K Number
K180527
Device Name
IS3
Manufacturer
Date Cleared
2018-05-16

(77 days)

Product Code
Regulation Number
872.4200
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
IS3 is indicated for use in measuring the stability of dental implants in the oral cavity and the maxillofacial region.
Device Description
IS3 measurement system consists of: IS3 Instrument Hand-held instrument, Multi Peg Driver Driver to attach the ISQ peg to the implant, IS3 Charger 100-240 VAC to 5VDC charger for the instrument batteries, Multi Peg Measurement pin to attach to the implant. Different pins are available to fit different implant types. The IS3 instrument is a hand-held, battery-driven device for measuring the relative stability of a dental implant. A small pin "Multi peg" is attached to the dental implant by a screw-connection, with the Multi Peg Driver. The pin has a small magnet incorporated into its top. The instrument is held towards the Multi Peg, and sends short magnetic pulses that bring the pin into vibration. After a pulse has been sent, the instrument measures the vibration by sampling the signal from the alternating magnetic field that follows from the vibrating pin. The frequency of the signal is determined by the instrument and is presented as an "ISQvalue", 1 to 100, where a higher number means higher stability. The measurement takes about 1 second. The instrument consists of a microcontroller and circuits to send the magnetic pulses, to receive the measurement signal, and to present the measurement value. A circuit for battery-charging is also included. Two 2-digit LED displays, one on each side of the instrument, show the measurement value and also communicate possible error codes and software id number at start-up. One operating key is used to turn the instrument on and off. The electronics are contained in a plastic body, which is sealed except for the back of the instrument which has a charging connector. The plastic body is made from PC/ABS plastic except for the tip, which is made from PEEK. No part of the instrument is intended to contact the patient; however, there can be unintentional contact with the tip of the instrument. The instrument is battery-driven and contains re-chargeable NiMh-batteries. The batteries can be charged during use, but it should not be attached while measuring due to the risk of power line interference making it impossible to measure. For safety, a charger complying with IEC 60601-1 is used.The charger connector is of a type that does not allow other chargers to be connected, thereby eliminating the risk of the wrong charger being used.
More Information

No
The description details a device that measures resonance frequency and converts it to a numerical value using a microcontroller and standard electronic circuits. There is no mention of AI or ML algorithms for data processing or interpretation.

No

The device is indicated for measuring the stability of dental implants, which is a diagnostic function, not a therapeutic one. It does not treat or cure any condition.

Yes

The device measures the "stability of dental implants in the oral cavity and the maxillofacial region" and presents this as an "ISQ-value". This measurement provides information about the patient's medical condition (implant stability), which is characteristic of a diagnostic device.

No

The device description clearly outlines multiple hardware components including a hand-held instrument, driver, charger, and measurement pin. The software is embedded within the instrument, but it is not the sole component of the medical device.

Based on the provided information, the IS3 device is not an In Vitro Diagnostic (IVD).

Here's why:

  • IVDs analyze samples taken from the human body. The IS3 device measures the stability of a dental implant in situ within the oral cavity and maxillofacial region. It does not analyze blood, tissue, urine, or any other bodily fluid or sample.
  • The device description clearly outlines a physical measurement process. It involves attaching a pin to the implant and measuring its vibration frequency in response to magnetic pulses. This is a mechanical/physical measurement, not a chemical, biological, or immunological analysis of a sample.
  • The intended use is to measure the stability of dental implants. This is a direct assessment of a medical device's performance within the body, not a diagnostic test performed on a sample to detect a disease or condition.

Therefore, the IS3 device falls under the category of a medical device used for assessment or measurement within the body, rather than an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

IS3 is indicated for use in measuring the stability of dental implants in the oral cavity and the maxillofacial region.

