K Number
K193623
Device Name
DIOnavi-Denture
Manufacturer
Date Cleared
2020-10-22

(301 days)

Product Code
Regulation Number
872.3760
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
DIOnavi-Denture is a light-curable resin indicated for fabrication and repair of full and partial removable dentures and baseplates. The material is an alternative to traditional heat-curable and auto polymerizing resins. Fabrication of dental prosthetics with DIOnavi-Denture requires a computer-aided design and manufacturing (CAD/CAM) system that includes the following components: digital denture based on a digital impression, a digital light processing (DLP) printer, and curing light equipment.
Device Description
DIOnavi-Denture is a photo-cured resin intended to fabricate full and partial removable dentures in a CAD/CAM additive printing process. The material is an alternative to traditional heat cured and auto polymerization resins. It is denture base resins, Photo-cured product family comprises a family of dimethacrylate resins. The dimethacrylate resin is polymerized via photo initiators in a 3D printer. The color of the denture is determined by the addition of pigments. The material is used in a 3D printer. which prints the shape determined by a 3D drawing. After printed product is placed in a UVlight curing box for final polymerization. 3D printer and UV-light curing box is not included with the device. The denture fabrication process begins with a traditional impression or optical impression of the oral region in the dentist office. This impression is sent to a dental lab. The denture base is then made layer-bylayer in a DLP (digital light processing) printer. After attachment of preformed plastic teeth, the denture is cured in a light chamber, and, lastly, sent back to the dentist for try-in and final adjustment.
More Information

No
The summary describes a photo-cured resin used in a CAD/CAM system for fabricating dentures. It mentions digital impressions, 3D printing, and curing, but there is no mention of AI or ML being used in the design, manufacturing, or analysis process. The performance studies focus on material properties and equivalence to a predicate device, not on algorithmic performance.

No.
This device is a material (light-curable resin) used for the fabrication and repair of dental prosthetics (dentures and baseplates), not a therapeutic device itself.

No Sex

This device is a light-curable resin used for fabricating and repairing dentures, which is a manufacturing process, not a diagnostic one.

No

The device is a light-curable resin, which is a physical material used in a manufacturing process. While it is part of a CAD/CAM system that includes software, the device itself is the resin material, not the software component.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, tissue) to provide information for the diagnosis, treatment, or prevention of disease.
  • DIOnavi-Denture's Intended Use: The intended use of DIOnavi-Denture is for the fabrication and repair of dental prosthetics (dentures and baseplates). This is a manufacturing process for a medical device that is placed in the body, not a test performed on a specimen taken from the body.
  • Device Description: The description details a material used in a 3D printing process to create a physical object (a denture). It doesn't involve analyzing biological samples.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analysis of biological specimens.
    • Providing diagnostic information.
    • Measuring biomarkers or analytes.
    • Use in a laboratory setting for testing purposes.

DIOnavi-Denture is a dental material used in the fabrication of a medical device (a denture). It falls under the category of dental prosthetics materials, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

DIOnavi-Denture is a light-curable resin indicated for fabrication and repair of full and partial removable dentures and baseplates. The material is an alternative to traditional heat-curable and auto polymerizing resins. Fabrication of dental prosthetics with DIOnavi-Denture requires a computer-aided design and manufacturing (CAD/CAM) system that includes the following components: digital denture based on a digital impression, a digital light processing (DLP) printer, and curing light equipment.

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

EBI

Device Description

DIOnavi-Denture is a photo-cured resin intended to fabricate full and partial removable dentures in a CAD/CAM additive printing process. The material is an alternative to traditional heat cured and auto polymerization resins. It is denture base resins, Photo-cured product family comprises a family of dimethacrylate resins. The dimethacrylate resin is polymerized via photo initiators in a 3D printer. The color of the denture is determined by the addition of pigments. The material is used in a 3D printer. which prints the shape determined by a 3D drawing. After printed product is placed in a UVlight curing box for final polymerization. 3D printer and UV-light curing box is not included with the device.

