K213524 · Cytonsys, Inc. · ILY · Aug 10, 2022 · Physical Medicine
Device Facts
Record ID
K213524
Device Name
CytonPro-5000
Applicant
Cytonsys, Inc.
Product Code
ILY · Physical Medicine
Decision Date
Aug 10, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5500
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The model CytonPro-5000 laser emits energy in the infrared spectrum to provide topical heating to elevate tissue temperature for temporary relief of muscle and joint pain, muscle spasm and stiffness associated with arthritis. It also increases blood circulation and relaxes muscle tissue.
Device Story
CytonPro-5000 is a non-invasive diode laser system for professional healthcare use. Device consists of a control unit and a treatment probe connected via optic fiber. System requires connection to a laptop running proprietary software to operate. Mechanism of action involves emitting infrared energy at 1064nm wavelength, supplemented by a 650nm red pointing diode (<3 mW). The probe is held 8 cm from the patient's skin. The device delivers topical heating to elevate tissue temperature, which provides temporary relief of muscle/joint pain, muscle spasms, and stiffness, while increasing blood circulation and relaxing muscle tissue. Healthcare providers operate the device, controlling treatment cycles (10 cycles of 1 minute each). The device benefits patients by providing therapeutic heat for pain management.
Clinical Evidence
Bench testing only. Testing included software verification and validation, electrical safety (ANSI/AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 62304, IEC 60601-2-22, IEC 60825-1), and temperature testing. Temperature testing on five subjects demonstrated the device successfully induced therapeutic topical heating within 100 seconds at 800mW/cm^2 and within four minutes at 300mW/cm^2, with skin temperature maintained within controlled limits.
Indicated for patients requiring topical heating for temporary relief of muscle and joint pain, muscle spasm, and stiffness associated with arthritis; also indicated to increase blood circulation and relax muscle tissue.
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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August 10, 2022
Cytonsys Inc Li-Da Huang President 7801 N. Lamar Blvd. ste C-59 Austin, Texas 78752
Re: K213524
Trade/Device Name: CytonPro-5000 Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared Lamp Regulatory Class: Class II Product Code: ILY Dated: October 28, 2021 Received: November 3, 2021
Dear Li-Da Huang:
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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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 (QS) 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,
Amber Ballard, PhD Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K213524
Device Name CytonPro-5000
Indications for Use (Describe)
The model CytonPro-5000 laser emits energy in the infrared spectrum to provide topical heating to elevate tissue temperature for temporary relief of muscle and joint pain, muscle spasm and stiffness associated with arthritis. It also increases blood circulation and relaxes muscle tissue.
Type of Use (Select one or both, as applicable)
| <span style="font-size:10px">☑ Prescription Use (Part 21 CFR 801 Subpart D)</span> | <span style="font-size:10px">☐ Over-The-Counter Use (21 CFR 801 Subpart G)</span> |
|------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|
|------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|
> Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
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#### 510(k) Summary
#### 1. SUBMITTER INFORMATION
Name: CytonSys Inc. 7801 N. Lamar Blvd, Suite C-59 Austin TX 78752 Tel: (512)572-0080 Date Prepared: August 9, 2022
#### 2. DEVICE
Name of Device: CytonPro-5000 Common or Usual Name: Infrared Lamp Classification Name: Infrared Lamp (21 CFR 890.5500) Regulation Number: II Product Code: ILY
### 3. PREDICATE DEVICE
- Cell Gen CG-4000 laser cleared under K080084 dated April 21, 2008 a.
## 4. INDICATIONS FOR USE
The model CytonPro-5000 laser emits energy in the infrared spectrum to provide topical heating to elevate tissue temperature for temporary relief of muscle and joint pain, muscle spasm and stiffness associated with arthritis. It also increases blood circulation and relaxes muscle tissue.
## 5. DEVICE DESCRIPTION
- a. Device Identification:
The CytonPro-5000 laser is a non-invasive, diode laser system consisting of an enclosure which contains the control unit and a treatment probe connected by an optic fiber.
- b. Device Characteristics:
- · Software
- c. Environment of Use: professional healthcare facility
- Brief Written Description of the Device: d.
- Explanation of how the device works/principle of operation:
- (a). Connect the CytonPro-5000 with your laptop.
- (b). Switch the toggle switch on the back panel.
- (c). Insert the key on the back panel too, and turn it on (horizontal).
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- Put the CD into the CD-ROM, and open the folder to view files. (d).
- Double click the "CytonPro" icon, and run the software (for (e). detailed operation, please refer to the Operator's manual).
- -Mechanism of action: the laser beam emitted by the CytonPro-5000 Laser System is a wavelength combination of 1064nm and 650nm (pointing diode). The 1064nm wavelength is invisible, and the 650nm (red) pointing diode power output is less than 3 mW and spread out over the treatment area. The suggested distance between treatment head and patients' skin is 8 cm.
