K152078 · 3Shape Medical A/S · LLZ · Dec 4, 2015 · Radiology
Device Facts
Record ID
K152078
Device Name
Implant Studio 2015
Applicant
3Shape Medical A/S
Product Code
LLZ · Radiology
Decision Date
Dec 4, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 892.2050
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
Implant Studio™ is indicated for use as a medical front-end software that can be used by medically trained professionals for the purpose of visualizing gray value images. It is intended for use as a pre-operative planning software for the placement of dental implant(s) based on imported CT image data, optionally aligned to an optical 3D surface scan. Virtual Crowns can be used for optimized implant positioning under the prosthetic aspect. The digital three dimensional model of a surgical guide for a guided surgery can be designed based on the approved implant position. This 3D data can be exported to manufacture a separate physical product. Indications of the dental implants do not change with guided surgery compared to conventional surgery. Use of the software requires that the necessary medical training in implantology and surgical dentistry.
Device Story
Implant Studio™ 2015 is a software-only medical device for pre-operative dental implant planning. It ingests DICOM CT image data, which can be aligned with optical 3D surface scans or segmented denture CT scans. Clinicians use the software to visualize gray value images, position virtual crowns for prosthetic optimization, and plan implant placement. The software enables the design of 3D digital models for surgical guides, which are exported to external manufacturing systems. Used in clinical settings by dental professionals, the output assists in surgical planning and guide fabrication. The device does not have patient contact; it serves as a planning tool to aid in the accurate placement of dental implants.
Clinical Evidence
No clinical data. Bench testing only. Verification and validation were performed in accordance with FDA software guidance, including user need validation, specification verification, and bug tracking.
Technological Characteristics
Software-only device programmed in C#. Operates on Windows 7/8 64-bit PCs with minimum 16GB RAM, 2GB/4GB video memory, and Intel Core i7 CPU. Features include CT image visualization, 3D surface scan alignment, and CAD-based surgical guide design. Connectivity via network/internet for data handling. Encrypted library files for implants and sleeves.
Indications for Use
Indicated for medically trained professionals in implantology and surgical dentistry for pre-operative planning of dental implant placement using CT image data and optional optical 3D surface scans.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus or a series of interconnected human profiles.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 4, 2015
3Shape Medical A/S % Ms. Hanne Nielsen Regulatory Affairs Manager Holmens Kanal 7 DK-1060 Copenhagen DENMARK
Re: K152078
Trade/Device Name: Implant Studio™ 2015 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ Dated: November 5, 2015 Received: November 9, 2015
Dear Ms. Nielsen:
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. 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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Michael O'Hara
For
Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health 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)
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Implant Studio™ 2015
Indications for Use (Describe)
Implant Studio™ is indicated for use as a medical front-end software that can be used by medically trained professionals for the purpose of visualizing gray value images. It is intended for use as a pre-operative planning software for the placement of dental implant(s) based on imported CT image data, optionally aligned to an optical 3D surface scan. Virtual Crowns can be used for optimized implant positioning under the prosthetic aspect. The digital three dimensional model of a surgical guide for a guided surgery can be designed based on the approved implant position. This 3D data can be exported to manufacture a separate physical product.
Indications of the dental implants do not change with guided surgery compared to conventional surgery.
Use of the software requires that the necessary medical training in implantology and surgical dentistry.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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3SHAPE IMPLANT STUDIO™ SOFTWARE SPECIAL 510(K) SUBMISSION 3 S N A
# 510(K) SUMMARY - Special 510(K)
# Submitter Information
| A | Company Name: | 3Shape Medical A/S |
|---|--------------------------------|---------------------------------------------|
| B | Company Address: | Holmens Kanal 7<br>DK-1060 Copenhagen K |
| C | Company Phone:<br>Company Fax: | +45 7027 2620<br>+45 7027 2621 |
| D | Contact Person: | Hanne Nielsen<br>Regulatory Affairs Manager |
| E | Date Summary Prepared: | July 23, 2015 |
# Device Identification
| A Trade/proprietary Name: | Implant Studio™ 2015-1 |
|-------------------------------|------------------------------------------------|
| B Common Name: | Implant Planning and Surgical Guide |
| C Device Classification Name: | Picture archiving and communications<br>system |
| C Regulation Number: | 892.2050 |
| C Classification: | Class II |
| D Product Code: | LLZ |
### Predicate Device
The 3Shape Implant Studio™ 2015-1 Software still has the same intended uses and major functions as Dentsply Simplant 2011 (K110300) and Straumann AG coDiagnostix (K130724).
Furthermore the 510(k) is submitted to modify a legally marketed device, the indications for use of the proposed device are unchanged and fundamental scientific technology of the proposed device is unchanged from the previous legally marketed device (Implant Studio 2014-1 - K141570).
Testing demonstrates the implementation functions as intended, and differences between the Device and the predicates do not raise additional concerns with the Device's safety and effectiveness.
