K200464 · Lg Electronics.Inc · OAP · Jul 23, 2020 · Physical Medicine
Device Facts
Record ID
K200464
Device Name
LG Pra. L Derma LD Scalp Care
Applicant
Lg Electronics.Inc
Product Code
OAP · Physical Medicine
Decision Date
Jul 23, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The LG Pra.L Derma LD Scalp Care is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of IIa-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.
Device Story
Dome-shaped helmet device for home use; treats androgenetic alopecia via low-level light therapy. Input: electrical power; Transformation: 250 light sources (laser diodes 650-667nm; LEDs 645-665nm) deliver 5mW per point to scalp; Output: light energy absorbed by scalp. Operated by patient via controller (power, mode selection, treatment start/pause) or smartphone app via Bluetooth. Device features automatic power-off post-treatment and battery charging cradle. Benefits patient by promoting hair growth; healthcare provider does not interact with device output.
Clinical Evidence
Bench testing only. Performance evaluated via wavelength, output power, and irradiance measurements. Safety validated per ES 60601-1, IEC 60601-1-2, and IEC 60825-1. Usability study with 34 participants demonstrated ability to understand labeling and safely operate the device.
Technological Characteristics
Dome-shaped helmet; 250 light sources (laser diodes 650-667nm, LEDs 645-665nm); 5mW output per point. Connectivity: Bluetooth to smartphone app. Standards: ES 60601-1 (safety), IEC 60601-1-2 (EMC), IEC 60825-1 (laser safety), ISO 14971 (risk management), ISO 62366-1 (usability).
Indications for Use
Indicated for males with androgenetic alopecia (Hamilton-Norwood IIa-V) and females with androgenetic alopecia (Ludwig-Savin I-II, Fitzpatrick Skin Phototypes I-IV) to promote hair growth.
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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July 23, 2020
LG Electronics, Inc. % Do-Hyun Kim CEO BT Solutions, Inc. 904-ho, Eonju-ro 86-gil 5 Gangnam-gu Seoul, 06210 Korea, Republic Of
Re: K200464
Trade/Device Name: LG Pra. L Derma LD Scalp Care Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared Lamp Regulatory Class: Class II Product Code: OAP Dated: February 24, 2020 Received: February 26, 2020
Dear Do-Hyun Kim:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Colin Kejing Chen Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
510(k) Number (if known) K200464
Device Name LG Pra.L Derma LD Scalp Care
Indications for Use (Describe)
The LG Pra.L Derma LD Scalp Care is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of IIa-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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# 6. 510(k) Summary
# 6.1 General Information
| Applicant/Submitter: | LG Electronics, Inc. |
|----------------------|----------------------------------------------------------------------------------------------------------------------------|
| Address: | 222 LG-ro Jinwi-myeon,<br>Pyeongtaek-Si, Gyeonggi-do, 17709<br>Rep. of Korea (South Korea)<br>Tel: +82-2-3777-5497 |
| Contact Person: | Do Hyun Kim, BT Solutions, Inc. |
| Address: | Unit 904, Eonju-ro 86gil 5,<br>Gangnam-gu, Seoul 06210, Korea.<br>Tel: +82-2-538-9140<br>Email: smanager@btsolutions.co.kr |
| Preparation Date: | February 24, 2020 |
# 6.2 Device Name and Code
| Device Trade Name: | LG Pra.L Derma LD Scalp Care |
|----------------------|-------------------------------------------------|
| Model Name: | HGN1 |
| Common Name: | Lamp, non-heating, for promotion of hair growth |
| Classification Name: | Infrared Lamp |
| Product Code: | OAP |
| Regulation Number: | 890.5500 |
| Classification: | Class II |
| Review Panel: | General & Plastic Surgery (ODE) |
# 6.3 Technical Characteristics in Comparison to Predicate Devices
| | Proposed Device | K162071 |
|----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Company | LG Electronics Inc. | EGlobal, LLC |
| Product name | LG Pra.L Derma LD Scalp Care | IllumiFlow Laser Cap |
| Product code | OAP | OAP |
| Regulation<br>number | 890.5500 | 890.5500 |
| Classification | Class II | Class II |
