(88 days)
No.
The document describes dental abutments and screws designed and manufactured using CAD/CAM software. It does not mention any AI, ML, or DNN technology in its description, intended use, or performance studies.
No.
A therapeutic device is one that treats or cures a disease or condition. This device, an abutment for dental implants, supports prosthetic restorations and restores chewing function, which is a restorative rather than a therapeutic function.
No
The device description clearly states its purpose is to provide "support for customized prosthetic restorations" as a "customized prosthetic abutment" placed onto dental implants. It is a restorative device for tooth replacement, not a diagnostic tool for identifying diseases or conditions.
No
The device is a physical medical implant (customized prosthetic abutment manufactured in titanium alloy) that is placed onto dental implants. While its design involves CAD/CAM software, the device itself is a tangible hardware component. The summary also details extensive hardware-centric testing, including bench testing for dynamic fatigue and torsion, biocompatibility, sterilization validation, and MRI compatibility.
No.
The device is a customized prosthetic abutment made of titanium alloy, designed to be placed onto dental implants to support other prosthetic restorations in the dental field. It is a physical implant used for mechanical support and restoration of chewing function, not a device used to provide information by means of in vitro examination of specimens derived from the human body.
N/A
Intended Use / Indications for Use
Custom Abutment AS Ti:
The Custom Abutment with Angled Screw Channel is a customized prosthetic abutment, manufactured in titanium alloy, placed onto dental implants to provide support for customized prosthetic restorations. All abutments are only intended to be digitally designed and manufactured using specifics CAD/CAM software according to digital dentistry workflow. Custom Abutments with Angled Screw Channel are indicated for screw-retained single restorations or cemented retained single or multiple restorations. All digitally designed abutments for use with the Custom Abutment Ti with Angled Screw Channel are intended to be sent to Straumann for manufacturing at a validated milling center.
ASC Screw:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
Product codes (comma separated list FDA assigned to the subject device)
NHA
Device Description
This premarket notification includes new digital abutments to the Neodent Implant System (GM, NGM and HS prosthetic interfaces). The abutments proposed on this submission are identical to devices already cleared in previous submissions of Neodent Implant System, according to predicate devices described above, being the only difference between them the introduction of a new angled channel solution. This submission intends to expand the portfolio of Neodent Implant System. The Custom Abutments AS Ti are composed of a unique body with two different regions: the upper region, which is the customizable portion, and the end region presents the prosthetic interface that fits with the implant, which does not allow customization. They must be sent to a Straumann Validated Milling
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
bone of the upper or lower jaw
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)
Bench Testing
Assessments regarding dynamic fatigue testing were conducted according to the FDA guidance document "Guidance for Industry and FDA Staff – Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments" and ISO 14801 "Dentistry — Implants — Dynamic loading test for endosseous dental implants". For dynamic fatigue tests, a worst case analysis determined that the subject devices are not a new worst case compared to those devices tested for the primary predicate. Therefore, no new testing was provided in this submission. Torsion tests were also performed to evaluate the strength of the screw used to fix all subject abutments against maximum twisting forces. The results prove that there is an adequate torsion strength in accordance with the installation torque recommended in IFU.
Biocompatibility Testing
Assessments regarding biological compatibility were performed according to ISO 10993-1 "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process" and to the FDA Guidance document "Use of International Standard ISO 10993- 1, 'Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process', Guidance for Industry and Food and Drug Administration Staff, Document issued on: June 16, 2016".
Representative samples of the subject devices were subjected to the following:
- Biological Safety Assessment guided by ISO 10993-1.
- Chemical characterization was performed per ISO 10993-18.
- Cytotoxicity testing was performed per ISO 10993-5.
The subject devices are equivalent in material and manufacturing processes to the primary predicate and reference devices, therefore, no new issues regarding biocompatibility were raised and no additional biocompatibility testing was required.
Sterilization validation
The proposed devices are delivered non-sterile and must be sterilized before installation in the mouth, the steam sterilization method was validated according to ISO 17665 – 1 "Sterilization of Health Care Products – Moist Heat – Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices", using the parameters described in IFU. The sterilization of the subject device are identical to the sterilization already cleared for the primary and reference predicate devices.
MRI Compatibility Testing
An assessment was made to demonstrate that the MR conditional labeling from K182620 is applicable to the subject devices, and a patient treated with them can be safely scanned observing the parameters previously established per reference 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.
