PAPAYA & PAPAYA Plus are 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 of teeth, 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 crosssectional radiographic images provide dimensional information for dental implant planning and information about location of impacted teeth.

Device Description

The proposed devices PAPAYA & PAPAYA Plus are diagnostic imaging system which consists of multiple image acquisition modes; panorama and cephalometric. The difference beteween PAPAYA & PAPA YA Plus is only optional of the cephalometric detector. (Without cephalometric detector, we model named PAPAYA, and with cephalometric detector, we model named PAPAYA Plus.)

The proposed devices have the CUST imaging option which is used to reconstruct tomographic images from a set of pre-acquired projection radiographic images of the object.

The differences from predicate device(K141700) are change of power voltage, addition of image processing software(Theia, Triana).

AI/ML Overview

This FDA submission describes the PAPAYA & PAPAYA Plus digital extraoral source X-ray systems, which are intended to produce panoramic and cephalometric images for dental and craniofacial diagnosis and treatment planning. The submission asserts substantial equivalence to a previously cleared device, PAPAYA Plus (K141700).

Here's an analysis of the provided information regarding acceptance criteria and supporting studies:

1. Table of Acceptance Criteria and Reported Device Performance

The submission does not explicitly list acceptance criteria in the format of a separate table with target values. Instead, it presents a comparative table between the proposed device and the predicate device, highlighting performance specifications and software features. The "acceptance criteria" are implied to be that the proposed device performs at least equivalently to the predicate device, with any changes either being safety-verified or not impacting overall efficacy.

Criteria	Proposed device (PAPAYA & PAPAYA Plus)	Predicate Device (PAPAYA Plus - K141700)	Conclusion on Equivalence against Implicit Criteria
Indications for Use	Same as predicate	Digital extraoral source X-ray system for panoramic and cephalometric images of oral/craniofacial anatomy, dental/skull radiographic examination, and CUST (Tomographic) option for cross-sectional images for implant planning and impacted teeth.	Equivalent
Performance Specification	Panoramic (PAPAYA), Panoramic and Cephalometric (PAPAYA Plus)	Panoramic (PAPAYA), Panoramic and Cephalometric (PAPAYA Plus)	Equivalent
Input Voltage	100-240 V~, 50/60Hz	120 V~, 60Hz	Different, but safety/EMC verified
Tube Voltage	60-90 kV	60-90 kV	Equivalent
Tube Current	4-12 mA	4-12 mA	Equivalent
Focal Spot Size	0.5 mm	0.5 mm	Equivalent
Exposure Time	Panorama: max 17 sec, Cephalo: max 12 sec	Panorama: max 17 sec, Cephalo: max 12 sec	Equivalent
Exposure Mode	Panoramic, TMJ, SINUS, CUST, Cephalo	Panoramic, TMJ, SINUS, CUST, Cephalo	Equivalent
Image Receptor	CMOS (Panoramic and Cephalometric)	CMOS (Panoramic and Cephalometric)	Equivalent
Image Processing Software	Triana (K103182) or Theia	N/A (Predicate did not specify external image processing software in this comparison)	Different, but Theia validated against IEC 62304 and deemed functionally equivalent to Triana
Safety/EMC/Performance Data	Tested to IEC 60601-1, -1-2, -1-3, -1-6, -2-63,IEC 62366, IEC 62304, Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance, Guidance for Industry and FDA Staff Guidance for the Content of Premarket Submissions for Software contained in Medical Devices, Pediatric Information for X-ray Imaging Device Premarket Notifications, Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging Devices, NEMA PS 3.1-3.20 (DICOM Set)	Established in K141700	Equivalent through compliance with relevant standards and guidelines

2. Sample Size Used for the Test Set and Data Provenance

The submission mentions "Clinical Evaluation Report and bench" testing for safety and effectiveness but does not provide specific details about the sample size used for any clinical test set or the provenance of any data (e.g., country of origin, retrospective/prospective). The primary focus of the performance data section is on adherence to regulatory standards and comparison to a predicate device's specifications.

3. Number of Experts Used to Establish Ground Truth and Qualifications

There is no mention of experts or ground truth establishment in the context of a diagnostic performance study for the proposed device in this submission. The submission centers on the physical device's specifications and software validation.

