K Number
K153350
Device Name
IBS Implant System
Date Cleared
2016-05-09

(171 days)

Product Code
Regulation Number
872.3640
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The IBS Implant System is intended to replace missing teeth to restore chewing function. The IBS Implant can be placed in support of single or multiple-unit restorations including; cement retained, screw retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.
Device Description
An endosseous dental implant is a device made of a material such as Ti-6AL-4V Eli (Conforming to ASTM Standard F-136). The IBS Implant System is consists of dental implants, abutments, and screws for use in one or two-stage dental implant placement and restorations. The implant-abutment connection is tight and precise fitting with internal hex and Morse taper bevel. The surface of the system has been treated with RBM (Resorbable Blasted media) to increase junction strength by increasing the area of bone-implant interface. There are 2 types of fixtures in this system, NR Fix and Magic FC. The NR Fix has diameters in 3.5mm and lengths in 9, 10, 11, 12, 13, 14 mm. The Magic FC has diameters in 4. 4.5. 5.0. 5.5. 6.0. 6.5mm and lengths in 7. 9. 11, 13. 15 mm. The contained various abutments and accessories in the system are Magic Screw retained type Abutment & protect cap, Healing Abutment, Angled Abutment (hexa, non hexa), Pair Abutment (non hexa), Solid Abutment & Solid abutment cap, Magic abutcoping (transfer type, pick up type), Multiunit abutment, UCLA abutment. Fixtures and abutments are packaged separately. The Fixtures are supplied sterile and the abutments and accessories are provided non-sterile. The abutments and accessories should be sterilized before use. But healing abutment is supplied sterile.
More Information

No
The summary describes a standard dental implant system with various components and surface treatments. There is no mention of AI, ML, image processing, or any other technology that would suggest the use of AI/ML. The performance studies focus on non-clinical tests and sterilization validation, not AI/ML performance metrics.

No
The device is described as an endosseous dental implant system intended to replace missing teeth and restore chewing function, which is a restorative purpose, not a therapeutic one. It does not treat or cure a disease or condition.

No

Explanation: The device is described as an "endosseous dental implant" intended to "replace missing teeth to restore chewing function." Its purpose is to physically restore a lost function, not to identify or diagnose a condition.

No

The device description clearly outlines physical components made of materials like Ti-6AL-4V Eli, including dental implants, abutments, and screws. It also details surface treatments and packaging, indicating a hardware-based medical device.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening.
  • Device Description and Intended Use: The provided text clearly describes a dental implant system intended to be surgically placed in the jawbone to replace missing teeth and restore chewing function. It is a physical device implanted into the body.
  • Lack of Specimen Analysis: There is no mention of this device being used to analyze any biological specimens. Its function is mechanical and structural.

Therefore, based on the provided information, the IBS Implant System is a medical device, specifically a dental implant system, and not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The IBS Implant System is intended to replace missing teeth to restore chewing function. The IBS Implant can be placed in support of single or multiple-unit restorations including; cement retained, screw retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.

Product codes (comma separated list FDA assigned to the subject device)

DZE, NHA

Device Description

An endosseous dental implant is a device made of a material such as Ti-6AL-4V Eli (Conforming to ASTM Standard F-136). The IBS Implant System is consists of dental implants, abutments, and screws for use in one or two-stage dental implant placement and restorations. The implant-abutment connection is tight and precise fitting with internal hex and Morse taper bevel.

The surface of the system has been treated with RBM (Resorbable Blasted media) to increase junction strength by increasing the area of bone-implant interface.

There are 2 types of fixtures in this system, NR Fix and Magic FC. The NR Fix has diameters in 3.5mm and lengths in 9, 10, 11, 12, 13, 14 mm. The Magic FC has diameters in 4. 4.5. 5.0. 5.5. 6.0. 6.5mm and lengths in 7. 9. 11, 13. 15 mm.