The denture fabrication process begins with a traditional impression or optical impression of the oral region in the dentist office. This impression is sent to a dental lab. The denture base is then made layer-bylayer in a DLP (digital light processing) printer. After attachment of preformed plastic teeth, the denture is cured in a light chamber, and, lastly, sent back to the dentist for try-in and final adjustment.

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 Testing: Performance tests in accordance with ISO 20795-1 including visual inspection, capacity, package integrity, dimensions, surface characteristics, shape capability, translucency, color stability, flexural strength. The results met the criteria of the standards and supported substantial equivalence.

Shelf Life Testing: Shelf-life testing for 2 years conducted with bench tests from ISO 20975-1.

Biocompatibility: Tests in accordance with FDA Guidance Document Use of International ISO 10993-1. Biological safety aspects addressed: Cytotoxicity (ISO 10993-5), Sensitization (ISO 10993-10), Irritation reactivity test (ISO 10993-10), Genotoxicity test (ISO 10993-3), Sub-acute toxicity (ISO 10993-11), Material-mediated pyrogenicity (ISO 10993-11).

No clinical testing was performed for this submission.

Key Results: All test results met the criteria and demonstrated that differences in formulation or printer type would not raise a question in substantial equivalence and the subject device would perform as well as the predicate devices.

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.

DENTCA Denture Base II (K162044)

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.

Nextdent Denture, E-Denture (K162572)

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

§ 872.3760 Denture relining, repairing, or rebasing resin.

(a)
Identification. A denture relining, repairing, or rebasing resin is a device composed of materials such as methylmethacrylate, intended to reline a denture surface that contacts tissue, to repair a fractured denture, or to form a new denture base. This device is not available for over-the-counter (OTC) use.(b)
Classification. Class II.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food & 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.

October 22, 2020

DIO Corporation % Priscilla Chung Regulatory Affairs Consultant LK Consulting Group USA, Inc 1150 Roosevelt, STE 200 Irvine, California 92620

Re: K193623

Trade/Device Name: DIOnavi-Denture Regulation Number: 21 CFR 872.3760 Regulation Name: Denture Relining, Repairing, Or Rebasing Resin Regulatory Class: Class II Product Code: EBI Dated: February 3, 2020 Received: February 11, 2020

Dear Priscilla Chung:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

1

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about 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-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

for Srinivas "Nandu" Nandkumar, Ph.D. Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K193623

Device Name DIOnavi-Denture

Indications for Use (Describe)

DIOnavi-Denture is a light-curable resin indicated for fabrication and repair of full and partial removable dentures and baseplates. The material is an alternative to traditional heat-curable and auto polymerizing resins. Fabrication of dental prosthetics with DIOnavi-Denture requires a computer-aided design and manufacturing (CAD/CAM) system that includes the following components: digital denture based on a digital impression, a digital light processing (DLP) printer, and curing light equipment.

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/1 description: The image shows the logo for DIO Implant Solution. The logo has the letters "DIO" in a sans-serif font, with "DI" in gray and "O" in pink with a small pink circle above and to the right of it. Below the letters is the text "Implant Solution" in a smaller, gray, sans-serif font.

510(k) Summary K193623

This 510(k) Summary is being submitted in accordance with requirement of 21 CFR Part 807.92

Submitter:

Jiae, Park DIO Corporation 66 Centum seo-ro, Haeundae-gu, Busan, 48058. Republic of Korea Phone +82-51-745-7836 Fax +82-51-745-7781

Official correspondent:

Priscilla Juhee Chung LK Consulting Group USA, Inc 1150 Roosevelt, STE 200, Irvine CA 92620 Email: juhee.c@lkconsultinggroup.com Phone +1-714-702-5789 +1-714-409-3357 Fax

Device Information:

