K153624 · Jjgc Industria E Comercio DE Materiais Dentarios S · NHA · Apr 15, 2016 · Dental
Device Facts
Record ID
K153624
Device Name
Neodent Implant System
Applicant
Jjgc Industria E Comercio DE Materiais Dentarios S
Product Code
NHA · Dental
Decision Date
Apr 15, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3630
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Titanium Base Abutment is a titanium base placed onto Neodent dental implants to provide support for customized prosthetic restorations. It is used with a coping and crown, or crown alone, and is indicated for cement-retained single or multi-unit restorations, or screw-retained single restorations. All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
Device Story
Neodent Implant System consists of two-piece hybrid abutments (titanium base + customized superstructure). Titanium base interfaces with Neodent dental implants via Morse taper connection; provides support for prosthetic restorations. Dental laboratory uses CAD software (DWOS or 3Shape) to design patient-specific superstructures (zirconia, Co-Cr, or IPS e.max CAD). Designs sent to Straumann-validated milling center for fabrication. Clinician prescribes restoration; cements coping/crown to titanium base. System used in dental clinics; operated by dental professionals. Benefits include customized prosthetic fit and support for various restoration types.
Clinical Evidence
No clinical data submitted. Substantial equivalence supported by bench testing, including mechanical dynamic fatigue testing per ISO 14801, dimensional analysis, and sterilization validation (ISO 11135 for EO, ISO 17665 for steam). Biocompatibility supported by material identity to predicate and reference devices.
Technological Characteristics
Two-piece hybrid abutment. Base: Titanium-6Aluminum-4Vanadium ELI alloy (ASTM F136). Superstructure: Zirconia, Co-Cr, or IPS e.max CAD. Interface: Morse taper with hexagonal indexing. Dimensions: 3.5/4.5 mm diameter; 0.8-4.5 mm gingival heights. Sterilization: EO (base), moist steam (user). Connectivity: CAD/CAM workflow via DWOS or 3Shape software to validated milling center.
Indications for Use
Indicated for patients requiring dental implant-supported prosthetic restorations, including cement-retained single or multi-unit restorations or screw-retained single restorations.
Regulatory Classification
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.
Special Controls
*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.)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 15. 2016
JJGC Indústria e Comércio de Materiais Dentários SA c/o Ms. Jennifer Jackson Head of Quality and Regulatory Straumann USA, LLC 60-100 Minuteman Road Andover, Massachusetts 01810
Re: K153624
Trade/Device Name: Neodent Implant System Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: March 15, 2016 Received: March 17, 2016
Dear Ms. 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 (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
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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 devicerelated 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.
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/ResourcesforYou/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 vours.
# Erin | Keith -S
Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control. and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known)
K153624
Device Name
Neodent Implant System
Indications for Use (Describe)
Titanium Base Abutment is a titanium base placed onto Neodent dental implants to provide support for customized prosthetic restorations. It is used with a coping and crown, or crown alone, and is indicated for cement-retained single or multi-unit restorations, or screw-retained single restorations.
