s-Clean SQ-SL Implant System Mini is indicated for use in partially or fully edentulous mandibles and maxillae, in support of single or multiple unit restorations including; cemented retained, or overdenture restorations, and terminal or intermediate abutment support for fixed bridgework. This system is dedicated for one and two stage surgical procedures. This system is intended for delayed loading.
Device Story
The s-Clean SQ-SL Implant System Mini is an endosseous dental implant system used to replace missing teeth. The system consists of a thread-type fixture (implanted into alveolar bone) and various abutments. The fixture features a dual screw-joint design and an internal hex anti-rotation connection. The fixture surface is treated with SLA (Sandblasted with Large-grit and Acid-etching) to facilitate osseointegration. The device is used by dental clinicians in surgical procedures. The clinician places the fixture into the mandible or maxilla; after healing, the abutment is connected to the fixture to support a dental prosthesis. The system restores tooth function and aesthetics for the patient. The dual screw-joint design allows for diverse screw connections (1.6M or 2.0M sizes).
Clinical Evidence
Bench testing only. Evidence includes fatigue testing per ISO 14801:2016 comparing single vs. dual screw-joint designs, demonstrating identical performance limits. Biocompatibility testing (ISO 10993 series), sterilization validation (ISO 11137, ISO 17665), shelf-life testing (ASTM F1980), and bacterial endotoxin testing (USP <161>, <85>) were leveraged from predicate submissions (K153639, K171027, K171694, K192688) based on identical materials, manufacturing processes, and packaging.
Technological Characteristics
Fixtures and cover screws: Pure titanium (ASTM F67). Abutments: Ti-6Al-4V ELI (ASTM F136). Surface: SLA (Sandblasted with Large-grit and Acid-etching) on fixtures; TiN coating on specific abutments. Connection: Internal hex. Sterilization: Gamma (fixtures) or steam (abutments). Dimensions: Fixtures Ø 3.7-4.1mm, lengths 7.5-13.5mm. Mechanical design: Dual screw-joint.
Indications for Use
Indicated for partially or fully edentulous mandibles and maxillae in patients requiring single or multiple unit restorations (cemented, screw-retained, or overdenture) or terminal/intermediate abutment support for fixed bridgework. Dedicated for one or two-stage surgery; intended for delayed loading.
Regulatory Classification
Identification
An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.
Special Controls
*Classification.* (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)(2)
*Classification.* Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.
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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: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
K202773
Dentis Co., Ltd. % April Lee Consultant Withus Group Inc. 106 Superior Irvine, California 92620
Re: K202773
Trade/Device Name: s-Clean SQ-SL Implant System Mini Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: Class II Product Code: DZE, NHA Dated: February 10, 2021 Received: February 17, 2021
Dear April Lee:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. 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/cdrl/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 medical devices and radiation-emitting products, including information about labeling regulations, please see Device (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 Andrew Steen Assistant Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia. Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known)
K202773
Device Name s-Clean SQ-SL Implant System Mini
#### Indications for Use (Describe)
s-Clean SQ-SL Implant System Mini is indicated for use in partially or fully edentulous mandibles, in support of single or multiple unit restorations including; cemented retained, or overdenture restorations, and terminal or intermediate abutment support for fixed bridgework. This system is dedicated for one and two stage surgical procedures. This system is intended for delayed loading.
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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## 510(K) Summary
#### Submitter
Dentis Co., Ltd. Gyu Ri Kim 99, Seongseoseo-ro, Dalseo-gu Daegu, 42718 Korea Email: kgr1026@dentis.co.kr Tel. +82-53-589-3541 Fax. +82-53-289-7922
## Official Correspondent
Withus Group Inc. April Lee 106 Superior, Irvine, CA 92620 USA Email: withus6664@gmail.com Phone: 1-909-274-9971 Fax: 1-909-460-8122
## Device Information
- Trade Name: s-Clean SQ-SL Implant System Mini ●
- . Common Name: Dental Implant System
- Classification Name: implant, endosseous, root-form
- Product Code: DZE
- Secondary Product Code: NHA
- Panel: Dental
- Regulation Number: 872.3640
- Device Class: Class II
- Date Prepared: 03/18/2021 ●
#### Predicate Devices:
The subject device is substantially equivalent to the following predicate devices:
#### Primary Predicate
- K200099, s-Clean SQ-SL Implant System Mini by Dentis Co., Ltd.