Proprietary Name: DIOnavi-Denture Common Name: Dental Denture Resin Classification Name: Denture Relining, Repairing, or Rebasing Resin Product Code: EBI Regulation Number: 21 CFR 872.3760 Device Class: Class II Date prepared: OCT 18, 2020

Description

DIOnavi-Denture is a photo-cured resin intended to fabricate full and partial removable dentures in a CAD/CAM additive printing process. The material is an alternative to traditional heat cured and auto polymerization resins. It is denture base resins, Photo-cured product family comprises a family of dimethacrylate resins. The dimethacrylate resin is polymerized via photo initiators in a 3D printer. The color of the denture is determined by the addition of pigments. The material is used in a 3D printer. which prints the shape determined by a 3D drawing. After printed product is placed in a UVlight curing box for final polymerization. 3D printer and UV-light curing box is not included with the device.

The denture fabrication process begins with a traditional impression or optical impression of the oral region in the dentist office. This impression is sent to a dental lab. The denture base is then made layer-bylayer in a DLP (digital light processing) printer. After attachment of preformed plastic teeth, the denture is cured in a light chamber, and, lastly, sent back to the dentist for try-in and final adjustment.

Indication For Use

DIOnavi-Denture is a light-curable resin indicated for fabrication and repair of full and partial removable dentures and baseplates. The material is an alternative to traditional heat-curable and auto polymerizing resins. Fabrication of dental prosthetics with DIOnavi-Denture requires a computer-aided design and manufacturing (CAD/CAM) system that includes the following components: digital denture base files based on a digital impression, a DLP (digital light processing) printer, and curing light equipment.

Predicate devices

The subject device is substantially equivalent to the following Predicate Device: Primary Predicate Device : Dentca Denture Base II (K162044) Reference Device : Nextdent Denture, E-Denture (K162572)

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Image /page/4/Picture/1 description: The image shows the logo for DIO Implant Solution. The word "DIO" is displayed in a bold, sans-serif font, with the "DI" in gray and the "O" in pink with a small pink circle above and to the right of it. Below the word "DIO" are the words "Implant Solution" in a smaller, gray, sans-serif font.

Summaries of Technological Characteristics

The following table compares technological and other characteristics of the subject and a predicate device.

Subject DevicePrimary Predicate DeviceReference Device
ApplicantDIO CorporationDentca, Inc.Vertex-Dental B.V.
Trade NameDIOnavi-DentureDentca Denture Base IINextDent™ Denture
E-Denture
510(K) No.K193623K162044K162572
Regulation
NameDenture Relining, Repairing, Or Rebasing
ResinDenture Relining, Repairing, Or Rebasing
ResinResin, Denture, Relining, Repairing, Rebasing
Product CodeEBIEBIEBI
ClassClass IIClass IIClass II
Device
IdentificationLight-cured resinLight-cured resinLight-Cure Resin,
provided in container
Indications
for UseDIOnavi-Denture is a light-curable resin
indicated for fabrication and repair of full and
partial removable dentures and baseplates. The
material is an alternative to traditional heat-
curable and auto polymerizing resins.
Fabrication of dental prosthetics with DIOnavi-
Denture requires a computer-aided design and
manufacturing (CAD/CAM) system that
includes the following components: digital
denture base files based on a digital impression,
a digital light processing(DLP) printer, and
curing light equipment.DENTCA Denture Base II is a light-curable
resin indicated for fabrication and repair of full
and partial removable dentures and baseplates.
The material is an alternative to traditional
heat-curable and auto polymerizing resins.
Fabrication of dental prosthetics with Dentca
Denture Base II requires a computer-aided
design and manufacturing (CAD/CAM) system
that includes the following components: digital
denture base files based on a digital impression,
stereolithographic additive printer, and curing
light equipment.NextDent™ Denture / E-Denture is a light-
cured resin indicated for the fabrication of
denture bases fabricated in dental laboratories,
including full and partial removable dentures.
The material is an alternative to traditional heat
cured and auto polymerization resins.
NextDent™ Denture / E-Denture is intended
exclusively for professional dental work.
Fabrication of denture bases with NextDent ™
Denture / E-Denture requires a computer-aided
and manufacturing (CAD/CAM) system that
includes the following; scanner, design
software, additive printer, and post-cure unit.
NextDent™ Denture / E-Denture is compatible
with the following CAD/CAM systems
components:

