DESS Multi-Unit Abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
Device Story
DESS Dental Smart Solutions are dental implant abutments used to support multi-unit screw-retained prosthetic restorations (bridges/bars). The system includes straight, 17° angled, and 30° angled abutments with corresponding screws. These components attach to specific Implant Direct internal hex and internal conical dental implants. Used in dental clinics by clinicians; the abutments are provided non-sterile and require sterilization before use. The device provides a mechanical interface between the endosseous implant and the final prosthetic restoration, facilitating functional and esthetic rehabilitation for edentulous patients.
Clinical Evidence
No clinical data included. Substantial equivalence supported by bench testing: static compression and compression fatigue testing per ISO 14801, biocompatibility per ISO 10993-5/12, and MR environment safety analysis.
Technological Characteristics
Materials: Titanium alloy (Ti-6Al-4V ELI) per ASTM F136. Designs: Straight, 17°, and 30° angled multi-unit abutments. Interface: Internal hex and internal conical connections. Provided non-sterile; requires moist heat sterilization. Mechanical testing per ISO 14801.
Indications for Use
Indicated for patients requiring prosthetic restoration support in the maxillary or mandibular arch using endosseous dental implants. Compatible with specific Implant Direct internal hex and internal conical 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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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: K230143
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: January 17, 2023 Received: January 18, 2023
## 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 -S
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
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.
K230143 510(k) Number (if known)
Device Name
DESS Dental Smart Solutions
Indications for Use (Describe)
DESS Multi-Unit Abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
| Compatible Implant Systems | Implant Body Ø, mm | Implant Platform Ø, mm |
|---------------------------------------------------------|--------------------|------------------------|
| Internal Hex Connection | | |
| Legacy1 | 3.7 | 3.5 |
| | 4.2 | 3.5 |
| | 4.7 | 4.5 |
| Legacy2, simplyLegacy2, Legacy3, simplyLegacy3, Legacy4 | 3.7 | 3.5 |
| | 4.2 | 3.5 |
| | 4.7 | 4.5 |
| | 5.2 | 4.5 |
| Internal Conical Connection | | |
| InterActive | 3.2 | 3.0 |
| | 3.7 | 3.0 |
| | 4.3 | 3.4 |
| | 5.0 | 3.4 |
| Simply Iconic™ | 3.2 | 3.0 |
| | 3.7 | 3.0 |
| | 4.2 | 3.0 |
| | 4.7 | 3.0 |
| | 4.7 | 3.4 |
| | 5.2 | 3.4 |
| | 5.7 | 3.4 |
#### Compatible Implant Systems
Type of Use (Select one or both, as applicable)
× Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary K231043 Terrats Medical SL DESS® Dental Smart Solutions February 27, 2023
#### ADMINISTRATIVE INFORMATION
| Manufacturer Name | Terrats Medical SL |
|---------------------------|------------------------------------------------|
| | Carrer Mogoda, 75-99 |
| | Barberà del Vallès 08210 |
| | Barcelona, Spain |
| Telephone | +34 935 646 006 |
| Official Contact | Roger Terrats, CEO |
| Representative/Consultant | Kevin A. Thomas, PhD |
| | Floyd G. Larson, MS, MBA |
| | PaxMed International, LLC |
| | 12264 El Camino Real, Suite 400 |
| | San Diego, CA 92130 |
| | Telephone +1 858-792-1235 |
| | Fax +1 858-792-1236 |
| | 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 K222269, DESS Dental Smart Solutions, Terrats Medical SL
Reference Devices K061319, Spectra Dental Implant System, Implant Direct, LLC K192221, Legacy2, Legacy3, Legacy4, simplyLegacy2, simplyLegacy3 dental implants; Legacy3, Legacy4 fixture-mounts, Implant Direct Sybron Manufacturing, LLC K130572, InterActive / SwishPlus 2 Implant System, Implant Direct Sybron Manufacturing LLC K201553, Simply Iconic™ Implants, Implant Direct Sybron Manufacturing LLC
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#### INDICATIONS FOR USE STATEMENT
DESS Multi-Unit Abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
| Compatible Implant Systems | Implant Body Ø, mm | Implant Platform Ø, mm |
|---------------------------------------------------------|--------------------|------------------------|
| Internal Hex Connection | | |
| Legacy1 | 3.7 | 3.5 |
| | 4.2 | 3.5 |
| | 4.7 | 4.5 |
| Legacy2, simplyLegacy2, Legacy3, simplyLegacy3, Legacy4 | 3.7 | 3.5 |
| | 4.2 | 3.5 |
| | 4.7 | 4.5 |
| | 5.2 | 4.5 |
| Internal Conical Connection | | |
| InterActive | 3.2 | 3.0 |
| | 3.7 | 3.0 |
| | 4.3 | 3.4 |
| | 5.0 | 3.4 |
| Simply Iconic™ | 3.2 | 3.0 |
| | 3.7 | 3.0 |
| | 4.2 | 3.0 |
| | 4.7 | 3.0 |
| | 4.7 | 3.4 |
| | 5.2 | 3.4 |
| | 5.7 | 3.4 |
#### 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, K212577, K212628, K222269, and K22288. These previously cleared abutments are compatible with a variety of original equipment manufacturers (OEM) of dental implants. This submission adds abutments for implant lines from Implant Direct Sybron Manufacturing LLC (hereinafter, Implant Direct). The subject device abutments are compatible with various Implant Direct internal hex and internal conical implant bodies. The subject device abutments include Multi-Unit Abutments in straight, 17° angled, and 30° angled designs. All abutments are provided with the appropriate abutment screw (ff applicable) for attachment to the corresponding implant. All abutments and screws are provided non-sterile. The subject device is only intended for multi-unit restorations such as bridges and bars.
