K Number
K150354
Device Name
PAPAYA 3D Plus
Manufacturer
Date Cleared
2015-12-10

(302 days)

Product Code
Regulation Number
892.1750
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
PAPAYA 3D Plus is a digital panoramic, cephalometric and tomographic extra-oral X-ray system, indicated for use in: - (i) producing panoramic X-ray images of the maxillofacial area, for diagnostic examination of dentition (teeth), jaws and oral structures; and - (ii) producing radiographs of jaws, parts of the skull and carpus for the purpose of cephalometric examination, when equipped with the cephalometric arm; - (iii) producing tomographic images of the oral and maxillofacial structure, for diagnostic examination of dentition(teeth), jaws ,oral structures and some cranial bones if equipped with CBCT option. The system accomplishes tomographic exam by acquiring a 360-degree rotational X-ray sequence of images and reconstructing a three-dimensional matrix of the examined volume, producing two-dimensional views of this volume and displaying both two dimensional images and three-dimensional renderings.
Device Description
PAPAYA 3D Plus is a diagnostic imaging system which consists of multiple image acquisition modes; panorama, cephalometric, and computed tomography. PAPAYA 3D Plus designed for dental radiography of the oral and craniofacial anatomy such as teeth, jaws and oral structures. PAPAYA 3D Plus is equipped with extra-oral flat panel x-ray detectors which is based on CMOS digital X-ray detector and has CT, panoramic and cephalometric radiography with an extra-oral x-ray tube. CMOS Flat panel detectors are used to capture scanned image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D diagnostic images of the anatomic structures by acquiring 360°rotational image sequences of oral and craniofacial area.
More Information

Not Found

No
The summary describes standard image acquisition and reconstruction techniques for panoramic, cephalometric, and CBCT imaging. There is no mention of AI, ML, or any related terms in the device description, intended use, or performance studies. The image processing described is limited to 3D reconstruction and 2D/3D rendering, which are conventional techniques in medical imaging.

No

This device is a diagnostic imaging system that produces X-ray images for examination, not a therapeutic device designed for treatment.

Yes

The "Intended Use / Indications for Use" section explicitly states that the device is indicated for "diagnostic examination" and "producing radiographs...for the purpose of cephalometric examination." The "Device Description" also labels it as a "diagnostic imaging system."

No

The device description explicitly states it is a "diagnostic imaging system which consists of multiple image acquisition modes" and is "equipped with extra-oral flat panel x-ray detectors" and an "extra-oral x-ray tube." This indicates the device includes significant hardware components for image acquisition, not just software for processing or display.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices intended for use in vitro for the examination of specimens, including blood, tissue, and urine, derived from the human body, to provide information for diagnostic purposes.
  • Device Function: The PAPAYA 3D Plus is an extra-oral X-ray system that produces images of anatomical structures (teeth, jaws, skull, etc.) using X-rays. It does not examine specimens derived from the human body.
  • Intended Use: The intended use is to produce and display images for diagnostic examination of anatomical structures, not to analyze biological samples.

Therefore, the PAPAYA 3D Plus falls under the category of a diagnostic imaging device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

PAPAYA 3D Plus is a digital panoramic, cephalometric and tomographic extra-oral X-ray system, indicated for use in:

  • (i) producing panoramic X-ray images of the maxillofacial area, for diagnostic examination of dentition (teeth), jaws and oral structures; and
  • (ii) producing radiographs of jaws, parts of the skull and carpus for the purpose of cephalometric examination, when equipped with the cephalometric arm;
  • (iii) producing tomographic images of the oral and maxillofacial structure, for diagnostic examination of dentition(teeth), jaws ,oral structures and some cranial bones if equipped with CBCT option.

The system accomplishes tomographic exam by acquiring a 360-degree rotational X-ray sequence of images and reconstructing a three-dimensional matrix of the examined volume, producing two-dimensional views of this volume and displaying both two dimensional images and three-dimensional renderings.