All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
Type of Use (Select one or both, as applicable)
| <span style="font-size: 16px;">☑</span> 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 | Straumann USA, LLC<br>60 Minuteman Road<br>Andover, MA 01810<br>Registration No.: 1222315<br>Owner/Operator No.: 9005052 | | |
|----------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|
| | on behalf of: | | |
| | JJGC Indústria e Comércio de Materiais Dentários SA Av. Juscelino<br>Kubitschek de Olivera, 3291<br>Curtiba, Parana, BRAZIL 81270-200<br>Registration No.: 3008261720<br>Owner/Operator No.: 10031702 | | |
| Contact Person | Jennifer M. Jackson, MS<br>Head of Quality and Regulatory, Straumann USA<br>Telephone (978) 747-2509 | | |
| Date Prepared | 15/April/2016 | | |
| Prepared by | Ana Carolina Martins Vianna<br>Regulatory Affairs Analyst, JJGC Indústria e Comércio de Materiais<br>Dentários SA<br>avianna@neodent.com.br | | |
| Product Code | NHA (21 CFR 872.3630) | | |
| Device Class | II (21 CFR 872.3630) | | |
| Classification Panel | Dental | | |
| Classification Name | Endosseous dental implant abutment (21 CFR 872.3630) | | |
| Common Name | Endosseous dental implant abutment | | |
| Proprietary name | Neodent Implant System | | |
| Primary Predicate | K150367 - Neodent Implant System, JJGC Indústria e Comércio de<br>Materiais Dentários SA | | |
| Reference Predicates | K120822 - Straumann® CARES® Variobase™ Abutments, Institu<br>Straumann AG<br>K142890 - Straumann® CARES® Variobase™ Abutments, Institut<br>Straumann AG | | |
#### Device Description
This submission includes the Titanium Base abutments (two-piece hybrid abutments) and the superstructures that compose the final abutment (the second part of the two-piece abutment).
The Titanium Base abutments are provided in two prosthetic platform diameters (3.5 and 4.5 mm), each in five gingival heights (0.8, 1.5, 2.5, 3.5 and 4.5 mm). They have a Morse taper implant-to-abutment interface and an additional hexagonal indexing feature at the apical end of the Morse taper connection. The surface is as-machined, without any type of treatment
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surface. The Titanium Base abutment is an intermediary prosthetic component between the implant and prosthesis; a CAD/CAM abutment design to be used as a base when fabricating a coping, crown or bridge superstructure. It is a stock abutment, previously cleared per K150367. The subject abutments are compatible with Neodent dental implants having Morse taper (CM) implant-to-interface cleared under K101945, K123022, K133592, K150182 and K150199.
The purpose of this submission is to expand the range of materials allowed in fabricating the superstructure, adding Co-Cr and IPS e.max "CAD materials to the previously cleared portfolio.
A dental laboratory equipped with an appropriate CAD system, will design a customized superstructure or restoration made of zirconia, IPS e.max CAD or Co-Cr. Each patient-specific superstructure is individually prescribed by the clinician. The minimum wall thickness of the structure is variable depending on the material, according to the table below. The maximum angling of the structure should not exceed 30°. The taper of the structure should not exceed 6°. In the case of a structure angled at the height of the cementable portion starting at the emergence profile (prosthetic height), it should not exceed 10 mm for the Morse Taper.
| Material | Minimum thickness (mm) |
|-----------|------------------------|
| CoCr | 0.3 |
| Zirconia | 0.5 |
| IPS e.max | 0.6 |
The planning of the customized superstructures must be made using the validated Dental Wings Operating System (DWOS) or 3Shape software. All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment system are intended to be sent to Straumann for manufacture at a validated milling center.
## Indications for Use
Titanium Base Abutment is a titanium base placed onto Neodent dental implants to provide support for customized prosthetic restorations. It is used with a coping and crown, or crown alone, and is indicated for cement-retained single or multi-unit restorations, or screw-retained single restorations.
All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
## Technological Characteristics
The Titanium Base abutment is a two-piece abutment consisting of a pre-manufactured (stock) abutment made of titanium alloy conforming to ASTM F136 - Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401), and a customized superstructure made of ceramics (zirconia or IPS e.max CAD) or Co-Cr. A dental laboratory equipped with an appropriate CAD system, will design a customized superstructure or restoration, which must be milled at a Straumann validated milling center.
The following table shows a comparison among the features of subject device and its predicate and reference devices. The assessment of the differences is also included.
