K222269 · Terrats Medical SL · NHA · Oct 26, 2022 · Dental
Device Facts
Record ID
K222269
Device Name
DESS Dental Smart Solutions
Applicant
Terrats Medical SL
Product Code
NHA · Dental
Decision Date
Oct 26, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3630
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations. All digitally designed custom abutments for use with DESS Bases or Blanks are to a Terrats Medical validated milling center for manufacture.
Device Story
DESS Dental Smart Solutions are dental implant abutments used to support prosthetic restorations (crowns, bridges). The system includes Multi Unit Abutments (straight, 17°, 30°), Ti Base and AURUM Base abutments (for CAD-CAM zirconia superstructures), and Premilled Blank Abutments. Inputs include patient-specific anatomical data captured via digital impression/scanning; these are processed at a Terrats Medical validated milling center to fabricate custom abutments or superstructures. The device is used in dental clinics by clinicians; the output is a custom-milled abutment or superstructure that attaches to the endosseous implant via an abutment screw. This provides a functional and esthetic interface for the final dental prosthesis. Benefits include patient-specific fit and restoration support. All components are provided non-sterile and require sterilization by the user.
Clinical Evidence
No clinical data included. Substantial equivalence is supported by bench testing, including static compression and compression fatigue testing per ISO 14801, biocompatibility testing per ISO 10993, and MR environment safety analysis.
Technological Characteristics
Materials: Ti-6Al-4V ELI (ASTM F136), Zirconia (ISO 13356). Surface: SelectGrip sandblasted or gold anodized. Components: Multi Unit, Ti Base, AURUM Base, Premilled Blanks. Connectivity: Compatible with specific OEM internal TiLobe, hex, and conical implant connections. Sterilization: Moist heat (non-sterile provided).
Indications for Use
Indicated for patients requiring prosthetic restoration support in the maxillary or mandibular arch using endosseous dental implants. Compatible with specific internal TiLobe, internal hex, and internal conical connection implant systems.
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 two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
Terrats Medical SL % Kevin Thomas Vice President & Director of Regulatory Affairs PaxMed International, LLC 12264 El Camino Real, Suite 400 San Diego, California 92130
Re: K222269
Trade/Device Name: DESS Dental Smart Solutions Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: July 28, 2022 Received: July 28, 2022
Dear Kevin Thomas:
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 (QS) 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.
Andrew I. Steen Assistant Director DHT1B: Division of Dental and ENT 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) K22269
Device Name
DESS Dental Smart Solutions
#### Indications for Use (Describe)
DESS Dental Smart Solutions abutnents are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
All digitally designed custom abutments for use with DESS Bases or Blanks are to a Terrats Medical validated milling center for manufacture.
| Compatible Implant System<br>(Connection) | Implant Body Diameter, mm | Implant Platform |
|-------------------------------------------------------|---------------------------|------------------------|
| PRIMA CONNEX<br>(Internal TiLobe, Tapered & Straight) | 3.3, 3.5 | 3.5 |
| | 4.0, 4.1 | 4.1 |
| | 5.0 | 5.0 |
| GENESIS<br>(Internal TiLobe) | 3.5, 3.8 | 3.5/3.8 |
| | 4.5 | 4.5 |
| | 5.5, 6.5 | 5.5/6.5 |
| MOLARIS TILOBEMAXX<br>(Internal TiLobe) | 7 | 5.7 |
| | 8 | 6.5 |
| | 9 | 7.5 |
| MOLARIS I-HEXMRT<br>(Internal Hex) | 7 | 5.7 |
| | 8 | 6.5 |
| | 9 | 7.5 |
| PALTOP ADVANCED CLASSIC<br>(Internal Hex) | 3.25 | NP (3.25) |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) |
| PALTOP ADVANCED PLUS<br>(Internal Hex) | 3.0, 3.25 | NP (3.25) |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) |
| | 6.0 | WP (6.0) |
| PALTOP DYNAMIC<br>(Internal Hex) | 3.0, 3.25 | NP (3.25) |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) |
| | 6.0 | WP (6.0) |
| PALTOP DYNAMIC CONICAL<br>(Internal Conical) | 3.25, 3.75, 4.2, 5.0 | CC (3.25/3.75/4.2/5.0) |