Product codes

OAS, MUH

Device Description

PAPAYA 3D Plus is a diagnostic imaging system which consists of multiple image acquisition modes; panorama, cephalometric, and computed tomography. PAPAYA 3D Plus designed for dental radiography of the oral and craniofacial anatomy such as teeth, jaws and oral structures.

PAPAYA 3D Plus is equipped with extra-oral flat panel x-ray detectors which is based on CMOS digital X-ray detector and has CT, panoramic and cephalometric radiography with an extra-oral x-ray tube. CMOS Flat panel detectors are used to capture scanned image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D diagnostic images of the anatomic structures by acquiring
360°rotational image sequences of oral and craniofacial area.

Mentions image processing

The system accomplishes tomographic exam by acquiring a 360-degree rotational X-ray sequence of images and reconstructing a three-dimensional matrix of the examined volume, producing two-dimensional views of this volume and displaying both two dimensional images and three-dimensional renderings.

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

X-ray

Anatomical Site

maxillofacial area, dentition (teeth), jaws, oral structures, skull, carpus, craniofacial anatomy, cranial bones

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Study Type: Safety, EMC and Performance data comparison to Predicate
Sample Size: Not specified
Key Results:

  • Complies with industry standards such as IEC 60601-1 Series and 21 CFR 1020.30, 21 CFR 1020.31, and 21 CFR 1020.33.
  • Electrical, mechanical, environmental safety and performance testing according to IEC 60601-1, IEC 60601-1-3, and IEC 60601-2-63 were performed.
  • EMC testing was conducted in accordance with IEC 60601-1-2.
  • Acceptance test according to IEC 61223-3-4 and IEC 61223-3-5 were performed.
  • FDA Guidance "Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging Devices" was performed for each new detector.
  • Existing detector tests: MTF of more than 80% at 21p/mm, DQE of about 80% at 01p/mm, dynamic range of more than 72dB.
  • Additional detector tests (new detectors): MTF of more than 60% at 11p/mm, DQE of about 70% at 01p/mm, dynamic range of more than 72dB.
  • Non-Clinical Test results indicate diagnostic image quality of new sensors is similar to predicate device with no significant difference in efficiency and safety.
  • 3D performance tests with phantoms (contrast scale, noise, slice thickness, and resolutions) were within standard value range.
  • Meets EPRC standards (21 CFR 1020.30, 31, 33).
  • Meets provisions of NEMA PS 3.1-3.18. Digital Imaging and Communications in Medicine (DICOM) Set.
  • OTS software (Triana) used as image viewer, with validation report conducted as recommended by FDA's Guidance document "Guidance for off-the-shelf Software Use in Medical Devices". Triana represents a Minor Level of Concern.
  • Tested for safety and effectiveness in Clinical Evaluation report.
  • All test results were satisfactory. Bench and clinical evaluation indicate the new device is as safe and effective as predicate devices.

Key Metrics

  • MTF (Modulation Transfer Function): more than 80% at 21p/mm (existing detectors); more than 60% at 11p/mm (new detectors)
  • DQE (Detective Quantum Efficiency): about 80% at 01p/mm (existing detectors); about 70% at 01p/mm (new detectors)
  • Dynamic Range: more than 72dB (both existing and new detectors)

Predicate Device(s)

K123381, K141700

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 892.1750 Computed tomography x-ray system.

(a)
Identification. A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.(b)
Classification. Class II.

0

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

December 10, 2015

GENORAY Co., Ltd. % Ms Kaitlynn Min Business Developer Manager GENORAY America, Inc. 3002 Dow Avenue, Suite 420 TUSTIN CA 92780

Re: K150354 Trade/Device Name: PAPAYA 3D Plus Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: II Product Code: OAS, MUH Dated: November 17, 2015 Received: November 18, 2015

Dear Ms. Min:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. 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.