4. Adjudication Method

No adjudication method is mentioned, as there is no description of a study involving subjective assessment of diagnostic accuracy.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No MRMC study comparing human readers with and without AI assistance is mentioned. The device described is an X-ray imaging system and associated image processing software, not an AI-assisted diagnostic tool in the sense of providing automated interpretations. While the software offers "3D visualization, 2D analysis, various MPR functions," which can assist human readers, it's not discussed in the context of an MRMC study for effect size improvement.

6. Standalone (Algorithm Only) Performance

A standalone performance study for the image processing software (Triana or Theia) beyond the validation against IEC 62304 for software lifecycle processes is not explicitly described in terms of diagnostic accuracy or a specific clinical task without human interaction. The software is described as a tool to "obtain, store, inquire, and process the acquired image," suggesting it's an enhancement for human interpretation, not a standalone diagnostic algorithm.

7. Type of Ground Truth Used

No specific "ground truth" (e.g., expert consensus, pathology, outcomes data) is mentioned as part of a diagnostic accuracy study. The safety and performance assessments are based on compliance with electrical, mechanical, and imaging standards, as well as software validation.

8. Sample Size for the Training Set

The submission does not mention a training set, as it does not describe the development or validation of a machine learning-based diagnostic algorithm. The software mentioned (Triana/Theia) performs image processing and visualization, not AI-driven diagnosis requiring a training set.

9. How the Ground Truth for the Training Set Was Established

Since no training set is mentioned, this information is not provided.

Summary

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA acronym with the agency's name on the right. The symbol on the left is the Department of Health & Human Services logo. The right side of the logo has the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

GENORAY Co., Ltd. % Kaitlynn Min Business Development GENORAY America Inc. 147 E. Bristol Lane ORANGE CA 92865

Re: K220423

Trade/Device Name: PAPAYA & PAPAYA Plus Regulation Number: 21 CFR 872.1800 Regulation Name: Extraoral source x-ray system Regulatory Class: Class II Product Code: MUH Dated: February 17, 2022 Received: February 18, 2022

Dear Kaitlynn 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. 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.

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

May 19, 2022

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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

Laurel Burk, Ph.D. Assistant Director Diagnostic X-ray Systems Team DHT 8B: Division of Radiological Imaging and Electronic Products OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K220423

Device Name PAPAYA & PAPAYA Plus

Indications for Use (Describe)

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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Exhibit 5 510(k) Summary

Date of Summary Preparation: Feb 16, 2022

1. Submitter and US Official Correspondent

Submitter	: GENORAY Co., Ltd.
Address	: 512, 560, Dunchon-daero, Junwong-gu, Seongnam-si, Gyeonggi-Do Korea
Telephone No.	: +82-31-5178-5770
Fax	: +82-31-5178-5699

Official Correspondent (U.S): Kaitlynn Min - Business Manager

Correspondent	: GENORAY America Inc.
Address	: 147 E. Bristol Lane, Orange, CA 92865 USA
Telephone No.	: +1-855-436-6729
Fax	: +1-714-786-8919
Email	: kaitlynn@genorayamerica.com

2. Establishment Registration Number

: 3005843418

3. Device Information

Trade Name / Proprietary Name: PAPAYA & PAPAYA Plus Common Name: Digital X-ray Imaging System Classification Name / Product Code: Extraoral Source X-ray System / MUH Regulation Number: 21 CFR 872.1800 Device Class: Class II

4. Predicate Device (Equivalent Legally Marketed Device)

Trade Name / Proprietary Name: PAPAYA Plus (K141700, GENORAY Co., Ltd) Common Name: Digital X-ray Imaging System Classification Name / Product Code: Extraoral Source X-ray System / MUH Regulation Number: 21 CFR 872.1800 Device Class: Class II

5. Reference Device (Equivalent Legally Marketed Device)

Trade / Proprietary Name : Triana (K103182) Device Class: Class II Regulation Number : 21 CFR 892.2050 Classification Name / Product Code: System, Image Processing, Radiological / LLZ Indications for Use(IFU) : Triana is intended for use as a software package which obtains medical images from CT,

Cephalometric / Panoramic X-ray system & etc., stores those and provides 3D visualization, 2D analysis, various MPR(Multi-Planar Reconstruction) functions for further rapid and precise diagnosis.

