K213889 · Asclepion Laser Technologies GmbH · GEX · Apr 22, 2022 · General, Plastic Surgery
Device Facts
Record ID
K213889
Device Name
PicoStar
Applicant
Asclepion Laser Technologies GmbH
Product Code
GEX · General, Plastic Surgery
Decision Date
Apr 22, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The PicoStar laser system is indicated for the following at the specified wavelength: 532 nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange. Indicated for benign pigmented lesions removal for Fitzpatrick skin types I-III. 1064 nm: Removal of tattoos for all skin types (Fitzpatrick I-V) to treat the following tattoo colors: black, brown, green, blue and purple. Indicated for benign pigmented lesions removal for Fitzpatrick skin types I-IV. Only with microspot handpiece, indicated for treatment of wrinkles in Fitzpatrick Skin Types I-IV. Only with microspot handpiece. indicated for the treatment of acne scars in Fitzpatrick Skin Types II-V.
Device Story
PicoStar is a solid-state Nd:YAG laser system delivering 532 nm and 1064 nm wavelengths; pulse durations up to 400 ps; repetition rates up to 10 Hz. System includes console, articulated arm, and interchangeable handpieces (full spot or microspot). Operated by clinicians in a professional setting via touch screen interface and footswitch. Laser energy targets pigment particles via selective photothermolysis; microspot handpiece facilitates skin resurfacing for wrinkles and acne scars. Output parameters (energy density, repetition rate) are user-selected to achieve therapeutic effects. Device provides non-invasive treatment for dermatological conditions.
Clinical Evidence
No clinical data. Substantial equivalence supported by non-clinical performance testing, including electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), laser safety (IEC 60601-2-22), software validation (IEC 62304), and risk management (ISO 14971). Biocompatibility established via predicate device.
Technological Characteristics
Nd:YAG laser; 532 nm and 1064 nm wavelengths; max pulse duration 400 ps; max repetition rate 10 Hz. Delivery via articulated arm and handpieces. System controlled by touch screen. Complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-22, IEC 62304, and ISO 14971.
Indications for Use
Indicated for tattoo removal (Fitzpatrick I-III for 532nm; I-V for 1064nm), benign pigmented lesion removal (Fitzpatrick I-III for 532nm; I-IV for 1064nm), wrinkle treatment (Fitzpatrick I-IV, microspot only), and acne scar treatment (Fitzpatrick II-V, microspot only).
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.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
April 22, 2022
Asclepion Laser Technologies GmbH Carolin Kuehling Head of Quality and Regulatory Affairs Bruesseler Strasse 10 Jena, Thuringia 07747 Germany
Re: K213889
Trade/Device Name: PicoStar 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: December 9, 2021 Received: December 13, 2021
Dear Carolin Kuehling:
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.
{1}------------------------------------------------
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-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.
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
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known) K213889
Device Name PicoStar
Indications for Use (Describe)
The PicoStar laser system is indicated for the following at the specified wavelength:
532 nm:
Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange. Indicated for benign pigmented lesions removal for Fitzpatrick skin types I-III.
1064 nm:
Removal of tattoos for all skin types (Fitzpatrick I-V) to treat the following tattoo colors: black, brown, green, blue and purple.
Indicated for benign pigmented lesions removal for Fitzpatrick skin types I-IV.
Only with microspot handpiece, indicated for treatment of wrinkles in Fitzpatrick Skin Types I-IV.
Only with microspot handpiece. indicated for the treatment of acne scars in Fitzpatrick Skin Types II-V.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
## CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
## *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
Image /page/3/Picture/0 description: The image shows the logo for Asclepion Laser Technologies. The word "Asclepion" is written in a large, gray, sans-serif font. Below it, the words "Laser Technologies" are written in a smaller, gray, sans-serif font. To the right of the word "Asclepion" is a cluster of seven dark blue circles of varying sizes.
# 510(k) SUMMARY
# [As Required by 21 CFR 807.92]
| Applicant: | ASCLEPION LASER TECHNOLOGIES GmbH<br>Bruesseler Str. 10<br>07747 Jena, Germany |
|------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) Contact Person: | Mrs. Carolin Kuehling<br>Head of Quality and Regulatory Affairs<br>Phone: +49 3641 77 00 213<br>Fax:+49 3641 77 00 102<br>E-mail: carolin.kuehling@asclepion.com |
| Preparation Date: | December 8th, 2021 |
| Common Name: | Nd:YAG laser |
| Device Trade Name: | PicoStar |
| Classification Name: | Laser surgical instrument for use in general and plastic surgery and in<br>Dermatology |
| Classification | Class II |
| Regulation Number | 21 CFR 878.4810 |
| Product Code | GEX |
| Submission Type: | Traditional 510(K) |
Page 1 of 4
{4}------------------------------------------------
Image /page/4/Picture/0 description: The image shows the logo for Asclepion Laser Technologies. The logo features the word "Asclepion" in a gray, sans-serif font, with the words "Laser Technologies" in a smaller font below it. To the right of the word "Asclepion" is a cluster of blue circles of varying sizes, arranged in a semi-circular pattern. The logo is simple and modern, and the blue circles add a touch of visual interest.