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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

1

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Robert Ocklo

Robert Ochs. Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K150354

Device Name PAPAYA 3D Plus

Indications for Use (Describe)

PAPAYA 3D Plus is a digital panoramic, cephalometric and tomographic extra-oral X-ray system, indicated for use in:

  • (i) producing panoramic X-ray images of the maxillofacial area, for diagnostic examination of dentition (teeth), jaws and oral structures; and
  • (ii) producing radiographs of jaws, parts of the skull and carpus for the purpose of cephalometric examination, when equipped with the cephalometric arm;
  • (ii) producing tomographic images of the oral and maxillofacial structure, for diagnostic examination of dentition(teeth), jaws ,oral structures and some cranial bones if equipped with CBCT option.

The system accomplishes tomographic exam by acquiring a 360-degree rotational X-ray sequence of images and reconstructing a three-dimensional matrix of the examined volumensional views of this volume and displaying both two dimensional images and three-dimensional renderings.

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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3

Exhibit 5 510(k) Summary

Date of Summary Preparation: Feb 01, 2015

    1. Submitter and US Official Correspondent Submitter: GENORAY Co., Ltd. Address: #512, Byucksan Technopia 434-6, Sangdaewon 1-dong, Jungwon-gu, Seongnam-city Gyeonggi-do, 462-716, Korea Telephone No.: +82-31-740-4100 Fax: +82-31-737-8025 Official Correspondent (U.S): Kaitlynn Min - Business Manager Correspondent: GENORAY America Inc. Address: 3002 Dow Avenue, Suite 420, Tustin, CA 92780 Telephone No.: 714-289-8020 Fax: 714-786-8919 Email: kaitlynn@genorayamerica.com
    1. Establishment Registration Number 3005843418
    1. Device Information Trade/Device Name: PAPAYA 3D Plus

Regulation Name: Computed tomography X-ray System

Classification Name/Product Code: X-ray, Tomography, Computed/OAS System, X-ray, Extraoral Source, Digital / MUH

Device Class: Class II per regulation 21 CFR 892.1750

    1. Predicate Device (Equivalent Legally Marketed Device) Hyperion X9 (K123381, Cefla S.C.) PAPAYA Plus (K141700 Genoray Co., Ltd)
  • ર. Description of the Device

PAPAYA 3D Plus is a diagnostic imaging system which consists of multiple image acquisition modes; panorama, cephalometric, and computed tomography. PAPAYA 3D Plus designed for dental radiography of the oral and craniofacial anatomy such as teeth, jaws and oral structures.

PAPAYA 3D Plus is equipped with extra-oral flat panel x-ray detectors which is based on CMOS digital X-ray detector and has CT, panoramic and cephalometric radiography with an extra-oral x-ray tube. CMOS Flat panel detectors are used to capture scanned image for obtaining diagnostic information for craniofacial surgery or other treatments. And it also provides 3D diagnostic images of the anatomic structures by acquiring

360°rotational image sequences of oral and craniofacial area.

4

Indications for use (intended use) 6.

PAPAYA 3D Plus is a digital panoramic, cephalometric and tomographic extra-oral Xray system, indicated for use in:

  • (i) producing panoramic X-ray images of the maxillofacial area, for diagnostic examination of dentition (teeth), jaws and oral structures; and
  • (ii) producing radiographs of jaws, parts of the skull and carpus for the purpose of cephalometric examination, when equipped with the cephalometric arm;
  • (iii) producing tomographic images of the oral and maxillofacial structure, for diagnostic examination of dentition(teeth), jaws ,oral structures and some cranial bones if equipped with CBCT option.

The system accomplishes tomographic exam by acquiring a 360-degree rotational Xray sequence of images and reconstructing a three-dimensional matrix of the examined volume, producing two-dimensional views of this volume and displaying both two dimensional images and three-dimensional renderings.