A summary of the subject device abutment designs and the compatible OEM implants is provided in the table Summary of Subject Device Multi-Unit Abutment Designs on the following page.
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| Connections | Subject Device<br>Multi-Unit Abutments | Implant-Abutment<br>Platform Ø, mm | Gingival<br>Height, mm | Compatible<br>Implant Direct<br>Implant Lines |
|------------------|----------------------------------------|------------------------------------|------------------------|----------------------------------------------------------------------------|
| | | | | |
| Internal hex | Straight | 3.5 | 1 – 5 | Legacy1<br>Legacy2<br>simplyLegacy2<br>Legacy3<br>simplyLegacy3<br>Legacy4 |
| | Straight | 4.5 | 1 - 3 | |
| | 17° Angled | 3.5 | 2.5, 3.5 | |
| | 17° Angled | 4.5 | 2.5, 3.5 | |
| | 30° Angled | 3.5 | 3.5, 4.5 | |
| | 30° Angled | 4.5 | 3.5, 4.5 | |
| Internal conical | Straight | 3.0 | 1.5 – 3.5 | InterActive<br>Simply Iconic™ |
| | Straight | 3.4 | 1.5 – 4.5 | |
| | 17° Angled | 3.0 | 2.5, 3.5 | |
| | 17° Angled | 3.4 | 2.5, 3.5 | |
| | 30° Angled | 3.0 | 3.5, 4.5 | |
| | 30° Angled | 3.4 | 3.5, 4.5 | |
#### Summary of Subject Device Multi-Unit Abutment Designs
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 Implant Direct and Terrats Medical SL to ensure that the abutments are designed to fit the corresponding Implant Direct 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 design of the straight Multi-Unit Abutments is similar to that of straight Multi-Unit Abutments cleared in K222269 with the exception of the implant connections and platform diameters. The straight Multi-Unit Abutment is provided only in a non-engaging, threaded design that attaches directly to the implant. All straight Multi-Unit Abutments are provided with a prosthetic platform diameter of 4.8 mm. Straight Multi-Unit Abutments are provided for Implant Direct internal hex implants with 3.5 mm and 4.5 mm platform diameters, and for Implant Direct internal conical implants with 3.0 mm platform diameters. The gingival height of the straight Multi-Unit Abutment ranges from 1.5 mm to 5.5 mm.
The angled Multi-Unit Abutments are provided in an engaging design that requires an abutment screw, with angulations of 17° and 30°. The angled Multi-Unit Abutments are provided for the same Implants as the straight Multi-Unit Abutments (internal hex implants with 3.5 mm platform diameters, and internal conical implants with 3.0 mm and 3.4 mm platform diameters). All angled Multi-Unit Abutments are provided with a prosthetic platform diameter of 4.8 mm, and with gingival heights from 2.5 mm. The designs of the angled Multi-Unit Abutments are similar to those of the angled Multi-Unit Abutments cleared in K222269. All Multi-Unit Abutments are manufactured from titanium alloy (Ti-6Al-4V) conforming to ASTM F136.
#### Screws
This submission includes three (3) abutment screws to be used with the subject device abutments. The screws have a hex or hexalobular instrument interface and are manufactured from titanium alloy (Ti-6A1-4V) conforming to ASTM F136.