#### Compatible Implant Systems
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary K22269 Terrats Medical SL DESS® Dental Smart Solutions
October 25, 2022
#### ADMINISTRATIVE INFORMATION
| Manufacturer Name | Terrats Medical SL<br>Carrer Mogoda, 75-99<br>08210 Barberà del Vallès<br>Barcelona, Spain |
|---------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Telephone | +34 935 646 006 |
| Official Contact | Roger Terrats, CEO |
| Representative/Consultant | Kevin A. Thomas, PhD<br>Floyd G. Larson, MS, MBA<br>PaxMed International, LLC<br>12264 El Camino Real, Suite 400<br>San Diego, CA 92130<br>Telephone +1 858-792-1235<br>Fax +1 858-792-1236<br>Email kthomas@paxmed.com<br>flarson@paxmed.com |
#### DEVICE NAME AND CLASSIFICATION
| Trade/Proprietary Name | DESS Dental Smart Solutions |
|------------------------|---------------------------------------------------------------------------------------------|
| Common Name | Dental implant abutment |
| Regulation Number | 21 CFR 872.3630 |
| Regulation Name | Endosseous dental implant abutment |
| Regulatory Class | Class II |
| Product Code | NHA |
| Classification Panel | Dental |
| Reviewing Office | Office of Health Technology 1 (Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices) |
| Reviewing Division | Division of Dental and ENT Devices |
#### PREDICATE DEVICE INFORMATION
Primary Predicate Device K212628, DESS Dental Smart Solutions, Terrats Medical SL
Reference Devices K212577, DESS Dental Smart Solutions, Terrats Medical SL K191986, DESS Dental Smart Solutions, Terrats Medical SL K173908, DESS Dental Smart Solutions, Terrats Medical SL K201334, Keystone Dental XL Dental Implant System, Keystone Dental, Inc.
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K051614, PrimaConnex™ Internal Connection Implant System, Lifecore Biomedical, Inc. K072768, Restore®, Stage-19, Renova®, PrimaConnex® Dental Implants, Lifecore Biomedical, Inc. K101545, Genesis Implant System, Keystone Dental, Inc. K112795, Paltop Dental Implant System, Paltop Advanced Dental Solutions Ltd. K210117, Paltop Narrow Implant, Paltop Advanced Dental Solutions, Ltd. K220200, Paltop Conical Implant System, Paltop Advanced Dental Solutions, Ltd.
## INDICATIONS FOR USE STATEMENT
DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
All digitally designed custom abutments for use with DESS Bases or Blanks are to be sent to a Terrats Medical validated milling center for manufacture.
| Compatible Implant System<br>(Connection) | Implant Body Diameter, mm | Implant Platform |
|-------------------------------------------------------|---------------------------|------------------------|
| PRIMA CONNEX<br>(Internal TiLobe, Tapered & Straight) | 3.3, 3.5 | 3.5 |
| | 4.0, 4.1 | 4.1 |
| | 5.0 | 5.0 |
| GENESIS<br>(Internal TiLobe) | 3.5, 3.8 | 3.5/3.8 |
| | 4.5 | 4.5 |
| | 5.5, 6.5 | 5.5/6.5 |
| MOLARIS TILOBEMAXX<br>(Internal TiLobe) | 7 | 5.7 |
| | 8 | 6.5 |
| | 9 | 7.5 |
| MOLARIS I-HEXMRT<br>(Internal Hex) | 7 | 5.7 |
| | 8 | 6.5 |
| | 9 | 7.5 |
| PALTOP ADVANCED CLASSIC<br>(Internal Hex) | 3.25 | NP (3.25) |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) |
| PALTOP ADVANCED PLUS<br>(Internal Hex) | 3.0, 3.25 | NP (3.25) |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) |
| | 6.0 | WP (6.0) |
| PALTOP DYNAMIC<br>(Internal Hex) | 3.0, 3.25 | NP (3.25) |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) |
| | 6.0 | WP (6.0) |
| PALTOP DYNAMIC CONICAL<br>(Internal Conical) | 3.25, 3.75, 4.2, 5.0 | CC (3.25/3.75/4.2/5.0) |
### Compatible Implant Systems
# SUBJECT DEVICE DESCRIPTION
The purpose of this submission is to add components to the DESS Dental Smart Solutions system, which includes abutments cleared previously in K170588, K173908, K191986, K203464, K212577, and K212628. This submission adds various abutments to eight (8) OEM implant lines from Keystone Dental, Inc., having three (3) implant-abutment connections (Internal TiLobe, Internal Conical). The subject device abutment
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designs include Multi Unit Abutments (straight and angled 17° and 30°), Ti Base abutments, and Premilled Blank Abutments. Abutments are provided with the appropriate abutment screw (if applicable) for attachment to the corresponding implant, and the appropriate prosthetic screw (if applicable) for attachment of a screw-retained prosthesis. All abutments and screws are provided non-sterile.