| Name | Proposed device
PAPAYA 3D Plus | Hyperion X9 | PAPAYA Plus |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufactur
er | GENORAY Co., Ltd. | CEFLA S.C. | GENORAY Co., Ltd. |
| 510(k) No. | - | K123381 | K141700 |
| Indications
for use | PAPAYA 3D Plus is a digital
panoramic, cephalometric and
tomographic extra-oral X-ray
system,
indicated for use in:
(i) producing panoramic X-ray
images of the maxillofacial area, for
diagnostic examination of dentition
(teeth), jaws and oral structures; and
(ii) producing radiographs of jaws,
parts of the skull and carpus for the
purpose of cephalometric
examination, when equipped with
the cephalometric arm;
(iii) producing tomographic images
of the oral and maxillofacial
structure, for diagnostic examination
of dentition(teeth), jaws ,oral
structures and some cranial bones if
equipped with CBCT option.
The system accomplishes
tomographic exam by acquiring a
360-degree rotational X-ray
sequence of images and
reconstructing a three-dimensional
matrix of the examined volume,
producing two-dimensional views of
this volume and displaying both two
dimensional images and three-
dimensional renderings. | Hyperion X9 is a digital panoramic,
cephalometric and tomographic
extra-oral X-ray system,
indicated for use in:
(i) producing panoramic X-ray
images of the maxillofacial area, for
diagnostic examination
of dentition (teeth), jaws and oral
structures; and
(ii) producing radiographs of jaws,
parts of the skull and carpus for the
purpose of cephalometric
examination, when equipped with
tele-radiographic arm (CEPH);
(iii) producing tomographic images
of the oral and maxillofacial
structure, for diagnostic examination
of dentition (teeth), jaws ,oral
structures and some cranial bones if
equipped with CBCT option.
The system accomplishes
tomographic exam by acquiring a
360-degree rotational X-ray
sequence of images and
reconstructing a three-dimensional
matrix of the examined volume,
producing two-dimensional views of
this volume and displaying both two
dimensional images and three-
dimensional renderings. | PAP A Y A Plus is a digital
extraoral source X-ray system
intended to produce panoramic and
cephalometric(option) images of the
oral and craniofacial anatomy for a
precise treatment planning in adult
and pediatric care. The system is
used for dental & skull radiographic
examination and diagnosis
ofteeth,jaw, oral structure, and skull
by exposing an X-ray image
receptor to ionizing radiation, with a
digital imaging capability for taking
both panoramic and cephalometric
images. And this system can be
equipped CUST(Tomographic)
option, which is capable of taking
cross-sectional radiographic images.
These images provide dimensional
information for dental implant
planning and information about
location of
impacted teeth |

7. Substantial equivalence chart

5

| Name | Proposed device
PAPAYA 3D Plus | Hyperion X9 | PAPAYA Plus |
|----------------------------------|------------------------------------------------------------------|---------------------------------------------------------------------|-----------------------------------------------------|
| Performance
Specificatio
n | Panoramic
Cephalometric
Computed tomography | Panoramic
Cephalometric
Computed tomography | Panoramic
Cephalometric
Tomography |
| 3D
Technology | Cone beam Computed tomography | Cone beam Computed tomography | Volumetric tomography |
| CT
FOV
(D×H) | 14×14, 14×8, 8×8, 7×7, 4×4cm | 11×8, 11×5, 8×8, 8×5, 5×5cm | 4.8×10 |
| Input
Voltage | 100-120V~ | 115 - 240 V~ | 100-120V~ |
| Tube
Voltage | 60-90 kV | 60-90 kV | 60-90 kV |
| Tube
Current | 4-12 mA | 1-10 mA | 4-12 mA |
| Focal Spot
Size | 0.5 mm | 0.5 mm | 0.5 mm |
| Exposure
Time | PANORAMA: max 17sec
CEPHALO: max 12sec
CT : max15sec | 160ms - 18 sec | Standard Panorama: 12 sec
Cephalo(Normal): 8 sec |
| Image
Receptor | Panoramic: CMOS FPD
Cephalometric: CMOS FPD
CBCT: CMOS FPD | Panoramic: CCD
Cephalometric: CCD
CBCT: Amorphous Silicon FPD | Panoramic: CMOS FPD
Cephalometric: CMOS FPD |

The proposed PAPAYA 3D Plus was developed from the PAPAYA Plus(K141700) by adding Computed tomography function. Accordingly, the characteristics of the PAPAYA 3D Plus are identical or similar to those of the PAPAYA Plus(K141700) regarding X-ray generation device characteristics including tube voltage, tube current, focal spot size and X-ray image capturing device including type of detector.