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.
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
§ 872.3630 Endosseous dental implant abutment.
(a)
Identification. An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.(b)
Classification. Class II (special controls). 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.)
FDA 510(k) Clearance Letter - Neodent Implant System Custom Abutments
Page 1
U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov
Doc ID # 04017.07.05
JJGC Indústria e Comércia de Materiais Dentários S.A.
℅ Jennifer Jackson
Sr. Director, Regulatory Affairs and Quality
Straumann USA, LLC
60 Minuteman Road
Andover, Massachusetts 01810
Re: K250614
Trade/Device Name: Neodent Implant System - Custom Abutments
Regulation Number: 21 CFR 872.3630
Regulation Name: Endosseous Dental Implant Abutment
Regulatory Class: Class II
Product Code: NHA
Dated: February 28, 2025
Received: February 28, 2025
Dear Jennifer Jackson:
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 (the 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 available 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.
May 27, 2025
Page 2
K250614 - Jennifer Jackson Page 2
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-device-reporting-mdr-how-report-medical-device-problems.
Page 3
K250614 - Jennifer Jackson Page 3
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/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-devices/device-advice-comprehensive-regulatory-assistance/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,
Andrew I. Steen -S
Andrew I. Steen
Assistant Director
DHT1B: Division of Dental and ENT Devices
OHT1: Office of Ophthalmic, Anesthesia,
Respiratory, ENT, and Dental Devices
Office of Product Evaluation and Quality
Center for Devices and Radiological Health
Enclosure
Page 4
Indications for Use
Please type in the marketing application/submission number, if it is known. This textbox will be left blank for original applications/submissions.
Please provide the device trade name(s).
Neodent Implant System - Custom Abutments
Please provide your Indications for Use below.
Custom Abutment AS Ti:
The Custom Abutment with Angled Screw Channel is a customized prosthetic abutment, manufactured in titanium alloy, placed onto dental implants to provide support for customized prosthetic restorations. All abutments are only intended to be digitally designed and manufactured using specifics CAD/CAM software according to digital dentistry workflow. Custom Abutments with Angled Screw Channel are indicated for screw-retained single restorations or cemented retained single or multiple restorations. All digitally designed abutments for use with the Custom Abutment Ti with Angled Screw Channel are intended to be sent to Straumann for manufacturing at a validated milling center.
ASC Screw:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
☑ Prescription Use (Part 21 CFR 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801 Subpart C)
Please select the types of uses (select one or both, as applicable).
Neodent Implant System - Custom Abutments Page 10 of 38
Page 5
Traditional 510(k) Submission
Neodent Implant System
510(k) Summary
Submitter's Contact Information
Submitter: Straumann USA, LLC
60 Minuteman Road
Andover, MA 01810, USA
Registration No.: 1222315 Owner/Operator No.: 9005052
On the behalf of:
JJGC Indústria e Comércio de Materiais Dentários S.A (dba Neodent)
Av. Juscelino Kubitschek de Oliveira, 3291
Curitiba, Paraná, Brazil 81270-200
Registration No.: 3008261720
Owner/Operator No.: 10031702
Contact Person: Jennifer M. Jackson, MS, RAC
Sr. Director, Regulatory Affairs and Quality
Phone Number: +1 978 747-2509
Fax Number: +1 978 747-0023
Email: jennifer.jackson@straumann.com
Prepared By & Alternate Contact: Leticia Milani
Regulatory Affairs Analyst
JJGC Indústria e Comércio de Materiais Dentários SA
Date Prepared: May 21, 2025
Name of the Device
| Trade Name: | Neodent Implant System - Custom Abutments |
|---|---|
| Common Name: | Endosseous dental implant abutment |
| Classification Name: | Endosseous dental implant abutment |
| Regulation Number: | 21 CFR 872.3630 |
| Device Classification: | II |
| Primary Product Code(s): | NHA |
| Classification Panel: | Dental |
JJGC Indústria e Comércio de Materiais Dentários S.A. 1
Page 6
Traditional 510(k) Submission
Neodent Implant System
Predicate Device(s)
Primary Predicate:
- K233857 – Neodent Implant System – Custom Abutments
Reference Devices:
- K163194 – Neodent Implant System – GM Line
- K182620 – MRI Compatibility for Existing Neodent Implant System
Device Description
This premarket notification includes new digital abutments to the Neodent Implant System (GM, NGM and HS prosthetic interfaces). The abutments proposed on this submission are identical to devices already cleared in previous submissions of Neodent Implant System, according to predicate devices described above, being the only difference between them the introduction of a new angled channel solution. This submission intends to expand the portfolio of Neodent Implant System. The Custom Abutments AS Ti are composed of a unique body with two different regions: the upper region, which is the customizable portion, and the end region presents the prosthetic interface that fits with the implant, which does not allow customization. They must be sent to a Straumann Validated Milling
Intended Use
The Custom Abutments AS Ti are used onto dental implants to provide support for customized prosthetic restorations (copings and crowns). They are indicated according to the interocclusal space available, existing transmucosal height and three-dimensional position of the implant. The ASC Screws are intended to attach the intermediate to the implant.