#### Reference Device
- . K121995, TS Fixture System by OSSTEM Implant Co., Ltd
#### Indication for Use:
s-Clean SO-SL Implant System Mini is indicated for use in partially or fully edentulous mandibles and maxillae, in support of single or multiple unit restorations including; cemented retained, or overdenture restorations, and terminal or intermediate abutment support for fixed bridgework. This system is dedicated for one and two stage surgical procedures. This system is intended for delayed loading.
{4}------------------------------------------------
## Device Description:
s-Clean SQ-SL Implant System Mini is composed of Fixture and Abutments. s-Clean SQ-SL Mini Fixture is a thread type implant made of Pure titanium according to ASTM F67 which will be placed in the alveolar bone to replace the function of the missing tooth. This device has connection between the upper prosthesis and the internal Hex.
The s-Clean SO-SL Implant System Mini Abutments are composed of s-Clean Sole Abutment S-Line, s-Clean TiN Half Coating Sole Abutment S-Line, and s-Clean Mini Fixture Cover Screw.
The subject implant body has a two screw-joint (structured with Upper and Lower screw joints) and a hex anti-rotation design connection. The two-screw-ioint feature is for diverse screw connection for 1.6M or 2.0M sizes. The implant bodies are only compatible with subject abutments of S-Clean Sole Abutment s-Line and s-Clean TiN Half Coating Sole Abutment s-Line with 2.0M screw. These abutments are connected with only upper screw of the implant body. The 1.6M size allows the implant to be compatible with potential future cleared abutments.
Image /page/4/Figure/6 description: The image shows three different dental implant configurations. The first configuration shows the "s-Clean SQ-SL Fixture" alone. The second configuration shows the "s-Clean SQ-SL Fixture" with the "s-Clean Cover Screw". The third configuration shows the "s-Clean SQ-SL Fixture" with the "s-Clean TiN Half Coating Sole Abutment".
The surface of fixture is treated with SLA (Sandblasted with Large-grit and Acid-etching). It is only part to be implanted into bone, and to provide connection of prosthetic devices or other components of a dental implant set with human body (mandibular or maxillary bone).
#### The dimensions of fixtures are as following:
| No. | Device Name | Dimension Ranges |
|-----|-------------------------------|-----------------------------------------------------|
| 1 | s-Clean SQ-SL Mini<br>Fixture | Ø 3.7 and 4.1mm (D) X 7.5, 9.5, 11.5 and 13.5mm (L) |
Tolerance of dimension shall be within ± 1% range.
#### The dimensions of abutments are as following:
| No. | Device Name | Dimension Ranges | Angulation |
|-----|--------------------------------------------------|-------------------------------------------------|------------|
| 1 | s-Clean Mini Fixture Cover Screw | Ø 3.2mm (D) X 5.0mm (L) | 0° |
| 2 | s-Clean Sole Abutment S-Line | Ø 4.0 and 4.5mm (D) X 11.01, 12.01, 13.01mm (L) | 0° |
| 3 | s-Clean TiN Half Coating Sole<br>Abutment S-Line | Ø 4.0 and 4.5mm (D) X 11.01, 12.01, 13.01mm (L) | 0° |
{5}------------------------------------------------
| Name | Uses | Surface | Connection |
|--------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------|-------------------|
| s-Clean Mini Fixture Cover<br>Screw | It is used for protecting inner hole and connecting<br>part with exposed upper part of structure during<br>the healing period after inserting dental implant<br>fixture | N/A | Screw<br>Retained |
| s-Clean Sole Abutment S-Line | The Abutment is connected with fixture and it<br>supports prosthesis which restores tooth function. | N/A | Internal Hex |
| s-Clean TiN Half Coating Sole<br>Abutment S-Line | The Abutment is connected with fixture and it<br>supports prosthesis which restores tooth function. | TiN-Coating | Internal Hex |
The Abutments have below featured:
Tolerance of dimension for Abutments shall be within ± 1% range.