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Image /page/5/Picture/1 description: The image shows the logo for DIO Implant Solution. The logo consists of the letters "DIO" in a bold, sans-serif font, with the "D" and "I" in gray and the "O" in pink with a small pink circle above and to the right of it. Below the letters, in a smaller, gray font, are the words "Implant Solution."

Design
BrandType
Scanner3ShapeD900
Design software3ShapeDental-System 2016-Premium
Printing:
PrinterBrandTypeSoftware
EnvisionTECDDDP 4Perfactory
RapidshapeD30NetFabb
Miicraft125YMiiUtility
MiiController
3D systemsFigure 43D Sprint
Roland DGDWP-80SVer1.1
Post-Curing:
Post-cure unitNextDent
LC-3DPrint Box
Chemical
compositionDimethacrylate-based resins with photo-
initiator, and pigments.Methacrylate-based resins with photo-initiator,
inhibitor and pigmentsDimethacrylate-based resins with photo-
initiator, and pigments.
Chemical
formulationPre-mixed liquid resin provided in a containerPre-mixed liquid resin provided in a containerPre-mixed liquid resin provided in a container
Polymerization
n
(Curing)
MethodVisible lightVisible lightVisible light
Fabrication of
Denture BaseAutomated 3D printing of resin in multiple
layers, each light-cured before adding next
layer, with post curing in light chamberAutomated 3D printing of resin in multiple
layers, each light-cured before adding next
layer, with post curing in light chamberAutomated 3D printing of resin in multiple
layers, each light-cured before adding next
layer, with post curing in light chamber
Post CuringVisible light-curing unitVisible light-curing unitVisible light-curing unit
Product StatePre-mixed resin (liquid)Pre-mixed resin (liquid)Pre-mixed resin (liquid)
Teeth
AssembleBondingBondingBonding
SterilizationNon-sterileNon-sterileNon-sterile
Shelf-life2 years-2 years
Device
CharacteristicsAutomated 3D printing of resin in multiple
layers, each light-cured before adding next
layer, with post curing in light chamber.Automated 3D printing of resin in multiple
layers, each light-cured before adding next
layer, with post curing in light chamber.Denture Base Resins, Photo-Cured product
family comprises a family of dimethacrylate
resins. In general, the products in this family
are composed of a 2-component dimethacrylic
system, polymerized via photo initiators in a

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Image /page/6/Picture/1 description: The image shows the logo for DIO Implant Solution. The logo has the letters "DIO" in a bold sans-serif font, with "DI" in gray and "O" in pink. Above the "O" is a small pink circle. Below the letters is the text "Implant Solution" in a smaller, sans-serif font.

| | | | 3D printer setting. The color of the denture is
determined by the addition of pigments. |
|------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|
| Physical
properties | Density: 1.11-1.3
Viscosity : 770-1430 cPs
Flexural strength (After curing): 65 30 days. The ISO 10993-1 standard was followed and the following biological safety aspects have been addressed: Cytotoxicity in accordance with ISO 10993-5 Sensitization in accordance with ISO 10993-10 Irritation reactivity test in accordance with ISO 10993-10 Genotoxicity test in accordance with ISO 10993-3

Sub-acute toxicity in accordance with ISO 10993-11

Material-mediated pyrogenicity in accordance with ISO 10993-11

Summary of clinical testing

No clinical testing was performed for this submission.

Conclusions

The test results of non-clinical tests performed on the subject device supported that it is substantially equivalent to the predicate devices despite the differences. Based on the information provided in this premarket notification, DIO Corporation concludes that the DIOnavi-Denture is substantially equivalent to the predicate device as described herein in.