#### Predicate Device Discovery Pico Family (K172376)
Device Description: PicoStar is a solid state laser capable of delivering energy at wavelengths of 1064 nm, or 532 nm at short durations of max 400 picoseconds (ps) and repetition rates up to 10 Hz. The device system is composed of a system console, an articulated arm, and attached delivery handpieces (full spot or microspot). The laser output at each wavelength is delivered to the skin through an articulated arm delivery system terminated by a handpiece. The PicoStar is controlled via a touch screen display housed in the front of the device. The control panel enables the user to select the desired energy density level and repetition rate. Emission is triggered by means of a footswitch.
### Indications for Use:
The PicoStar laser system is indicated for the following at the specified wavelength:
- 532 nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, vellow and orange. Indicated for benign pigmented lesions removal for Fitzpatrick skin types I-III. 1064 nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple. Indicated for benign pigmented lesions removal for Fitzpatrick skin types I-IV. Only with microspot handpiece, indicated for treatment of wrinkles in Fitzpatrick Skin Types I-IV. Only with microspot handpiece, indicated for the treatment of acne scars in Fitzpatrick Skin Types II-V.
{5}------------------------------------------------
Image /page/5/Picture/0 description: The image shows the logo for Asclepion Laser Technologies. The word "Asclepion" is written in a gray, sans-serif font. Below it, the words "Laser Technologies" are written in a smaller, gray, sans-serif font. To the right of the word "Asclepion" is a cluster of blue circles of varying sizes, arranged in a pattern that suggests a burst or spray.
# Summary of technological characteristics
| | Predicate Device | | Subject Device | |
|----------------------------|-------------------------------------|-----------|-----------------------------------|-------------------------------|
| Model Name | Discovery Pico Family | | PicoStar | |
| Manufacturer | Quanta System SPA | | Asclepion Laser Technologies GmbH | |
| Laser Type | Nd:YAG | | Nd:YAG | |
| Wavelength (nm) | 532 | 1064 | 532 | 1064 |
| Delivery System | Articulated arm | | Articulated arm | |
| Max. Pulse duration (ps) | up to 400 | up to 450 | up to 400 | up to 400 |
| Spot size (mm) | up to 12 round<br>up to 9x9 squared | | up to 5 round | up to 16 round<br>7x7 squared |
| Max Energy (mJ) | 300 | 800 | 300 | 800 |
| Pulse Repetition rate (Hz) | Max 10 Hz | | Max 10 Hz | |
| Microspot handpiece | Available | | Available | |
### Non-clinical Performance Data:
The following performance data were applied in support of the substantial equivalence determination:
- . ISO 60601-1: Medical electrical equipment – Part 1: General requirements for safety and essential performance
- . ISO 60601-1-2 Medical electrical equipment - Part 1-2: General requirements for safety and essential performance - Collateral standard: Electromagnetic compatibility - Requirements and tests
- IEC 62304 Medical Device Software Software life cycle processes ●
- IEC 60601-2-22 Medical electrical equipment Part 2: Particular requirements for the safety of ● diagnostic and therapeutic laser equipment
- . ISO 14971 Medical devices - Application of risk management to medical devices
Software verification and validation testing was conducted and documentation is 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".
PicoStar passed all the required testing and is in compliance will all applicable sections of the abovementioned performance standards.
# Biocompatibility:
The biocompatibility of PicoStar is established based on the predicate device.
{6}------------------------------------------------
Image /page/6/Picture/0 description: The image shows the logo for Asclepion Laser Technologies. The logo features the word "Asclepion" in gray, with the words "Laser Technologies" in a smaller font size underneath. To the right of the text is a cluster of blue circles of varying sizes, arranged in a scattered pattern.
## Clinical Performance Data: None
# Comparison with predicate device
The PicoStar and the predicate device have the same intended use with similar indications for use.
The PicoStar Laser System presents the same or similar technological characteristics as its predicate devices, including the laser type, wavelengths, device design, pulse width, frequency, spot sizes and system components. Any minor differences do not present any new types of safety or effectiveness questions since the PicoStar parameters are similar to the ones of the predicates. Further, PicoStar performance has been demonstrated in non-clinical performance data, and results confirm the safety and performance of the device. The PicoStar device and its predicate operate with the same mechanism of action based on selective photothermolysis of pigment particles using laser energy. Therefore, the PicoStar has the same intended use and similar indications for use, technological characteristics, and principles of operation as the predicate devices. The PicoStar is substantially equivalent to the predicate device.
# Summary
It is demonstrated that the Picostar performs as intended and 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.