K233104 · Sofwave Medical, Ltd. · OHV · Dec 22, 2023 · General, Plastic Surgery
Device Facts
Record ID
K233104
Device Name
SofWave System
Applicant
Sofwave Medical, Ltd.
Product Code
OHV · General, Plastic Surgery
Decision Date
Dec 22, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4590
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The SofWave System is indicated for use as a non-invasive dermatological aesthetic treatment to improve facial lines and wrinkles, lift the eyebrow, and lift lax submental (beneath the chin) and neck tissue; which can also affect the appearance of lax tissue in the submental and neck regions for subjects aged 22 and older. The SofWave System is also intended for short-term improvement in the appearance of cellulite and the treatment of acne scars. The SofWave System is indicated to improve the appearance of skin laxity on the upper arms.
Device Story
The SofWave System is a non-invasive aesthetic device using high-intensity, non-focused ultrasound to treat skin laxity and wrinkles. The system comprises a console (power, cooling, UI) and an applicator containing an array of ultrasonic transducers. The applicator emits continuous acoustic waves to heat the dermis, causing controlled thermal damage, while an integrated active cooling element protects the skin surface. Used in clinical settings by trained professionals, the device provides visual feedback via an LCD touchscreen. The output is thermal energy delivered to the dermis; this stimulates tissue response to improve skin appearance. The device is used for facial, submental, neck, and upper arm treatments. Clinical benefits include improved skin laxity, reduced wrinkles, and scar treatment with a favorable safety profile.
Clinical Evidence
Prospective, single-arm, multicenter study (n=46) evaluated upper arm skin laxity improvement. Subjects received 2 treatments (1-3 weeks apart) with 3-month follow-up. Primary endpoint: 93% of treated arms showed improvement via blinded photo review. Secondary endpoints: average improvement from severe to moderate laxity on a 5-point scale; 93% of arms rated 'improved' or 'very much improved' on the Global Aesthetic Improvement Scale. No device-related adverse events reported; anticipated responses (erythema, edema) resolved spontaneously.
Indicated for non-invasive dermatological aesthetic treatment in subjects aged 22 and older. Uses include: improvement of facial lines and wrinkles, eyebrow lifting, lifting of lax submental and neck tissue, short-term improvement of cellulite appearance, treatment of acne scars, and improvement of skin laxity on the upper arms.
Regulatory Classification
Identification
A Focused Ultrasound Stimulator System for Aesthetic Use is a device using focused ultrasound to produce localized, mechanical motion within tissues and cells for the purpose of producing either localized heating for tissue coagulation or for mechanical cellular membrane disruption intended for noninvasive aesthetic use.
Special Controls
*Classification.* Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Focused Ultrasound Stimulator System for Aesthetic Use.” See § 878.1(e) for the availability of this guidance document.
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December 22, 2023
Sofwave Medical Ltd. % Janice Hogan Partner Hogan Lovells US LLP 1735 Market St. Floor 23 Philadelphia, Pennsylvania 19103
Re: K233104
Trade/Device Name: SofWave System Regulation Number: 21 CFR 878.4590 Regulation Name: Focused Ultrasound Stimulator System For Aesthetic Use Regulatory Class: Class II Product Code: OHV Dated: September 26, 2023 Received: September 26, 2023
Dear Janice Hogan:
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 (the 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 available 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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Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,
# Francisco Delgado -S 2023.12.22 09:25:16 -05'00'
for Long Chen, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices
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Enclosure
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Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2023 See PRA Statement below
#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Indications for Use
510(k) Number (if known) K233104
Device Name
SofWave System
Indications for Use (Describe)
The SofWave System is indicated for use as a non-invasive dermatological aesthetic treatment to improve facial lines and wrinkles, lift the eyebrow, and lift lax submental (beneath the chin) and neck tissue; which can also affect the appearance of lax tissue in the submental and neck regions for subjects aged 22 and older. The SofWave System is also intended for short-term improvement in the appearance of cellulite and the treatment of acne scars. The SofWave System is indicated to improve the appearance of skin laxity on the upper arms.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <span style="text-decoration: underline;">☑</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
# SofWave Medical's SofWave System
# Submitter's Name, Address, Telephone Number, Contact Person, and Date Prepared
SofWave Medical Ltd. 1 Ha-Otsma St. Yokneam Ilit, Israel 2069200
Submission Correspondent: Janice M. Hogan Hogan Lovells US LLP janice.hogan@hoganlovells.com (267) 675-4611
Date Prepared: November 28, 2023
## Name of Device
SofWave System
#### Common or Usual Name
Focused Ultrasound Stimulator System for Aesthetic Use
#### Classification Name
21 CFR 878.4590 (Focused Ultrasound Stimulator System for Aesthetic Use), Class II, product code OHV
## Predicate Device
SofWave Medical's SofWave System (K231537)
## Technological Characteristics
The SofWave System is an ultrasound system intended for aesthetic purposes. The system generates high frequency ultrasonic pulses that elevate the temperature in the dermis layer and cause controlled isolated areas of thermal damage.
The SofWave System consists of two main functional components: 1) the console, and 2) the applicator. The console includes the power sources, cooling unit, electrical components, loT, and the user interface. The applicator is comprised of an array of ultrasonic transducers that emit continuous acoustic waves and an active cooling element that is used to cool the skin area in contact with the applicator. The applicator is connected by a flexible cable to the console.
