Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories. This Device includes a dental chair and is intended for use in the dental clinic environment and is designed for use by trained dental professionals, dentists and/or dental assistants.
Device Story
Luvis Chair (LC700C) is a dental unit chair providing patient positioning and power/base support for dental instruments. Input: electrical power (100-120/220-240V), compressed air, and water. Operation: hydraulic electromotor adjusts chair seat, backrest, and headrest; pneumatically controlled valves manage air/water flow to handpieces and syringes. Output: mechanical positioning of patient; delivery of air/water to dental tools. Used in dental clinics by dentists/assistants. Controls located on Dr. Table and Assist Table allow adjustment of chair position, light, and instrument function. Benefits: provides stable, adjustable platform for dental procedures, improving clinician access and patient comfort.
Clinical Evidence
No clinical data. Bench testing only. Verification and validation included electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), biocompatibility (cytotoxicity, irritation, sensitization), and performance testing per ISO 7494-1/2 and IEC 80601-2-60. Reprocessing and waterline biofilm treatment validated per ISO 17665 and ISO 16954.
Indicated for use in dental clinic environments by trained dental professionals, dentists, and/or dental assistants to provide patient seating and power/base support for dental devices and accessories.
Regulatory Classification
Identification
A dental chair and accessories is a device, usually AC-powered, in which a patient sits. The device is intended to properly position a patient to perform dental procedures. A dental operative unit may be attached.
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Image /page/0/Picture/0 description: The image contains 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.
September 6, 2024
DENTIS CO., LTD. Kaon Kim Junior Manager 99, Seongseoseo-Ro, Dalseo-Gu Daegu. 42718 SOUTH KOREA
Re: K233921
Trade/Device Name: Luvis Chair (LC700C) Regulation Number: 21 CFR 872.6250 Regulation Name: Dental Chair and Accessories Regulatory Class: Class I, reserved Product Code: KLC, EIA Dated: August 12, 2024 Received: August 12, 2024
Dear Kaon Kim:
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 (the 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 available 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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Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 mediation-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-regulatory
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assistance/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,
# Michael E. Adjodha -S
Michael E. Adjodha, MChE, RAC, CQIA 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
Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.
Submission Number (if known)
K233921
Device Name
Luvis Chair (LC700C)
#### Indications for Use (Describe)
Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories. This Device includes a dental chair and is intended for use in the dental clinic environment and is designed for use by trained dental professionals, dentists and/or dental assistants.
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)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
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Image /page/4/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved graphic. The graphic is a stylized representation of a dental tool or a tooth.
# 510(k) Summary - K233921
[As required by 21 CFR 807.92]
## 1. Date Prepared [21 CFR 807.92(a)(1)]
September 5th, 2024.
## 2. Submitter's Information [21 CFR 807.92(a)(1)]
- Name of Applicant: DENTIS CO., LTD. 99, Seongseoseo-Ro, Dalseo-Gu, Daegu, - Address: 42718, Korea, South - Name of Manufacturer: DENTIS MEDICAL DIVISION - Address: 6, Yuram-ro, Dong-gu, Daegu, 41065, Korea, South - Contact Person: Kaon Kim / Junior Manager - Telephone No.: +82-53-583-2804 - Fax No.: +82-53-583-2806 - Email Address: kaonkim@dentis.co.kr - Registration No.: 3010373494
## 3. Trade Name, Regulation Name, Classification [21 CFR 807.92(a)(2)]
| Device Name | Luvis Chair (LC700C) |
|---------------------|------------------------|
| Regulation Number | 21 CFR 872.6640 |
| Common/Usual Name | Dental Unit Chair |
| Regulatory Class | Class I |
| Product Code | EIA |
| Classification Name | unit, operative dental |
| Panel | Dental |
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Image /page/5/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, abstract symbol that resembles a flame or a stylized letter 'O'. The overall design is simple and clean, suggesting a professional or corporate identity.