6. Description of the Device

The proposed devices have the CUST imaging option which is used to reconstruct tomographic images from a set of pre-acquired projection radiographic images of the object.

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The differences from predicate device(K141700) are change of power voltage, addition of image processing software(Theia, Triana).

First of all, the input voltage (power rating) of predicate device was 120V~, 60Hz. However due to change of the power board, proposed device is available to 100-240V~. 50/60Hz. Due to this power specification change, critical components change was verified via safety/EMC test report performed by CSA and SGS according to IEC 60601-1 (3.0 ed), IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-63.

Second, the proposed device can be used with image processing software, Triana(K103182) or Thiea. Triana (K103182) and Theia are image processing software that processes image acquired through PAPAYA & PAPAYA Plus. The two software uses not only the purpose of use, but also acquires and stores the image, and Inquires and processes the acquired image (deletion, enlargement, reduction, distance and angle measurement, drawing information in the image, 3D image reconstruction, etc.), it is the same in that it has the function to finally transmit to the DICOM Server. However, in Theia, by rearranging the configuration within the UI to improve the user's convenience, there is only a visual difference between Triana and Theia were validated throughout IEC 62304:2006/AC: 2008.

7. Indications for use

PAPAYA & PAPAYA Plus are 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 of teeth, 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

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7. Substantial equivalence chart

Criteria	Proposed device		Predicate Device
Name	PAPAYA & PAPAYA Plus		PAPAYA Plus
Manufacturer	GENORAY Co., Ltd.		GENORAY Co., Ltd.
510(k) No.	-		K141700
Figure	Image: PAPAYA	Image: PAPAYA Plus	Image: PAPAYA	Image: PAPAYA Plus

Indicationsfor use	PAPAYA & PAPAYA Plus are digital extraoral source X-raysystem intended to produce panoramic and cephalometric(option)images of the oral and craniofacial anatomy for a precise treatmentplanning in adult and pediatric care. The system is used for dental &skull radiographic examination and diagnosis of teeth, jaw, oralstructure, and skull by exposing an X-ray image receptor to ionizingradiation, with a digital imaging capability for taking bothpanoramic and cephalometric images. And This system can beequipped cust(Tomographic) option, which is capable of takingcross-sectional radiographic images. These images providedimensional information for dental implant planning and informationabout location of impacted teeth.		PAPAYA & PAPAYA Plus are digital extraoral source X-raysystem intended to produce panoramic and cephalometric(option)images of the oral and craniofacial anatomy for a precise treatmentplanning in adult and pediatric care. The system is used for dental &skull radiographic examination and diagnosis of teeth, jaw, oralstructure, and skull by exposing an X-ray image receptor to ionizingradiation, with a digital imaging capability for taking bothpanoramic and cephalometric images. And This system can beequipped cust(Tomographic) option, which is capable of takingcross-sectional radiographic images. These images providedimensional information for dental implant planning andinformation about location of impacted teeth.
Performance Specification	Panoramic	Panoramic and Cephalometric	Panoramic	Panoramic and Cephalometric
Input Voltage	100-240 V~, 50/60Hz	100-240 V~, 50/60Hz	120 V~, 60Hz	120 V~, 60Hz
Tube Voltage	60-90 kV	60-90 kV	60-90 kV	60-90 kV
Tube Current	4-12 mA	4-12 mA	4-12 mA	4-12 mA
Focal Spot Size	0.5 mm	0.5 mm	0.5 mm	0.5 mm
Exposure Time	Panorama: max 17 sec.	Panorama: max 17 sec.Cephalo : max 12 sec.	Panorama: max 17 sec.	Cephalo : max 12 sec.
Exposure mode	Panorama: Panoramic modeTMJ modeSINUS modeCUST mode	Panorama: Panoramic modeTMJ modeSINUS modeCUST modeCephalo: Cephalo mode	Panorama: Panoramic modeTMJ modeSINUS modeCUST mode	Panorama: Panoramic modeTMJ modeSINUS modeCUST modeCephalo: Cephalo mode
Image Receptor	Panoramic sensor : CMOS	Panoramic & cephalometricsensor : CMOS	Panoramic sensor : CMOS	Panoramic & cephalometricsensor : CMOS
ImageprocessingSoftware	S/W	Triana(K103182)	Theia
	IntendedUse	Triana and Theia are intended for use as a software packagesoftware which obtains medical images from CT,Cephalometric / Panoramic X-ray system & etc., stores thoseand provides 3D visualization, 2D analysis, various MPR(Multi-Planar Reconstruction) functions for further rapid andprecise diagnosis.
	GeneralFunction	- obtaining medical images- storing medical images- Inquires and processes theacquired image (deletion,enlargement, reduction,rotation, distance andanglemeasurement, drawinginformation in the image)- 3D visualization- 2D analysis- various MPR (Multi-PlanarReconstruction)	- obtaining medical images- storing medical images- Inquires and processes theacquired image (deletion,enlargement, reduction,rotation, distance andanglemeasurement, drawinginformation in the image)- 3D visualiziation- 2D analysis- various MPR (Multi-PlanarReconstruction)
Result			The proposed devices, PAPAYA & PAPAYA Plus, are was developed from the predicate device PAPAYA Plus (K141700), andmodifications are changing of input power, addition of image processing software.First of all, the input voltage (power rating) of predicate device was 120V~, 60Hz. However due to change of the power board,proposed device is available to 100-240V~. 50/60Hz. Due to this power specification change, critical components change wasverified via safety/EMC test report performed by CSA and SGS according to IEC 60601-1 (3.0 ed), IEC 60601-1-2, IEC 60601-1-3, IEC 60601-2-63.

