IS Multi Unit Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as bridges.
Device Story
The IS Multi Unit Abutment System consists of premanufactured titanium dental implant abutments and associated components (cylinders, healing caps, screws). The system connects to endosseous dental implants via internal hex connections to provide a platform for multi-unit loaded restorations. Used in dental clinics by clinicians, the system supports the attachment of prosthetic bridges. The device acts as an interface between the implant fixture and the final prosthesis, facilitating tooth function restoration. Components are either supplied sterile or require steam sterilization by the user. The system provides structural support for prosthetic restorations, benefiting patients by enabling the replacement of missing teeth through implant-supported bridges.
Clinical Evidence
Bench testing only. Evidence includes fatigue testing per ISO 14801:2016 and sterilization validation per ANSI/AAMI ST79 and ISO 17665. Biocompatibility, shelf-life, and bacterial endotoxin testing were leveraged from predicate device K181138. All tests met applicable standards.
Indicated for use with dental implants to support prosthetic restorations, specifically bridges, in patients requiring dental implant-supported prosthetics.
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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Neobiotech Co., Ltd. % April Lee Consultant Withus Group Inc 106 Superior Irvine, California 92620
Re: K210903
Trade/Device Name: IS Multi Unit Abutment System Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: April 21, 2021 Received: April 26, 2021
### 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,
Andrew I. Steen Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K210903
Device Name IS Multi Unit Abutment System
Indications for Use (Describe)
IS Multi Unit Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as bridges.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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#### 510(k) Summary
#### Submitter
Neobiotech Co., Ltd. Young-Ku, Heo #204, 36, Digital-ro 27 gil Guro-gu, Seoul, 08381, South Korea Email: sypark@neobiotech.com Tel. +82-2-582-2885 Fax. +82-2-582-2883
# Official Correspondent
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
#### Device Information
- Trade Name: IS Multi Unit Abutment System
- Common Name: Endosseous Dental Implant Abutment
- Classification Name: Abutment, Implant, Dental, Endosseous
- . Product Code: NHA
- Panel: Dental
- Regulation Number: 21 CFR 872.3630
- Device Class: Class II
- Date Prepared: 07/22/2021
#### Predicate Devices:
Primary Predicate
- K161689, OSSTEM Implant System-Abutment by Osstem Implant Co.,Ltd. .
#### Reference Devices
- . K120530, DENTIN Dental Implant System by Dentin Implant Technologies Ltd.
- K180282, MIS Internal Hex Dental Implant System by MIS Implant Technologies Ltd.
- K181138, IS-III active System by Neobiotech Co., Ltd.
- K182091, Osstem Abutment System by Osstem Implant Co.,Ltd. ●
- K182194, UV Active Implant System by DIO Corporation ●
#### Indications for Use:
IS Multi Unit Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as bridges.
{4}------------------------------------------------
#### Device Description
IS Multi Unit Abutments are premanufactured dental implant abutments directly connected to the endosseous dental implant with internal hex connections (multiple tooth). IS Multi Unit Abutment System is made of Titanium ELI according to ASTM F136.
IS Multi Unit Abutment System is composed of IS Multi Unit Abutment, IS Multi Unit Angled Abutment, Multi Unit Abutment Cylinder, Multi Unit Healing Cap, Multi Unit Temporary Cylinder, IS Multi Unit Angled Abutment Screw and Cylinder Screw.
All Multi-Unit Abutments (Straight/Angled) are intended only for multi-unit loaded restoration.
| Name | Diameter<br>(Ø) | Cuff(mm) | Length(mm) | Angulation |
|-------------------------------------|-----------------|-------------------------|------------|------------|
| IS Multi Unit Abutment | Ø 4.8 | 1.0/2.0/3.0/4.0/5.0/6.0 | - | 0° |
| IS Multi Unit Angled Abutment | Ø 4.8 | 1.0/2.0/3.0/4.0 | - | 17°,30° |
| Multi Unit Abutment Cylinder | Ø 4.8 | - | 5.0 | 0° |
| Multi Unit Healing Cap | Ø 4.8 | - | 4.1 | 0° |
| Multi Unit Temporary Cylinder | Ø 4.8/6.0 | - | 11.0 | 0° |
| IS Multi Unit Angled Abutment Screw | Ø2.3 | - | 8.3 | 0° |
| Cylinder Screw | Ø2.3 | - | 4.1 | 0° |
The dimensions of abutments are as following:
The tolerance of dimension shall be within ± 1% range.
