Custom Legacy and Custom InterActive Titanium Abutments
K192218 · Implant Direct Sybron Manufacturing, LLC · NHA · May 8, 2020 · Dental
Device Facts
Record ID
K192218
Device Name
Custom Legacy and Custom InterActive Titanium Abutments
Applicant
Implant Direct Sybron Manufacturing, LLC
Product Code
NHA · Dental
Decision Date
May 8, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3630
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Custom Titanium Abutments are customizable devices intended for use with dental implants in the maxillary and/or mandibular arches to provide support for crowns or bridges for edentulous or partially edentulous patients. - Custom Titanium Abutment for narrow (3.2mmD) implants: Indicated for single-tooth replacement of mandibular central and lateral incisors and maxillary lateral incisors. Also indicated for multiple tooth replacements. - Custom Titanium Abutment for short (8mm) 3.7mmD implants: Indicated for tooth replacement of mandibular and maxillary central and lateral incisors. Custom Legacy Titanium Abutments are compatible at the implant-level with Legacy2, Legacy3, Legacy4, simplyLegacy2 and simplyLegacy3 implants, excluding 6mm length implants. Custom InterActive Titanium Abutments are compatible at the implant-level with InterActive, SimplyInterActive and SwishActive implants, excluding 6mm length implants.
Device Story
Custom Titanium Abutments are one-piece, patient-specific titanium (6AL-4V ELI) dental abutments; used to support crowns or bridges on dental implants. Device customization occurs via digital workflow: intraoral/impression scans processed using 3Shape Abutment Designer software; designs milled at Implant Direct facility. Workflows include 'Design-and-Mill' (manufacturer designs, clinician approves) or 'Mill-only' (clinician designs, sends .stl file). Abutments feature hex-engaging interface for implant connection; secured via fixation screw. Used in dental clinics; operated by dental practitioners/laboratory staff. Output is a custom-milled abutment; facilitates prosthetic restoration of chewing function. Benefits include patient-specific fit and integration into digital dentistry workflows.
Clinical Evidence
No clinical or animal testing was submitted. Substantial equivalence is supported by bench testing: biocompatibility (ISO 10993-1: cytotoxicity, sensitization, irritation, systemic toxicity, mutagenicity), fatigue testing (ISO 14801) on worst-case designs (30-degree angulation, 0.4mm wall thickness), and steam sterilization validation (ISO 17665) achieving SAL 10^-6.
Technological Characteristics
Material: Titanium 6AL-4V ELI. Design: One-piece hex-engaging abutment with straight post. Interface: Internal hex (Legacy) or internal hex with 12-degree conical lead-in bevel (InterActive). Dimensions: Various diameters (3.0mm-5.7mm). Connectivity: Digital workflow using 3Shape Abutment Designer software (K151455) via .stl file transmission. Sterilization: Non-sterile, steam-sterilizable by end user. Software: Off-the-shelf design library with locked parameters.
Indications for Use
Indicated for edentulous or partially edentulous patients requiring dental implant-supported crowns or bridges in maxillary/mandibular arches. Specific indications: narrow (3.2mmD) implants for single-tooth replacement of mandibular central/lateral incisors and maxillary lateral incisors, or multiple tooth replacements; short (8mm) 3.7mmD implants for mandibular/maxillary central and lateral incisor replacement.
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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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, with the word "ADMINISTRATION" underneath.
May 8, 2020
Implant Direct Sybron Manufacturing, LLC % Kelliann Payne Partner Hogan Lovells U.S. LLP 1735 Market Street, 23rd Floor Philadelphia, Pennsylvania 19103
Re: K192218
Trade/Device Name: Custom Legacy and Custom InterActive Titanium Abutments Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous dental implant abutment Regulatory Class: Class II Product Code: NHA Dated: April 10, 2020 Received: April 10, 2020
Dear Kelliann Payne:
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.
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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.
Srinivas Nandkumar, Ph.D. for Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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510(k) Number (if known) K192218
#### Device Name
#### Custom Leqacy and Custom InterActive Titanium Abutments
Custom Titanium Abutments are customizable devices intended for use with dental implants in the maxillary and/or mandibular arches to provide support for crowns or bridges for edentulous or partially edentulous patients.
- Custom Titanium Abutment for narrow (3.2mmD) implants: Indicated for single-tooth . replacement of mandibular central and lateral incisors and maxillary lateral incisors. Also indicated for multiple tooth replacements.
- Custom Titanium Abutment for short (8mm) 3.7mmD implants: Indicated for tooth replacement of mandibular and maxillary central and lateral incisors.