A summary of the subject device abutment designs and the compatible OEM implants is provided in the table Summary of Subject Device Abutment Designs and Compatible Implants on the following page.
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# Summary of Subject Device Abutment Designs and Compatible Implants
| Connection | Compatible Implant Systems | Implant Body Ø, mm | Implant Platform Ø, mm | Multi Unit<br>Straight and 17° Angled | Multi Unit<br>30° Angled | Subject Device Abutments | | |
|------------------|-----------------------------------------------------------------------------|----------------------|------------------------|---------------------------------------|--------------------------|--------------------------|-------------|------------------|
| | | | | | | Ti Bases | AURUM Bases | Premilled Blanks |
| Internal TiLobe | PRIMA CONNEX<br>(Internal TiLobe, Tapered & Straight)<br>K051614<br>K072768 | 3.3, 3.5 | 3.5 | X | X | X | X | X |
| | 4.0, 4.1 | 4.1 | X | X | X | X | X | |
| | 5.0 | 5.0 | X | X | X | X | X | |
| | GENESIS<br>(Internal TiLobe)<br>K101545 | 3.5, 3.8 | 3.5/3.8 | X | X | X | X | X |
| | 4.5 | 4.5 | X | X | X | X | X | |
| | 5.5, 6.5 | 5.5/6.5 | X | X | X | X | X | |
| | MOLARIS TILOBEMAXX<br>(Internal TiLobe)<br>K201334 | 7 | 5.7 | X | | X | | X |
| | 8 | 6.5 | X | | X | | X | |
| | 9 | 7.5 | X | | X | | X | |
| | MOLARIS I-HEXMRT<br>(Internal Hex)<br>K201334 | 7 | 5.7 | X | | X | | X |
| | 8 | 6.5 | X | | X | | X | |
| | 9 | 7.5 | X | | X | | X | |
| Internal Hex | PALTOP ADVANCED CLASSIC<br>(Internal Hex)<br>K112795 | 3.25 | NP (3.25) | X | | X | X | X |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) | X | X | X | X | X | |
| | PALTOP ADVANCED PLUS<br>(Internal Hex)<br>K210117 | 3.0, 3.25 | NP (3.25) | X | | X | X | X |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) | X | X | X | X | X | |
| | 6.0 | WP (6.0) | X | | X | X | X | |
| | PALTOP DYNAMIC<br>(Internal Hex)<br>K112795 | 3.0, 3.25 | NP (3.25) | X | | X | X | X |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) | X | X | X | X | X | |
| | 6.0 | WP (6.0) | X | | X | X | X | |
| Internal Conical | PALTOP DYNAMIC CONICAL<br>(Internal Conical)<br>K220200 | 3.25, 3.75, 4.2, 5.0 | CC (3.25/3.75/4.2/5.0) | X | X | X | X | X |
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The design dimensions and tolerances of subject device abutments and screws have been established on the basis of a contractual agreement and working relationship between Keystone Dental, Inc., and Terrats Medical SL to ensure that the abutments are designed to fit the corresponding Keystone Dental implants listed above.
### Multi Unit Abutments
The Multi Unit Abutment is designed for attachment of multi-unit screw-retained restorations and is provided in three (3) designs, straight, angled 17°, and angled 30°. The straight Multi Unit Abutment is provided only in a non-engaging, threaded design that attaches directly to the implant, with a prosthetic platform diameter of 4.8 mm or 6.0 mm, and with a gingival height ranging from 1 mm to 5 mm. Straight Multi Unit Abutments are provided for all eight (8) compatible OEM implant lines. The angled Multi Unit Abutments are provided only in an engaging design that requires an abutment screw, with a prosthetic platform diameter of 4.8 mm, and with a gingival height ranging from 2.5 mm. The Multi Unit Abutments angled 30° are provided with a prosthetic platform diameter of 4.8 mm, and with a gingival height ranging from 3 mm to 5 mm. The Multi Unit Abutments angled 17° are provided for all eight (8) compatible OEM implant lines, and the Multi Unit Abutments angled 30° are provided for six (6) compatible OEM implant lines.