The differences of the PAPAYA 3D Plus from the PAPAYA Plus(K141700) are the addition of detector options and Computed tomography function.

New SSXI detectors are Extor-P for Panorammic mode, Extor-C for Cephalo mode, and DualRay-S for CBCT mode. They are for the newly upgraded PAPAYA Plus(K141700). Remaining detectors are the same, the non-clinical considerations are also equivalent, and the report regarding non-clinical & clinical consideration for the added new detectors are provided separately.

The Computed tomography function of the PAPAYA 3D Plus is similar to Hyperion X9(K123381). The system accomplishes tomographic exam by acquiring a 360-degree rotational X-ray sequence of images and reconstructing a three-dimensional matrix of the examined volume, producing two-dimensional views of this volume and displaying both two dimensional images and three-dimensional renderings. It is known as CBCT.

The PAPAYA 3D Plus has the similar characteristics regarding intended use, X-ray generation device characteristics including tube voltage, tube current, and focal spot size as Hyperion X9(K123381). The PAPAYA 3D Plus has the same indication for use as the Hyperion X9(K123381).

6

8. Safety, EMC and Performance data comparison to Predicate

PAPAYA 3D Plus complies with industry standards such as IEC 60601-1 Series and 21 CFR 1020.30 and 21 CFR 1020.31 and 21 CFR 1020.33 to minimize electrical, mechanical and radiation hazards.

  • Electrical, mechanical, environmental safety and performance testing according to standard IEC 60601-1, IEC 60601-1-3, and IEC 60601-2-63 were performed.
  • EMC testing was conducted in accordance with standard IEC 60601-1-2.
  • Acceptance test according to standard IEC 61223-3-4 and IEC 61223-3-5 were performed. ।
  • FDA Guidance "Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging । Devices" was performed for each new detector of PAPAYA 3D Plus. The existing detector test results are as follows.

The tests include the MTF, DQE and the dynamic range of the panoramic sensor and the cephalometric sensor. Both the MTF of the two detectors shows the resolution more than 80% at 21p / mm and the DQE of them shows the performance of about 80% at 01p / mm. The dynamic range of them shows more than 72dB.

And, the additional detector test results are as follows.

The tests include the MTF, DQE and the dynamic range of the panoramic sensor, the cephalometric sensor and the CT sensor. The MTF of the new detectors shows the resolution more than 60% at 11p / mm and the DQE of them shows the performance of about 70% at 01p / mm. The dynamic range of them shows more than 72dB.

Based on the Non-Clinical Test results, even though the pixel size and active area of the new SSXI detectors are different, the diagnostic image quality of new sensors is similar to that of the predicate device and there is no significant difference in efficiency and safety.

Please refer to Attachment X. Solid State X-ray imaging Device.

And 3D performance tests with phantoms were performed. Test items are contrast scale, noise, slice thickness, and resolutions. All test results were within standard value range.

  • PAPAYA 3D Plus meets the EPRC standards (21 CFR 1020.30. 31. 33)
  • PAPAYA 3D Plus also meets the provisions of NEMA PS 3.1-3.18. Digital Imaging and - Communications in Medicine (DICOM) Set.
  • PAPAYA 3D Plus uses OTS software, Triana as an image viewer. Software validation report was conducted as recommended by FDA's Guidance document "Guidance for off-the-shelf Software Use in Medical Devices" The OTS Software, Triana in PAPAYA 3D Plus represents a Minor Level of Concern since failures or latent design flaws would not be expected to result in any injury to the patient or operator.
  • PAPAYA 3D Plus was tested for safety and effectiveness related in Clinical Evaluation i report.

All test results were satisfactory. The result of bench and clinical evaluation indicates that the new device is as safe and effective as the predicate devices.

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9. Conclusion

In reference to the comparison information provided in substantial equivalence chart, most of functions and electronic features are similar with predicate devices. We believe that the PAPAYA 3D Plus is safe and effective as predicate devices, and has no new indication for use. Thus PAPAYA 3D Plus is substantially equivalent to predicate devices.