K201827 · Pro3Dure Medical GmbH · EBG · Nov 5, 2020 · Dental
Device Facts
Record ID
K201827
Device Name
GR-17 Resin System
Applicant
Pro3Dure Medical GmbH
Product Code
EBG · Dental
Decision Date
Nov 5, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3770
Device Class
Class 2
Indications for Use
The GR-17 Resin System is a light-curable polymerizable resin intended to be used in conjunction with extra-oral curing light equipment. The GR-17 temporary is indicated for the fabrication, by additive manufacturing, of temporary anterior dental restorations. The GR-17.1 temporary is indicated for the fabrication, by additive manufacturing, of temporary dental restorations, and for the fabrication, by additive manufacturing, of preformed denture teeth to be used in a denture.
Device Story
GR-17 Resin System consists of light-curable methacrylic resins with inorganic fillers (0.4-3 microns); available in seven shades. Liquid resin polymerized via 405nm image projection systems (additive manufacturing/CAM systems like Nyomo, Rapidshape, Envisiontec, or Asiga). Used in dental clinics/labs by professionals to fabricate temporary dental restorations and denture teeth. Output is a physical dental prosthetic. Benefits include efficient, customized fabrication of temporary restorations and denture components.
Clinical Evidence
Bench testing only. Performance testing conducted per ISO 10477 and ISO 22112. Biocompatibility testing conducted per ISO 10993-1. Shelf life testing performed per ASTM F1980-16.
Technological Characteristics
Methacrylate-based resin with inorganic fillers (0.4-3 microns). Curing via 405nm UV light projection. Complies with ISO 10477, ISO 22112, ISO 4049, and ISO 10993. Liquid form factor.
Indications for Use
Indicated for fabrication of temporary anterior dental restorations (GR-17 temporary) and temporary dental restorations or preformed denture teeth (GR-17.1 temporary) via additive manufacturing.
Regulatory Classification
Identification
A temporary crown and bridge resin is a device composed of a material, such as polymethylmethacrylate, intended to make a temporary prosthesis, such as a crown or bridge, for use until a permanent restoration is fabricated.
Predicate Devices
DeltaMed e-Dent Temporary Resin and Extra-Oral Curing System (K102776)
Reference Devices
Dentis Resin for Temporary Crown & Bridge (K180657)
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November 5, 2020
Pro3dure Medical GmbH % Patricia Kontoudis Specialist, Regulatory Affairs Regulatory and Quality Solutions, LLC 2790 Mosside Blvd., Suite 800 Monroeville, Pennsylvania 15146
Re: K201827
Trade/Device Name: GR-17 Resin System Regulation Number: 21 CFR 872.3770 Regulation Name: Temporary Crown and Bridge Resin Regulatory Class: Class II Product Code: EBG, PZY Dated: October 6, 2020 Received: October 7, 2020
Dear Patricia Kontoudis:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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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 mediation-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,
For Srinivas "Nandu" Nandkumar, Ph.D. 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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## Indications for Use
510(k) Number (if known) K201827
Device Name GR-17 Resin System
#### Indications for Use (Describe)
The GR-17 Resin System is a light-curable resin intended to be used in conjunction with extra-oral curing light equipment.
The GR-17 temporary is indicated for the fabrication, by additive manufacturing, of temporary anterior dental restorations.
The GR-17.1 temporary is indicated for the fabrication, by additive manufacturing, of temporary dental restorations, and for the fabrication, by additive manufacturing, of preformed denture teeth to be used in a denture.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <div> <span> <svg height="16" width="16"> <polygon points="0,0 0,16 16,16 16,0" style="fill:none;stroke:black;stroke-width:1"></polygon> <polyline points="2,8 6,12 14,4" style="fill:none;stroke:black;stroke-width:2"></polyline> </svg> </span> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div> <span> <svg height="16" width="16"> <polygon points="0,0 0,16 16,16 16,0" style="fill:none;stroke:black;stroke-width:1"></polygon> </svg> </span> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
| X | Prescription Use (Part 21 CFR 801 Subpart D)
| | Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary
| Device Trade Name | GR-17 Resin System<br>(GR-17 temporary and GR-17.1 temporary It) |
|--------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Pro3dure Medical GmbH<br>Am Burgberg 13<br>58642 Iserlohn<br>Germany |
| Contact | Dr. Martin Klare<br>Phone: +49 (0)2374 920050-11<br>Fax: +49 (0)2374 920050-50<br>martin.klare@pro3dure.com |
| Prepared by | Ms. Patricia Kontoudis<br>Specialist, Regulatory Affairs<br>Regulatory and Quality Solutions, LLC<br>2790 Mosside Blvd., Suite 800<br>Monroeville, PA 15146<br>Phone: (443)722-0126<br>pkontoudis@rqteam.com |
| Date Prepared | November 5, 2020 |
| Common Name | Crown and Bridge, Temporary, Resin |
| Classification Name | Temporary Crown and Bridge Resin |
| Regulation Number | 21 CFR 872.3770 |
| Regulatory Class | Class II |
| Product Codes | EBG |
| Subsequent Product Code | PZY |
| Primary Predicate Device | DeltaMed e-Dent Temporary Resin and Extra-Oral<br>Curing System (K102776) |
| Reference Device | Dentis Resin for Temporary Crown & Bridge<br>(K180657)<br>Dentca, Dentca Denture Teeth (K172398) |
