Welcome to the Brave New World. Boards and chipsets and software need only ONE thing to circumvent the regs, a single disclaimer:
This product is neither manufactured nor intended for use in electronic cigarettes or personal vaporizers.
Done. Evolv can make whatever they want. They can sell it to whomever they want, preferably an electronics distribution chain with volume discounting that distributes to companies who make other things (like flashlights) besides ecigs. To be extra safe, the board would have a slider or two plates or jumper, one for pulse and one for on/off, for use in those flashlights. There really is no way that the FDA can deem a circuit board specifically manufactured for any use other than in PVs under the deeming regs.
<edit> Flashlight is but one readily used example. Toaster over could be another. Portable personal heater/glove warmer, and so on. Just because the FDA sees only a single application for a device does not mean that it can't have multiple applications. And, if I were Evolv, I would manufacture one of those, with the same boards and software, and say, "see?" THIS is our intended use, we have no control over what other manufacturers of consumer products do with our boards, but this is our intent.