s-Clean SQ-SL Mini Fixture and s-Clean Mini Fixture Cover Screw are provided sterilized. And the other Abutments are provided non-sterilized.
s-Clean SQ-SL Mini Fixture is enclosed with s-Clean Mini Fixture Cover Screw in a set packing. s-Clean Mini Fixture Cover Screw is also provided separately.
## Materials:
- The fixtures and s-Clean Mini Fixture Cover Screw are fabricated from Pure titanium of ASTM F67 ●
- . The s-Clean Sole Abutment S-Line and s-Clean TiN Half Coating Sole Abutment S-Line are fabricated from Ti-6A1-4V of ASTM F136
{6}------------------------------------------------
# Summaries of Technological Characteristics & Substantial Equivalence Discussion:
| s-Clean SQ-SL Mini Fixture | | | |
|------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Division | Subject Device | Primary Predicate | Reference Device |
| 510(k)<br>Number | N/A | K200099 | K121995 |
| Trade Name | s-Clean SQ-SL Implant<br>System Mini | s-Clean SQ-SL Implant<br>System Mini | TS Fixture System |
| Manufacturer | Dentis Co., Ltd | Dentis Co., Ltd | OSSTEM Implant Co., Ltd |
| Product Code | DZE | DZE | DZE |
| Diameter(Ø) | 3.7, 4.1 | 3.7, 4.1 | 3.5, 3.75, 3.77, 4.2, 4.25, 4.4, 4.6,<br>4.63, 4.65, 4.9, 5.05, 5.08, 5.1 |
| Length(mm) | 7.5, 9.5, 11.5, 13.5 | 7, 7.5, 9.5, 11.5, 13.5 | 7.0~15.0 |
| Design | | | |
| Screw-joint | Two screw-joint | One screw-joint | Two screw-joint |
| Surface<br>Treatment | SLA | SLA | SLA |
| Material | CP Titanium Grade4<br>(ASTM F67) | CP Titanium Grade4<br>(ASTM F67) | CP Titanium Grade4 (ASTM F67) |
| Abutment<br>Connection<br>Platform | Hex | Hex | Hex |
| Sterilization | Gamma Sterilization | Gamma Sterilization | Gamma Sterilization |
| Shelf-Life | 8years | 8years | 8years |
| Indication for<br>Use | s-Clean SQ-SL Implant System Mini is indicated for use<br>in partially or fully edentulous mandibles and maxillae,<br>in support of single or multiple unit restorations<br>including; cemented retained, screw retained, or<br>overdenture restorations, and terminal or intermediate<br>abutment support for fixed bridgework. This system is<br>dedicated for one and two stage surgical procedures.<br>This system is intended for delayed loading. | | The TS Fixture System is designed<br>for dental implant surgery; it is<br>placed on the maxillary or<br>mandibular alveolar bone through a<br>surgical procedure, and after<br>osseointegration with the alveolar<br>bone, it can replace a lost tooth by<br>connecting the abutment post. The<br>TS Fixture System is indicated for<br>use in partially or fully dentulous<br>mandibles and maxillae, in support<br>or single or multiple-unit<br>restorations including: cemented<br>retained screw retained or<br>overdenture restorations and final or<br>temporary abutment support for<br>fixed bridgework. It is intended for<br>delayed loading. |
| SE<br>Comparison | The subject device and primary predicate has same characteristics such as indications for Use,<br>outer design, dimensions, surface treatment, material, and sterilization.<br>The difference between two devices is only design of screw joint between fixture and abutment.<br>Subject device has two screw-joint of fixture and abutment but predicate device has only one<br>screw-joint of fixture and abutment. This difference is mitigated through reference device,<br>K121995. Reference device, K121995, has same feature as dual screw joint and screw<br>connection location. Subject device and reference device has dual screw joint and are connected<br>with upper screw joint among upper and low screw joint. Results of dynamic fatigue testing<br>demonstrated that the device is substantially equivalent as the predicates despite the<br>technological differences. | | |