| K number | System Name | Diameter (Ø) | Length(mm) |
|----------|--------------------------|-------------------------------|-----------------------------|
| K181138 | IS-III active System | Ø 4.0/4.5/5.0/5.5 | 7.3/8.5/10.0/11.5/13.0/15.0 |
| | | Ø 6.0/7.0 | 7.3/8.5/10.0/11.5/13.0 |
| K120503 | CMI Implant IS II active | Ø 4.0/4.5/5.0/5.5/6.0/7.0/8.0 | 7.3/8.5/10.0/11.5/13.0/15.0 |
The IS Multi Unit Abutment System is compatible with following implant system:
#### The features of each abutment are as following:
| Name | Uses | Surface<br>Treatment | Connection |
|----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------|-------------------|
| IS Multi Unit Abutment | It is connected with Fixture and it supports | N/A | Screw<br>Retained |
| IS Multi Unit Angled<br>Abutment | prosthesis which restores tooth function. | N/A | Hex,<br>Non-Hex, |
| Multi Unit Abutment Cylinder | It is connected with Multi Unit Abutment<br>(Straight/Angled) in order to cement final<br>prosthesis. | N/A | Non-Hex |
| Multi Unit Healing Cap | It is connected with Multi Unit Abutment (Straight/<br>Angled type) in order to protect Multi Unit<br>Abutment (Straight/Angled) and inner hole during<br>the healing period. | N/A | Screw<br>Retained |
| Multi Unit Temporary<br>Cylinder | It is connected with Multi Unit Abutment (Straight/<br>Angled) and it supports prosthesis which restores<br>tooth function as a temporary dental prosthesis. | N/A | Non-Hex |
| IS Multi Unit Angled<br>Abutment Screw | It is used to fix Multi Unit Angled Abutment at the<br>top of Fixture. | N/A | Screw<br>Retained |
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| Cylinder Screw | It is used to fix Multi Unit Abutment Cylinder or<br>Multi Unit Temporary Cylinder at the top of Multi<br>Unit Abutment (Straight/ Angled). | N/A | Screw<br>Retained |
|----------------|---------------------------------------------------------------------------------------------------------------------------------------------|-----|-------------------|
|----------------|---------------------------------------------------------------------------------------------------------------------------------------------|-----|-------------------|
Multi Unit Healing Cap is supplied sterile, and intended for singled use. Other Multi Unit components are supplied non sterile, to be steam sterilized by the user according to the labeling, and intended for single use.
IS Multi Unit Angled Abutment, Multi Unit Temporary Cylinder, Multi Unit Abutment Cylinder are provided with IS Multi Unit Abutment Screw or Cylinder Screw in packing.
And IS Multi Unit Abutment and Multi Unit Healing Cap have built in screw as an integral system. All of above products including enclosed product are packed separately for convenience.
#### Materials:
All subject devices are made of Titanium ELI of ASTM F136.