Custom Legacy Titanium Abutments are compatible at the implant-level with Legacy2, Legacy3, Leqacy4, simplyLegacy2 and simplyLegacy3 implants, excluding 6mm length implants.
| Implant Line | Body Diameter | Platform Diameter | Implant Length |
|------------------------------------------------------------|-------------------------------------------------|----------------------------|----------------|
| Legacy1 | 3.7mm, 4.2mm, 4.7mm, 5.7mm | 3.5mm, 4.5mm, 5.7mm | 8mm to 16mm |
| Legacy2, Legacy3, Legacy4,<br>simplyLegacy2, simplyLegacy3 | 3.2mm, 3.7mm, 4.2mm, 4.7mm, 5.2mm, 5.7mm, 7.0mm | 3.0mm, 3.5mm, 4.5mm, 5.7mm | |
Custom InterActive Titanium Abutments are compatible at the implant-level with InterActive, SimplyInterActive and SwishActive implants, excluding 6mm length implants.
| Implant Line | Body Diameter | Platform Diameter | Implant Length |
|--------------------------------|----------------------------|-------------------|----------------|
| InterActive, simplyInterActive | 3.2mm, 3.7mm, 4.3mm, 5.0mm | 3.0mm, 3.4mm | 8mm to16mm |
| SwishActive | 3.3mm, 4.1mm, 4.8mm | 3.0mm, 3.4mm | 8mm to16mm |
Type of Use (Select one or both, as applicable)
区 Prescription Use (Part 21 CFR 801 Subpart D)
□ Over-The-Counter Use (21 CFR 801 Subpart C)
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## 510(k) SUMMARY
## Implant Direct Sybron Manufacturing, LLC's Custom Legacy Titanium Abutments and Custom InterActive Titanium Abutments
| Submitter:<br>Address:<br>Phone:<br>Contact Person: | Implant Direct Sybron Manufacturing, LLC<br>3050 East Hillcrest Drive<br>Thousand Oaks, CA 91362<br>(818) 444-3306<br>Reina Choi, Regulatory Affairs Manager |
|-------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Date Prepared: | May 7, 2020 |
| Name of Device:<br>Common or Usual Name:<br>Regulation Number:<br>Classification Panel:<br>Regulatory Class:<br>Product Code: | Custom Legacy and Custom InterActive Titanium Abutments<br>Endosseous dental implant abutments<br>21 C.F.R. § 872.3630<br>Dental<br>Class II<br>NHA |
| Predicate Device: | Implant Direct Sybron Manufacturing, LLC's Legacy Abutment<br>System (K060063) |
| Reference Devices: | |
lmplant Direct Sybron Manufacturing, LLC's InterActive/SwishPlus2 Implant System (K130572) 3Shape A/S's 3Shape Abutment Designer Software (K151455) Implant Direct Sybron Manufacturing, LLC's InterActive SMARTBase Abutments (K181359)
# Device Description
The Custom Legacy Titanium Abutments and Custom InterActive Titanium Abutments (collectively the "Custom Titanium Abutments") are one-piece hex type engaging abutments comprised of Titanium 6AL-4V ELI, which serve as a final abutment upon which a prosthetic dental restoration will be fitted.
The Custom Legacy Abutments are offered in 3.0mm, 3.5mm, and 5.7mm diameters that correspond to the platform diameters of the Legacy Implant System; the Custom InterActive Abutments are offered in 3.0mm and 3.4mm diameters that correspond to the InterActive Implant System. The devices are supplied with fixation screws that are placed through the abutment to secure it to the implant's reciprocal hex platform. The Custom Abutments are provided with a large amount of modifiable material to accommodate the digital workflow used for device customization. Customization of the final abutment is performed in Implant Direct's Custom Direct laboratory under Implant Direct's manufacturing control, where the devices are milled to meet individual patient specifications. The digital workflow uses the following additional devices:
- . 3Shape Abutment Design Software (K151455)
- о Dental System Control Panel
- Dental Designer o
- Lab Scanner (3Shape D700 and 3Shape Scan-it Restoration Dental System (510(k)-exempt, . Product Code NOF)
- . Intra-oral scanners
- 3M True Definition Scanner (K122467) o
- Itero Scanner Software (K131101) o
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The Custom Abutments are patient-specific and may be modified within the following parameters:
- Maximum angle of 30° from the axis of the implant .
- . Minimum wall thickness of 0.4mm
- . Minimum post height of 4mm
The Custom Abutments are available using either a Design-and-Mill or Mill-only digital workflow. With the Design-and-Mill process flow, the patient's dentition information (impression or intraoral scan) is sent to Implant Direct. Implant Direct will design an abutment and forward the design to the end user for approval prior to manufacturing. With the Mill-only process flow, the end user uses intra-oral scanners and lab scanners to design the abutment using the 3Shape software. The abutment design file (.stl) is sent to Implant Direct for manufacturing.