# s-Clean SO-SL Mini Fixture
{7}------------------------------------------------
| Division | Subject Device | Primary Predicate Device | |
|---------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|--|
| 510(k) Number | N/A | K200099 | |
| Trade Name | s-Clean SQ-SL Implant System Mini | s-Clean SQ-SL Implant System Mini | |
| Manufacturer | Dentis Co., Ltd | Dentis Co., Ltd | |
| Product Code | NHA | NHA | |
| Diameter(Ø) | 3.2 | 3.1 | |
| Length(mm) | 5.0 | 5.4 | |
| Material | CP Titanium Grade4 (ASTM F67) | CP Titanium Grade4 (ASTM F67) | |
| Sterilization | Gamma Sterilization | Gamma Sterilization | |
| Comparison | The subject device and predicate device have same characteristic such as design, material,<br>sterilization, and indication for Use.<br>The diameter and length are slight difference but this difference is not an important factor to<br>the device performance. | | |
## s-Clean Mini Fixture Cover Screw
# s-Clean Sole Abutment S-Line
| Division | Subject Device | Primary Predicate Device | |
|---------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|--|
| 510(k) Number | N/A | K200099 | |
| Trade Name | s-Clean SQ-SL Implant System Mini | s-Clean SQ-SL Implant System Mini | |
| Manufacturer | Dentis Co., Ltd | Dentis Co., Ltd | |
| Product Code | NHA | NHA | |
| Diameter(Ø) | 4.0, 4.5 | 4.0, 5.0 | |
| Length(mm) | 11.01, 12.01, 13.01 | 11.2, 12.2, 13.2 | |
| Material | Ti-6Al-4V ELI (ASTM F136) | Ti-6Al-4V ELI (ASTM F136) | |
| Angulation | N/A | N/A | |
| Sterilization | Steam sterilization by End user | Steam sterilization by End user | |
| Comparison | The subject device and predicate device have same characteristic such as design, material,<br>sterilization, angulation and indication for Use.<br>The subject device has shorter lengths of the abutments such as 11.01mm, however, this<br>difference is minimal and does not impact device performance as demonstrated by fatigue<br>testing. In conclusion, subject device and predicate device are substantially equivalent. | | |
# s-C lean TiN Half Coating Sole Abutment S-Line
| Division | Subject Device | Primary Predicate Device |
|----------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|
| 510(k) Number | N/A | K200099 |
| Trade Name | s-Clean SQ-SL Implant System Mini | s-Clean SQ-SL Implant System Mini |
| Manufacturer | Dentis Co., Ltd | Dentis Co., Ltd |
| Product Code | NHA | NHA |
| Diameter(ø) | 4.0, 4.5 | 4.0, 5.0 |
| Length(mm) | 11.01, 12.01, 13.01 | 11.2, 12.2, 13.2 |
| Material | Ti-6Al-4V ELI (ASTM F136) | Ti-6Al-4V ELI (ASTM F136) |
| Angulation | N/A | N/A |
| Sterilization | Steam sterilization by End user | Steam sterilization by End user |
| Surface<br>Treatment | TiN Coating | TiN Coating |
| Comparison | The subject device and predicate device have same characteristic such as design, material,<br>sterilization, angulation, surface treatment, and indication for Use.<br>The subject device has shorter lengths of the abutments such as 11.01mm, however, this<br>difference is minimal and does not affect device performance as demonstrated by fatigue<br>testing. In conclusion, subject device and predicate device are substantially equivalent. | |
{8}------------------------------------------------
## Non-Clinical Test Data:
Below tests were performed for predicate devices and leveraged for the subject device:
- Sterilization Validation Test on Fixtures according to ISO 11137-1.2,3 referenced in K153639
- . End User Sterilization Validation Test Report on Abutments according to ANSI/AAMI ST79, ISO 17665-1. ISO 17665-2. ISO 11737-1. ISO 11737-2. and ISO 11138-1 referenced in K171027