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

EKX

Device Description

IS3 measurement system consists of: IS3 Instrument Hand-held instrument, Multi Peg Driver Driver to attach the ISQ peg to the implant, IS3 Charger 100-240 VAC to 5VDC charger for the instrument batteries, Multi Peg Measurement pin to attach to the implant. Different pins are available to fit different implant types. The IS3 instrument is a hand-held, battery-driven device for measuring the relative stability of a dental implant. A small pin "Multi peg" is attached to the dental implant by a screw-connection, with the Multi Peg Driver. The pin has a small magnet incorporated into its top. The instrument is held towards the Multi Peg, and sends short magnetic pulses that bring the pin into vibration. After a pulse has been sent, the instrument measures the vibration by sampling the signal from the alternating magnetic field that follows from the vibrating pin. The frequency of the signal is determined by the instrument and is presented as an "ISQvalue", 1 to 100, where a higher number means higher stability. The measurement takes about 1 second. The instrument consists of a microcontroller and circuits to send the magnetic pulses, to receive the measurement signal, and to present the measurement value. A circuit for battery-charging is also included. Two 2-digit LED displays, one on each side of the instrument, show the measurement value and also communicate possible error codes and software id number at start-up. One operating key is used to turn the instrument on and off. The electronics are contained in a plastic body, which is sealed except for the back of the instrument which has a charging connector. The plastic body is made from PC/ABS plastic except for the tip, which is made from PEEK. No part of the instrument is intended to contact the patient; however, there can be unintentional contact with the tip of the instrument. The instrument is battery-driven and contains re-chargeable NiMh-batteries. The batteries can be charged during use, but it should not be attached while measuring due to the risk of power line interference making it impossible to measure. For safety, a charger complying with IEC 60601-1 is used.The charger connector is of a type that does not allow other chargers to be connected, thereby eliminating the risk of the wrong charger being used.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

oral cavity and the maxillofacial region.

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Dentists office or hospital

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)

The IS3 instrument brings a pin attached to a dental implant into vibration and then measures the resonance frequency of the vibrating pin. The resonance frequency is then presented as an "ISQ-value" 1-100. The primary predicate device does the same technological principle and the electronic, software since same circuits are used.

Equipment
The IS3 instrument has been tested according to, and found to comply with the following:

  • · EMC standard IEC 60601-1-2
  • · Software validation according to FDA guidance for Software Contained in a Medical Device
  • · Sterilization validation according to ISO 17665-1 and ISO 17665-2
  • · Biocompatibility standard ISO 10993-1
    The device description, software validation, performing testing, sterilization and biocompatibility assessment demonstrate the substantial equivalence of the submission device to the identified primary predicate device.

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.

Tellos ISQ Buddy ( K143445 )

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.

Osstell ISQ ( K082523 )

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

§ 872.4200 Dental handpiece and accessories.

(a)
Identification. A dental handpiece and accessories is an AC-powered, water-powered, air-powered, or belt-driven, hand-held device that may include a foot controller for regulation of speed and direction of rotation or a contra-angle attachment for difficult to reach areas intended to prepare dental cavities for restorations, such as fillings, and for cleaning teeth.(b)
Classification. Class I.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA acronym followed by the full name of the agency, "U.S. Food & Drug Administration," on the right. The FDA part of the logo is in blue, with the acronym in a solid blue square and the agency's name in a lighter shade of blue.

Hiossen, Inc. David Kim RA Manager 85 Ben Fairless Dr. Fairless Hills, Pennsylvania 19030 May 16, 2018

Re: K180527

Trade/Device Name: IS3 Regulation Number: 21 CFR 872.4200 Regulation Name: Dental Handpiece And Accessories Regulatory Class: Class I Product Code: EKX Dated: February 28, 2018 Received: February 28, 2018

Dear David 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 (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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820);

1

and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Mary S. Runner -S

For Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K180527

Device Name IS3

Indications for Use (Describe)

IS3 is indicated for use in measuring the stability of dental implants in the oral cavity and the maxillofacial region.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

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Image /page/3/Picture/0 description: The image shows the logo for HIOSSEN. The logo is in two colors, red and gray. The letters "HI" are in red, and the rest of the word "OSSEN" is in gray. There is a red swoosh above the "O" in "OSSEN".

85 Ben Fairless Dr. Fairless Hills, PA 19030 Tel : 1-888-678-0001 / Fax : 1-267-759-7004 www.hiossen.com

510(k) Summarv

This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of 21 CFR Part 807.92.

