The IBS Implant System II is intended to replace missing teeth to restore chewing function. The IBS Implant System II can be placed in support of single or multiple-unit restorations including; cement retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.
Device Story
IBS Implant System II (Magic Motion Abutment) is an attachment-retained prosthetic system for dental restoration; used in patients with fully edentulous maxilla. System components include Magic Motion Abutment, Housing, and O-ring. Device functions as a solid, one-piece structure to support overdenture restorations. Clinicians select collar heights based on gingival height. Device is non-sterile; requires end-user steam sterilization before surgical placement. Output is a stable prosthetic connection for dental implants, restoring chewing function. Used in clinical dental settings by licensed practitioners.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, including dimensional comparison analysis, biocompatibility testing (ISO 10993-1, -10, -11), and end-user steam sterilization validation (AAMI TIR12:2010).
Technological Characteristics
Materials: Ti-6AL-4V Eli (ASTM F-136) for abutment/housing; silicon rubber for O-ring. Connection: Internal hex. Design: One-piece solid structure. Sterilization: End-user steam sterilization. Dimensions: 4.0mm diameter, 10.05-16.05mm length, 1.4-7.4mm cuff height.
Indications for Use
Indicated for patients with missing teeth requiring single or multiple-unit restorations, including cement-retained or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. Suitable for fully edentulous maxilla. Contraindications not specified.
Regulatory Classification
Identification
An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.
Special Controls
*Classification.* Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)
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Image /page/0/Picture/0 description: The image shows 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.
June 9, 2020
InnoBioSurg Co., Ltd. % April Lee Consultant Withus Group, Inc. 106 Superior Irvine, California 92620
Re: K200753
Trade/Device Name: IBS Implant System II Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: May 8, 2020 Received: May 13, 2020
Dear April Lee:
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.
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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 medical devices and radiation-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.
for Srinivas Nandkumar, Ph.D. Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K200753
Device Name IBS Implant System II
#### Indications for Use (Describe)
The IBS Implant System II is intended to replace missing teeth to restore chewing function. The IBS Implant System II can be placed in support of single or multiple-unit restorations including; cement retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
| <div> <span> ☑ Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> |
|-----------------------------------------------------------------------------------|
| <div> <span> ☐ Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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#### 510(k) Summary
#### Submitter
InnoBioSurg Co., Ltd. Bo-Yeon Lim 44-19, Techno 10-ro, Yuseong-gu Daejeon, 34027 Republic of Korea Email: bylim@ibsimplant.com Tel. +82-42-933-2879 Fax. +82-42-933-2881
### Device Information
- . Trade Name: IBS Implant System II
- . Common Name: Endosseous dental implant abutment
- Classification Name: Endosseous dental implant abutment .
- . Product Code: NHA
- . Panel: Dental
- . Regulation Number: 872.3630
- . Device Class: Class II
- Date prepared: 06/09/2020 .
### Predicate Devices:
The subject device is substantially equivalent to the following predicate devices:
#### Primary Predicate
K162099, IBS Implant System II manufactured by InnoBioSurg Co., Ltd.
#### Indication for Use
The IBS Implant System II is intended to replace missing teeth to restore chewing function. The IBS Implant System II can be placed in support of single or multiple-unit restorations including; cement retained, screw retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.
### Device Description
This submission is to add new magic Motion Abutment to the previously cleared device, IBS Implant System II (K162099).
The Magic Motion Abutment system is composed of Magic Motion Abutment, Housing and O-ring. The Magic Motion Abutment is a device made of a material such as Ti-6AL-4V Eli (Conforming to ASTM Standard F-136). Magic Motion is an attachment-retained prosthetic product, which is used with patients with a fully edentulous maxilla. It is a one-piece structure. Various collar heights of the magic motions can be selected based on the gingival height. Magic motion does not have movement and it is a solid type.
### Withus Group Inc April Lee 106 Superior Irvine, CA 92620 USA Email: withus6664@gmail.com Phone: 1-909-274-9971 Fax: 1-909-460-8122
Official Correspondent
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The diameters and lengths of the Magic Motion Abutment are below:
### Magic Motion
| Product name | Diameter (Ø) | Cuff (mm) | Length (mm) |
|--------------|-----------------------------------------------------|-----------|-------------|
| Magic Motion | 3.9 (Cleared in K162099 -<br>Changed product codes) | 1 | 9.65 |
| | | 2 | 10.65 |
| | | 3 | 11.65 |
| | | 4 | 12.65 |
| | | 5 | 13.65 |
| | | 6 | 14.65 |
| | | 7 | 15.65 |
| | | 8 | 16.65 |
| | 4 (Newly Added) | 1.4 | 10.05 |
| | | 2.4 | 11.05 |
| | | 3.4 | 12.05 |
| | | 4.4 | 13.05 |
| | | 5.4 | 14.05 |
| | | 6.4 | 15.05 |
| | | 7.4 | 16.05 |
The subject device is compatible with the following Implants:
| K number | Compatible Implants |
|----------|-----------------------|
| K162099 | IBS Implant System II |
The Magic Motion Abutment is provided non-sterile and packaged separately. The abutment should be sterilized before use. The purpose of this submission is to change the product codes for the current cleared magic motion abutments add the new Magic Motion Abutments.