Indications for Use
Custom Abutment AS Ti:
The Customized Abutment with Angled Screw Channel is a customized prosthetic abutment, manufactured in titanium alloy, placed onto dental implants to provide support for customized prosthetic restorations. All abutments are only intended to be digitally designed and manufactured using specifics CAD/CAM software according to digital dentistry workflow. Custom Abutments with Angled Screw Channel are indicated for screw-retained single restorations or cemented retained single or multiple restorations. All digitally designed abutments for use with the Custom Abutment Ti
JJGC Indústria e Comércio de Materiais Dentários S.A. 2
Page 7
Traditional 510(k) Submission
Neodent Implant System
with Angled Screw Channel are intended to be sent to Straumann for manufacturing at a validated milling center.
ASC Screw:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
JJGC Indústria e Comércio de Materiais Dentários S.A. 3
Page 8
Traditional 510(k) Submission
Neodent Implant System
Technological Characteristics
The technological characteristics of the subject devices are compared to the primary predicate and reference devices in the following tables:
Table 1 – Table of Substantial Equivalence for proposed devices.
| FEATURE | PROPOSED DEVICE | PRIMARY PREDICATE DEVICE | REFERENCE DEVICE |
|---|---|---|---|
| K Number | - | K233857 Neodent Implant System – Custom Abutments | K163194 Neodent Implant System – GM Line |
| Indications for Use | Custom Abutment AS: The Custom Abutment with Angled Screw Channel is a customized prosthetic abutment, manufactured in titanium alloy, placed onto dental implants to provide support for customized prosthetic restorations. All abutments are only intended to be digitally designed and manufactured using specifics CAD/CAM software according to digital dentistry workflow. Custom Abutments with Angled Screw Channel are indicated for screw-retained single restorations or cemented-retained single or multiple restorations. All digitally designed abutments for use with the Custom Abutment Ti with Angled Screw Channel are intended to be sent to Straumann for manufacturing at a validated milling center. ASC Screw: The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading. | Custom Abutment AS: The Custom Abutment with Angled Screw Channel is a customized prosthetic abutment, manufactured in titanium alloy, placed onto dental implants to provide support for customized prosthetic restorations. All abutments are only intended to be digitally designed and manufactured using specifics CAD/CAM software according to digital dentistry workflow. Custom Abutments with Angled Screw Channel are indicated for screw-retained single restorations or cemented-retained single or multiple restorations. All digitally designed abutments for use with the Custom Abutment Ti with Angled Screw Channel are intended to be sent to Straumann for manufacturing at a validated milling center. Screw: The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading. | Screw: The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading. |
| Material | Device and Screw: Titanium alloy, according to ASTM F136. | Device and Screw: Titanium alloy, according to ASTM F136. | Screw: Titanium alloy, according to ASTM F136. |
| Implant Abutment Connection | Narrow Grand Morse (NGM) Helix Short (HS) Grand Morse (GM) | Narrow Grand Morse (NGM) Helix Short (HS) Grand Morse (GM) | Grand Morse (GM) |
| Channel Solution | Angled | Straight and angled | - |
| Maximum Customization Angulation | 30° | 30° | - |
JJGC Indústria e Comércio de Materiais Dentários S.A. 4
Page 9
Traditional 510(k) Submission
Neodent Implant System
| FEATURE | PROPOSED DEVICE | PRIMARY PREDICATE DEVICE | REFERENCE DEVICE |
|---|---|---|---|
| K Number | - | K233857 Neodent Implant System – Custom Abutments | K163194 Neodent Implant System – GM Line |
| Maximum Channel Angulation | 25° | 25° | - |
| Minimum Wall Thickness | 0.4 mm | 0.4 mm | - |
| Minimum Abutment Post Height | 4 mm | 4 mm | - |