## 4. Identification of Predicate Device(s) [21 CFR 807.92(a)(3)]
The identified predicate and reference devices within this submission are shown as follow;
#### Predicate device
- 510(k) Number: K183347
- Applicant: Osstem Implant Co., Ltd.
- Device Name: K3
- Regulation Number: 21 CFR 872.6640
- Regulation Name: Dental Operative Unit and Accessories
- Regulatory Class: Class I
- Product Code: EIA
- Classification Name: unit, operative dental
#### Reference device
- K211556 - 510(k) Number: - Applicant: MeqaGen Implant Co., Ltd. - Device Name: N2 - Regulation Number: 21 CFR 872.6640 - Regulation Name: Dental Operative Unit and Accessories - Requlatory Class: Class I - Product Code: EIA
- Classification Name: unit, operative dental
The Luvis Chair (LC700C) is substantially equivalent to the predicate devices with respect to intended use, principles of operation, and technological characteristics. The subject device has the same Indications for Use and similar technological characterizes as compared to the predicate and reference devices. Therefore, the Luvis Chair (LC700C) is considered substantially equivalent to the predicate and reference devices.
#### 5. Description of the Device [21 CFR 807.92(a)(4)]
The Luvis Chair (LC700C) includes a chair used by dentists to provide seating for patients during dental procedures. It is designed to position the patient during treatment. The chair consists of a seat, backrest, and armrests that can be adjusted to accommodate the patient's position. Additionally, it may feature a headrest to offer additional support.
Dental unit chairs come equipped with various tools and attachments, including dental lights, suction devices, and air- water syringes. The chair's controls are usually located within reach of the dentist, allowing for quick adjustments during the procedure. The Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories.
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Image /page/6/Picture/0 description: The image contains the logo for DENTIS. The logo consists of an orange swirl shape on the left, followed by the word "DENTIS" in black, bold, sans-serif font. The swirl is a stylized representation of a tooth or dental element.
[Note] The handpieces and scalers are not included within the scope of this submission. Furthermore, HVE and Saliva Ejector Tips are not included within the scope of the submission.
## 1) The Luvis Chair (LC700C) is classified as shown below:
LC700C consists of the following:
| Model<br>Number | Chair Part | Unit Part | Dr. Table | Assist<br>Table | Foot<br>Controller | Note |
|-----------------|------------|----------------------------|--------------------|-----------------|--------------------|------|
| LC700C | • | •<br>Dental Light:<br>C700 | •<br>Mount<br>Type | • | • | |
2) Description of main components and specifications
The components of the Luvis Chair (LC700C) consist of following items:
| Model<br>Number | Parts | Description | Note |
|-----------------|--------------------|------------------------------------------|------------------------------------------------------------------------------------------------------------------------|
| LC700C | Chair Part | Chair Part | |
| | Unit Part | Dental Light | C700 |
| | | Instrument 1 | 3-Way Syringe |
| | Dr. Table | Instrument 2,3<br>(Air High) | 1. Air High Handpiece (Not<br>included in the submission) |
| | | Instrument 4<br>(Air Low / Elec.<br>Low) | 1. Air Low Handpiece (Not<br>included in the submission)<br>2. Elec. Low Handpiece (Not<br>included in the submission) |
| | | Instrument 5<br>(Scaler) | 1. Scaler (Not included in the<br>submission) |
| | Assist Table | Instrument 1 | Dry Air Syringe |
| | | Instrument 2 | 3-Way Syringe |
| | | Instrument 3 | HVE |
| | | Instrument 4 | Saliva Ejector |
| | Foot<br>Controller | Foot Controller | |
# 6. Indications for Use [21 CFR 807.92(a)(5)]
Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories. This device includes a dental chair and is intended for use in the dental clinic environment and is designed for use by trained dental professionals, dentists and/or dental assistants.