### Ti Base and AURUM Base Abutments
Ti Base and AURUM Base abutments are designed for patient-specific abutment fabrication of a CAD-CAM zirconia superstructure on which a crown may be placed. They also may be used for support of a crown placed directly on the abutment. The cement recommended for bonding of superstructures is Multi-Link cement by Ivoclar Vivadent (K130436). All patient-specific abutment fabrication for Ti Base and AURUM Base abutments is by prescription on the order of the clinician. All zirconia superstructures for use with the subject device Ti Base and AURUM Base abutments will be made at a Terrats Medical milling center under FDA quality system regulations, and the material will conform to ISO 13356.
The Ti Bases and AURUM Bases are used as part of a two piece abutment. where the base is premanufactured from titanium alloy (Ti-6Al-4V ELI) and the top half is a CAD-CAM zirconia superstructure, milled at a validated milling center. These pieces are cemented together to form the final abutment.
Ti Base abutments are provided in engaging design and non-engaging designs for all eight (8) compatible OEM implant lines. Ti Base abutments are provided with a prosthetic platform diameter ranging from 4.1 mm to 7.0 mm, and a gingival height ranging from 1 mm to 3 mm. The prosthetic post height is 4.2 mm for all Ti Base abutments. Ti Base Abutments are manufactured from titanium alloy with a sandblasted surface treatment process (SelectGrip®) to aid in bonding retention of a cemented prosthesis. When used for a direct crown, Ti Base Interface may be used with a POM burn out sleeve, an exempt laboratory component not a subject of this submission, that is available for laboratory fabrication of the prosthesis.
The design parameters for the CAD-CAM zirconia superstructure, or traditional laboratory fabrication such as precious or non-precious cast, to be used on Ti Base Abutments are:
Minimum wall thickness – 0.4 mm
Minimum post height for single-unit restoration - 4.2 mm
Minimum gingival height - 0.5 mm
Maximum gingival height - 6.0 mm
All zirconia superstructures and PFM crowns for use with the titanium bases are for straight restorations only.
AURUM Base Abutments are provided in engaging design and non-engaging designs for six (6) compatible OEM implant lines. The design of the AURUM Base allows for easier instrument access to the abutment screw (up to 25° of instrument angulation) and allows for placement of the screw channel out of the esthetic region of the restoration. AURUM Base abutments are provided with a prosthetic platform diameter ranging from 4.1 mm to 6.0 mm, and a gingival height of 1 mm. Before attachment of the zirconia superstructure or crown, the AURUM
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Base prosthetic post height is 3.0 mm. When used for a single-unit restoration the AURUM Base is to be used with a superstructure to create a minimum post height of 4.0 mm.
AURUM Base Abutments are manufactured from titanium alloy (Ti-6A1-4V) and are colored gold by an anodization process in which the abutment is submerged in an electrolytic solution and exposed to an electric current to achieve the gold color.
The design parameters for the CAD-CAM zirconia superstructure, or traditional laboratory fabrication such as precious or non-precious cast, to be used on AURUM Base Abutments are:
Minimum wall thickness – 0.4 mm Minimum post height for single-unit restoration – 4.0 mm Minimum gingival height - 0.5 mm Maximum gingival height - 6.0 mm All zirconia superstructures and PFM crowns for use with the AURUM bases are for straight restorations only.
### Premilled Blank Abutments
Premilled Blank Abutments are available in engaging designs only, for all eight (8) compatible OEM implant lines. All patient-specific abutment fabrication of Premilled Blank Abutments is by prescription on the order of the clinician, and will be done at a Terrats Medical validated milling center under FDA quality system regulations. The Premilled Blank Abutments have a maximum (before milling) diameter of 10 mm or 14 mm.