The contained various abutments and accessories in the system are Magic Screw retained type Abutment & protect cap, Healing Abutment, Angled Abutment (hexa, non hexa), Pair Abutment (non hexa), Solid Abutment & Solid abutment cap, Magic abutcoping (transfer type, pick up type), Multiunit abutment, UCLA abutment.

Fixtures and abutments are packaged separately. The Fixtures are supplied sterile and the abutments and accessories are provided non-sterile. The abutments and accessories should be sterilized before use. But healing abutment is supplied sterile.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

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, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical tests followed the recommendations in the "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implant and Endosseous Dental Implant abutments". Sterilization Validation testing performed in accordance with ISO 11137-1:2006, ISO 11137-2:2009 and surface treatment analysis were used to support the decision of substantial equivalence. Fatigue test was performed under the worst case scenario in accordance with ISO 14801:2007.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K140806

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K140507, K123755, K111120

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 872.3640 Endosseous dental implant.

(a)
Identification. An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.(b)
Classification. (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. 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.)(2)
Classification. Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle or bird symbol, with three profiles facing right, representing people. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird symbol.

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

May 9, 2016

InnoBioSurg Co., Ltd. c/o Ms. April Lee Consultant Withus Group Inc. 2531 Pepperdale Drive Rowland Heights, California 91748

Re: K153350

Trade/Device Name: IBS Implant System Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: II Product Code: DZE, NHA Dated: April 1, 2016 Received: April 8, 2016

Dear Ms. 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. 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.

1

Page 2 - Ms. April Lee

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

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/ResourcesforYou/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,

Tina Kiang
-s

for Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Image /page/2/Picture/0 description: The image shows the logo for IBS implant. The logo consists of the letters "IBS" in a bold, dark blue font, followed by the word "implant" in a smaller, dark blue font. Below the word "implant" is the text "Innobiosurg Co.,Ltd" in a smaller, light yellow font. The logo also includes a stylized square with a yellow accent in the upper left corner.

InnoBioSurg Co., Ltd.

44-19, Techno 10-ro Tel. 82- 42-933-2879 / Fax. 8

Indication for Use

K153350 510(K) Number (if known):

Device Name: IBS Implant System

Indication for Use:

The IBS Implant System is intended to replace missing teeth to restore chewing function. The IBS Implant can be placed in support of single or multiple-unit restorations including; cement retained, screw retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.

Prescription Use

AND/OR

Over-The-Counter

(Part 21 CFR 801 Subpart D)

(Per 21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Page 1 of 1

3

Image /page/3/Picture/1 description: The image shows the logo for IBS Implant InnoBiosurg Co., Ltd. The logo features the letters "IBS" in a bold, dark blue font, with a yellow square in the upper left corner of the "I". To the right of "IBS" is the word "implant" in a smaller, dark blue font. Below "implant" is the text "InnoBiosurg Co., Ltd" in a smaller, light yellow font.

Tel. 82- 42-933-2879 / Fax. 82-42-933-288

510(k) Summary

Submitter

InnoBioSurg Co., Ltd. Bo-reum Yoo 44-19, Techno 10-ro, Yuseong-gu, Daejeon, 34027 Republic of Korea Email: bryoo@ibsimplant.com Tel.+82-42-933-2879 Fax.+82-42-933-2881

Official Correspondent

Withus Group Inc April Lee 2531 Pepperdale Drive Rowland Heights, CA 91748 USA Email:withus6664@gmail.com Phone: 1-909-274-9971 Fax: 1-909-460-8122

Device Information

  • . Trade Name: IBS Implant System
  • Common Name: Dental Implant System
  • Classification Name: Endosseous dental implant
  • Primary Product Code: DZE
  • Secondary Product Code: NHA
  • Panel: Dental
  • Regulation Number: 872.3640
  • Device Class: Class II ●
  • Date prepared: 5/2/2016

General Description

An endosseous dental implant is a device made of a material such as Ti-6AL-4V Eli (Conforming to ASTM Standard F-136). The IBS Implant System is consists of dental implants, abutments, and screws for use in one or two-stage dental implant placement and restorations. The implant-abutment connection is tight and precise fitting with internal hex and Morse taper bevel.

