CEREC Ortho Software is intended for use with image data acquired from handheld intra oral 3D cameras and desktop laboratory scanners to create 3D virtual models to be used for data acquisition and modeling analysis for orthodontic patients and conditions. The CEREC Ortho Software 3D model data can be exported to orthodontic design software to aid in the design of orthodontic appliances.
Device Story
CEREC Ortho Software is a standalone software application used by dental professionals to process 3D image data from intra-oral cameras or desktop scanners. It generates 3D virtual dental models, serving as digital equivalents to physical plaster casts. The software enables segmentation, editing, and clinical measurements, including Bolton, Nance, and Moyers analyses. Users perform occlusal mapping and define dental arch parameters. The resulting models and analyses are exported to external orthodontic design software or laboratories for treatment planning and appliance fabrication. The device assists clinicians in visualizing patient anatomy and planning orthodontic interventions, potentially improving treatment accuracy and workflow efficiency compared to traditional physical impressions.
Clinical Evidence
No clinical data was included. Substantial equivalence is supported by non-clinical bench testing, including verification of measurement accuracy, trueness and precision of optical impressions, and software lifecycle validation per IEC 62304.
Technological Characteristics
Standalone software for Windows 7 (64-bit) OS. Minimum requirements: Intel QuadCore 1.6 GHz, 8 GB RAM, 250 GB storage, and dedicated graphics card. Inputs: intra-oral 3D camera data and desktop scanner STL files. Outputs: 3D virtual models and analysis data. No patient-contacting components; no biocompatibility or sterilization required.
Indications for Use
Indicated for orthodontic patients requiring data acquisition and modeling analysis of 3D virtual dental models created from intra-oral 3D camera or desktop scanner image data to aid in orthodontic treatment planning and appliance design.
Regulatory Classification
Identification
An orthodontic plastic bracket is a plastic device intended to be bonded to a tooth to apply pressure to a tooth from a flexible orthodontic wire to alter its position.
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Image /page/0/Picture/0 description: The image contains the logos of the U.S. Department of Health & Human Services and the U.S. Food & Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is 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.
January 11, 2018
Dentsply Sirona Karl J. Nittinger Senior Manager & Corporate Regulatory Affairs 221 West Philadelphia Street, Suite 60W York, Pennsylvania 17401
Re: K171122
Trade/Device Name: CEREC Ortho Software Regulation Number: 21 CFR 872.5470 Regulation Name: Orthodontic plastic bracket Regulatory Class: Class II Product Code: PNN, LLZ Dated: December 11, 2017 Received: December 13, 2017
## Dear Karl J. Nittinger:
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.
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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); 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.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Mary S. Runner -S
For Tina Kiang, Ph.D. Acting 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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# Indications for Use
510(k) Number (if known)
K171122
Device Name
### CEREC Ortho Software
Indications for Use (Describe)
CEREC Ortho Software is intended for use with image data acquired from handheld intra oral 3D cameras and desktop laboratory scanners to create 3D virtual models to be used for data acquisition and modeling analysis for orthodontic patients and conditions. The CEREC Ortho Software 3D model data can be exported to orthodontic design software to aid in the design of orthodontic appliances.
| Type of Use (Select one or both, as applicable) |
|------------------------------------------------------------------------------------------------------------------------------------------------------|
| <div> <span> X Prescription Use (Part 21 CFR 801 Subpart D) </span> <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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## SECTION 5. 510(k) SUMMARY K171122 CEREC Ortho Software
#### 1. Submitter Information:
Dentsply Sirona 221 West Philadelphia Street Suite 60 York, PA 17404
| Contact Person: | Karl Nittinger |
|-------------------|----------------|
| Telephone Number: | 717-849-4424 |
| Fax Number: | 717-849-4343 |
Date Prepared: January 5, 2018
#### 2. Device Name:
| • Proprietary Name: | CEREC Ortho Software |
|-----------------------------------|------------------------------|
| • Classification Regulation Name: | Orthodontic plastic bracket. |
| • CFR Number: | 21 CFR 872.5470 |
| • Device Class: | Class II |
- Product Code: PNN (Orthodontic Software) ●
#### Predicate Device: 3.
The predicate device for the CEREC Ortho Software is:
| Predicate Device Name | 510(k) | Company Name |
|-----------------------|---------|--------------|
| 3Shape Ortho System™ | K152086 | 3Shape A/S |
#### 4. Description of Device:
The CEREC Ortho Software is stand-alone software which utilizes images of the patient's intraoral anatomy from intra-oral cameras and/or desktop laboratory scanners to create a 3D virtual dental model that can be used in the same manner as a traditional physical dental model.