The design parameters for the CAD-CAM fabrication of patient-specific abutments from Premilled Blank Abutments are:
Minimum wall thickness - 0.45 mm Minimum post height for single-unit restoration - 4.0 mm Minimum gingival height - 0.5 mm Maximum gingival height - 6.0 mm Pre-Milled Blanks are for straight abutments only
#### Screws
This submission includes ten (10) abutment screws to be used with the subject device abutments, and seven (7) prosthetic screws to be used with the subject device Multi Unit abutments. The screws have hex, hexalobular, or square drive instrument interfaces and are manufactured from titanium alloy (Ti-6Al-4V) with the Diamond-like Carbon (DLC) coating.
### MATERIAL COMPOSITION
All subject device abutments, abutment screws, and prosthetic screws are manufactured from Ti-6A1-4V alloy conforming to ASTM F136. Abutment screws and prosthetic screws manufactured from ASTM F136 titanium alloy and coated with Diamond-like carbon (DLC) are provided to attach the abutments to the implant and to attach the attach the restoration to the abutment. The titanium alloy and DLC coating are identical to the material and coating used to manufacture DESS Dental Smart Solutions screws cleared in K212628, K212577, and K173908.
Ti Base Abutments have a sandblasted surface finish (SelectGrip®). This surface is identical to the surface used on DESS Dental Smart Solutions components cleared in K212628. The anodization process used for the subject AURUM Abutments is identical to the anodization treatment used to manufacture DESS Aurum Abutments cleared in K212628 and K173908.
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All superstructures for use with the CAD-CAM abutments (Ti Bases and AURUM Bases) will be manufactured from zirconia conforming to ISO 13356. This material is identical to the zirconia material to be used to manufacture superstructures for DESS Dental Smart Solutions components cleared in K212628 and K173908.
## PERFORMANCE DATA
Non-clinical data submitted, referenced, or relied upon to demonstrate substantial equivalence included:
sterilization validation according to ISO 17665-1 and ISO 17665-2, referenced from K212628;
biocompatibility according to ISO 10993-5 and ISO 10993-12. referenced from K212628;
non-clinical analysis performed to evaluate the metallic subject devices in the MR environment using scientific rationale and published literature (TO Woods, JG Delfino, "Assessment of Magnetically Induced Displacement Force and Torque on Metal Alloys Used in Medical Devices," Journal of Testing and Evaluation, Volume 49, No. 2, 2021, pp. 783-795); the analysis addressed parameters per the FDA guidance Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment (issued May 2021) including magnetically induced displacement force and torque; and
static compression and compression fatigue testing of worst-case constructs comprising the subject device Multi Unit Angled Abutments and compatible OEM implants in conformance with ISO 14801.
No clinical data were included in this submission.
# EQUIVALENCE TO MARKETED DEVICES
The subject device abutments are substantially equivalent in intended use to the primary predicate device cleared in K212628 and the additional predicate devices cleared in 212577 and K173908. All are intended for use with endosseous dental implants in the maxilla and mandible to provide functional and esthetic rehabilitation of the edentulous maxilla and mandible. The Indications for Use Statement (IFUS) for the subject device is substantially equivalent to that of K212628, K212577, and K173908, except for the list of compatible OEM implants.
Differences between the subject device IFUS and that of the additional predicate K201334 include additional language in K201334 describing the use of the dental implants that is not applicable to the subject device abutments. The IFUS for K201334 does include language regarding support of dental prostheses that is similar to that of the subject device.
All subject device abutments are similar or identical in design, materials and technological characteristics to corresponding abutments of the primary predicate device K212628 and the additional predicate devices K212577, and K173908. In some cases, the abutments vary slightly from the subject device to the previous submissions (K212628, K212577, and K173908).
The SelectGrip® surface on the subject device Ti Base Abutments is identical to the Select Grip® surface on equivalent abutments cleared in K212628 and K173908. The gold anodized surface on the subject device AURUM Base Abutments is identical to the anodized surface on Aurum Abutments of the predicate devices K212628 and K173908.
The cement recommended in labeling for bonding of superstructures is Multi-Link cement from Ivoclar Vivadent, cleared under K130436. This is the same cement recommended in labeling for the primary predicate device K212628 and the additional predicate device K173908.
All screws are identical in design, materials and technological characteristics to those cleared in predicate devices K212628, K212577, and K173908, except for threads and lengths that accommodate the new compatibilities. The
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510(k) Summary Page 8 of 14
Diamond-like carbon (DLC) coating applied to all screws is identical to the DLC coating on screws cleared in K212628, K212577, and K173908.