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| Indications for Use | The GR-17 Resin System is a light-curable<br>polymerizable resin intended to be used in<br>conjunction with extra-oral curing light equipment.<br><br>The GR-17 temporary is indicated for the fabrication,<br>by additive manufacturing, of temporary anterior<br>dental restorations.<br><br>The GR-17.1 temporary is indicated for the<br>fabrication, by additive manufacturing, of<br>temporary dental restorations, and for the<br>fabrication, by additive manufacturing, of preformed<br>denture teeth to be used in a denture. |
|---------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Description | GR-17 Resin System includes the GR-17 temporary<br>and GR-17.1 temporary It and is made of functional<br>methacrylic resins and inorganic fillers with particle<br>sizes from 0.4 to 3 microns. It is available in seven<br>shades based on the shade guide, A1, A2, A3, A3.5,<br>B1, B2 and bleach. The resin is a liquid photo-<br>curable material that is polymerized by image<br>projection systems at 405nm to create temporary<br>dental restorations, and preformed denture teeth to<br>be used in a denture. The GR-17 Resin System is<br>intended to be used in conjunction with an additive<br>Computer-Aided Manufacturing (CAM) and curing<br>system such as Nyomo, Rapidshape, Envisiontec or<br>Asiga Systems. |
| Performance Testing | Performance testing for the GR-17 Resin System was<br>performed in accordance with ISO 10477 and ISO<br>22112. |
| Biocompatibility | Biocompatibility testing was conducted in<br>accordance with ISO 10993-1. |
| Shelf Life | The shelf life of the GR-17 Resin System is 2 year.<br>Testing was performed in accordance with ASTM<br>F1980-16. |
| | GR-17 Resin<br>System | Predicate Device:<br>e-Dent Temporary<br>Resin and Extra-<br>Oral Curing System | Reference Device:<br>Resin for<br>Temporary Crown<br>& Bridge | Reference<br>Device: Dentca<br>Denture Teeth |
|-------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Pro3dure Medical<br>GmbH | DeltaMed GmbH | Dentis Co. Ltd. | Dentca, Inc. |
| 510(k) Number | K201827 | K102776 | K180657 | K172398 |
| Indications for use | The GR-17 Resin System is a light-curable polymerizable resin intended to be used in conjunction with extra-oral curing light equipment. The GR-17 temporary is indicated for the fabrication, by additive manufacturing, of temporary anterior dental restorations. The GR-17.1 temporary It is indicated for the fabrication, by additive manufacturing, of temporary dental restorations, and for the fabrication, by additive manufacturing, of preformed denture teeth to be used in a denture. | The e-DENT TEMPORARY resin is indicated for the fabrication of temporary dental restorations in conjunction with extra-oral curing light equipment. | Resin for Temporary Crown & Bridge is indicated for the fabrication of temporary dental restorations in conjunction with extra-oral curing light equipment. Duration is less than 30 days in oral environment. | DENTCA Denture Teeth is a light-curable polymerizable resin to fabricate, by additive manufacturing, preformed denture teeth to be used in a denture. |
| Comparison: The GR-17 Resin System has similar indications as the predicate devices. | | | | |
| Chemical Description | Methacrylate- based resin | Methacrylate- based resin | Methacrylate- based resin | Methacrylate- based resin |
| Comparison: The GR-17 Resin System has similar chemical characterization as the predicate devices. | | | | |
| Acrylic Resin | Extra-oral light cure resin | Extra-oral light cure resin | Extra-oral light cure resin | Extra-oral light cure resin |
| Comparison: The GR-17 Resin System and the predicate devices are extra-oral light cure resins. | | | | |
| Curing Method | UV Light | UV Light | UV Light | UV Light |
| Comparison: The GR-17 Resin System uses the same curing method as the predicate devices. | | | | |
| Product State | Liquid | Liquid | Liquid | Liquid |
| Comparison: The GR-17 Resin System and the predicate devices are provided in liquid form. | | | | |
| Physical and Mechanical Properties | Flexural Strength<br>Modulus of Elasticity<br>Water Absorption<br>Solubility | Flexural Strength<br>Modulus of Elasticity<br>Water Absorption<br>Solubility | Not Available | Modulus of Elasticity<br>Water Absorption<br>Solubility |
| Comparison: The GR-17 Resin System and the predicate devices are equivalent physical and mechanical properties. | | | | |
| Manufacturing | Additive | Additive | Additive | Additive |
| Comparison: The GR-17 Resin System and the predicate devices use additive manufacturing to fabricate the final product. | | | | |
| Standards | ISO 10477<br>ISO 22112<br>ISO 4049 | ISO 10477<br>ISO 4049 | ISO 10477 | ISO 10477<br>ISO 22112 |
| Comparison: The GR-17 Resin System and the predicate devices comply with the same standards. | | | | |
| Biocompatibility | ISO 7405<br>ISO 10993 | ISO 10993 | ISO 10993 | ISO 7405<br>ISO 10993 |
| Comparison: The GR-17 Resin System and the predicate devices use biocompatible according to the same standards. | | | | |
## Comparison to Predicate
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Conclusion The GR-17 Resin System is substantially equivalent in indications, technical characteristics, function, material, performance, biocompatibility, and shelf life to the predicate and reference devices.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.