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# Intended Use / Indications for Use
The SofWave System is indicated for use as a non-invasive dermatological aesthetic treatment to improve facial lines and wrinkles, lift the eyebrow, and lift lax submental (beneath the chin) and neck tissue; which can also affect the appearance of lax tissue in the submental and neck regions for subjects aged 22 and older. The SofWave System is also intended for short-term improvement in the appearance of cellulite and the treatment of acne scars. The SofWave System is indicated to improve the appearance of skin laxity on the upper arms.
# Comparison of Technological Characteristics with the Predicate Device
The SofWave System has similar technological characteristics compared to the predicate device. The subject SofWave device is almost identical to the previous SofWave device that was cleared in K231537, except minor hardware and software changes that do not significantly affect clinical functionality or performance specifications of the device and have been verified and tested. The treatment parameters or energy specifications of the device remain identical to those cleared in K231537. The purpose of this 510(k) notification is to expand the indications for use to include improvement of the appearance of skin laxity on the upper arms. This additional indication for use does not require any additional hardware or software changes to the device.
| | Subject device:<br>SofWave System | Predicate device:<br>SofWave System (K231537) |
|---------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Regulation | 878.4590 | 878.4590 |
| Product code | OHV | OHV |
| Indications for Use | The SofWave System is indicated for use as a non-invasive dermatological aesthetic treatment to improve facial lines and wrinkles, lift the eyebrow, and lift lax submental (beneath the chin) and neck tissue; which can also affect the appearance of lax tissue in the submental and neck regions for subjects aged 22 and older. The SofWave System is also intended for short-term improvement in the appearance of cellulite and the treatment of acne scars. The SofWave System is indicated to improve the appearance of skin laxity on the upper arms. | The SofWave System is indicated for use as a non-invasive dermatological aesthetic treatment to improve facial lines and wrinkles, lift the eyebrow, and lift lax submental (beneath the chin) and neck tissue; which can also affect the appearance of lax tissue in the submental and neck regions for subjects aged 22 and older. The SofWave System is also intended for short-term improvement in the appearance of cellulite and the treatment of acne scars. |
| Technology | High intensity non-focused ultrasound | High intensity non-focused ultrasound |
| System components | Console that includes the power sources, electrical components and user interface (touchscreen) Handpiece | Console that includes the power sources, electrical components and user interface (touchscreen) Handpiece |
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| | Subject device:<br>SofWave System | Predicate device:<br>SofWave System (K231537) |
|-------------------------------|--------------------------------------------------|--------------------------------------------------|
| Energy delivered /<br>fluence | 3-5 Joule per PZT<br>(or 6-10 J/cm²) | 3-5 Joule per PZT<br>(or 6-10 J/cm²) |
| Epidermal impact | Non-invasive | Non-invasive |
| Treatment area | 15 or 35 mm² | 15 or 35 mm² |
| User interface | LCD touch screen graphic user<br>interface | LCD touch screen graphic user<br>interface |
| Electrical safety /<br>EMC | IEC 60601-1 Compliant<br>IEC 60601-1-2 Compliant | IEC 60601-1 Compliant<br>IEC 60601-1-2 Compliant |
| Input power | 100-240 VAC, 60Hz, 10A | 100-240VAC, 60Hz, 10A |
#### Performance Data
#### Nonclinical Testing
The following nonclinical testing was conducted to support substantial equivalence of the SofWave System to its predicate device. In all instances, the SofWave System functioned as intended.
- Biocompatibility of the patient-contacting components of the device was established in accordance with ISO 10993-1.
- Software verification and validation was performed and demonstrated that the software performs as intended.
- Electrical safety and electromagnetic compatibility were established in accordance with IEC 60601-1-2, IEC 60601-1, IEC 60601-1-6, and IEC 60601-2-62.
- . Functional bench testing was conducted to verify that the modifications to the device did not affect the device performance.
## Clinical Testing
To support the expansion of the device's indications for use, a single arm, prospective, selfcontrolled, multicenter study was conducted to evaluate the SofWave device for improving the appearance of skin laxity on the upper arms. A total of 46 subjects were enrolled and treated on both upper arms at 4 sites in the United States. Subjects attended 2 treatment sessions (1-3 weeks apart) and a follow-up visit 3 months after the final treatment visit.
The primary efficacy evaluation found that 93% of treated arms showed improvement in upper arm skin laxity, as assessed by the correct identification of the pre- and post-treatment photographs by at least 2 of 3 blinded reviewers. Consistent with the results for the primary efficacy endpoint, the secondary efficacy endpoint results also supported device effectiveness for the expanded indications for use. As assessed by the blinded reviewers, on average the treated arms improved from severe skin laxity at baseline to moderate skin laxity after treatment, based on a 5-point upper arm skin crepiness/laxity grading scale. Additionally, 93% of the treated arms were improved or very much improved in appearance, as rated by the blinded reviewers using the Global Aesthetic Improvement Scale.
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The clinical study also demonstrated a favorable safety profile for the SofWave System for use in improving the appearance of skin laxity on the upper arms. Throughout the study, there were no device-related adverse events. Anticipated tissue responses mostly consisted of erythema and edema that resolved spontaneously after treatment. Most subjects reported none to mild levels of pain during treatment and no discomfort afterward, further confirming that the device was welltolerated.
## Conclusion
SofWave has the same general intended use and similar indications, technological characteristics, and principles of operation as the company's previously cleared SofWave System (K231537). The minor technological differences between the subject and the predicate device do not raise different questions of safety or effectiveness. Performance testing of the device has demonstrated that the device performs as intended and thus is substantially equivalent.
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.