The LOCATOR® RTx Attachment System is designed for use with overdentures or partial dentures, retained in whole or in part, by endosseous implants in the mandible or maxilla.
Device Story
LOCATOR RTx is a dental implant attachment system consisting of titanium alloy abutments, nylon or PEEK liners, and denture caps. It functions as a resilient attachment for endosseous implants. The abutment connects to the implant via a threaded apical end; the coronal end features a double-ridge design for retention. It accommodates implant path divergence up to 30°. Used in dental clinics by dentists to secure overdentures or partial dentures. The device provides a mechanical connection between the implant and the prosthesis, improving denture stability and patient comfort. Abutments are available in various cuff heights and diameters to match specific implant systems.
Clinical Evidence
Bench testing only. Testing included sterilization validation (ISO 17665-1/2), biocompatibility (ISO 10993-1, -5, -10), and characterization of the TiCN coating.
Technological Characteristics
Materials: Ti-6Al-4V ELI titanium alloy abutments with TiCN or TiN coating; nylon or PEEK retention liners. Design: Coronal double-ridge retention; threaded apical connection. Dimensions: 3.0-7.0 mm diameter; 1-6 mm cuff heights. Sterilization: Moist heat. Connectivity: None (mechanical).
Indications for Use
Indicated for patients requiring overdentures or partial dentures retained by endosseous implants in the mandible or maxilla.
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/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing right, one behind the other, with flowing lines representing hair or fabric.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 24,2015
Zest Anchors, LLC % Linda Schulz Regulatory Affairs Paxmed International, LLC 12264 El Camino Real, Suite 400 San Diego, California 92130
Re: K150295
Trade/Device Name: LOCATOR RTx Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: June 17, 2015 Received: June 18, 2015
Dear Linda Schulz:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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 (reporting of medical device
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related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Susan Runno DDS, MA
Erin Keith, M.S. Director Division of Anesthesiology, General Hospital. Respiratory. Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known)
#### K150295
Device Name
LOCATOR® RTx
#### Indications for Use (Describe)
The LOCATOR® RTx Attachment System is designed for use with overdentures or partial dentures, retained in whole or in part, by endosseous implants in the mandible or maxilla.
LOCATOR® RTx Attachment System is compatible with the following implant systems.
| Implant Manufacturer: | System: |
|-----------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|
| BioHorizons | Internal Hex (3.0, 3.5, 4.5, 5.7 mm)<br>External Hex (3.5, 4.0, 5.0 mm) |
| Biomet 3i | Certain Internal (3.4, 4.1, 5.0, 6.0 mm)<br>External Hex (3.4, 4.1, 5.0, 6.0 mm) |
| Camlog | Camlog and Conelog; (3.3, 3.8, 4.3, 5.0 mm)<br>iSy (3.8, 4.4, 5.0 mm) |
| Dentsply | Ankylos (3.5, 4.5, 5.5, 7.0 mm)<br>XiVE/FRIALIT-2 (3.4, 3.8, 4.5, 5.5 mm)<br>Astra Tech OsseoSpeed EV (3.6, 4.2, 4.8 mm) |
| MIS Implants | Internal Hex (3.75, 4.5 mm) |
| Nobel Biocare | Replace: Internal (3.5, 4.3, 5.0, 6.0 mm),<br>NobelActive: Internal Conical (3.0, 3.5, 4.3, 5.0 mm),<br>Brånemark: External Hex (3.3, 3.75, 4.0, 5.0 mm) |
| Straumann | Tissue Level (3.5, 4.8, 6.5 mm)<br>Bone Level (3.3, 4.1, 4.8 mm) |
| Zimmer | Tapered Screw Vent: Internal Hex (3.5, 4.5, 5.7 mm)<br>Spline (3.25, 4.0, 5.0 mm)<br>Swiss Plus: Internal Octagon (3.8, 4.8 mm) |
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
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# 510(k) Summary Zest Anchors, LLC LOCATOR® RTx K150295
July 23, 2015
# ADMINISTRATIVE INFORMATION
| Manufacturer Name | Zest Anchors, LLC<br>2061 Wineridge Place<br>Escondido, CA 92029 |
|---------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|
| Telephone: | +1 (760) 743-7744 ext. 140 |
| Fax: | +1 (760) 743-7975 |
| Official Contact | Annie Wright<br>Regulatory Affairs Manager |
| Representative/Consultant | Linda K. Schulz, BSDH, RDH<br>Floyd G. Larson, MS, MBA<br>PaxMed International, LLC<br>12264 El Camino Real, Suite 400<br>San Diego, CA 92130 |
| Telephone: | +1 (858) 792-1235 |
| Fax: | +1 (858) 792-1236 |
| Email: | lschulz@paxmed.com<br>flarson@paxmed.com |
# DEVICE NAME AND CLASSIFICATION
| Trade/Proprietary Name | LOCATOR® RTx |
|---------------------------|------------------------------------|
| Common Name | Dental implant abutment |
| Classification Name | Endosseous dental implant abutment |
| Classification Regulation | Class II, 21 CFR 872.3630 |
| Product Code | NHA |
| Classification Panel | Dental Products Panel |
| Reviewing Branch | Dental Devices Branch |
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## 510(k) Summary LOCATOR® RTx
## INTENDED USE
The LOCATOR® RTx Attachment System is designed for use with overdentures or partial dentures, retained in whole or in part, by endosseous implants in the mandible or maxilla.