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Image /page/7/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved shape that resembles a flame or a stylized letter 'D'. The logo appears to be for a dental-related company or product, given the association with teeth.
## 7. Comparison of Technological Characteristics with the Predicate Device
Summary of technological characteristics of the device compared to the predicate device. [21 CFR 807.92(a)(6)]
| Applicant | DENTIS CO., LTD. | Osstem Implant Co., Ltd. | MegaGen Implant Co.,<br>Ltd. | SE Note |
|------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Device Name | Luvis Chair (LC700C) | K3 | N2 | - |
| | Subject Device | Predicate Device | Reference Device | - |
| 510(k)<br>Number | K233921 | K183347 | K211556 | - |
| Common/Usu<br>al Name | Dental Unit Chair | Unit, Operative Dental | Unit, Operative Dental | - |
| Regulation<br>Number | 21 CFR 872.6640 | 21 CFR 872.6640 | 21 CFR 872.6640 | - |
| Product Code | EIA | EIA | EIA | - |
| Class | Class I | Class I | Class I | - |
| Model<br>Number | LC700C | K3 | N2 | - |
| Indications<br>for Use | Luvis Chair is intended to<br>supply power to and serve<br>as a base for dental<br>devices and accessories.<br>This device includes a<br>dental chair and is<br>intended for use in the<br>dental clinic environment<br>and is designed for use by<br>trained dental<br>professionals, dentists<br>and/or dental assistants. | K3 is intended to supply<br>power to and serve as a<br>base for dental devices<br>and accessories. This<br>device includes a dental<br>chair and is intended for<br>use in the dental clinic<br>environment and is<br>designed for use by trained<br>dental professionals,<br>dentists and/or dental<br>assistants. | N2 is intended to supply<br>power to and serve as a<br>base for dental devices<br>and accessories. This<br>includes a dental chair and<br>is intended for use in the<br>dental clinic environment<br>and is designed for use by<br>trained dental<br>professionals, dentists<br>and/or dental assistants. | Similar |
| Dentist<br>Element Type<br>(Dr. Table<br>Type) | Mount Type | Mount Type, Cart Type | Mount Type, Cart Type | Similar |
| Unit Type | Single Type | Single Type | A Type, B Type | Same |
| Supply Mains | 100-120/220-240 Va.c.,<br>50/60 Hz | 100-120/220-240 Va.c.,<br>50/60 Hz | 100-120/220-240 Va.c.,<br>50/60 Hz | Same |
| Utility Supply | Compressed air, and<br>Water | Compressed air, and<br>Water | Compressed air, and<br>Water | Same |
| Main<br>Components | Chair Part, Unit Part,<br>Table(Dr. Table, Assist<br>Table), Chair Seat, Stool,<br>Monitor Arm, Compact<br>Console | Chair, Unit, Table, Seat,<br>Stool, Monitor Arm*,<br>Hanaro Console* (Note: K3<br>Cart* model applied ONLY) | Chair, Unit, Table, Seat,<br>Stool, Monitor Arm,<br>Operation Table | Similar |
| Dentist<br>Element<br>(Dr. Table) | 1) Accessories: 3-Way<br>Syringe<br>2) Control of Water Supply,<br>Scaler Vibration Power,<br>Table Height, Patient Chair<br>Positioning, Light On/Off,<br>Handpiece Function,<br>Timer, Mode Selection,<br>LED Display | 1) Accessories: 3-Way<br>Syringe<br>2) Control of Water Supply,<br>Scaler Vibration Power,<br>Table Height, Patient<br>Position, System Power,<br>Film Viewer, Patient Chair<br>Positioning, Light On/Off,<br>Handpiece Function,<br>Timer, Mode Selection,<br>LED Display | 1) Accessories: 3-Way<br>Syringe<br>2) Control of Water Supply,<br>Scaler Vibration Power,<br>Table Height, Patient Chair<br>Positioning, Handpiece<br>Function, Timer, LED<br>Display | Similar |
