K213594 · Elesta S.P.A · GEX · May 3, 2022 · General, Plastic Surgery
Device Facts
Record ID
K213594
Device Name
ECHOLASER X4
Applicant
Elesta S.P.A
Product Code
GEX · General, Plastic Surgery
Decision Date
May 3, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The ECHOLASER X4 laser system is indicated for use to necrotize or coagulate soft tissue through interstitial irradiation in medicine and surgery in cardiovascular thoracic surgery (excluding the heart and the pericardial sac), dermatology, ear-nose-throat surgery, gastroenterology, general surgery, gynecology, head and neck surgery, plastic surgery, orthopedics, pulmonology, radiology, and urology, at a wavelength of 1064 nm.
Device Story
Echolaser X4 is a diode laser system emitting 1064nm light in continuous wave mode; used for interstitial soft tissue necrosis or coagulation. System transmits laser energy via optical fibers; supports 1-4 simultaneous fibers with independent power adjustment. Operated by physician via footswitch; used in clinical settings across multiple surgical specialties. Device provides thermal destruction of target tissue; benefits include minimally invasive tissue treatment. No changes to hardware or performance from predicate K181510; modification limited to updated indications for use language.
Clinical Evidence
No clinical data provided. Substantial equivalence is based on identical technological characteristics and performance to the primary predicate device.
Technological Characteristics
Diode laser source; 1064nm wavelength (±10%); 28W max power (7W/fiber); continuous wave mode; TEC cooling; SMA 905 output port; Class 4 laser; Class 2 FDA safety classification. Includes emergency switch, remote interlock, and internal power monitoring. Software-controlled emission via footswitch.
Indications for Use
Indicated for patients requiring soft tissue necrosis or coagulation via interstitial irradiation across various surgical specialties including cardiovascular thoracic (excluding heart/pericardial sac), dermatology, ENT, gastroenterology, general, gynecology, head and neck, orthopedics, pulmonology, radiology, and urology.
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.
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May 3, 2022
Elesta Spa % Maurizio Pantaleoni RA/QA Consultant Maurizio Pantaleoni Via Borgo Santa Cristina 12 Imola, Bologna 40026 Italy
Re: K213594
Trade/Device Name: Echolaser X4 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: April 4, 2022 Received: April 6, 2022
Dear Maurizio Pantaleoni:
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.
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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 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-reporting-
combination-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.
Purva Pandya, D.Eng. 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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# Indications for Use
510(k) Number (if known) K213594
Device Name ECHOLASER X4
#### Indications for Use (Describe)
The ECHOLASER X4 laser system is indicated for use to necrotize or coagulate soft tissue through interstitial irradiation in medicine and surgery in cardiovascular thoracic surgery (excluding the heart and the pericardial sac), dermatology, ear-nose-throat surgery, gastroenterology, general surgery, gynecology, head and neck surgery, plastic surgery, orthopedics, pulmonology, radiology, and urology, at a wavelength of 1064 nm.
**Type of Use (Select one or both, as applicable)**
| ☑ Remediation Use (Part 21 CFR 601.21 and P) | ☐ Same-Time Studies (21 CFR 601.21 and s) |
|----------------------------------------------|-------------------------------------------|
|----------------------------------------------|-------------------------------------------|
> 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. General Information
Applicant:
ELESTA SpA Via Baldanzese, 17 Calenzano (FI) Italy 50041, Italy Tel. +39 055 8826807 Fax +39 055 7766698
Establishment Registration Number: 3015077548
| Contact for the application: | Maurizio Pantaleoni |
|------------------------------|--------------------------------------|
| | Via Borgo Santa Cristina 12 |
| | Imola (BO) 40026, Italy |
| | Tel. +39 3484435155 |
| | Email: maurizio.pantaleoni@gmail.com |
Summary Preparation Date: October 22, 2021
#### Name & Classification 2.
Common Name/Trade Name/Device Name: ECHOLASER X4
Classification names Powered laser surgical instrument (GEX)
Laser surgical instrument for use in general and plastic surgery and Regulation Name in dermatology (21 CFR§878.4810).
Product Code GEX
CLASS: II
### 3. Predicate Devices
| Predicate | Applicant | Device name | 510(k) Number |
|-----------|--------------------------------------|----------------------------------|---------------|
| Primary | EL.EN. ELECTRONIC<br>ENGINEERING SPA | ECHOLASER X4 | K181510 |
| Reference | Medtronic Navigation Inc. | Visualase Thermal Therapy System | K181859 |
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The device modification is related to the ECHOLASER X4, already cleared by the Agency with K181510.
Requested change is related to a language revision of the Intended use of ECHOLASER X4, in order to reflect the description of applications of a predicate device which was unavailable at the of the previous submission K181510. A reference predicate (K181859) is provided in support of the change in the intended use language.
No other changes have been made to the existing ECHOLASER X4 cleared by the Agency under K181510.
The technical features, the design, the performance and safety of the ECHOLASER X4 device are not affected by this device modification since they are precisely the same .
# 4. Device description
The ECHOLASER X4 is a medical device equipped with a diode laser source emitting at 1064nm wavelength in CW mode. The laser beam is transmitted via optical fibers . The operator can use 1 to 4 (or 1 to 2 in case of two channels model) fibers simultaneously, one independent from the other in both activation and power adjustment. Laser activation is controlled by footswitch.
# 5. Indications for Use
The ECHOLASER X4 laser system is indicated for use to necrotize or coagulate soft tissue through interstitial irradiation in medicine and surgery in cardiovascular thoracic surgery (excluding the heart and the vessels in the pericardial sac), dermatology, ear-nose-throat surgery, gastroenterology, general surgery, gynecology, head and neck surgery, orthopedics, pulmonology, radiology, and urology, at a wavelength of 1064nm.
