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U.S. Department of Health and Human Services

Inspections, Compliance, Enforcement, and Criminal Investigations

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IntelSource Group Inc dba Electro Medical Technologies LLC 6/25/09


hhsbluebirdDepartment of Health and Human Services

Public Health Service
Food and Drug Administration
  Center for Devices and
Radiological Health
9200 Corporate Blvd
Rockville. MD 20850



JUN 25 2009


Matthew Wolfson
IntelSource Group, Inc.
3104 E Camelback Rd #528
Pboenix, AZ 85016

RE: Wellness Pro 2010

Dear Mr. Wolfson:

The Food and Drug Administration (FDA) has learned that your firm is marketing the
Wellness Pro 2010 in the United States (U.S.) for new uses without marketing clearance or
approval, in violation of the Federal Food, Drug, and Cosmetic Act (the Act). FDA reviewed
your website, www.electromedtech.com. for the Wellness Pro 2010 on June 16,2009, and
has also reviewed the WellnessPro Brochure that is available for purchase on your website.

The Wellness Pro 2010 is a device within the meaning of section 201 (h) of the Act, 21 U.S.C.
321(h), because it is intended for use in the diagnosis of disease or other conditions or in the
cure, mitigation, treatment, or prevention of disease, or are intended to affect the structure or
function of the body.

The Wellness Pro 2010 is adulterated under section 501(f)(1)(B) of the Act, 21 U.S.C.
351(f)(1)(B), because you do not have an approved application for premarket approval
(PMA) in effect pursuant to section 515(a) of the Act 21 U.S.C. 360e(a), or an approved
application for an investigational device exemption (IDE) under section 520(g) of the Act, 21
U.S.C.360j(g). Your device is also misbranded under section 502(0) of the Act 21 U.S.C.
352(0), because you did not notify the agency of your intent to introduce the device into
commercial distribution for the new uses discussed below, as required by section 510(k) of
the Act 21 U.S.C. 360(k) and 21 CFR 807.81(a)(3)(ii).

Specifically, we cleared your premarket notification (510(k)) for the Wellness Pro 2010,
K062616, for relief of chronic, intractable pain, and for adjunctive treatment of post-surgical
or post-traumatic acute pain. However, your website and the referenced product brochure
state that the Wellness Pro 2010 is effective for the reduction of pain in a "wide range" of
specific conditions, such as Alzheimer's and Parkinson's diseases, and can be used for
''injury trauma rehabilitation," "detoxification," and "increased[d] blood flow." Your
website also contains ICD-9 codes indicating that the Wellness Pro 2010 can be used for a
long list of diseases and conditions, such as "brachial neuritis;' "tear lateral meniscus,"
"urinary incontinence," and "cerebral palsy." These statements represent a major change or
modification in the intended use of your device that require a new premarket notification.
21 CFR 807.81(a)(3)(ii).

FDA requests that IntelSource Group immediately cease marketing the Wellness Pro 2010 for
unapproved uses such as those described above. You should take prompt action to correct
these violation(s). Failure to promptly correct these violation(s) may result in regulatory
action being initiated by the Food and Drug Administration without further notice. These
actions include. but are not limited to seizure, injunction, and lor civil money penalties.

Please submit a written response to this letter within 15 working days from the date you
receive this letter, describing what steps you have taken to correct the problem and how you
plan to prevent this from happening again. Please list all promotional materials for Wellness
Pro 2010 containing claims for unapproved uses such as those described above, and explain
your plan for discontinuing such claims. Please direct your response to:

Jennifer Medicus
Office of Compliance
W066 RM2626
10903 New Hampshire Ave.
Silver Spring, MD 20993

The violations discussed in this letter do not necessarily constitute an exhaustive list. It is
your responsibility to ensure that your promotional materials for the Wellness Pro 2010
comply with each applicable requirement of the Act and FDA implementing regulations.

Sincerely yours,


Timothy A. Ulatowski
Office of Compliance
Center for Devices and
Radiological Health