffness, minor arthritis pain or muscle spasm, the temporary increase in local blood circulation, and the temporary relaxation of muscles.
| Type of Use (Select one or both, as applicable) | <table><tr><td>Prescription Use (Part 21 CFR 801 Subpart D)</td></tr><tr><td>Over-The-Counter Use (21 CFR 806 Subpart C)</td></tr></table> | Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 806 Subpart C) |
|-------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------|---------------------------------------------|
| Prescription Use (Part 21 CFR 801 Subpart D) | | | |
| Over-The-Counter Use (21 CFR 806 Subpart C) | | | |
_ | Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary of Safety and Effectiveness
LED Intellectual Properties, LLC.
# Device: LightStim for Pain LED Belt K151333
## 1. General Information
Submitter: LED Intellectual Properties, LLC 16552 Von Karman Ave. Irvine, Ca. 92606
Contact Person: Steve Marchese & Chase Marchese Office: (949) 502-4088 Mobile: (714) 924-0492
Emails: Steve@lightstim.com & Chase@lightstim.com
#### 2. Device name and code
Device Proprietary Name: LightStim for Pain LED Belt
Classification Code and name: ILY OTC Lamp Infrared Therapeutic Heating
#### 3. Predicate Devices
LED Intellectual Properties LLC LightStim Professional 2-Panel Light System #2 (K150098), and LightStim for Pain (K083580)
#### 4. Device Description
The LightStim for Pain LED Belt is a portable device that has between one and four separate LED pods, each of which has 52 LEDs and are attached to a elastic belt that stretches to encircle different sizes from as small as an ankle to as large as the torso, and attaches to itself with Velcro. Each pod has an LED array of 630nm, 865nm, and 940nm. The device is powered by a separate AC to DC 12-volt power supply and has an on/off switch, with a timer that shuts the device off automatically after 30 minutes of operation. Recommended treatment time is 5 to 30 minutes.
#### 5. Indications for Use
The LightStim for Pain LED Belt is an Over-The-Counter device intended to emit energy in the visible and near infrared spectrum to provide topical heating for the purpose of elevating tissue temperature for a temporary relief of minor muscle and joint pain and stiffness, minor arthritis pain or muscle spasm, the temporary increase in local blood circulation, and the temporary relaxation of muscles.
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### 6. Substantial Equivalency
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(s). The LightStim for Pain LED Belt K151333 has the same intended use, is manufactured by the same LED Intellectual Properties, LLC, utilizes the exact same LEDs, has the same power output, and has a similar size treatment area as both predicates (see Summary of Safety & Effectiveness Table below).
| Characteristic | LightStim for Pain LED<br>Belt K151333 | LightStim for Pain<br>K083580 | LightStim Professional<br>2-Panel Light - (System<br>#2 for the purposes of<br>this submission) K150098 |
|---------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | LED Intellectual<br>Properties, LLC | LED Intellectual<br>Properties, LLC | LED Intellectual<br>Properties, LLC |
| LED Wavelengths | 630, 660, 855, 940 | 630, 660, 855, 940 | 630, 660, 855, 940 |
| Output in Milliwatts | 60mW cm2 | 60mW cm2 | 60mW cm2 |
| Number of Pods of<br>LEDs | Minimum: 1 pod<br>Maximum: 4 pods | Minimum: 1 pod<br>Maximum: 1 pod | Minimum: 1 pod<br>Maximum: 2 pods |
| # of LEDs per Pod | 52 | 72 | 565 |
| Min./Max. Treatment<br>Area (sq. cm) and<br>size compatibility to<br>various areas of the<br>body | Min:<br>ട് 55<br>Max: 220<br>1-4 smaller pods<br>allows user to adjust<br>for curved areas of the<br>body, e.g. legs,<br>ankles, lower back. | Min: 42<br>Treats only smaller<br>single areas of the<br>body. | Min 1 Pod:<br>13<br>Max 1 Pod:<br>350<br>Max: 2 Pods: 700<br>Treats mostly large<br>flat areas of the body,<br>e.g. the back or chest. |
## 7. Performance Testing
The LightStim for Pain LED Belt results in patient contact with an electrically powered component therefore; it was tested according to 60601-1: Medical Electrical Equipment -Part 1: General requirements for basic safety and essential performance
The LightStim for Pain LED Belt includes an electronic component, and it was tested according to 60601-1-2 Medical Electrical Equipment – Part 1-2: General Requirements for Safety and Essential Performance.
Temperature testing was performed on 3 individuals. The LightStim for Pain LED Belt warmed the temperature of the skin to 40 degrees centigrade or more on all 3 individuals
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in the first 5 minutes of the treatment. Temperatures were checked every 5 minutes and fluctuated between between 40.0 and 41.8 degrees during the entire 30-minutes test.
A Usability Study was conducted with 33 male and female participants of a variety of races, between the ages of 20 and 79, with education levels varying from 900 grade to 4year college degrees. 100% of the participants correctly self-selected. 97% (32 of the 33 participants) correctly answered all 19 questions relating to the Instruction Manual and correctly demonstrated their understanding and use of the device without any difficulties.
Therefore, taking into consideration the Table for Substantial Equivalence and the Summary of Safety & Effectiveness Table, an analysis of safety, indications, intended uses, performance, and technological properties, the LightStim for Pain LED Belt K151333 raises no new issues of safety or effectiveness and has been found to be substantially equivalent to the predicate devices.
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.