# Materials
The Magic Motion Abutment and Housing are fabricated from Ti-6AL-4V Eli. The Magic Motion O-ring is fabricated from silicon rubber.
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### Summaries of Technology Characteristics:
| | Subject Device | Primary Predicate |
|-----------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Innobiosurg Co., Ltd | Innobiosurg Co., Ltd |
| Device Name | Magic Motion Abutment | IBS Implant System II |
| 510(k) No. | K200753 | K162099 |
| Indications for Use | The IBS Implant System II is intended to<br>replace missing teeth to restore chewing<br>function. The IBS Implant System II can<br>be placed in support of single or<br>multiple-unit restorations including;<br>cement retained, screw retained, or<br>overdenture restorations, and terminal or<br>immediate abutment support for fixed<br>bridgework. This system is for one or<br>two stage surgical procedures. This<br>system is intended for delayed loading. | The IBS Implant System II is intended to<br>replace missing teeth to restore chewing<br>function. The IBS Implant System II can<br>be placed in support of single or<br>multiple-unit restorations including;<br>cement retained, screw retained, or<br>overdenture restorations, and terminal or<br>immediate abutment support for fixed<br>bridgework. This system is for one or<br>two stage surgical procedures. This<br>system is intended for delayed loading. |
| Design | Image: Design of Subject Device | Image: Design of Primary Predicate |
| Connection Type | Internal Hex-Connected | Internal Hex-Connected |
| Hex | 3.6 | 3.47 |
| Diameters (Ø) | 4.0 mm | 3.9 mm |
| Lengths | 10.05-16.05 mm | 9.65-16.65 mm |
| G/H Length (mm) | 1.4-7.4 mm | 1-8 mm |
| Angle (°) | No Angulation | No Angulation |
| Material | Titanium Alloy<br>(ASTM F 136) | Titanium Alloy<br>(ASTM F 136) |
| Surface | Machine | Machine |
| Sterilization | End User Sterilization | End User Sterilization |
| Diameters and<br>Heights of Magic<br>Motion Housing | Diameter: 5.3 (Ø)<br>Heights: 3.0 mm | Diameter: 5.0 (Ø)<br>Heights: 3.0 mm |
K162099, IBS Implant System II by InnoBioSurg Co., Ltd.
# Similarities
The subject Magic Motion Abutment has a substantially equivalent intended use as the identified predicates. The subject device is similar in fundamental scientific technology, principle of operation, design, technology, functions, dimensions and materials.
# Differences
- New Magic Motion Abutment: Compared to the primary predicate device, the subject device's diameter and hex of subject device is larger. In addition, the neck and head diameter of the subject magic motion abutment is a bit larger than the predicate. Because of the larger neck and head diameter, the design of the
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head shape of the subject magic motion abutment is changed to more round. This difference is to improve the connection of Magic Motion and Magic Motion Housing and doesn't impact product's substantial equivalence.
- New Magic Motion Housing: The height and diameter of subject device is larger than primary predicate device, however, it doesn't impact product's substantial equivalence.
# Non-Clinical Data
Design Control Activity Summary was provided including dimensional comparison analysis with respective acceptance criteria to demonstrate that the subject device is substantially equivalent with the predicate device.
Below tests were performed for predicate device and leveraged for the subject device:
- End User Steam Sterilization Test according to AAMI TIR12:2010 referenced in K140806 ●
- Biocompatibility tests according to ISO 10993-1, ISO 10993-10 and ISO 10993-11 ● referenced in K162099
The results of the above tests have met the criteria of the standards and demonstrated the substantial equivalence with the predicate device. Non-clinical tests followed the recommendations in the "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implant and Endosseous Dental Implant abutments".
# Conclusion
The subject Magic Motion Abutment constitutes a substantially equivalent medical device, meeting all the declared requirements of its intended use. This abutment has the same intended use and fundamental scientific technology as its predicate device. Therefore, Magic Motion Abutment and its predicate are 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.