| Intended Use | The LG Pra.L Derma LD Scalp Care is<br>indicated to promote hair growth in males<br>with androgenetic alopecia who have<br>Hamilton-Norwood Classifications of IIa-V<br>and females with androgenetic alopecia<br>who have Ludwig-Savin Classifications of | IllumiFlow is indicated to promote hair<br>growth in males with androgenic alopecia<br>who have Norwood-Hamilton<br>classifications of IIa to V or females with<br>androgenic alopecia who have Ludwig-<br>Savin Classification of I-II and both with |
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| | I-II and Fitzpatrick Classification of Skin<br>Phototypes I to IV. | Fitzpatrick Skin Phototypes I to IV. |
|----------------------------------|--------------------------------------------------------------------|--------------------------------------|
| Intended user | Both sex | Both sex |
| Type of use | OTC | OTC |
| Technological<br>characteristics | | |
| Mode of operation | Low-level laser diodes and light emitting<br>diodes | Low-level laser diodes |
| Wavelength | LD: 650 ~ 667nm<br>LED: 645 ~ 665nm | 650 nm |
| No. of light<br>source | 250 | 272 |
| Power output | 5 mW per light output point | 5 mW per light output point |
| Usage duration | | |
| Treatment<br>duration | 18 minutes or 27 minutes | 30 minutes |
### LG Pra.L Derma LD Scalp Care 510(k) Summary
Reference Device: Apira Science, Inc's iGrow II Hair Growth System (K140931).
## 6.4 Device Description
The LG Pra.L Derma LD Scalp Care utilizes a combination of laser diodes and light-emitting diodes (LEDs). 5-milliwatt laser diodes emit light from a range of wavelengths of about 650 nm to 667 nm, which is combined with light from 5 milliwatt LEDs emitting wavelengths from about 645nm to 665 nm. The combined light is absorbed by the scalp.
The LG Pra.L Derma LD Scalp Care is a dome shaped helmet with laser diodes and LEDs on the inside surface. By connecting a controller, the user can power the device on and off, start and pause treatment, and change the care mode. In addition, there is a charging cradle to place the controller in to charge the battery, and the status of the battery is displayed on the controller's indicator. The device can also be connected wirelessly via Bluetooth to a Smartphone App in order to manage treatment. After a treatment is completed, the LG Pra.L Derma LD Scalp Care device can automatically power off the laser, LEDs and controllers.
## 6.5 Indications / Intended Use
The LG Pra.L Derma LD Scalp Care is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of IIa-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.
## 6.6 Performance Data
Non-clinical tests: Measurement of wavelength, average output power, and total irradiance (power density, in units of J/cm2) of treatment LEDs and LDs were Other performance, such as safety of laser product, electromagnetic performed. compatibility and electrical safety, etc, were tested using following consensus standards:
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- -Basic safety and essential performance of the LG Pra.L Derma LD Scalp Care is tested and evaluated according to the FDA-recognized consensus standard, ES 60601-1.
- Effect to the device by electromagnetic disturbances were tested and evaluated according to the FDA-recognized consensus standard IEC 60601-1-2.
- -Safety of laser product is evaluated in accordance with IEC 60825-1: 2014.
- Risk management was recorded by referring to ISO 14971. -
- -Usability was documented by referring to ISO 62366-1.
Testing of 34 participants was conducted showing that the participants were able to understand the user manual and box labeling and were able to safely and effectively use the device.
#### 6.7 Conclusions
The proposed device uses similar or identical technology as the predicate device and has the same intended use. Based upon the predicted overall performance characteristics for LG Pra.L Derma LD Scalp Care, LG Electronics, Inc. believes that the technological characteristics of LG Pra.L Derma LD Scalp Care do not raise new types of questions regarding its safety and efficacy for its intended use compared with the predicate device. On the basis of the information provided in this 510(k), LG Electronics, Inc. believes that the LG Pra.L Derma LD Scalp Care is substantially equivalent to the predicate device.
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.