#### Summaries of Technological Characteristics: 1) IS Multi Unit Abutment
| | Subject Device | Primary Predicate Device | Reference Device |
|------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Company | Neobiotech Co., Ltd | Osstem Implant Co., Ltd. | Dentin Implants Technologies<br>Ltd. |
| Device Name | IS Multi Unit Abutment System | OSSTEM Implant System-<br>Abutment | DENTIN Dental Implant System |
| 510(k) Number | K210903 | K161689 | K120530 |
| Classification<br>Name | Abutment, Implant, Dental,<br>Endosseous | Abutment, Implant, Dental,<br>Endosseous | Abutment, Implant, Dental,<br>Endosseous |
| Product Code | NHA | NHA | NHA |
| Regulation<br>Number | 872.3630 | 872.3630 | 872.3630 |
| Intended Use | IS Multi Unit Abutment System<br>is intended for use with a dental<br>implant to provide support for<br>prosthetic restorations such as<br>bridges. | The OSSTEM Implant System –<br>Abutment is intended for use<br>with a dental implant to provide<br>support for prosthetic<br>restorations such as crowns,<br>bridges, or overdenture | DENTIN® Dental Implants<br>System is indicated for use in<br>surgical and restorative<br>applications for placement in the<br>bone of the upper or lower jaw<br>to provide support<br>for prosthetic devices, such as<br>artificial teeth, in order to restore<br>the patient's<br>chewing function. DENTIN®<br>Dental Implants System is<br>indicated also for<br>immediate loading when good<br>primary stability is achieved and<br>with appropriate<br>occlusal loading.<br>Two Stage Implants: CLASSIC,<br>RAPID, PRESTIGE.<br>One Stage Implants: ONE<br>PIECE<br>DENTIN® ONEPIECE Implants<br>3.0 mmd are intended for<br>placement at the mandibular<br>central and lateral incisors and<br>maxillary and lateral incisors. |
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| | | | Indicated also for denture<br>stabilization using multiple<br>implants. |
|------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Design 1 | Image: Design 2 | Image: Design 3 |
| Abutment/Impl<br>ant Interface<br>Connection<br>Type | Internal Non-Hex | Internal Non-Hex | Internal Non-Hex |
| Diameters (Ø) | 4.8 | 4.8 | 5.0 |
| Cuff(mm) | 1.0/2.0/3.0/4.0/5.0/6.0 | 1.0/2.0/3.0/4.0/5.0 | 6.0 |
| Post Height<br>(mm) | 2.2 | - | - |
| Surface<br>Treatment | N/A | TiN-Coating | TiN-Coating |
| Sterilization | End-User Moist Heat<br>Sterilization | - | - |
| Principle of<br>Operation | It is indicated for cement<br>retained bridge restorations. | It is indicated for screw-retained<br>single tooth or cement retained<br>single tooth and bridge<br>restorations. | It is indicated for screw-retained<br>single tooth or cement retained<br>single tooth and bridge<br>restorations. |
| Shelf Life | N/A | N/A | N/A |
| Similarities | The subject and primary predicate have same functions, materials, principle of operation and similar<br>indications for use, design and dimensions. | | |
| Differences | There are differences in Indications for Use, design, cuff length and surface treatment between the<br>subject device and primary predicate.<br>- Indications for Use: The subject device doesn't include the "O-ring" as the component; therefore, it is<br>not intended to use for overdenture. Also, since the subject devices are only indicated for multi-unit<br>restorations, it is not intended to use for crowns. As the indications for use of the subject device are in<br>range of the predicate's, it doesn't affect the substantial equivalence.<br>- Design, Cuff length, and Surface treatment: To support Ø4.8X6.0mm of subject abutment and surface<br>treatment, K120530 was added as the reference device. These differences don't affect product's<br>fundamental functions and substantial equivalence. | | |
# 2) IS Multi Unit Angled Abutment
| | Subject Device | Reference Device |
|---------------|-------------------------------|---------------------------------------------------------|
| Company | Neobiotech Co., Ltd | Dio Corporation |
| Device Name | IS Multi Unit Angled Abutment | UV Active Implant System-<br>Angled Multi-Unit Abutment |
| 510(k) Number | K210903 | K182194 |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
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| Design | | | |
|--------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------|----------------------------------------------------------------------------------------------------------------|
| Abutment/Implant<br>Interface<br>Connection Type | Internal Hex | Internal Non-Hex | Internal Hex |
| Diameters (Ø) | 4.8 | | 4.8 |
| Cuff(mm) | 1.0/2.0/3.0/4.0 | | 1.5/2.5/3.5/4.5/5.5 |
| Post Height(mm) | 2.2 | | - |
| Angle(°) | 17/30 | | 20/30 |
| Surface Treatment | N/A | | N/A |
| Sterilization | End-User Moist Heat Sterilization | | - |