The CEREC Ortho Software facilitates the segmentation and editing of the 3D virtual digital model as well as analysis which can be used in secondary orthodontic treatment planning. The software allows for measurement and jaw analysis to be performed - including Bolton, Nance, and Moyers analyses. The models and analysis produced by the proposed CEREC Ortho Software can be exported to an orthodontic laboratory or directly to orthodontic appliance manufacturers for use in orthodontic treatment planning and design of orthodontic appliances.
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The proposed CEREC Ortho Software is intended to be used wherever cast impressions are used and in the identical manner in which the traditional physical models are used (i.e., to record topographical characteristics of dentition, gingiva, palate, and/or oral anatomy in conjunction with the treatment planning and production of orthognathic/orthodontic appliances).
#### న. Indications for Use:
CEREC Ortho Software is intended for use with image data acquired from handheld intra oral 3D cameras and desktop laboratory scanners to create 3D virtual models to be used for data acquisition and modeling analysis for orthodontic patients and conditions. The CEREC Ortho Software 3D model data can be exported to orthodontic design software to aid in the design of orthodontic appliances.
#### 6. Substantial Equivalence:
The CEREC Ortho Software has the same intended use and incorporates the same fundamental technology as the predicate software device. Both the CEREC Ortho Software and the predicate 3Shape Ortho System™ (K152086) are stand-alone software devices which are intended as Orthodontic Treatment Software devices (Product Code PNN, under 21 CFR 872.5470 ) and. as such are intended to aid in the diagnosis and treatment planning of orthodontic patients and conditions.
Detailed comparison of the intended use and technological characteristics and features of the CEREC Ortho Software and the predicate 3Shape Ortho System™ (K152086) devices is presented in Tables 6.1 and 6.2.
Table 6.1: Indications for Use
| Subject Device<br>CEREC Ortho Software | Predicate Device<br>3Shape Ortho System™<br>(K152086) |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| CEREC Ortho Software is intended for use with image data<br>acquired from handheld intra oral 3D cameras and desktop<br>laboratory scanners to create 3D virtual models to be used for data<br>acquisition and modeling analysis for orthodontic patients and<br>conditions. The CEREC Ortho Software 3D model data can be<br>exported to orthodontic design software to aid in the design of<br>orthodontic appliances. | 3Shape Ortho System™ is intended for use as a<br>medical front-end device providing tools for<br>management of orthodontic models, systematic<br>inspections, detailed analysis, treatment simulation<br>and virtual appliance design options (Custom metal<br>bands, Export of Models, Indirect Bonding Transfer<br>Media) based on 3D models of the patient's dentition<br>before the start of an orthodontic treatment. It can also<br>be applied during the treatment to inspect and analyze<br>the progress of the treatment. It can be used at the end<br>of the treatment to evaluate if the outcome is consistent<br>with the planned/desired treatment objectives.<br>The use of Ortho System™ requires the user to have<br>the necessary training and domain knowledge in the<br>practice of orthodontics, as well as to have received<br>training in the use of the software. |
| Proposed Device<br>CEREC Ortho Software | Predicate Device<br>3Shape Ortho System™<br>(K152086) |
| Supported Computer Formats | |
| - Intended for loading on a personal computer. | - Intended for loading on a personal computer. |
| Minimum requirements: | Minimum requirements: |
| - Functions within Windows 7, 64-bit operating system. | - Functions within Windows 7 or 8, 64-bit operating system. |
| - 250 GB hard disk storage. | - 250 GB hard disk storage. |
| - 8 GB RAM memory. | - 8 GB RAM memory. |
| - Intel QuadCore 1.6 GHz processor. | - Intel Core i5 or equivalent processor. |
| - NVidia or AMD graphics card with 1 GB memory. | - GeForce graphics card with 1 GB memory. |
| Acquisition Data Formats Support | |
| Intra-oral scan data | Intra-oral scan data |
| Desktop scanner STL data | Desktop scanner STL data |
| N/A | Computed Tomography (CT) DICOM image data |
| N/A | 2D overlay data |
| Supported anatomic areas | |
| Maxilla | Maxilla |
| Mandible | Mandible |
| Functionality | |
| Acquisition of oral topography image data | Acquisition of oral topography image data |
| Creation of virtual 3D virtual dental models | Creation of virtual 3D virtual dental models |