Date : Feb 26, 2018

1. Company and Correspondent making the submission

1) Submitter's Name :HIOSSEN, Inc.
2) Address :85 Ben Fairless Dr. Fairless Hills, PA 19030 USA
3) Telephone No.888 678 0001
4) Contact :Mr. David Kim

2. Device

Trade or (Proprietary) Name :IS3
Common or usual name :Dental implant stability analyzer
Accessories name :Mult-Peg
Regulation number :872.4200
Classification code :EKX
Device class :Class I

3. Predicate Device

Primary Predicate Device : Tellos ISQ Buddy ( K143445 ) Reference Predicate Device : Osstell ISQ ( K082523 )

4. Device Description :

  • 4.1. Description : IS3 measurement system consists of:
    IS3 Instrument Hand-held instrument
Multi Peg DriverDriver to attach the ISQ peg to the implant
IS3 Charger100-240 VAC to 5VDC charger for the instrument batteries
Multi PegMeasurement pin to attach to the implant. Different pins are available to fit different implant types.

SECTION 008

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Image /page/4/Picture/0 description: The image shows the logo for Hiossen Implant. The logo is composed of the word "Hiossen" in a stylized font. The "Hi" portion of the word is in red, while the "ossen" portion is in gray. The "H" in "Hi" is connected to a curved line above the "i", adding a unique design element to the logo.

85 Ben Fairless Dr. Fairless Hills. PA 19030 Tel : 1-888-678-0001 / Fax : 1-267-759-7004 www.hiossen.com

4.2. Basic principle and functionality

The IS3 instrument is a hand-held, battery-driven device for measuring the relative stability of a dental implant. A small pin "Multi peg" is attached to the dental implant by a screw-connection, with the Multi Peg Driver. The pin has a small magnet incorporated into its top. The instrument is held towards the Multi Peg, and sends short magnetic pulses that bring the pin into vibration. After a pulse has been sent, the instrument measures the vibration by sampling the signal from the alternating magnetic field that follows from the vibrating pin. The frequency of the signal is determined by the instrument and is presented as an "ISQvalue", 1 to 100, where a higher number means higher stability. The measurement takes about 1 second.

4.3. Technical detail

The instrument consists of a microcontroller and circuits to send the magnetic pulses, to receive the measurement signal, and to present the measurement value. A circuit for battery-charging is also included. Two 2-digit LED displays, one on each side of the instrument, show the measurement value and also communicate possible error codes and software id number at start-up. One operating key is used to turn the instrument on and off. The electronics are contained in a plastic body, which is sealed except for the back of the instrument which has a charging connector. The plastic body is made from PC/ABS plastic except for the tip, which is made from PEEK. No part of the instrument is intended to contact the patient; however, there can be unintentional contact with the tip of the instrument. The instrument is battery-driven and contains re-chargeable NiMh-batteries. The batteries can be charged during use, but it should not be attached while measuring due to the risk of power line interference making it impossible to measure. For safety, a charger complying with IEC 60601-1 is used.The charger connector is of a type that does not allow other chargers to be connected, thereby eliminating the risk of the wrong charger being used.

4.4. Material used

Instrument body: PC/ABS Instrument tip: PEEK (USP VI) Instrument seal : Silicone (USP VI) Instrument key : Silicone (USP VI) Multi Peg Driver: Stainless steel, ASTM F899 Multi Peg: Titanium grade 5, ASTM F136

5. Indication for Use

IS3 is indicated for use in measuring the stability of dental implants in the oral cavity and the maxillofacial region.

6. Comparison and differences to the Predicate Device

The instrument functions the same way as the predicate device regarding the measurement principle and technology used. There is no difference in between the subject device and primary predicate device. The differences with reference device are in the IS3(subject device) and Tellos(primary predicate device) are hand-held instruments while the Osstell ISO(reference

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Image /page/5/Picture/0 description: The image shows the logo for Hiossen Implant. The logo is composed of the word "Hiossen" in a stylized font. The "H" and "I" are in red, with a red swoosh above the "H". The rest of the word, "ossen", is in gray.