| Assist<br>Element<br>(Assist Table) | 1) Accessories: Suction<br>(Saliva Ejector, HVE), Dry<br>Air Syringe, 3-Way Syringe<br>2) Light On/Off,<br>Cup/Spittoon Water<br>Dispenser, Changing the<br>Settings, Position<br>Memories, 1 Person<br>Helper System | 1) Accessories: Saliva<br>Ejector (Small, Large), 3-<br>Way Syringe<br>2) Light On/Off,<br>Cup/Spittoon Water<br>Dispenser, Changing the<br>Settings, Position<br>Memories | 1) Accessories: Saliva<br>Ejector, HVE (Small,<br>Large), 3-Way Syringe<br>2) Second Assi Power<br>Switch, Waterline Power<br>Switch, Control of Water,<br>Light On/Off, Position<br>Memories, Spittoon Wash | Similar |
| Syringe | Dry Air Syringe, 3-Way<br>Syringe | 3-Way Syringe | 3-Way Syringe | Similar |
| Control of<br>Water and Air | Uses pneumatically<br>controlled valves to water<br>control the flow of air and<br>water.<br>On/Off and intensity<br>controlled by foot pedal | Uses pneumatically<br>controlled valves to water<br>control the flow of air and<br>water.<br>On/Off and intensity<br>controlled by foot pedal | Uses pneumatically<br>controlled valves to water<br>control the flow of air and<br>water.<br>On/Off and intensity<br>controlled by foot pedal | Same |
| Water System | City Water Supply | City Water Supply | City Water Supply | Same |
| Cleaning | Cleaning method provided<br>for Chair Upholstery, Tray<br>Table, Assist Table, Dr. Table,<br>Spittoon, Suction Filter,<br>Suction(Saliva Ejector,<br>HVE), Dry Air Syringe, 3-<br>Way Syringe, and<br>Waterline | - | Waterline cleaning<br>according to ISO 16954<br>- Waterline: Routine (Daily)<br>- Shock Treatment<br>(2weeks)<br>Water Flushing (each<br>patient) | - |
| Warmer | Heating Method: Heating<br>Coil<br>Storage Container<br>Temperature: Max. 40°C<br>Water Temperature: Avg.<br>33 ~ 35°C<br>Temperature Sensor: Bi-<br>metallic Thermostats | - | Heating Method: Heating<br>Coil<br>Storage Container<br>Temperature: Max. 40°C<br>Water Temperature: Avg.<br>33 ~ 35°C<br>Temperature Sensor: Bi-<br>metallic Thermostats | - |
| Water<br>Sanitation<br>System | Distilled water container | Distilled water container | Distilled water container | Same |
| Suction | 1) HVE (High Volume<br>Evacuator)<br>2) Saliva Ejector<br>3) 1 Person Helper System | 1) HVE (High Volume<br>Evacuator)<br>2) Saliva Ejector | 1) HVE (High Volume<br>Evacuator)<br>2) Saliva Ejector<br>3) Second Assi | Same |
| Air Pressure | 500kPa(Min) /<br>750kPa(Max) | 500kPa(Min) /<br>750kPa(Max) | 500kPa(Min) /<br>750kPa(Max) | Same |
| Water<br>Pressure | 215kPa(Min) /<br>275kPa(Max)<br>(2.5 ± 0.3 kgf/cm2) | 250kPa(Min) /<br>600kPa(Max) | 245 kPa(Max) | Similar |
| Patient Load | Max. 150 kg | Max. 135 kg | Max. 150 kg | Similar |
| Chair Height | Max. 770±50mm,<br>Min. 480±50mm | Max. 795±10mm,<br>Min. 365±10mm | Max. 700±10mm,<br>Min. 400±10mm | Similar |
| Back Rest | 0°±5° to 65°±5° | 0°±5° to 67°±5° | 0°±3° to 68°±3° | Similar |
| Head Rest | Double-articulating<br>headrest<br>First joint: -<br>$-150°~+150°(±5°)$<br>Second joint: -<br>$162°~+174°(±5°)$ | -10 °to 45° | -50° to 14°±2° | Similar |
| Lift Motor | Hydraulic Electromotor | Hydraulic Electromotor | Hydraulic Electromotor | Same |
| Dental Light | Available | Available | Available | Same |