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# Indications for Use/Intended Use
Implant Studio™ is indicated for use as medical front-end software that can be used by medically trained professionals for the purpose of visualizing gray value images. It is intended for use as pre-operative planning software for the placement of dental implant(s) based on imported CT image data, optionally aligned to an optical 3D surface scan. Virtual Crowns can be used for optimized implant positioning under the prosthetic aspect. The digital three dimensional model of a surgical guide for a guided surgery can be designed based on the approved implant position. This 3D data can be exported to manufacture a separate physical product.
Indications of the dental implants do not change with guided surgery compared to conventional surgery.
Use of the software requires that the user has the necessary medical training in implantology and surgical dentistry.
### Device Description
Implant Studio™ is a software only device used to pre-operatively plan the placement of a dental implant and to visualize a patient's CT image, optionally aligned to an optical 3D surface data. Virtual crown(s) can be used to guide the planning under the final prosthetic aspect. The surgical quide data can be designed then exported to an external system for manufacturing.
The device has no patient contact.
### Device Comparison
3Shape Implant Studio™ 2015-1 covered in this submission is based on the same technology platform as the previously cleared 3Shape Implant Studio™ 2014-1.
The main difference between these two devices is the introduction is a dedicated workflow for edentulous treatment and the related software features and functionalities to plan for this treatment concept. The following table compares all newly added features and functionalities between these two devices and the selected predicate devices:
| Feature name | 3Shape<br>Implant<br>Studio™ 2015 | 3Shape<br>Implant<br>Studio™ 2014 | Straumann<br>coDiagnostiX | Dentsply<br>Simplant 2011 |
|-----------------------------------------------------|-----------------------------------|-----------------------------------|---------------------------|---------------------------|
| 510(k) Number | | K141570 | K130724 | K110300 |
| Segmentation of<br>Denture CT scan | Yes | No | Yes | Yes |
| Alignment of CT scan data<br>via radiopaque markers | Yes | No | Yes | Yes |
| Option to manually align<br>two scan data set | Yes | No | Yes | Yes |
| Support for anchor pins | Yes | No | Yes | Yes |
| Gingiva supported surgical<br>guide design possible | Yes | No | Yes | Yes |
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* Picture archiving and communications system, 21CFR892.2050
The added support for edentulous treatment and subsequent design of gingiva supported quides in the 2015 version of Implant Studio™ are identical in the intended use but also available features and functionalities compared to the predicated devices.
The difference between Implant Studio™ 2015-1 and Implant Studio™ 2014-1 software as well the predicate devices do not raise additional concerns regarding its safety and effectiveness.
# Scientific Concept
The underlying scientific concept is the visualization of an imported CT image from DICOM data to pre-operatively analyze and plan the placement of dental implant(s) in the maxilla and/or mandible region by taking the prosthetic and clinical requirements into consideration. Optionally, the CT image scan data can be aligned to optical 3D surface scan data or to a segmented CT scan of a denture. The implant and sleeve library files are provided via encrypted library files which are generated by 3Shape and approved by the corresponding original manufactures. CAD designed virtual crown(s) can be used to assist during the planning phase. Moreover, the use of CAD design technology allows the design of a surgical guide, which can be exported to a 3rd party manufacturing device. The guide can be used for aiding the placement of the implant(s) to the intended position(s). PDF reports are generated to document the planning information and to provide an overview of the required surgical components.
### Summary of the technological characteristics
Implant Studio™ 2015-1 is a software only device programmed in C# and has the following recommended PC/ laptop hardware requirements:
| Item | Recommended |
|----------------------|-----------------------------|
| OS: | Windows 7 or 8 64-bit |
| RAM: | 16GB or better |
| Monitor Resolution: | 1920x1200 or higher |
| Video Card Memory: | 2GB GeForce or better |
| Available HDD Space: | 500GB |
| CPU: | IntelCore i7 or higher |
| Network: | Network Internet connection |
| Mouse: | With the wheel button |
Note! For the edentulous workflow, 4GB video memory is recommended.
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3SHAPE IMPLANT STUDIO™ SOFTWARE SPECIAL 510(K) SUBMISSSION 3 S NA PE P
### Nonclinical Testing
Software, hardware, and integration verification and validation testing was performed in accordance with the FDA Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (Issued on May 11, 2005).
Prior to release, verification and validation testing of the Implant Studio 2015-1 has been completed using the approved acceptance criteria: Each user need has its own validation acceptance criteria; each specification has its own verification acceptance criteria; bug verification consists in ensuring issue is not reproducible; issues reported by beta partners must be reviewed and handled appropriately.
The validation suite includes validation of implemented mitigations related to device hazards identified in the risk management procedures.
All test results have been reviewed and approved, showing the Implant Studio to be substantially equivalent in safety and effectiveness to the predicate.
# Clinical Testing
Clinical testing is not a requirement and has not been performed.
#### Conclusion
Based on a comparison of intended use, indications, principle of operations, features and technical data, and the test results, the Implant Studio 2015-1 is found to be substantially equivalent in safety and effectiveness to the predicate. Intended use and performance is found to be substantially equivalent to the Predicate Devices.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
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.