| Gingival Height | Angled screw channel NGM: 0.6 - 8.6mm HS: tissue level implant system, GH is given by the implant design ** | Straight screw channel GM: 0.6 – 5.8 mm NGM: 0.6 – 5.8 mm HS: 0.2 – 5.4 mm** Angled screw channel GM: 0.6 – 5.6mm Note: The maximum gingiva height reported above represents the maximum gingiva height tested in the ISO 14871 dynamic fatigue set up. The maximum gingiva height that the blank allows milling to considering the 4mm minimum abutment post height is the following: Straight screw channel: GM interface: 0.6 - 8.6 mm NGM interface: 0.6 - 8.6 mm HS interface: tissue level implant system, GH is given by the implant design ** Angled screw channel GM: 0.6 – 8.6 mm | - |
| Fabrication Workflow | Milling by Straumann centralized validated milling center | Milling by Straumann centralized validated milling center | - |
| Single use | Yes | Yes | - |
| Sterilization Method | Provided non-sterile. Terminally sterilized by user via moist heat. Moist heat cycle parameters have been validated to a SAL of 1x10-6. | Provided non-sterile. Terminally sterilized by user via moist heat. Moist heat cycle parameters have been validated to a SAL of 1x10-6. | - |
*Post height is the length above the abutment collar/gingival height.
**Helix Short (HS) Implant System, K223638, is a tissue level implant system.
JJGC Indústria e Comércio de Materiais Dentários S.A. 5
Page 10
Traditional 510(k) Submission
Neodent Implant System
Performance Testing
Performance Testing
Bench Testing
Assessments regarding dynamic fatigue testing were conducted according to the FDA guidance document "Guidance for Industry and FDA Staff – Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments" and ISO 14801 "Dentistry — Implants — Dynamic loading test for endosseous dental implants". For dynamic fatigue tests, a worst case analysis determined that the subject devices are not a new worst case compared to those devices tested for the primary predicate. Therefore, no new testing was provided in this submission. Torsion tests were also performed to evaluate the strength of the screw used to fix all subject abutments against maximum twisting forces. The results prove that there is an adequate torsion strength in accordance with the installation torque recommended in IFU.
Biocompatibility Testing
Assessments regarding biological compatibility were performed according to ISO 10993-1 "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process" and to the FDA Guidance document "Use of International Standard ISO 10993- 1, 'Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process', Guidance for Industry and Food and Drug Administration Staff, Document issued on: June 16, 2016".
Representative samples of the subject devices were subjected to the following:
- Biological Safety Assessment guided by ISO 10993-1.
- Chemical characterization was performed per ISO 10993-18.
- Cytotoxicity testing was performed per ISO 10993-5.
The subject devices are equivalent in material and manufacturing processes to the primary predicate and reference devices, therefore, no new issues regarding biocompatibility were raised and no additional biocompatibility testing was required.
JJGC Indústria e Comércio de Materiais Dentários S.A. 9
Page 11
Traditional 510(k) Submission
Neodent Implant System
Performance Testing
Sterilization validation
The proposed devices are delivered non-sterile and must be sterilized before installation in the mouth, the steam sterilization method was validated according to ISO 17665 – 1 "Sterilization of Health Care Products – Moist Heat – Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices", using the parameters described in IFU. The sterilization of the subject device are identical to the sterilization already cleared for the primary and reference predicate devices.
MRI Compatibility Testing
An assessment was made to demonstrate that the MR conditional labeling from K182620 is applicable to the subject devices, and a patient treated with them can be safely scanned observing the parameters previously established per reference devices.
Conclusion
The subject, primary predicate and reference devices have similar indications for use, intended use, design, raw material and overall dimensions. Thus, all documentation submitted in this premarket notification demonstrate that they are substantially equivalent.
JJGC Indústria e Comércio de Materiais Dentários S.A. 10