| Foot Control | Available | Available | Available | Same |
| Electrical<br>Safety | Complied with IEC 60601-<br>1 | Complied with IEC 60601-<br>1 | Complied with IEC 60601-<br>1 | Same |
| Electromagne<br>tic<br>Compatibility | Complied with IEC 60601-<br>1-2 | Complied with IEC 60601-<br>1-2 | Complied with IEC 60601-<br>1-2 | Same |
| Patient<br>Contacting<br>Components | Seat: Polyvinyl Chloride,<br>Polyester<br>Waterline: Polyurethane,<br>Polyamide 66+ GF25%,<br>Stainless Steel (Chromium<br>plated), C3604 (Chromium<br>plated)<br>Airline: Polyurethane,<br>Polyamide 66+ GF25%,<br>C3604 (Chromium plated),<br>Aluminum Alloy<br>HVE: Aluminum Alloy<br>3-Way Syringe: C3604<br>(Chromium plated)<br>Dry Air Syringe: C3604<br>(Chromium plated)<br>Saliva Ejector: Aluminum<br>Alloy<br>Warmer: Stainless Steel<br>(Chromium Plated) | - | Seat: Polyvinyl Chloride,<br>Polyester<br>Waterline: Polyurethane<br>resin, Polyamide 66+<br>GF25%, Stainless Steel,<br>C3604, Silicon<br>Airline: Polyurethane,<br>Polyamide 66+ GF25%,<br>Aluminum Alloy<br>HVE: Aluminum Alloy<br>3-Way Syringe: C3604<br>(Chromium Plated),<br>Aluminum Alloy<br>Saliva Ejector: Aluminum<br>Alloy<br>Warmer: Stainless Steel<br>304 (Chromium Plated)<br>Water Block: C3604<br>(Chromium Plated) | Similar |
| Principle of<br>Operation | The chair is operated, the<br>rising S/W is activated and<br>the chair is hydraulically<br>operated.<br>The handpiece is operated,<br>pressing the foot control<br>pedal opens the air supply<br>valve to rotate the<br>handpiece turbine.<br>The 3-Way Syringe is<br>operated by air pressure or<br>electronic circuit S/W | The chair is operated, the<br>rising S/W is activated and<br>the chair is hydraulically<br>operated.<br>The handpiece is operated,<br>pressing the foot control<br>pedal opens the air supply<br>valve to rotate the<br>handpiece turbine.<br>The 3-Way Syringe is<br>operated by air pressure or<br>electronic circuit S/W | The chair is operated, the<br>rising S/W is activated and<br>the chair is hydraulically<br>operated.<br>The handpiece is operated,<br>pressing the foot control<br>pedal opens the air supply<br>valve to rotate the<br>handpiece turbine.<br>The 3-Way Syringe is<br>operated by air pressure or<br>electronic circuit S/W | Similar |
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Image /page/8/Picture/0 description: The image contains the word "DENTIS" in bold, black letters. To the left of the word is an orange, spiral-like graphic. The graphic appears to be a stylized representation of a tooth or a dental instrument. The overall design is clean and modern.
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Image /page/9/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved shape that resembles a flame or a stylized letter "D". The logo appears to be for a dental-related company or product, given the association with the word "dentis".
b) Substantial Equivalence Discussion
The Luvis Chair (LC700C) is substantially equivalent to the predicate and reference devices identified above with respect to intended use, principles of operation, and technological characteristics. The subject device has the same Indications for Use and similar technological characterizes as compared to the predicate and reference devices. Therefore, the Luvis Chair (LC700C) is considered substantially equivalent to the predicate devices.