The Custom Abutments are single-use and supplied non-sterilization by the end user. They are externally-communicating devices which come in permanent contact (>30 days) with a patient's tissue/bone.
## Intended Use / Indications for Use
Custom Titanium Abutments are customizable devices intended for use with dental implants in the maxillary and/or mandibular arches to provide support for crowns or bridges for edentulous or partially edentulous patients.
- . Custom Titanium Abutment for narrow (3.2mmD) implants: Indicated for single-tooth replacement of mandibular central and lateral incisors and maxillary lateral incisors. Also indicated for multiple tooth replacements.
- Custom Titanium Abutment for short (8mm) 3.7mmD implants: Indicated for tooth replacement ● of mandibular and maxillary central and lateral incisors.
Custom Legacy Titanium Abutments are compatible at the implant-level with Legacy2, Legacy3, Legacy4, simplyLegacy2 and simplyLegacy3 implants, excluding 6mm length implants.
| Implant Line | Body Diameter | Platform Diameter | Implant Length |
|---------------------------------------------------------|-------------------------------------------------|----------------------------|----------------|
| Legacy1 | 3.7mm, 4.2mm, 4.7mm, 5.7mm | 3.5mm, 4.5mm, 5.7mm | 8mm to 16mm |
| Legacy2, Legacy3, Legacy4, simplyLegacy2, simplyLegacy3 | 3.2mm, 3.7mm, 4.2mm, 4.7mm, 5.2mm, 5.7mm, 7.0mm | 3.0mm, 3.5mm, 4.5mm, 5.7mm | |
Custom InterActive Titanium Abutments are compatible at the implant-level with InterActive, SimplyInterActive and SwishActive implants, excluding 6mm length implants.
| Implant Line | Body Diameter | Platform Diameter | Implant Length |
|-----------------------------------|-------------------------------|-------------------|----------------|
| InterActive,<br>simplyInterActive | 3.2mm, 3.7mm, 4.3mm,<br>5.0mm | 3.0mm, 3.4mm | 8mm to16mm |
| SwishActive | 3.3mm, 4.1mm, 4.8mm | 3.0mm, 3.4mm | 8mm to16mm |
The minor differences in indications for use of the Custom Abutments as compared to the predicate device do not alter the intended therapeutic effect of these devices or raise different questions of safety or effectiveness, as they are primarily intended for clarification of the appropriate conditions of use (e.g., compatibility) and to facilitate achievement of the same general intended use (in
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conjunction with dental implants to support crowns and bridges for edentulous or partially edentulous patients) via a digital dentistry workflow.
## Summary of Technological Characteristics
Both the subject and predicate devices are based on the fundamental principle of providing support for (a) dental implant(s) in order to enable a dental restoration to be inserted into the patient's mouth to aid in rehabilitating a patient's chewing function. At a high level, the subject and predicate devices are based on the following same technological elements:
- . Both subject devices and the predicate are one-piece abutments comprised of Titanium 6AL-4V ELI which can be modified to patient-specific requirements.
- . Both subject devices and the predicate utilize a hex engaging feature that attaches to the reciprocal hex platform of the corresponding implant.
- . Both subject devices and the predicate feature the same fundamental design (e.g., straight post for modifying custom features) and same corresponding screw size.
The Custom Abutments are available using either a Design-and-mill or Mill-only digital workflow, both of which employ the scanners identified in the Device Description section above and the 3Shape Abutment Designer Software (K151455).
- The Design-and-mill workflow uses impression or intraoral scan data provided by the dental . practitioner as input for Implant Direct to design a Custom Abutment using 3Shape within its controlled facility. The resulting abutment design is approved by the dental practitioner and manufactured within the Implant Direct facility.
- The Mill-only workflow allows the dental practitioner or dental laboratory staff to design the Custom Abutment using the 3Shape software. An encrypted .stl file is then transmitted to Implant Direct for manufacturing. A digital library provided by Implant Direct controls the abutment design parameters.
Thus, the main technological difference between the subject and predicate devices is the use of a digital workflow to modify the stock material of the subject devices into a final abutment, as compared to the conventional workflow used to modify/finalize the predicate abutment. This difference does not raise different questions of safety or effectiveness, because all of the devices are modified to clinician-prescribed, patient-specific parameters, and the same considerations apply around the safety and integrity of the final product under the anticipated loads in the mouth. In all cases with both the predicate and reference devices, as well as with the subject devices using either the Design-and-Mill or Mill-only workflows, the end user must approve the final abutment parameters/design. Moreover, the off-the-shelf software used to fabricate the Custom Abutments has been previously cleared by FDA (K151455) for use in producing abutments. The Custom InterActive Abutment has a slightly different connection to the implant than the predicate, but this connection supports the same functionality (mating between implant and abutment) and was previously cleared by FDA in the InterActive implant reference device (K130572).