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| | SUBJECT DEVICE | PRIMARY PREDICATE | |
|-----------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Neodent Implant System | Neodent Implant System<br>(K150367) | EQUIVALENCE DISCUSSION |
| Indications for Use | Titanium Base Abutment is a titanium base<br>placed onto Neodent dental implants to<br>provide support for customized prosthetic<br>restorations. It is used with a coping and<br>crown, or crown alone, and is indicated for<br>cement-retained single or multi-unit<br>restorations, or screw-retained single<br>restorations.<br>All digitally designed copings and/or<br>crowns for use with the Neodent Titanium<br>Base Abutment System are intended to be<br>sent to Straumann for manufacture at a<br>validated milling center. | Titanium Base Abutment is a titanium base<br>placed onto Neodent dental implants to<br>provide support for customized prosthetic<br>restorations. It is used with a coping and<br>crown, or crown alone, and is indicated for<br>cement-retained single or multi-unit<br>restorations, or screw-retained single<br>restorations. | Equivalent<br>The basic indication of providing support<br>for prostheses is identical. Additional<br>wording was added to the indications to<br>support the titanium base abutments<br>manufacturing process. The subject<br>device and primary predicate have<br>slightly different Indications for Use<br>language. However, the difference in<br>language does not change the intended<br>use or substantial equivalence. |
| Abutment Diameter(s) | 3.5 and 4.5 mm | 3.5 and 4.5 mm | Identical |
| Implant-to-Abutment<br>Connection | Morse taper (CM) interface | Morse taper (CM) interface | Identical |
| Compatibility | Morse taper (CM) implant lines of Neodent<br>Implant System. | Morse taper (CM) implant lines of Neodent<br>Implant System. | Identical |
| Mode of attachment | Screw-retained or cement<br>retained | Screw-retained or cement<br>retained | Identical |
| Restoration<br>Angulation(s) | Up to 30° | Up to 30° | Identical |
| Gingival Height(s) | 0.8, 1.5, 2.5, 3.5 and 4.5mm | 0.8, 1.5, 2.5, 3.5 and 4.5mm | Identical |
| Material of abutment | Titanium-aluminum-vanadium alloy Ti-6Al-<br>4V | Titanium-aluminum-vanadium alloy Ti-6Al-<br>4V | Identical |
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| | SUBJECT DEVICE | PRIMARY PREDICATE | EQUIVALENCE DISCUSSION |
|-------------------------------|-----------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Neodent Implant System | Neodent Implant System<br>(K150367) | |
| Material of<br>superstructure | Zirconia<br>Co-Cr<br>IPS e-max CAD | Zirconia | Equivalent<br><br>Addition of IPS e.max CAD and CoCr<br>materials does not change the Indications<br>For Use. These materials are used widely<br>for dental restorations, including with the<br>Straumann Variobase devices identified as<br>reference devices to this submission. |
| Sterility | Delivered sterile by EO exposure. To be<br>sterilized by user after the coping<br>cementation, before placed in patient<br>mouth. | Delivered sterile by EO exposure. To be<br>sterilized by user after the coping<br>cementation, before placed in patient<br>mouth. | Identical |
| Sterilization by end<br>user | Moist steam sterilization | Moist steam sterilization | Identical |
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# Performance data
Non-clinical data submitted, referenced, or relied upon to demonstrate substantial equivalence include engineering analysis, and dimensional analysis. Testing submitted or referenced in this submission in support of a substantial equivalence determination is as follows:
- . Mechanical testing was performed on the Titanium Base abutments including the superstructures according to ISO 14801 - Dentistry - Implants - Dynamic fatigue test for endosseous dental implants and FDA document Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments dated May 12, 2004
- . Ethylene Oxide sterilization validation per ISO 11135
- . Steam sterilization validation per the ISO 17665 series standards
- . Biocompatibility is supported as the material of the titanium base is identical to the company's own predicate. In addition, the materials for construction of the superstructure are identical to Straumann reference predicates and manufactured at a Straumann validated milling center.
- . Clinical data were not submitted in this premarket notification.
# Conclusions
Based upon our assessment of the design and applicable performance data, the subject devices have been determined to be substantially equivalent to the identified predicate devices and do not raise new issues of safety and effectiveness when uses as labeled.
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.