- Energy source: An adapter (12Vdc, 15A, Max. 180W).
- Materials of Use e.
- General type of material used: aluminum and steel ●
- Duration and type of contact: the laser is set for 10 cycles, of 1 minute ● and 0 seconds each.
- Key Performance Specifications/Characteristics of the Device f. The CytonPro-5000 has the same wavelength with predicated devices.
# 6. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
The CytonPro-5000 and the aforementioned predicate devices are infrared lamps as defined in 21 CFR890.5500. These devices use infrared laser diodes to generate topical heating for temporary relief of muscle and joint pain. The overall safety and effectiveness of the CytonPro-5000 is not affected by differences in design from the predicate devices.
| Performance<br>Characteristic | CytonPro-5000 | Cell Gen CG-4000 |
|-------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) Number | Not assigned | K080084 |
| Indications for Use | The model CytonPro-5000<br>laser emits energy in the<br>infrared spectrum to provide<br>topical heating to elevate<br>tissue temperature for<br>temporary relief of muscle<br>and joint pain, muscle spasm<br>and stiffness associated with<br>arthritis. It also increases<br>blood circulation and relaxes | The model CG-4000 Cell<br>Gen laser emits energy in the<br>infrared spectrum to provide<br>topical heating to elevate<br>tissue temperature for<br>temporary relief of muscle<br>and joint pain, muscle spasm<br>and stiffness associated with<br>arthritis. It also increases<br>blood circulation and relaxes |
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| | muscle tissue | muscle tissue. |
|--------------------------------------|--------------------------------------|------------------------------------|
| Wavelength | 1064nm | 1064nm |
| Spectral Width | +/-5nm | +/- 5 nm |
| Beam Size | 50mm | 40mm +/- 5mm |
| Max Output Power from Treatment head | 20W | 20W |
| Max Power | 800mW/ cm^2 | 1.6 W/ cm^2 |
| Coupling | 200um optical fiber | Integrated Fiber |
| Umbilical Length | 6 ft (2 meters) | 6 ft (2 meters) |
| Minimum Bend Radius | 3 in. (75mm) | 3 in. (75mm) |
| Expected Lifetime | > 25,000 hrs | >5000 hrs |
| Max Input Power | 180W | 650VA |
| Input Voltage | 100-240VAC, 50/60 Hz | 120 V, 60Hz 5A |
| Temperature Range | Device: 20C ~ 50C<br>Skin: 30C ~ 45C | Device: 20C~ 50C<br>Skin: 30C~ 45C |
| System Weight | 4.8kg | 14kg (30.86lbs) |
The above comparison table indicates that the CytonPro-5000 is substantially equivalent to the predicate device. In addition, CytonPro-5000 passed all the electrical and safety testing according to national and international testing standards.
The wavelength of the CytonPro-5000 is exactly the same as the predicate device. The input voltage ranges from 100~240v, same as the predicate devices as well.
The max output power of the treatment head is the same as the predicate device Cell Gen CG-4000. The max power density of the CytonPro-5000 is 800mW/cm^2, less than the CG-4000, due to the slightly wider aperture of CytonPro-5000. This advanced lens design produces more evenly distributed and lower peak power density at the center.
The consumed power of the CytonPro-5000 is far less than the prior predicate device, and the weight is much lighter as well.
From the above side-by-side comparison, obviously the CytonPro-5000 is substantially equivalent to the predicate device and safer.
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## 7. PERFORMANCE TESTING (non-clinical)
Testing of the CytonPro-5000 include Software verification and validation testing. electrical safety testing, and laser testing in accordance with all applicable standards for this type of medical device.
The following testing of standards were provided in support of the substantial equivalence determination.
- a. Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
- b. Electrical Safety Testing
The CytonPro-5000 device complies with the applicable voluntary standards for Electromagnetic Compatibility and Safety. The device passed all the electrical and safety testing according to national and international standards, as below:
ANSI/AAMI ES60601-1:2005/A1:2012 IEC 60601-1-2:2014 IEC60601-1-6:2010/A1:2013 IEC 62304:2015 IEC 60601-2-22 IEC 60825-1
- Temperature Testing c.
The CytonPro-5000 induced therapeutic topical heating on the hand and foot of five subjects within 100 seconds for the 800mW/cm2 setting, and within four minutes for the 300mW/cm2 power density setting. Afterwards, the temperature of this therapeutic heating level is kept and slightly increases during this treatment protocol. However, the skin temperature is under very well controlled.
#### 8. CONCLUSION
In Consideration of the testing and comparison to the predicate device, the CytonPro-5000 has similar function, performance, energy source and intended use to the predicate device. This laser is designed to comply with the generally accepted therapeutic heat performance specifications by producing a level of tissue temperature reported in literature. Therefore, the CytonPro-5000 is substantially equivalent to the Cell Gen CG-4000.
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.