Explanation of Differences: The above indications for use language is different than the indications for use language present in the primary predicate K181510. However, the intended use of the subject and predicate devices is identical (i.e., thermal destruction of the soft tissue of interest). Moreover, the modified language is comparable to the language present in the indications for use of the reference predicate and does not raise different questions of safety and effectiveness.
# 6. Summary of Technological Similarities/Differences
The device modification is related to the language revision of the Intended use of ECHOLASER X4. No other relevant changes have been made to the existing ECHOLASER X4 cleared by the Agency under K181510.
| | Subject Device | Primary Predicate Device | Comments |
|------------------------------------|-------------------------------------------------------------|----------------------------------------------------------|-------------------------------|
| Product Name | ECHOLASER X4 | ECHOLASER X4 | NA |
| 510(K) No. | K213594 | K181510 | NA |
| Applicant | Elesta SpA | El.En. SpA | NA |
| Classification | 21 CFR§878.4810, Laser<br>Surgical Instrument for | 21 CFR§878.4810, Laser<br>Surgical Instrument for Use in | Identical |
| | Subject Device | Primary Predicate Device | Comments |
| | Use in General and Plastic<br>Surgery and in<br>Dermatology | General and Plastic Surgery<br>and in Dermatology | |
| Product Code | GEX | GEX | Identical |
| Indications for | The ECHOLASER X4 laser | The ECHOLASER X4 laser | Comparable, do not raise |
| Use | system is indicated for use | system is intended for use in | different questions of safety |
| | to necrotize or coagulate | cutting, vaporization, ablation | and effectiveness since the |
| | tissue<br>through<br>soft | and coagulation of soft tissue | intended use are the same. |
| | interstitial irradiation<br>in | in conjunction with | |
| | medicine and surgery in | endoscopic equipment | |
| | cardiovascular<br>thoracic | (including laparoscopes , | |
| | surgery (excluding<br>the | hysteroscopes, | |
| | heart and the vessels in the | bronchoscopes, gastroscopes, | |
| | pericardial<br>sac), | cystoscopes and | |
| | ear-nose-<br>dermatology, | colonoscopies), in | |
| | throat<br>surgery, | incision/excision, | |
| | gastroenterology, general | vaporization, ablation and | |
| | surgery, gynecology, head | coagulation of soft tissue in | |
| | and neck surgery, plastic | contact and non-contact | |
| | orthopedics,<br>surgery, | open surgery (with or without | |
| | pulmonology, radiology, | a handpiece), and in the | |
| | and<br>urology,<br>at<br>a | treatment and/or removal of | |
| | wavelength of 1064nm. | vascular lesions (tumors). | |
| Laser Type | DIODE | DIODE | Identical |
| Wavelength (μm) | 1064 nm ± 10% | 1064 nm ± 10% | Identical |
| Output mode | Multimode | Multimode | Identical |
| Maximum | 28W (up to 7 W for each | 28W (up to 7 W for each laser | Identical |
| delivered Power | laser fiber) | fiber) | |
| Stability of the | ±20% | +20% | Identical |
| output power | | | |
| level | | | |
| Mode of | Continuous wave | Continuous wave | Identical |
| operation | | | |
| Output power | 0.5W | 0.5W | Identical |
| increments | | | |
| Cooling | TEC | TEC | Identical |
| Emission | Controlled by footswitch | Controlled by footswitch | Identical |
| Aiming Beam | Diode | Diode | Identical |
| Laser Type<br>● | 630-670 nm | 630-670 nm | |
| Wavelength<br>● | < 3 mW | < 3 mW | |
| Maximum<br>● | | | |
| Delivered | | | |
| Output Power | | | |
| Output port | SMA 905 | SMA 905 | Identical |
| Introducers | Elesta – El AG2 020 620 | Biopsybell TR2111.9EC | Comparable in material, |
| | Elesta - El AG2 0020 640 | Biopsybell TR2120.8EC | construction, and processing |
| | | | and thus do not raise |
| | | | different questions of safety |
| | | | and effectiveness. |
| Laser Type (per<br>IEC 60825-1) | Class 4 | Class 4 | Identical |
| | Subject Device | Primary Predicate Device | Comments |
| Laser Safety<br>Classification FDA | Class 2 | Class 2 | Identical |
| Power source<br>(General) | 110-120V AC / 50-60Hz | 110-120V AC / 50-60Hz | Identical |
| Operating<br>temperature<br>range | 10°C – 35°C | 10°C – 35°C | Identical |
| Emergency<br>switch | Yes | Yes | Identical |
| Key activation of<br>laser output | Yes | Yes | Identical |
| Remote Interlock | Yes | Yes | Identical |
| Power ON/OFF<br>visual indicator | Yes | Yes | Identical |
| Laser emission<br>Indicator | Yes | Yes | Identical |
| Internal laser<br>power monitor | Yes | Yes | Identical |
| Fiber insertion<br>interlock | Yes | Yes | Identical |
| Audio warning<br>signal level | Fixed at HIGH | Fixed at HIGH | Identical |
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# 7. Non-Clinical Testing
The following non-clinical tests were performed:
i) Biocompatibility assessment per ISO 10993.
No additional non-clinical testing is needed since the subject device is identical to the primary predicate.
# 8. Clinical Testing
No additional clinical testing is needed since the subject device is identical to the primary predicate.
# 9. Conclusions
In light of evidence summarized above and based on classification, intended use, technological characteristics and performance data, the subject device is substantially equivalent to the primary 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.