A table comparing the key features of the subject and predicate devices is provided below.
## Performance Data
Non-clinical testing was performed on the subject device to support its safety and performance. Successful test results indicate that the Custom Titanium Abutments will perform as intended and
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support the device's substantial equivalence, as summarized below.
#### Biocompatibility
The Custom Abutments were subjected to biocompatibility testing according to ISO 10993-1. Worstcase Custom Abutments were tested for Cytotoxicity (ISO 10993-5), Sensitization (ISO 10993-10), Irritation (ISO 10993-10), Systemic toxicity (ISO 10993-11), and Mutagenicity (ISO 10993-3). The testing showed no adverse biological effects.
#### Fatigue Testing
Fatigue testing was performed per ISO 14801. Testing was performed on worst-case scenario designs and implant-abutment loading configurations. The design parameters considered were maximum angulation (30 degrees), minimum wall thickness (0.4mm), minimum post height (4mm), and maximum overall length of abutment.
#### Steam Sterilization
Steam sterilization validation was performed per ISO 17665 on worst-case Custom Abutments, taking into consideration overall size, surface area, weight, and lumen diameter. The validation ensures an SAL of 10to.
#### Software Verification and Validation
Software verification and validation testing was performed for the off-the-shelf abutment design library used in the subject devices' digital workflow, 3Shape Abutment Designer™ Software (K151455). The testing demonstrated that the established design limitations are locked and cannot be modified by the end user within the abutment design library.
No animal or clinical testing was submitted in support of this 510(k) notice.
## Conclusion
The Custom Legacy and Custom InterActive Titanium Abutments are as safe and effective as the predicate Legacy Abutment System (K060063). The Custom Titanium Abutments and previously cleared Legacy Scalloped (now called Straight Contoured) Abutment have the same intended use and very similar indications, technological characteristics, and principles of operation. The minor differences between the subject and predicate devices do not alter the therapeutic/surgical use of the device and do not present different questions of safety or effectiveness, because they do not represent fundamental differences in design or mechanism of action. In addition, performance data demonstrates that the subject Custom Abutments are as safe and effective as the predicate device. Thus, the Custom Titanium Abutments are substantially equivalent to the Legacy Abutment System.
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| | Custom Titanium Abutments<br>(Subject Device) | Legacy Abutment System<br>(K060063)<br>(Predicate Device) | InterActive SwishPlus2 Implant<br>System (K130572) (Abutment<br>Component: Reference Device) | 3Shape Abutment Designer<br>Software (K151455)<br>(Reference Device) |
|------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Classification | 21 CFR § 872.3630; Product Code NHA | | 21 CFR §§ 872.3640, 872.3630;<br>Product Codes DZE, NHA | 21 CFR § 872.3630; Product<br>Code PNP |
| Intended Use /<br>Indications for<br>Use | Custom Titanium Abutments are<br>customizable devices intended for use<br>with dental implants in the maxillary<br>and/or mandibular arches to provide<br>support for crowns or bridges for<br>edentulous or partially edentulous<br>patients.<br>Custom Titanium Abutment for narrow (3.2mmD, 3.3.mD) implants: Indicated for single-tooth replacement of mandibular central and lateral incisors and maxillary lateral incisors. Also indicated for multiple tooth replacements. Custom Titanium Abutment for short (8mm) 3.7mmD implants: Indicated for tooth replacement of mandibular and maxillary central and lateral incisors. | The Legacy Abutment<br>System is intended for use<br>with dental implants in the<br>maxillary and/or mandibular<br>arches to provide support for<br>crowns, bridges, or<br>overdentures for edentulous<br>or partially edentulous<br>patients. | The InterActive/SwishPlus2 Implant<br>System consists of two-piece implants for<br>one-stage or two-stage surgical<br>procedures. The abutment component of<br>the system is included herein as a<br>reference device. These implants are<br>intended for use in partially and fully<br>edentulous upper and lower jaws in<br>support of single or multiple-unit<br>restorations and terminal or intermediate<br>abutment support for fixed bridgework:<br>Implants can be indicated for immediate<br>loading when good primary stability has<br>been achieved and with appropriate<br>occlusal loading.