The range of dimensions of the subject device abutments are encompassed by the corresponding predicate devices. including the abutment-implant platform diameter, prosthetic platform diameter, gingival height, and abutment angulation. The additional predicate device K212577 includes Premilled Blank abutments designs with up to 30° of angulation, which is the maximum angulation of the subject Multi Unit Abutments. The additional predicate device K201334, in addition to the implant compatibilities, is for substantial equivalence of the implantabutment platform diameter (up to 7.5 mm) and abutment prosthetic platform diameter (up to 7 mm).
All subject device components are provided non-sterile and are to be sterilized by the same moist heat cycle recommended in the predicate submissions K212628, K212577, and K173908. The subject devices are packaged in either a PETG blister pack or a PET bag, the same packaging as cleared in K212628, K212577, and K173908.
The risks associated with use of the subject device Angled Multi Unit Abutments in combination with the compatible implants are mitigated by the mechanical testing provided in Section 18 Performance Testing -Bench.
### CONCLUSION
The subject device, the primary predicate device, and the additional predicate devices have intended use, have similar technological characteristics, and are materials. The subject device, the primary predicate, and additional predicate devices encompass the same range of physical dimensions, are packaged in similar materials, and are to be sterilized using similar methods. The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.
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| Table of Substantial Equivalence - Indications for Use Statement | |
|------------------------------------------------------------------|--|
|------------------------------------------------------------------|--|
| Subject Device | Indications for Use Statement | | |
|----------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------|-----------------------|
| DESS Dental Smart<br>Solutions<br><br>Terrats Medical SL | DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental<br>implants in the maxillary or mandibular arch to provide support for prosthetic restorations.<br><br>All digitally designed custom abutments for use with DESS Bases or Blanks are to be sent to a Terrats<br>Medical validated milling center for manufacture. | | |
| <b>Compatible Implant Systems</b> | | | |
| Compatible Implant System<br>(Connection) | Implant Body Diameter, mm | Implant Platform | |
| PRIMA CONNEX<br>(Internal TiLobe, Tapered & Straight) | 3.3, 3.5 | 3.5 | |
| | 4.0, 4.1 | 4.1 | |
| | 5.0 | 5.0 | |
| GENESIS<br>(Internal TiLobe) | 3.5, 3.8 | 3.5/3.8 | |
| | 4.5 | 4.5 | |
| | 5.5, 6.5 | 5.5/6.5 | |
| MOLARIS TILOBEMAXX<br>(Internal TiLobe) | 7 | 5.7 | |
| | 8 | 6.5 | |
| | 9 | 7.5 | |
| MOLARIS I-HEXMRT<br>(Internal Hex) | 7 | 5.7 | |
| | 8 | 6.5 | |
| | 9 | 7.5 | |
| PALTOP ADVANCED CLASSIC<br>(Internal Hex) | 3.25 | NP (3.25) | |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) | |
| PALTOP ADVANCED PLUS<br>(Internal Hex) | 3.0, 3.25 | NP (3.25) | |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) | |
| | 6.0 | WP (6.0) | |
| PALTOP DYNAMIC<br>(Internal Hex) | 3.0, 3.25 | NP (3.25) | |
| | 3.75, 4.2, 5.0 | SP (3.75/4.2/5.0) | |
| | 6.0 | WP (6.0) | |
| PALTOP DYNAMIC CONICAL<br>(Internal Conical) | 3.25, 3.75, 4.2, 5.0 | CC (3.25/3.75/4.2/5.0) | |