The surface of the system has been treated with RBM (Resorbable Blasted media) to increase junction strength by increasing the area of bone-implant interface.

There are 2 types of fixtures in this system, NR Fix and Magic FC. The NR Fix has diameters in 3.5mm and lengths in 9, 10, 11, 12, 13, 14 mm. The Magic FC has diameters in 4. 4.5. 5.0. 5.5. 6.0. 6.5mm and lengths in 7. 9. 11, 13. 15 mm.

The contained various abutments and accessories in the system are Magic Screw retained type Abutment & protect cap, Healing Abutment, Angled Abutment (hexa, non hexa), Pair Abutment (non hexa), Solid Abutment & Solid abutment cap, Magic abutcoping (transfer type, pick up type), Multiunit abutment, UCLA abutment.

Fixtures and abutments are packaged separately. The Fixtures are supplied sterile and the abutments and accessories are provided non-sterile. The abutments and accessories should be sterilized before use. But healing abutment is supplied sterile.

4

Image /page/4/Picture/0 description: The image contains the logo for IBS Implant InnoBiosurg Co., Ltd. The logo features a stylized "i" and "G" in a blue square, followed by the text "IBS" in bold, blue letters. To the right of "IBS" is the word "implant" in a smaller, blue font, and below that is "InnoBiosurg Co.,Ltd" in a smaller, lighter font.

InnoBioSurg Co., Ltd.
44-19, Techno 10-ro, Yuseong-gu, Daejeon, 305-510, Kore
00

The purpose of this submission is to add new fixtures (NR Fix, Magic FC), magic screw, healing abutment, angled abutment, pair abutment (non-hexa), screw retained type abutment and solid abutment cap, magic abutcoping, UCLA abutment, and Multi unit abutment. Also, the shelf life of the products is changed from 2 years to 5 years.

Indication for Use

The IBS Implant System is intended to replace missing teeth to restore chewing function. The IBS Implant can be placed in support of single or multiple-unit restorations including; cement retained, screw retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.

Materials:

The dental implants are fabricated fromTi-6AL-4V Eli (Conforming to ASTM Standard F-136).

Non-Clinical Data:

Non-clinical tests followed the recommendations in the "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implant and Endosseous Dental Implant abutments". Sterilization Validation testing performed in accordance with ISO 11137-1:2006, ISO 11137-2:2009 and surface treatment analysis were used to support the decision of substantial equivalence. Fatigue test was performed under the worst case scenario in accordance with ISO 14801:2007.

5

Image /page/5/Picture/0 description: The image is a logo for IBS implant. The logo consists of the letters "IBS" in a bold, sans-serif font, with the "I" having a yellow square in the upper left corner. To the right of "IBS" is the word "implant" in a smaller, sans-serif font. Below "implant" is the text "Innobiosurg Co.,Ltd" in an even smaller, sans-serif font.

Comparison to Predicate Devices:

Comparison of the technological characteristics of the subject device and predicate devices is shown in the Table of Substantial Equivalence below.

