ABCcolla® Bone Matrix is an implant intended to fill bony voids or gaps of the skeletal system (i.e., extremities and pelvis). These osseous defects are surgically created or the result of traumatic injury to the bone and are not intrinsic to the stability of the bony structure. ABCcolla® Bone Matrix resorbs and is replaced with bone during the healing process.
Device Story
ABCcolla® Bone Matrix is a porcine-derived bone mineral matrix; physically and chemically comparable to human bone mineralized matrix. Used as a resorbable bone void filler to fill non-structural bony defects in extremities and pelvis. Implanted by surgeons during orthopedic procedures; resorbs over time and is replaced by host bone during healing. Subject device is an extension of the predicate line, offering new cube or block dimensions within previously cleared volume limits (max 5 c.c.).
Clinical Evidence
Bench testing only. No clinical data presented. Device performance verified through material characterization, physical dimension testing, moisture content analysis, and sterility testing. Endotoxin testing performed per USP<85> and USP<161> with acceptance limit of 20 EU/device.
Technological Characteristics
Porcine-derived bone mineral matrix. Form factors: granules, cubes, and blocks. Sterilization: Gamma radiation. Packaging: Glass bottle and Tyvek pouch. Testing standards: USP<85> (Bacterial Endotoxins Test), USP<161> (Transfusion and Infusion Assemblies and Similar Medical Devices).
Indications for Use
Indicated for filling bony voids or gaps in the skeletal system (extremities and pelvis) that are not intrinsic to the stability of the bone structure, resulting from surgical creation or traumatic injury.
Regulatory Classification
Identification
A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.
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October 8, 2021
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ACRO Biomedical Co., Ltd. Dar-Jen Hsieh, CEO 3rd Fl., No. 57, Luke 2nd Rd., Lujhu Dist. Kaohsiung City, 82151 Taiwan
Re: K212156
Trade/Device Name: ABCcolla® Bone Matrix Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MQV Dated: July 12, 2021 Received: July 12, 2021
Dear Dar-Jen Hsieh:
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 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
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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 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,
Laura C. Rose, Ph.D. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use Statement
510(K) Number (If Known):
Device Name: ABCcolla® Bone Matrix
Indications for Use: ABCcolla® Bone Matrix is intended to fill bony voids or gaps of skeletal system (i.e., extremities and pelvis). These osseous defects are surgically created or the result of traumatic injury to the bone and are not intrinsic to the stability of bone structure. ABCcolla® Bone Matrix provides resorbs and is replaced by bone during the healing process.
Prescription Use______________________________________________________________________________________________________________________________________________________________ (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use_ (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH Office of Device Evaluation (ODE)
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## 510(k) Summary
This summary of 510(k) Safety and Effectiveness information is being submitted in accordance with the requirements of Safe Medical Device Act (SMDA) of 1990 and Title 21 CFR 807.92. The assigned 510(k) number is_________________________________________________________________________________________________________________________________________________
| Applicant | ACRO Biomedical Co., Ltd.<br>3rd Fl., No.57, Luke 2nd Rd., Lujhu Dist., Kaohsiung City 82151,<br>Taiwan<br>Telephone: +886-7-6955-569<br>Fax: +886-7-6955-069 |
|-------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person | DAR-JEN HSIEH<br>CEO<br>E mail: dj@acrobiomedical.com |
| Date of Summary | June 1st, 2021 |
| Name of Device | ABCcolla® Bone Matrix |
| Common Name | Resorbable Bone Void Filler |
| Classification | Class II |
| Regulation Number | 21 CFR 888.3045 |
| Product Code | MQV |
| Advisory Panel | ORTHOPEDIC DEVICES |
| Predicate Device | · ABCcolla® Bone Graft, K171629<br>ACRO Biomedical Co., Ltd. |
| Reference Device | · ORTHOSS® Resorbable Bone Void Filler, K090401<br>Ed. Geistlich Soehne Ag Für Chemische Industrie |
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| • Bicera™ Resorbable Bone Substitute, K110949<br>Wiltrom Corporation Limited | | |
|------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| • Geistlich Bio-Oss®, K122894<br>Geistlich Pharma Ag | | |
| Device Description | ABCcolla® Bone Matrix is a bone mineral matrix of porcine origin.<br>ABCcolla® Bone Matrx is physically and chemically comparable to<br>the mineralized matrix of human bone. | |
| Intended Use | ABCcolla® Bone Matrix is an implant intended to fill bony voids o<br>gaps of the skeletal system (i.e., extremities and pelvis). These<br>osseous defects are surgically created or the result of traumatic<br>injury to the bone and are not intrinsic to the stability of the bony<br>structure. ABCcolla® Bone Matrix resorbs and is replaced with<br>bone during the healing process. | |
| Comparison of<br>Technological<br>Characteristics | The subject device is identical to predicate device with respect to<br>materials characteristics, manufacturing, sterilization method, and<br>sterile barrier system.<br>Since prior clearance of the device, the only change was to add new<br>product specifications for cube or block form. | |
| Characteristic | ABCcolla® Bone Graft<br>(K171629) | ABCcolla® Bone Matrix<br>(subject device) |
| Intended Use | ABCcolla® Bone Graft is an<br>implant intended to fill bony<br>voids or gaps of the skeletal<br>system (i.e., extremities and<br>pelvis). These osseous defects<br>are surgically created or the<br>result of traumatic injury to<br>the bone and are not intrinsic<br>to the stability of the bony<br>structure. | ABCcolla® Bone Matrix is an<br>implant intended to fill bony<br>voids or gaps of the skeletal<br>system (i.e., extremities and<br>pelvis). These osseous defects<br>are surgically created or the<br>result of traumatic injury to<br>the bone and are not intrinsic<br>to the stability of the bony<br>structure. |
| | Graft resorbs and is replaced<br>with bone during the healing<br>process. | Matrix resorbs and is<br>replaced with bone during the<br>healing process. |
| Physical characteristics | | |
| Form | Granule and Cube | Granule and Block |
| Specifications | Maximum volume 5 c.c. | Maximum volume 5 c.c. |
| Manufacture | | |
| Manufacturing<br>conditions | Same manufacturing<br>conditions | Same manufacturing<br>conditions |
| Viral inactivation | Same viral inactivation step | Same viral inactivation step |
| Sterilization | Gamma radiation | Gamma radiation |
| Packaging | Glass bottle and Tyvek pouch | Glass bottle and Tyvek pouch |
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The subject device is made of the same raw materials and Substantial manufactured with the same manufacturing process (except for Equivalence cutting the bone material in different length and/or height to Summary generate the new specifications), hence the material properties are identical.
> Further, the same release testing as performed for the predicate is conducted for the subject device and includes determination of appearance, specification (granule size, weight, or dimension), moisture content and sterility test. The predicate and subject devices are also tested according to USP<85> and USP<161>. and the devices are met the endotoxin acceptance limit of 20 EU/device. The only difference between the subject device and predicate device is the dimension of the cube/block form products. These new product specifications are all within the range of product volume previously cleared for the predicate device, and the lot tests have been done that confirm that the dimension change does not affect the final product and that, as such, it is substantially equivalent to the previously cleared predicate device.
- Based on the 510(k) summaries and the information provided Conclusion herein, it can be concluded that ABCcolla® Bone Matrix is
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substantially equivalent to the predicate device, ABCcolla® Bone Graft (K171629).
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
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.