| Principle of<br>Operation | It is indicated for cement retained bridge<br>restorations. | | It is indicated for screw-retained single tooth<br>or cement retained single tooth and bridge<br>restorations. |
| Shelf Life | N/A | | N/A |
| Similarities | The subject and reference devices have same intended use, functions, materials, surface<br>treatment, general shape (design) and dimensions. | | |
| Differences | There are slightly different designs and dimensions between subject and reference devices.<br>These differences don't affect product's fundamental functions and substantial equivalence. | | |
# 3) Multi Unit Abutment Cylinder
| | Subject Device | Reference Device |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|
| Company | Neobiotech Co., Ltd | MIS Implants Technologies Ltd. |
| Device Name | Multi Unit Abutment Cylinder | Cementing cap for Multi-Unit |
| 510(k) Number | K210903 | K180282 |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Multi Unit Abutment Cylinder design | Image: Cementing cap for Multi-Unit design |
| Diameters (Ø) | 4.8 | 4.8 |
| Lengths(mm) | 5.0 | 3.3 |
| Post Height(mm) | 5.0 | 3.3 |
| Surface Treatment | N/A | TiN-Coating |
| Sterilization | End-User Moist Heat Sterilization | Gamma irradiation |
| Principle of<br>Operation | It is used to support the prosthesis, and it is<br>connected with Multi Unit Abutment with<br>Cylinder Screw. | It is used to support the prosthesis, and it is<br>connected with Multi Unit Abutment with<br>Cylinder Screw. |
| Shelf Life | N/A | 5 years |
| Similarities | The subject and reference devices have same intended use, functions, materials, surface<br>treatment, general shape (design) and dimensions. | |
| Differences | There are slightly different design and length. These differences don't affect product's<br>fundamental functions and substantial equivalence. | |
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# 4) Multi Unit Healing Cap
| | Subject Device | Reference Device |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Company | Neobiotech Co., Ltd | MIS Implants Technologies Ltd. |
| Device Name | Multi Unit Healing Cap | Healing Cap |
| 510(k)<br>Number | K210903 | K180282 |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Subject Device Design | Image: Reference Device Design |
| Diameters(Ø) | 4.8 | 4.8 |
| Length (mm) | 4.1 | 4.3 |
| Post Height<br>(mm) | 4.1 | 4.3 |
| Surface<br>Treatment | N/A | TiN-Coating |
| Sterilization | Gamma irradiation | - |
| Principle of<br>Operation | It is connected to the dental Abutment during<br>soft tissue healing period combined with<br>Implant. It should be removed when the<br>superstructure is set up. | It is connected to the dental Abutment during<br>soft tissue healing period combined with<br>Implant. It should be removed when the<br>superstructure is set up. |
| Shelf Life | 5 years | 5 years |
| Similarities | The subject and reference devices have same intended use, functions, materials, general shape<br>(design) and dimensions. | |
| Differences | There are slightly different design and length. These differences don't affect product's fundamental<br>functions and substantial equivalence. | |
## 5) Multi Unit Temporary Cylinder
| | Subject Device | Reference Device |
|---------------------------|-------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|
| Company | Neobiotech Co., Ltd | DIO Corporation |
| Device<br>Name | Multi Unit Temporary Cylinder | Temporary Cylinder |
| 510(k)<br>Number | K210903 | K182194 |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Subject Device Design | Image: Reference Device Design |
| Diameters<br>(Ø) | 4.8/6.0 | 5.4 |
| Length<br>(mm) | 11.0 | 12.0 |
| Post Height<br>(mm) | 11.0 | 12.0 |
| Surface<br>Treatment | N/A | N/A |
| Sterilization | End-User Moist Heat Sterilization | - |
| Principle of<br>Operation | It is designed to serve as a temporary dental<br>prosthesis during the healing process until a<br>permanent bridges are made. | It is designed to serve as a temporary dental<br>prosthesis during the healing process until a<br>permanent crown is made. |
| Shelf Life | N/A | N/A |
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| Similarities | The subject and reference devices have same intended use, functions, materials, and general shape<br>(design). |
|--------------|---------------------------------------------------------------------------------------------------------------------------------------------------|
| Differences | There are slightly different design and dimensions. These differences don't affect device's<br>fundamental functions and substantial equivalence. |
# 6) IS Multi Unit Angled Abutment Screw
| 6) IS Multi Unit Angled Abutment Screw | | |
|----------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------|
| | Subject Device | Reference Device |
| Company | Neobiotech Co., Ltd | Dio Coporation |