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Image /page/10/Picture/0 description: The image contains the logo for DENTIS. The logo consists of an orange abstract shape on the left, resembling a stylized flame or a curved, layered design. To the right of the shape is the word "DENTIS" in bold, black capital letters.
#### 8. Non-Clinical Test Summary
The Luvis Chair (LC700C) is verified and validated according to the FDA design control requirements, 21 CFR 820. The subject device had been subjected to the applicable safety and performance testing before release to ensure the device meets all its specifications. The quality assurance measures applied to the design and development of the subject device include, but not limited to risk analysis, verification and validation, product specifications and design reviews.
#### 1) Thermal, electrical, mechanical safety & Electromagnetic Compatibility
The Luvis Chair (LC700C) complies with the electrical safety and electromagnetic compatibility requirements established by the standards below:
- ANSI AAMI ES60601-1 General requirements for basic safety and essential performance - IEC 60601-1-2 General requirements for basic safety and essential performance -Collateral Standard: Electromagnetic disturbances
- IEC 80601-2-60 Particular requirements for the basic safety and essential performance of dental equipment
#### 2) Software Validations
The Luvis Chair (LC700C) utilizes original software. The Luvis Chair (LC700C) contains Basic documentation level, and MODERATE level of concern software. Software was designed and developed according to a software development process and was verified and validated.
Software information is provided in accordance with FDA guidance: "Guidance for the Content of Premarket Submissions for Software Functions, issued on June 14, 2023."
## 3) Biocompatibility
The biocompatibility evaluation for the Luvis Chair (LC700C) was conducted in accordance with FDA guidance:
- "Guidance for the Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process, issued on September 8, 2023"
- ISO 7405 Dentistry - Evaluation of biocompatibility of medical devices used in dentistry
The biocompatibility testing included the following tests:
- In vitro cytotoxicity test
- Oral mucosa Irritation test
- Skin sensitization test
- In vitro cytotoxicity test Agar diffusion method
- In vitro cytotoxicity test Filter diffusion method
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Image /page/11/Picture/0 description: The image contains the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved graphic. The graphic is a stylized representation of a flame or a curved shape.
#### 4) Performance Test
The performance test for Luvis Chair (LC700C) was conducted in accordance with the standards below:
- IEC 80601-2-60 Particular requirements for the basic safety and essential performance of dental equipment
- ISO 7494-1 Dentistry - Stationary dental units and dental patient chairs - Part 1: General requirements
- ISO 7494-2 Dentistry - Dental units - Part 2: Air, water, suction and waste water systems
#### 5) Cleaning and Sterilization Validation
Reprocessing validation testing has conducted in accordance with FDA guidance:
"Guidance for Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling, issued on March 17, 2015"
The cleaning and sterilization was conducted in accordance with the standards below:
- ISO 17665-1 Sterilization of health care products - Moist heat - Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices
- ISO TS 17665-2 Sterilization of health care products - Moist heat - Part 2: Guidance on the application of ISO 17665-1
Dental unit waterline biofilm treatment testing has conducted in accordance with the standards below:
- ISO 16954 Dentistry - Test methods for dental unit waterline biofilm treatment
- ISO 19458 Water quality - Sampling for microbiological analysis
## 9. Conclusions [21 CFR 807.92(b)(3)]
In conclusion, the conducted tests, as well as all verification and validation activities, demonstrate that the design specifications and technological characteristics of the Luvis Chair (LC700C) meet applicable requirements and standards. The testing and validation activities conducted demonstrate that any differences between the subject device and the predicate devices do not raise new questions of safety and effectiveness compared to the predicate and reference devices. Therefore, the Luvis Chair (LC700C) is substantially equivalent to the predicate and reference devices.
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.