  1. Fixture
  • K140806, IBS Implant System by InnoBioSurg Co., Ltd. .
Subject DevicePredicate Device
Product NameIBS Implant SystemIBS Implant System
510(k)
Product code
ClassNA
DZE
IIK140806
DZE
II
ManufacturerInnoBioSurg Co., Ltd.InnoBioSurg Co., Ltd.
Indication for
useThe IBS Implant System is intended to
replace missing teeth to restore chewing
function. The IBS Implant System can
be placed in support of single or
multiple-unit restorations including;
cement retained, screw retained, or
overdenture restorations, and terminal
or immediate abutment support for fixed
bridgework. This system is for one or
two stage surgical procedures. This
system is intended for delayed loading.The IBS Implant System is intended to
replace missing teeth to restore chewing
function.
The IBS Implant System can be placed in
support of single or multiple-unit
restorations including; cement retained,
screw retained, or overdenture restorations,
and terminal or immediate abutment
support for fixed bridgework. This system
is for one or two stage surgical procedures
and not for immediate loading. This system
is intended for delayed loading.
DesignImage: NR Fix
Image: Magic FCImage of a screw
Composition of
MaterialTitanium Alloy
Ti-6Al-4V Eli
ASTM F136Titanium Alloy
Ti-6Al-4V Eli
ASTM F136
Fixture TypeSubmergedSubmerged
Endosseous
ImplantTapered, macro threadsTapered, macro and
micro threads
ComponentsVarious abutments and
accessoriesVarious abutments and accessories
Range of
Diameters (mm)NR Fix : 3.5mm
Magic Fc : 4.0, 4.5, 5.0, 5.5, 6.0, 6.5
mm3.8, 4.3, 4.8, 5.3, 5.8, 6.3 mm
Range of
Lengths (mm)NR Fix : 9, 10, 11, 12, 13, 14mm
Magic FC : 7, 9, 11, 13, 15mm7 mm – 15 mm
Modified
SurfaceR.B.M.R.B.M.
Surgical
Technique1 stage and 2 stage, self tapping1 stage and 2 stage, self tapping
Gamma
SterilizationYesYes

6

Image /page/6/Picture/0 description: The image shows the logo for IBS Implant InnoBiosurg Co., Ltd. The logo features the letters "IBS" in a bold, dark blue font, with a yellow square in the upper left corner of the "I". To the right of "IBS" is the word "implant" in a smaller, dark blue font, and below that is the text "InnoBiosurg Co., Ltd" in a smaller, light yellow font.

InnoBioSurg

44-19, Techno 10-ro, Yuseong-gu, Daejeon, 305-510, Korea


2) Abutments

  • K140507, Hiossen Prosthetic System by Osstem Implant Co., Ltd. ●
  • K123755, Multi Angled Abutment by Osstem Implant Co., Ltd. ●
  • K111120, CSM Submerged-R Implant System by CSM Implant .
Subject DevicePredicate devices
Hiossen Prosthetic SystemMulti Angled AbutmentCSM Submerged-R Implant System
ManufacturerInnobiosurg Co., LtdOSSTEM Implant Co., Ltd.OSSTEM Implant Co., Ltd.CSM Implant
DesignImage: pair angled solidImage: Rigid Transfer AngledImage: Multi Angle
Image: Multiunit
510(k) No.-K140507K123755K111120
Intended
UseIBS prosthetic
system is
intended for use
with a dental
implant to
provide support
for prosthetic
restorations such
as crowns,
bridges, or
overdentures.Hiossen Prosthetic
System is intended for
use with a dental
implant to provide
support for prosthetic
restorations such as
crowns, bridges, or
overdentures.Multi Angled
Abutment is
intended for use
a dental implant
to provide
support for
prosthetic
restoration such
as crowns,
bridges, or
overdentures.The CSM
Submerged-R
implant system is
especially
designed for use in
dental implant
surgery.
StructureInternal HexExternal HexExternal HexInternal Hex
Connection
TypeInternal Hex-
ConnectedScrew & External Hex-
ConnectedScrew &
External Hex-
ConnectedInternal Hex-
Connected
Diameter (mm)Solid:3.5/4.0/4.5/
5.0/5.5/6.0/6.5
Pair:4.0/4.5/5.0/5.
5/6.0/6.5
Angled:4.0/4.5/5.
0
UCLA:3.5/4/4.5/
5/5.5
Multiunit:4.1/4.5/
5.0/5.5/6.0/6.5
Screw retained
type:3.5/4.0/4.5/5
.5/6.5Rigid : 4.0/4.6/5.0/6.0
/7.0/8.0
Transfer : 4.0/4.6/5.0/
6.0/7.0/8.0
Angled : 4.0/4.3/4.5/
4.8/5.5/6.0Multi Angle : -UCLA:4.5
G/H Length
(mm)Solid:1.0/2.0/3.0/
4.0
Pair:
1.0/2.0/3.0/4.0
Angled:
1.0/2.0/3.0/4.0
UCLA:
1.0/2.0/3.0/4.0
Multiunit:
1.0/2.0/3.0/4.0/5.Rigid : 0.5/1.0/2.0/2.5/
3.0/4.0/5.0
Transfer : 0.5/1.0/2.0/
2.5/3.0/4.0/5.0
Angled : 0.5/1.0/2.0/
2.5 / 3.0 / 4.0Multi Angle : -UCLA:0.75
0
Screw retained
type:0.7/1.5/2.5/3
.5/4.5/5.5/6.5
Post Length
(mm)Solid:4.0/6.0/8.0
Pair:6.0
Angled:0,1.0/2.0/
3.0/4.0
UCLA:1.0/2.0/3.0
/4.0Rigid : 4.0/5.5/7.0
Transfer :
4.0/5.5/7.0/8.0
Angled : -Multi Angle : -UCLA:12
Angle(°)Angled : 15°/
25°/30°
Multi Angel :
17°/30°Angled : 17° / 25°Multi Angle :
17°/30°-
Material of
AbutmentTitanium Alloy
(ASTM F 136)
Polydiacetate:
Cap, UCLA
Titanium Gr4
(ASTM F67) :
Multiunit
abutment capTitanium Alloy (ASTM
F 136) : Rigid,
Transfer, Angled,
ConvertibleTitanium Alloy
(ASTM F 136) :P.O.M(UCLA)
SurfaceMachineMachine or TiNMachineMachine
SterilizationNon-SterileNon-SterileNon-SterileNon-Sterile