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Second, the proposed device can be used with image processing software, Triana or Theia. The difference between Triana and
Theia is only UI, and the Theia was developed for marketing purpose only. Triana and Theia were validated throughout IEC
62304:2006/AC: 2008.
Third, Theia is a newly developed software after the release of Triana, but as can be seen from the table above, both Triana and
Theia can be used for PAPAYA & PAPAYA Plus, and the technical characteristics and applications, including the Intended
Use, are essentially the same. can be judged to be equivalent. Also, the general functions of both software are the same overall.
The General function is the same for both Theia and Triana. However, Theia added 3D TMJ Screen (a function to view the
TMJ part separately) and Airway screen (a function to indicate the airway), which are detailed functions within the 3D
visualization function, to improve the user's convenience in the functions of Triana.

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8. Safety, EMC and Performance data comparison to Predicate

Device Safety, EMC and Performance data is same to predicate device which has been established in 510(k) submission K141700 as below. All test results were satisfactory.

Electrical, mechanical, environmental safety and performance testing to standard IEC 60601-1, IEC 60601-1-3, , IEC 60601-1-6, IEC 60601-2-63, IEC 62366 and IEC 62304 were performed.
EMC testing was conducted in accordance with standard IEC 60601-1-2.
Content of Premarket Submissions for Management of Cybersecurity in Medical Devices Guidance for Industry and Food and Drug Administration Staff Document Issued on: October 2, 2014
Guidance for Industry and FDA Staff Guidance for the Content of Premarket Submissions for Software contained in Medical Devices, Document issued on: May 11, 2005 Medical Devices, Document issued on: May 11, 2005
Guidance for Industry and Food and Drug Administration Staff Pediatric Information for X-ray Imaging Device Premarket Notifications, November 2017
FDA Guidance "Guidance for the submissions of 510(k)'s for Solid State X-ray Imaging Devices" was performed. The tests include the MTF, DQE and the dynamic range of the panoramic sensor and the cephalometric sensor.
PAPAYA & PAPAYA Plus also meet the provisions of NEMA PS 3.1-3.20. Digital Imaging and Communications in Medicine (DICOM) Set.
PAPAYA & PAPAYA Plus were tested for safety and effectiveness in Clinical Evaluation Report and bench.

9.Conclusion

Proposed device has the same indication for use as the predicate device. And there have been no changes that impact either the fundamental technology or the indication for use. The proposed device with modification outlined in this Premarket Notification is substantially equivalent to the currently commercially available predicate device.

Regulation Number and Section

§ 872.1800 Extraoral source x-ray system.

(a)
Identification. An extraoral source x-ray system is an AC-powered device that produces x-rays and is intended for dental radiographic examination and diagnosis of diseases of the teeth, jaw, and oral structures. The x-ray source (a tube) is located outside the mouth. This generic type of device may include patient and equipment supports and component parts.(b)
Classification. Class II.