<br>Narrow Diameter (3.2, 3.3mm) Implants:<br>Indicated for single-tooth replacement of<br>mandibular central and lateral incisors<br>and maxillary lateral incisors. Also<br>indicated for multiple tooth replacements<br>or denture stabilization. | The 3Shape Abutment<br>Designer Software is intended<br>as an aid to the restoration of<br>chewing function in partially or<br>fully edentulous mandibles and<br>maxillae. The 3Shape<br>Abutment Designer Software<br>is intended for use by a dental<br>practitioner or dental<br>laboratory staff for designing<br>the patient specific component<br>of a two-piece, one-piece, or<br>hybrid dental implant<br>abutment. The single or multi-<br>unit abutment design is<br>intended to be used by the<br>manufacturer of an<br>endosseous dental implant<br>abutment to create the final<br>device. |
| Compatibility | Custom Legacy Titanium Abutments are<br>compatible at the implant-level with<br>Legacy1, Legacy2, Legacy3, Legacy4,<br>simplyLegacy2 and simplyLegacy3<br>implants, excluding 6mm length<br>implants.<br>Custom InterActive Titanium Abutments<br>are compatible at the implant-level with<br>InterActive, SimplyInterActive and<br>SwishActive implants, excluding 6mm<br>length implants. | The Legacy Abutment System<br>is compatible with implants<br>that have mating diameters,<br>lead-in bevels, internal hex<br>sizes, and 1-72UNF internal<br>threads, as shown in the<br>Zimmer Dental Tapered<br>Screw-Vent Surgical Manual.<br>Implant Direct LLC will monitor<br>the compatible implants for<br>modifications to ensure future<br>compatibility. In the event of<br>any modification, Implant<br>Direct LLC will either modify<br>the Legacy abutment to<br>ensure compatibility, or cease | InterActive and SwishPlus2 implants are<br>prosthetically compatible with InterActive<br>3.0 and 3.4mm abutments and Nobel<br>Biocare conical connection NobelActive<br>NP (Narrow Platform - 3.0mm diameter)<br>and NobelActive RP (Regular Platform -<br>3.4mm diameter) abutments. InterActive<br>3.0 and 3.4mm abutments are<br>prosthetically compatible with Nobel<br>Biocare conical connection. NobelActive<br>NP (Narrow Platform- 3.0mm diameter)<br>and NobelActive RP (Regular Platform -<br>3.4mm diameter) (3.5-5.0mmD, 8.5-<br>18mmLength) implants. | N/A |
| | Custom Titanium Abutments<br>(Subject Device) | Legacy Abutment System<br>(K060063)<br>(Predicate Device) | InterActive SwishPlus2 Implant<br>System (K130572) (Abutment<br>Component: Reference Device) | 3Shape Abutment Designer<br>Software (K151455)<br>(Reference Device) |
| | | claiming compatibility to the | | |
| | | modified Zimmer Dental | | |
| | | Screw-Vent implants. | | |
| Material | | Titanium 6AL-4V ELI | | N/A |
| General Design | One-piece abutment with hex engaging feature and straight post for modifying custom features | | | N/A - Software only device |
| Implant/Abutmen<br>t Interface | Internal hex (Legacy) and Internal hex<br>with 12 degree conical lead-in bevel<br>(InterActive) | Internal hex with 45 degree<br>bevel | Internal hex with 12 degree conical<br>lead-in bevel | N/A - Software only device |
| Implant/Abutmen | Legacy Model: 3.0mmD, 3.5mmD,<br>4.5mmD, 5.7mmD | 3.5mmD, 4.5mmD, 5.7mmD | 3.0mmD, 3.4mmD | N/A - Software only device |
| t Interface | | | | |
| Diameters | InterActive Model: 3.0mmD, 3.4mmD | | | |
| Cuff Diameters | 3.2mm – 12.7mm | 4.5mm, 5.4mm, 6.5mm | 3.7mm, 4.7mm, 5.7mm | N/A - Software only device |
| Modifying<br>Workflow | Customization design provided by<br>customer or prepared in-house and<br>then machined in-house | Abutments are modified by outside laboratory and/or chairside by the<br>dentist using hand instruments. | | N/A |
| | | | | |
| | | | | |
| Screw Material<br>and Thread | Titanium alloy; M1.6, M2, 1-72UNF | Titanium alloy; 1-72 UNF | Titanium alloy; M1.6, M2 | N/A |
| Single vs.<br>Multiple Use | Single-use | Single-use | Single-use | Multiple use |
| Packaging | Packaged affixed via a fixation screw to a plastic screw-mount. The screw-mount is placed within a larger outer vial | | | N/A - Software only device |
| | and closed with a vial cap. | | |…
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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.