BIOSPACE BODY COMPOSITION ANALYZERS, MODELS INBODY 520, 720 AND S20
Applicant
Biospace Corporation Limited
Product Code
MNW · Cardiovascular
Decision Date
Dec 16, 2005
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.2770
Device Class
Class 2
Indications for Use
For use only in healthy subjects for Measurement Of: Estimated : Extra-Cellular Water (ECW), Intra-Cellular Water (ICW),Total Body Water, (TBW), ECW to TBW ratio, Body Fat, Body Lean + Dry Lean, Metabolic Rates, Segmental Lean Mass Actual : Weight, (except for model S20, which requires the manual entry of weight) Body Mass Index (BMI),and Impedance Values
Device Story
InBody 520, 720, and S20 are body composition analyzers using bioelectrical impedance analysis (BIA). Devices apply electrical signals to body; measure resistance and capacitance of biological tissues. High water/electrolyte content in lean tissue makes it conductive; fat/bone are poor conductors. Device processes impedance/reactance data to estimate body composition parameters (water distribution, fat, lean mass, metabolic rates). Used in clinical or health settings; operated by healthcare providers or patients. Output provided to user/provider to assess body composition. S20 requires manual weight entry; others measure weight automatically. Benefits include non-invasive assessment of body composition metrics.
Clinical Evidence
Bench and clinical testing performed. Results indicate the devices are as safe and effective as the predicate. No specific sensitivity, specificity, or p-values provided in the summary.
Technological Characteristics
Bioelectrical impedance analysis (BIA) technology. Measures resistance and capacitance. Operating frequencies: 1, 5, 50, 250, 500, 1000 kHz (varies by model). Measures impedance and reactance values. Standalone body composition analyzer form factor.
Indications for Use
Indicated for healthy subjects to measure body composition parameters including ECW, ICW, TBW, ECW/TBW ratio, body fat, lean mass, metabolic rates, segmental lean mass, weight, BMI, and impedance values.
Regulatory Classification
Identification
An impedance plethysmograph is a device used to estimate peripheral blood flow by measuring electrical impedance changes in a region of the body such as the arms and legs.
Special Controls
*Classification.* Class II (special controls). The device, when it is a body composition analyzer which is not intended to diagnose or treat any medical condition, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.
Predicate Devices
Biospace Body Composition Analyzer Model InBody 3.0 (K042528)
Submission Summary (Full Text)
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K052646
PAGE 1 OF 2
## DEC 16 2005
## EXHIBIT 2
510(k) Summary Biospace Corporation Limited 363 Yangjae-dong, Seocho-gu, Seoul 137-898, Korea Tel : +82-2-501-3939, Fax : +82-2-501-3978 Homepage : http:// www.biospace.co.kr September 20, 2005 Contact: Kichul Cha, CEO
- 1. Identification of the Device: Iuchintation of the Device Body Composition Analyzers, Models Inbody 520, Inbody 720, and Inbody S20 520, Inoody 720, and moody works on ANALYZER, BODY COMPOSITION Common/Usual Name: Body fat meter
- 2. Equivalent legally marketed devices: Biospace Body Composition Analyzer Model InBody 3.0, K042528
- 3. Indications for Use (intended use) For use only in healthy subjects for measurcment of: Estimated : Extra-Cellular Water (ECW), Intra-Cellular Water (ICW),Total Body 01: Estimatou : ECW to TBW ratio, Body Fat, Body Lean + Dry Lean, Mctabolic Rates, Segmental Lean Mass Actual : Weight, (except for model S20, which requires the manual entry of weight) Body Mass Index (BMI),and Impedance Values
- Description of the Device: Models Inbody 520, Inbody 720, and Inbody S20 are 4. Description of the or apposition analyzers. The devices determine body mipodation parameters based on bioclectrical impedance analysis (BIA). BIA relies on the differing behavior of biological tissues in response to an applied electrical on the unrently otharrerally highly conductive because it contains large amounts of bound water and electrolytes, while fat tissue and bone arc relatively poor or ovallars. By analyzing the response to clectrical signals, BIA thereby permits differentiation of lean tissue, fat, and water and, in some instances, derivation of related body composition parameters. The total impedance resulting from BIA incorporates both resistance and capacitance components.
- Safety and Effectiveness, comparison to predicate device. The results of bench 5. and clinical testing indicates that the new device is as safe and effective as the predicate devices.