| Device Name | IS Multi Unit Angled Abutment Screw | Multi Angled Abutment Screw |
| 510(k)<br>Number | K210903 | K182194 |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Subject Device Design | Image: Reference Device Design |
| Diameters(Ø) | 2.3 | 2.2 |
| Length (mm) | 8.3 | 6.0 |
| Surface<br>Treatment | N/A | N/A |
| Sterilization | End-User Moist Heat Sterilization | |
| Principle of<br>Operation | This product is a screw for connected with<br>Abutment and fixture. | This product is a screw for connected with<br>Abutment and fixture. |
| Shelf Life | N/A | N/A |
| Similarities | The subject and reference devices have same intended use, functions, materials, and general shape<br>(design). | |
| Differences | There are slightly different design and dimensions. These differences don't affect device's<br>fundamental functions and substantial equivalence. | |
# 7) Cylinder Screw
| | Subject Device | Reference Device |
|------------------------|------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------|
| Company | Neobiotech Co., Ltd | Dio Coporation |
| Device Name | Cylinder Screw | Cylinder Screw |
| 510(k) Number | K210903 | K182194 |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Cylinder Screw | Image: Cylinder Screw |
| Diameters(Ø) | 2.3 | 2.15 |
| Length (mm) | 4.1 | 4.0 |
| Surface Treatment | N/A | N/A |
| Sterilization | End-User Moist Heat Sterilization | - |
| Principle of Operation | This product is a screw for connected with Multi Unit Abutment (Straight/Angled) and Cylinder. | This product is a screw for connected with Multi Unit Abutment (Straight/Angled) and Cylinder. |
| Shelf Life | N/A | N/A |
| Similarities | The subject and reference devices have same intended use, functions, materials, and general shape (design). | |
| Differences | There are slightly different design and dimensions. These differences don't affect device's fundamental functions and substantial equivalence. | |
{10}------------------------------------------------
#### Similarities:
IS Multi Unit Abutment System has same device characteristics with the Primary predicate devices, OSSTEM Implant System-Abutment (K161689) and commercially available products based on the indications for use, the technology used, the material composition employed and performance characteristics as predicate devices. The subject device has been supposed to performance and product validations prior to release. Testing including performance and fatigue test has been finished to ensure the devices comply with the applicable International standards and US FDA Guidance.
### Differences:
There are differences in Indications for Use, design, cuff length and surface treatment between the subject device and primary predicate.
- Indications for Use: The subject device doesn't include the "O-ring" as the component; therefore, it is not intended to use for overdenture. As the indications for use of the subject device are in range of the predicate's, it doesn't affect the substantial equivalence.
- Design, Cuff length, and Surface treatment: To support Ø4.8X6.0mm of subject abutment and surface treatment, K182194 and K120530 were added as the reference device. These differences don't affect product's fundamental functions and substantial equivalence.
### Non-clinical testing data:
The subject device was tested to evaluate its substantial equivalence according to the following standards.
- End User Sterilization Validation Test Report on IS Multi Unit Abutment Angled Abutment ● (Hex type) according to ANSI/AAMI ST79, ISO 17665-1, ISO 17665-2, ISO 11737-1, ISO 11737-2, and ISO 11138-1
- . Fatigue Test Report according to ISO 14801:2016
Below tests were performed for predicate devices and leveraged for the subject device:
- Sterilization Validation Test on Healing Abutments according to ISO 11137-1,2,3 referenced in K181138
- Shelf-Life Test on Healing Abutments according to ASTM F1980 referenced in K181138
- Biocompatibility Test according to ISO 10993-1 referenced in K181138
- Bacterial Endotoxin Testing on Healing Abutments according to ANSI/AAMI ST72:2011, USP ● <161>, and USP <85>, referenced in K181138
The results of the above tests have met the criteria of the standards, and demonstrated the substantial equivalence with the predicate device.
The non-clinical testing results demonstrate that the subject device is substantially equivalent to the predicate device.
### Conclusion
IS Multi Unit Abutment System constitutes a substantially equivalent medical device, meeting all the declared requirements of its intended use. This system has the same intended use and fundamental scientific technology as its predicate devices. Therefore, IS Multi Unit Abutment System and its predicates are substantially equivalent.
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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.