| Alignment of 3D virtual dental models | Alignment of 3D virtual dental models |
| Measurement of 3D virtual dental models | Measurement of 3D virtual dental models |
| Analysis of 3D virtual dental models | Analysis of 3D virtual dental models |
| N/A | Orthodontic treatment simulation |
| N/A | Virtual orthodontic appliance design |
| Exporting of 3D virtual model and analysis data | Exporting of 3D virtual model, analysis and treatment case<br>data |
| Proposed Device<br>CEREC Ortho Software | Predicate Device<br>3Shape Ortho System™<br>(K152086) |
| Analysis Features | |
| Occlusal mapping | Occlusal mapping |
| Tooth and gingiva separation/segmentation | Tooth and gingiva separation/segmentation |
| Definition of dental arch shape and length | Definition of dental arch shape and length |
| Tooth width measurements | Tooth width measurements |
| Bolton's analysis | Bolton's analysis |
| Nance and Moyer space analyses | Space analyses |
| Orthodontic Treatment Simulation | |
| N/A | 2D and 3D simulated orthodontic treatment |
| Virtual Orthodontic Appliance Design | |
| N/A | Orthodontic appliance search library. |
| N/A | Virtual placement of orthodontic appliances. |
| N/A | Design of orthodontic appliances |
| N/A | Export of orthodontic appliance designs |
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Table 6.2: Technological Characteristics and Features
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Table 6.2: Technological Characteristics and Features (continued)
The CEREC Ortho Software and the predicate 3Shape Ortho System™ (K152086) both facilitate their intended use through the acquisition of image scan data of the oral topography. With the acquired image data, the proposed device and predicate device (K152086) create 3D virtual dental models of the patient's dentition. These virtual dental models are functional equivalents of physical cast models.
The CEREC Ortho Software and the predicate 3Shape Ortho System™ (K152086) automatically provide alignment tools, measurement, and perform analysis of the 3D virtual models. With respect to the proposed CEREC Ortho Software, the 3D virtual model and finalized analysis can be exported to support orthodontic treatment planning. However, in the case of the predicate 3Shape Ortho System™ (K152086), orthodontic treatment planning is also integral to the software device functionality through: simulated orthodontic treatment; virtual design and placement of orthodontic appliances, and export for the finalized orthodontic treatment plan.
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#### 7. Non-Clinical Performance Data
In support of the substantial equivalence of the CEREC Ortho Software, performance and software testing were conducted and are included and the results support substantial equivalence:
- . Testing to verify the accuracy of the measurement functions of the CEREC Ortho Software as well as the trueness and precision of optical impressions produced using CEREC optical impression systems and the CEREC Omnicam intra-oral scanner (510(k)-exempt under 21 CFR 872.3661).
- Validation of the CEREC Ortho Software in conformity with IEC 62304 (Medical device . software – Software lifecycle processes).
The CEREC Ortho Software does not include any physical device, accessory, or component with patient contacting intended use. Therefore, no biocompatibility data, sterilization, or shelf life analyses were included in support of substantial equivalence.
#### 8. Clinical Performance Data
No human clinical data was included to support substantial equivalence.
#### 9. Conclusion Regarding Substantial Equivalence
The CEREC Ortho Software has the same intended use as that of the predicate 3Shape Ortho System™ (K152086) software. Both devices are orthodontic software devices regulated under 21 CFR 872.5470 and as such are intended for use to aid in the diagnosis and treatment planning of orthodontic patients and conditions.
The predicate 3Shape Ortho System™ (K152086) is additionally regulated as a Radiological Image Processing System under 21 CFR 892.2050 due to its functionality to utilize CT DICOM images as input. However, the proposed CEREC Ortho Software does not incorporate this functionality and therefore is proposed for an intended use which is a subset of the predicate device (K152086) to which it is compared.
Non-clinical testing and software validation data are included to demonstrate the performance of the CEREC Ortho Software against its design, functional, and safety requirements. The results of the testing support a determination of substantial equivalence.
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.