SECTION 008

85 Ben Fairless Dr. Fairless Hills, PA 19030 Tel : 1-888-678-0001 / Fax : 1-267-759-7004 www.hiossen.com

predicate device) consists of two parts; the instrument and the measurement probe. The IS3(subject device) and Tellos(primary predicate device) have no memory to store the measurement values; the reference predicate device has a memory that stores the measurements and also has an inbuilt clock timer, and a computer connection for transferring measurement values. IS3 and Primary predicate device has no timer or computer connection. The lack of these features (memory, timer, data transfer) is not considered to be an inconvenience for the user. Instead, it decreases the risk of mixing up values with each other.

| | Proposed device | Primary
Predicate devices | Reference
Predicate device |
|--------------------------------|--------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | IS3 | Tellos ISQ Buddy
(K143445) | Osstell ISQ
(K082523) |
| Manufacturer | HIOSSEN, INC. | Tellos Medical AB | Osstell AB |
| Product Code
/Class | EKX / Class I | EKX / Class I | EKX / Class I |
| Regulation
Number | 872.4200 | 872.4200 | 872.4200 |
| Indication
for Use | Same as primary
predicate device. | The device is indicated for use in
measuring the stability of
implants in the oral cavity and
the maxillofacial region. | The device is indicated for use in
measuring the stability of
implants in the oral cavity and
craniofacial region. |
| Target
Population | Same as primary
predicate device. | Patients with one or more
dental implants | Patients with one or more
dental implants |
| Anatomical
site | Same as primary
predicate device. | Oral cavity or
craniofacial region | Oral cavity or
craniofacial region |
| Usage
location | Same as primary
predicate device. | Dentists office or hospital | Dentists office or hospital |
| Energy
used/delivered | Same as primary
predicate device. | No energy is intended to be
delivered. A small amount of
energy could reach the dental
implant from the self-vibrating
measurement pin. | No energy is intended to be
delivered. A small amount of
energy could reach the dental
implant from the self-vibrating
measurement pin. |
| Technology | Same as primary
predicate device. | A microcontroller sends electric
pulses to a coil in the instrument
tip. As a consequence, magnetic
pulses are emitted that affect the
pin connected to the implant.
The pin then starts to vibrate
with its resonance frequency.
Vibration creates an alternating | A microcontroller sends electric
pulses to a coil in the instrument
tip. As a consequence, magnetic
pulses are emitted that affect the
pin connected to the implant.
The pin then starts to vibrate
with its resonance frequency.
Vibration creates an alternating |
| | | magnetic field which is being | magnetic field which is being |
| | | picked up by another coil in the | picked up by another coil in the |
| | | instrument tip. The electrical | instrument tip. The electrical |
| | | signal from the receiving coil is | signal from the receiving coil is |
| | | analyzed and the frequency is | analyzed and the frequency is |
| | | determined. The Frequency is | determined. The Frequency is |
| | | presented on the display as an | presented on the display as an |
| | | "ISQvalue" | "ISQvalue" |
| Measurement
output | Same as primary
predicate device. | It presents the resonance
frequency of the ISQ peg as an
ISQ number, 1-100. The ISQ
number is calculated from the
resonance frequency. | It presents the resonance
frequency of the ISQ peg as an
ISQ number, 1-100. The ISQ
number is calculated from the
resonance frequency. |
| | | The operating key is pushed and
the instrument is held towards
the attached ISQ peg. The
instrument then presents the ISQ
value. | Any key is pushed and the
measurement probe is held
towards the attached SmartPeg.
The instrument then presents the
ISQ value. |
| Operation | Same as primary
predicate device. | | |
| System
components | Same as primary
predicate device. | Tellos ISQ Buddy instrument,
ISQ Peg, ISQ Peg Driver and
instrument charger. | Osstell ISQ instrument,
measurement probe, SmartPeg
and instrument charger. |
| Power, weight
& size | Same as primary
predicate device. | 3VA, 0.1 Kg, 200 x 30 mm | 8 VA, 0.4 Kg, 195 x 20 x 45 mm |
| Materials
used | Same as primary
predicate device. | Instrument; PC/ABS and PEEK.
Gasket and operating key:
Silicone
ISQ Peg Driver: Stainless steel
ISQ Peg: Titanium | Instrument: Not available
Measurement probe: Not
available
SmartPeg driver: Not Available
SmartPeg: Aluminum |
| Instrument
memory | Same as primary
predicate device. | Tellos ISQ Buddy has no data
memory.The instrument displays
the measurement value after the
measurement. The memory is
not a necessary feature and the
absence of a memory decreases
the risk of mixing up values
between different implants
during a patient session. | Osstell ISQ has a memory for
storing measurement values. |
| Instrument
setup-menu | Same as primary
predicate device. | No setup-menu is needed for
Tellos ISQ Buddy. The
instrument has one operating key
and no parameters to change. | Instrument has a setup-menu for
various instrument parameters
such as display contrast and
computer connection. |
| Data transfer | Same as primary
predicate device | Since Tellos ISQ Buddy has no
memory, there are no data to
transfer. This is not a necessary
feature, and the absence of | Osstell ISQ has a cable
attachment to a PC computer,
for transferring data. |
| Clock Timer | Same as primary
predicate device | the risk of mixing up values
between different implants
during a patient session.
Since Tellos ISQ Buddy has no
memory, there is no need for a
clock timer. | Osstell ISQ has a built-in clock
timer. |
| Number of
operating
keys | Same as primary
predicate device | Tellos ISQ Buddy has one
operating key, used for turning
on and off the instrument. Since
the instrument has no memory or
setup-menu, not more than one
key is needed. With one key,the
instrument is more intuitive and
easier to use, which leaves less
room for user errors compared to
the predicate device. | Osstell ISQ has 5 operating keys,
for working the setup-menu and
for navigating the instrument
memory. |
| Display | Same as primary
predicate device | Tellos ISQ Buddy has two LED-
displays; one on each side of the
instrument for easy reading. | Osstell ISQ has one LCD display
on the instrument. |
| Measurement
pins | Same as primary
predicate device | Tellos ISQ Buddy uses the
Osstell SmartPegs, or
corresponding Tellos pins, “ISQ
Pegs” from titanium. | Osstell ISQ uses disposable
aluminum pins, “SmartPegs”. |
| Electrical
safety | Same as primary
predicate device | It is designed to the standard
IEC 60601-1 Medical Electrical | Osstell ISQ is designed to the
standard IEC 60601-1 Medical |