| Primary Predicate<br>Device<br>K212628 | DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental<br>implants in the maxillary or mandibular arch to provide support for prosthetic restorations. | | |
| | All digitally designed custom abutments for use with DESS Bases or Blanks are to be sent to a Terrats<br>Medical validated milling center for manufacture. | | |
| DESS Dental Smart<br>Solutions | Compatible Implant Systems | | |
| Terrats Medical SL | Compatible Implant System | Implant Body Diameter, mm | Implant Platform Name |
| | | 3.0 | 3.0 |
| | | 3.6 | 3.6 |
| | Astra Tech EV | 4.2 | 4.2 |
| | | 4.8 | 4.8 |
| | | 5.4 | 5.4 |
| | | 3.0 | 3.0 |
| | Astra Tech OsseoSpeed™ | 3.5/4.0 | 3.5/4.0 |
| | | 4.5/5.0 | 4.5/5.0 |
| | | 3.0, 3.4, 3.8 | 3.0 |
| | BioHorizons | 3.8, 4.6 | 3.5 |
| | | 4.6, 5.8 | 4.5 |
| | | 5.8 | 5.7 |
| | | 3.25 | 3.4 |
| | Biomet 3i Certain® | 4.0 | 4.1 |
| | | 5.0 | 5.0 |
| | | 3.25 | 3.4 |
| | Biomet 3i OSSEOTITE® | 3.75, 4.0 | 4.1 |
| | | 5.0 | 5.0 |
| | | 3.8 | 3.8 |
| | Camlog | 4.3 | 4.3 |
| | | 5.0 | 5.0 |
| | | 3.8 | 3.8 |
| | FRIADENT XIVE® | 4.5 | 4.5 |
| | | 5.5 | 5.5 |
| | Neodent Grand Morse | 3.5, 3.75, 4.0, 4.3, 5.0, 6.0, 7.0 | Grand Morse (GM) |
| | NobelActive®, NobelParallel<br>Conical | 3.0 | 3.0 |
| | | 3.5 | NP |
| | | 4.3, 5.0 | RP |
| | | 4.3 | RP |
| | NobelReplace® Trilobe | 5.0 | WP |
| | | 6.0 | 6.0 |
| | | 3.3 | NP |
| | Nobel Brånemark System® | 3.75, 4.0 | RP |
| | | 3.5 | Mini |
| | Osstem TS | 4.0, 4.5, 5.0, 6.0, 7.0 | Regular |
| | | 3.5, 3.75, 4.0, 4.5 | RB |
| | Straumann BLX | 5.0, 5.5, 6.5 | WB |
| | | 3.3 | NC |
| | Straumann® Bone Level | 4.1/4.8 | RC |
| | Straumann® Tissue Level | 3.3 | NNC |
| | | 3.3, 3.7, 4.1 | 3.5 |
| | Zimmer Screw Vent®/ Tapered<br>Screw-Vent® | 4.7 | 4.5 |
| | | 6.0 | 5.7 |
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#### 510(k) Summary Page 10 of 14
{13}------------------------------------------------
| K212577 | | DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental<br>implants in the maxillary or mandibular arch to provide support for prosthetic restorations. | | | | |
|--------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------|--|--|--|
| DESS Dental Smart<br>Solutions | All digitally designed custom abutments for use with Pre-milled Blank are to be sent to a Terrats Medical<br>validated milling center for manufacture. | | | | | |
| | | Compatible Implant Systems | | | | |
| Terrats Medical SL | Compatible Implant System | Implant Body Diameter, mm | Implant Platform | | | |
| | NobelActive®, NobelParallel | 3.5 | NP | | | |
| | Conical | 4.3, 5.0<br>ર .5 | RP<br>WP | | | |
| | | 3.3 | NC | | | |
| | Straumann® Bone Level | 4.1/4.8 | RC | | | |
| | | 3.7, 4.1 | 3.5 | | | |
| | Zimmer Screw-Vent® / Tapered | 4.7 | 4.5 | | | |
| | Screw-Vent® | 6.0 | 5.7 | | | |
| Reference Device | | DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental | | | | |
| K173908 | | implants in the maxillary or mandibular arch to provide support for prosthetic restorations. | | | | |
| | | All digitally designed custom abutments for use with Aurum™ Abutment or Pre-milled Blank are to be sent to | | | | |
| DESS Dental Smart<br>Solutions | a Terrats Medical validated milling center for manufacture. | Compatible Implant Systems | | | | |
| Terrats Medical SL | Implant System Compatibility | Implant Body | Implant Platform | | | |
| | 3i Certain® | 3.25, 4.0, 5.0 | 3.4, 4.1, 5.0 | | | |
| | 3i OSSEOTITE® | 3.25, 3.75, 4.0, 5.0 | 3.4, 4.1, 5.0 | | | |
| | OsseoSpeed™ | 3.5, 4.0, 5.0…
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.