- . Shelf Life Test on Fixtures according to ASTM F1980 referenced in K153639
- Biocompatibility testing on fixtures according to ISO 10993-1:2009, ISO 10993-3:2014.ISO ● 10993-5:2009, ISO 10993-6:2007, ISO 10993-10:2010 and ISO 10993-11:2006 referenced in K153639
- Biocompatibility testing on Abutments according to ISO 10993-1:2009, ISO 10993-3:2014, ISO 10993-5:2009, ISO 10993-6:2007, ISO 10993-10:2010 and ISO 10993-11:2006 referenced in K171027
- . Biocompatibility testing on TiN Coating Abutments according to ISO 10993-1:2009, ISO 10993-5:2009, ISO 10993-10:2010 and ISO 10993-11:2006 referenced in K171694
- . Bacterial Endotoxin Test Report on Fixtures according to ANSVAAMI ST72:2011, USP <161>, and USP <85> referenced in K192688
The results of the above tests have met the criteria of the standards, and demonstrated the substantial equivalence with the predicate device.
The surface modification information with SLA (Sandblasted with Large-grit and Acid-etching) for fixtures was provided. To compare surface modification between the subject and predicate devices, K153639, surface roughness, surface composition analysis, and SEM imaging were provided and it demonstrate the substantial equivalence.
The Sterilization validation test and shelf-life test for fixtures were performed for predicate device, K153639 and leveraged for the subject device because the material, sterilization method, packaging methods, and manufacturing process of the both products are exactly same.
The end user sterilization test was performed for predicate device, K171027 and leveraged for the subject device because the product category, material, manufacturing process, facility, and packaging of the both products are exactly same.
The Biocompatibility Test was conducted on the predicate device and leveraged for the subject device because both products are manufactured with same materials and manufacturing process. It demonstrates that the subject device is biocompatible and substantial equivalence with the predicate.
The fatigue testing per ISO 14801 was conducted under the worst-case scenario. To demonstrate the substantial equivalence of the device performance between single screw joint implant and dual screw joint implant, two fatigue tests were performed comparatively, and result say that device performance was substantial equivalent.
| Fatigue Test Report | Predicate Device | Subject Device-1 | Subject Device-2 |
|---------------------------------------|------------------|------------------|------------------|
| Fixture Size | Ø 3.7 x 13.5mm | Ø 3.7 x 7.5mm | Ø 3.7 x 13.5mm |
| Abutment Size | Ø 4.0 x 12.2mm | Ø 4.5 x 13.01mm | Ø 4.5 x 13.01mm |
| Screw Joint Design | Single | Dual | Dual |
| Compressive Load Result | Similar | Similar | Similar |
| Fatigue Test Method<br>(ISO Standard) | ISO14801:2016 | ISO14801:2016 | ISO14801:2016 |
| Fatigue Test Result<br>(Limit) | Identical | Identical | Identical |
| Gap of connection part | 0 µm | 0 µm | 0 µm |
{9}------------------------------------------------
The non-clinical testing results demonstrate that the subject device is substantially equivalent to the predicate device.
## Conclusion:
s-Clean SQ-SL Implant System Mini constitutes a substantially equivalent medical device, meeting all the declared requirements of its intended use. This system has the same intended use and fundamental scientific technology as its predicate devices. Therefore, s-Clean SQ-SL Implant System Mini and its predicates are substantially equivalent.
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Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.