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Image /page/6/Picture/0 description: The image shows the logo for Hiossen Implant. The logo features the word "Hiossen" in a stylized font. The "H" and "I" are in red, while the rest of the word is in gray. There is a red swoosh above the "H" and "I".

Hiossen Inc.

85 Ben Fairless Dr. Fairless Hills, PA 19030 Tel : 1-888-678-0001 / Fax : 1-267-759-7004 www.hiossen.com

7

Image /page/7/Picture/0 description: The image shows the Hiossen logo. The "HI" part of the logo is in red, while the "OSSEN" part is in gray. There is a red swoosh above the "HI" part of the logo.

Hiossen Inc.

85 Ben Fairless Dr. Fairless Hills, PA 19030 Tel : 1-888-678-0001 / Fax : 1-267-759-7004 www.hiossen.com

7. Performance testing

The IS3 instrument brings a pin attached to a dental implant into vibration and then measures the resonance frequency of the vibrating pin. The resonance frequency is then presented as an "ISQ-value" 1-100. The primary predicate device does the same technological principle and the electronic, software since same circuits are used.

Equipment

The IS3 instrument has been tested according to, and found to comply with the following:

  • · EMC standard IEC 60601-1-2
  • · Software validation according to FDA guidance for Software Contained in a Medical Device
  • · Sterilization validation according to ISO 17665-1 and ISO 17665-2
  • · Biocompatibility standard ISO 10993-1

SECTION 008

Electrical Equipment

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Image /page/8/Picture/0 description: The image shows the Hiossen logo. The "HI" is in red, and the "OSSEN" is in gray. The "H" is capitalized, and the "I" is lowercase. The "OSSEN" is all capitalized. There is a red swoosh above the "HI".

SECTION 008

85 Ben Fairless Dr. Fairless Hills, PA 19030 Tel : 1-888-678-0001 / Fax : 1-267-759-7004 www.hiossen.com

8. Substantial Equivalence Conclusion

The purpose of using the instrument is to measure the ISQ value (the relative stability) of the implant. The IS3 has the same indication for use, measurement output and technology as the primary predicate device.

The device description, software validation, performing testing, sterilization and biocompatibility assessment demonstrate the substantial equivalence of the submission device to the identified primary predicate device.

Therefore, the IS3 can be found substantially equivalent to the Tellos ISQ Buddy.