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## 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 K22269;
biocompatibility according to ISO 10993-5 and ISO 10993-12, referenced from K22269;
non-clinical analysis performed to evaluate the metallic subject devices and compatible dental implants in the MR environment using scientific rationale and published literature (TO Woods, JG Delfino, and S Rajan, "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 K222269. 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 K222269, except for the list of compatible OEM implants. An additional difference between the IFUS of the subject device and that of the primary predicate K22269 is the language in K22269 describing the requirement of a validated milling center for CAD-CAM abutments. This language is not applicable to the subject device abutments. All reference devices identified are for OEM implant body compatibilities.
The range of dimensions of the subject device abutment-implant platform diameter, prosthetic platform diameter, gingival height, and abutment angulation, is encompassed by the corresponding multiunit abutments in the primary predicate device K222269.
All subject device components are provided non-sterile and are to be sterilized by the same moist heat cycle recommended in the primary predicate K222269. The subject devices are packaged in either a PETG blister pack or a PET bag, the same packaging as cleared in K222269.
The risks associated with use of the subject device angled multi-unit abutments in combination with the compatible implants are mitigated by mechanical testing performed according to ISO 14801.
#### CONCLUSION
The subject device, the primary predicate device, and the reference devices have the same intended use, have similar technological characteristics, and are materials. The subject device and the primary predicate device 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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| Indications for Use Statement | | | |
|----------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|------------------------|
| Subject Device | DESS Multi-Unit Abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations. | | |
| K231043 | Compatible Implant Systems | | |
| DESS Dental Smart Solutions | Compatible Implant Systems | Implant Body Ø, mm | Implant Platform Ø, mm |
| Terrats Medical SL | Internal Hex Connection | | |
| | Legacy1 | 3.7 | 3.5 |
| | | 4.2 | 3.5 |
| | | 4.7 | 4.5 |
| | Legacy2, simplyLegacy2,<br>Legacy3, simplyLegacy3,<br>Legacy4 | 3.7 | 3.5 |
| | | 4.2 | 3.5 |
| | | 4.7 | 4.5 |
| | | 5.2 | 4.5 |
| | Internal Conical Connection | | |
| | | 3.2 | 3.0 |
| | | 3.7 | 3.0 |
| | InterActive | 4.3 | 3.4 |
| | | 5.0 | 3.4 |
| | | 3.2 | 3.0 |
| | | 3.7 | 3.0 |
| | | 4.2 | 3.0 |
| | Simply Iconic™ | 4.7 | 3.0 |
| | | 4.7 | 3.4 |
| | | 5.2 | 3.4 |
| | | 5.7 | 3.4 |
| Primary Predicate Device | 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. | | |
| K222269 | 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. | | |
| DESS Dental Smart Solutions | Compatible Implant Systems | | |
| Terrats Medical SL | Compatible Implant System (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) | |
# Table of Substantial Equivalence – Indications for Use Statement
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# Table of Substantial Equivalence – Technological Characteristics
| | Subject Device<br>K231043<br>DESS Dental Smart Solutions<br>Terrats Medical SL | Primary Predicate Device<br>K222269<br>DESS Dental Smart Solutions<br>Terrats Medical SL |
|------------------------------------|---------------------------------------------------------------------------------|------------------------------------------------------------------------------------------|
| | | |
| Reason for Predicate Device | Not applicable | Abutment designs, materials, sterilization |
| Product Codes | NHA | NHA |
| Intended Use | Functional and esthetic rehabilitation of the<br>edentulous mandible or maxilla | Functional and esthetic rehabilitation of the<br>edentulous mandible or maxilla |
| Abutment Designs | | |
| Abutment Types | Multi-Unit, Straight (0°), 17°, 30° | Multi-Unit, Straight (0°), 17°, 30°<br>Ti Base<br>AURUM Base<br>Premilled Blank |
| Prosthesis Attachment | Screw Retained | Cement-retained<br>Screw Retained |
| Restoration | Multi-unit | Single-unit<br>Multi-unit |
| Prosthetic Interface Connections | Internal | Internal |
| Abutment/Implant Platform Diameter | 3.0 - 4.5 mm | MUAs: 3.25 mm – 7.5 mm |
| Prosthetic Platform Diameter | 4.8 mm | MUAs: 4.8 mm, 6.0 mm |
| Gingival Height | 1 mm - 5 mm | MUAs: 1 mm – 5 mm |
| Abutment Angulation, degrees | Straight (0°), 17°, 30° | MUAs: Straight (0°), 17°, 30° |
| Abutment Material | Ti-6Al-4V ELI | Ti-6Al-4V ELI |
| Abutment Screw Material | Ti-6Al-4V ELI | Ti-6Al-4V ELI |
| How Provided | | |
| Sterilization | Non-sterile | Non-sterile |
| Usage - All Components | Single patient, single use | Single patient, single use |
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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.