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| | Biospace Body<br>Composition<br>Analyzer Model<br>InBody 3.0,<br>Predicate | Biospace Body<br>Composition<br>Analyzer Model<br>InBody 720 | Biospace Body<br>Composition<br>Analyzer Model<br>InBody S20 | Biospace Body<br>Composition<br>Analyzer Model<br>InBody 520 |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k)<br>number | K042528 | New | New | New |
| Intended<br>Use | Body<br>composition<br>analyzer | Body<br>composition<br>analyzer | Body<br>composition<br>analyzer | Body<br>composition<br>analyzer |
| Indications<br>for Use | (Healthy<br>Subjects)<br>Measurement<br>Of:<br>Estimated :<br>Extra-Cellular<br>Water(ECW),<br>Intra-Cellular<br>Water(ICW),<br>Total Body<br>Water,<br>ECW/TBW<br>Body Fat,<br>Body Lean +<br>Dry Lean,<br>Metabolic<br>Rates,<br>Segmental<br>Lean Mass<br>Actual :<br>Weight,<br>Body Mass<br>Index (BMI),<br>and<br>Impedance<br>Values:<br>5, 50, 250,<br>500kHz | (Healthy<br>Subjects)<br>Measurement<br>Of:<br>Estimated :<br>Extra-Cellular<br>Water(ECW),<br>Intra-Cellular<br>Water(ICW),<br>Total Body<br>Water,<br>ECW/TBW<br>Body Fat,<br>Body Lean +<br>Dry Lean,<br>Metabolic<br>Rates,<br>Segmental<br>Lean Mass<br>Actual :<br>Weight,<br>Body Mass<br>Index (BMI),<br>Impedance<br>Values:<br>1, 5, 50, 250,<br>500, 1,000kHz,<br>and<br>Reactance<br>Values:<br>5,50,250kHz | (Healthy<br>Subjects)<br>Measurement<br>Of:<br>Estimated :<br>Extra-Cellular<br>Water(ECW),<br>Intra-Cellular<br>Water(ICW),<br>Total Body<br>Water,<br>ECW/TBW<br>Body Fat,<br>Body Lean +<br>Dry Lean,<br>Metabolic<br>Rates,<br>Segmental<br>Lean Mass<br>Actual :<br>Weight,<br>Body Mass<br>Index (BMI),<br>Impedance<br>Values:<br>1, 5, 50, 250,<br>500, 1,000kHz,<br>and<br>Reactance<br>Values:<br>5,50,250kHz | (Healthy<br>Subjects)<br>Measurement<br>Of:<br>Estimated :<br>Extra-Cellular<br>Water(ECW),<br>Intra-Cellular<br>Water(ICW),<br>Total Body<br>Water,<br>ECW/TBW<br>Body Fat,<br>Body Lean +<br>Dry Lean,<br>Metabolic<br>Rates,<br>Segmental<br>Lean Mass<br>Actual :<br>Weight,<br>Body Mass<br>Index (BMI),<br>and<br>Impedance<br>Values:<br>5, 50, 500kHz |
| Analysis<br>Method | Bioelectrical<br>Impedance | Bioelectrical<br>Impedance | Bioelectrical<br>Impedance | Bioelectrical<br>Impedance |
| Operating<br>parameters | Frequency:<br>5, 50, 250, | Frequency: | Frequency: | Frequency: |
| | | 1, 5, 50, 250, | 1, 5, 50, 250, | 5, 50, 500kHz |
## 6. Substantial Equivalence Chart, Models Inbody 520, Inbody 720, and Inbody S20
Substantial Equivalence Chart, Models VITED C BODY COMPOSITION ANALYZERS
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Image /page/2/Picture/1 description: The image shows a logo with a stylized bird-like figure composed of three curved lines, suggesting movement or flight. To the left of the bird, there's a curved text element, possibly the name of an organization or brand. The overall design is simple and abstract, with a focus on conveying a sense of dynamism and connection to nature.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
DEC 16 2005
Biospace Corporation Limited c/o Daniel Kamm, P.E. Regulatory Engineer Kamm & Associates P.O. Box 7007 DEERFIELD IL 60015
Re: K052646
Trade/Device Name: InBody Body Composition Analyzers, Models 520, 720 and S20 Regulation Number: 21 CFR §870.2770 Regulation Name: Impedance plethysmograph Regulatory Class: II Product Code: MNW Dated: November 16, 2005 Received: November 17, 2005
Dear Mr. Kamm:
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. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such 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.
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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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This letter will allow you to begin marketing your device as described in your Section 510(k) I ms letter will anow you to begin manoting of substantial equivalence of your device to a legally premarket notification. THC I DA miding of bactuallian for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 11 you desire specific advice tor your corres on of the following numbers, based on the regulation number at the top of this letter:
| 21 CFR 876.xxxx | (Gastroenterology/Renal/Urology) | 240-276-0115 |
|-----------------|----------------------------------|--------------|
| 21 CFR 884.xxxx | (Obstetrics/Gynecology) | 240-276-0115 |
| 21 CFR 892.xxxx | (Radiology) | 240-276-0120 |
| Other | | 240-276-0100 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Also, please note the regulation entitled, "Albertation on your responsibilities under the Act from the 807.97). Tou may obtain outch general michel. Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Nancy C. Hogdon
Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known): ____K052646
Device Name: Biospace Body Composition Analyzers, Models Inbody 520, Inbody 720, and Inbody S20
Indications For Use:
For use only in healthy subjects for Measurement Of: Estimated : Extra-Cellular Water (ECW), Intra-Cellular Water (ICW),Total Body Water, (TBW), ECW to TBW ratio, Body Fat, Body Lean + Dry Lean, Metabolic Rates, Segmental Lean Mass Actual : Weight, (except for model S20, which requires the manual entry of weight) Body Mass Index (BMI),and Impedance Values
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use X (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Nancy C broadon
(Division Sign-Off Division of Reproductive. and Radiological Devices 510(k) Number.
Page 1 of 1
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.