7

Image /page/7/Picture/0 description: The image contains the logo for IBS implant. The logo consists of a blue square with a stylized white "iG" inside, followed by the text "IBS implant" in a bold, dark blue font. Below the word "implant" is the text "Innobiosurg Co.,Ltd" in a smaller, lighter font.

InnoBioSurg Co., Ltd.

44-19, Techno 10-ro, Yuseong-gu, Daejeon, 305-510, Korea
11 Tel. 82-42-933-2879 / Fax. 82-42-933-2881

44-19, Techno 10-ro, Yuseong-gu, Daejeon, 305-510, Korea
Tel. 82-42-933-2879 / Fax. 82-42-933-2881

8

Image /page/8/Picture/0 description: The image shows the logo for IBS implant. The logo consists of the letters "IBS" in a bold, dark blue font, with a yellow dot above the "I". To the right of "IBS" is the word "implant" in a smaller, dark blue font. Below "implant" is the text "Innobiosurg Co.,Ltd" in a smaller, light yellow font.

44-19, Techno 10-ro, Yuseong-gu, Daejeon, 305-510, Korea
Tel. 82-42-933-2879 / Fax. 82-42-933-2881

Substantial Equivalence Discussion

The IBM Implant System has a substantially equivalent intended use as the identified predicates. The subject device is similar in fundamental scientific technology to the predicate device in that they all have been designed, manufactured and tested in compliance with FDA's Class II special controls guidance document root-form endosseous dental implants and endosseous dental implant abutments, and they are all constructed of titanium.

The subject and predicate devices are similar in indications, design, technology, functions, dimensions and materials.

The subject device and predicate have slightly different Indications for Use language. However, the difference in language does not change the intended use or substantial equivalence. The differences between the subject device and predicate devices are slight differences in fixture's design and sizes. Differences in technological characteristics do not raise different questions of safety and effectiveness compared to the predicate device.

9

Image /page/9/Picture/0 description: The image is a logo for IBS Implant. The logo features the letters "IBS" in a bold, dark blue font, with a stylized icon to the left of the letters. To the right of "IBS" is the word "implant" in a smaller, dark blue font. Below "implant" is the text "Innobiosurg Co., Ltd" in a smaller, lighter font.

InnoBioSurg Co., Ltd. 44-19, Techno 10-ro, Yuseong-gu, Daejeon, 305-510, Korea

Conclusion

The IBS Implant System, subject device of this submission, 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, IBS Implant System and its predicate are substantially equivalent.