LOCATOR® RTx Attachment System is compatible with the following implant systems.
| Implant<br>Manufacturer | Connection |
|-------------------------|-------------------------------------------------------|
| BioHorizons | Internal Hex (3.0, 3.5, 4.5, 5.7 mm) |
| | External Hex (3.5, 4.0, 5.0 mm) |
| Biomet 3i | Certain Internal (3.4, 4.1, 5.0, 6.0 mm) |
| | External Hex (3.4, 4.1, 5.0, 6.0 mm) |
| Camlog | Camlog and Conelog; (3.3, 3.8, 4.3, 5.0 mm) |
| | iSy (3.8, 4.4, 5.0 mm) |
| Dentsply | Ankylos (3.5, 4.5, 5.5, 7.0 mm) |
| | XiVE/FRIALIT-2 (3.4, 3.8, 4.5, 5.5 mm) |
| | Astra Tech OsseoSpeed EV (3.6, 4.2, 4.8 mm) |
| MIS Implants | Internal Hex (3.75, 4.5 mm) |
| Nobel | Replace: Internal (3.5, 4.3, 5.0, 6.0 mm) |
| Biocare | NobelActive: Internal Conical (3.0, 3.5, 4.3, 5.0 mm) |
| | Brånemark: External Hex (3.3, 3.75, 4.0, 5.0 mm) |
| Straumann | Tissue Level (3.5, 4.8, 6.5 mm) |
| | Bone Level (3.3, 4.1, 4.8 mm) |
| Zimmer | Tapered Screw Vent: Internal Hex (3.5, 4.5, 5.7 mm) |
| | Spline (3.25, 4.0, 5.0 mm) |
| | Swiss Plus: Internal Octagon (3.8, 4.8 mm) |
# DEVICE DESCRIPTION
LOCATOR® RTx implant attachment system, consists of abutments, nylon or PEEK liners and denture caps to serve in a similar function to LOCATOR® as a resilient attachment for endosseous implants. All LOCATOR RTx abutments are made of titanium alloy and have the same coronal double ridge retention design that attaches to the overdenture component. The threaded apical end of the abutment connects to the implant and is specific to each compatible implant system and diameter. LOCATOR RTx is designed to accommodate a path of insertion on implants that are divergent up to 30° unless prohibited by the implant manufacturer. LOCATOR RTx abutments are provided with either TiCN or TiN coating and are available in six cuff heights (1, 2, 3, 4, 5, and 6 mm). They are provided in diameters 3.0 - 7.0 mm as shown in the compatibility table above.
# PERFORMANCE DATA
Performance testing to demonstrate substantial equivalence included methods described in the following standards: ISO 17665-1 Sterilization of health care products - Moist heat - Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices; ISO 17665-2 Sterilization of health care products - Moist heat - Part 2: Guidance on the application of ISO 17665-1; ISO 10993-1 Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process; ISO 10993-5 Biological Evaluation of Medical Devices – Part 5: Tests for In Vitro Cytotoxicity; and
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ISO 10993-10 Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization. Non-clinical testing data submitted, referenced, or relied upon to demonstrate substantial equivalence included: sterilization testing, biocompatibility testing of the TiCN coating, and characterization testing of the TiCN coating. The performance data included in this submission demonstrate substantial equivalence to the predicate devices listed below.
# EQUIVALENCE TO MARKETED DEVICE
LOCATOR RTx is substantially equivalent to LOCATOR in that it uses the identical interface for compatible implant systems and it is a nylon or PEEK liner overdenture system with varying cuff heights.
Primary predicate: Zest Anchors, Inc., Modification to Locator Implant Anchor cleared under K072878.
Reference Device: Astra Tech AB, OsseoSpeed Plus cleared under K120414.
| 510(k) Number | Implant System Compatibility |
|---------------|----------------------------------|
| K063341 | Biomet 3i Osseotite® Certain® |
| K063286 | Biomet 3i Osseotite® |
| K061410 | Zimmer Tapered Screw-vent® |
| K010073 | Zimmer Spline |
| K082639 | Zimmer SwissPlus |
| K103089 | MIS |
| K062129 | Straumann Bone Level |
| K130222 | Straumann Standard |
| K020646 | Nobel Biocare Replace™ Select |
| K071370 | Nobel Biocare NobelActive™ |
| K102436 | Nobel Biocare NobelActive™ |
| K022562 | Nobel Biocare Brånemark |
| K041509 | Dentsply Friadent® Ankylos® |
| K073075 | Dentsply Friadent® Frialit/XiVE® |
| K120414 | Astra Tech OsseoSpeed Plus (EV) |
| K000100 | Camlog Rootform Implant System |
| K083496 | Camlog Implant System |
| K113779 | Conelog Implant System |
| K133991 | Camlog iSy Implant System |
| K071638 | Camlog iSy Implant System |
| K093321 | BioHorizons Internal |
| K143022 | BioHorizons Internal |
| K030463 | BioHorizons External Hex |
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| | Subject Device | Primary Predicate Device | Additional Predicate Device |
|--------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | | Zest Anchors, Inc. | Astra Tech AB |
| | Zest Anchors, LLC<br>LOCATOR® RTx | LOCATOR Implant Anchor<br>Abutment for Endosseous<br>Dental Implant<br>K072878 | OsseoSpeed Plus<br>K120414 |
| Indications for Use | The LOCATOR® RTx Implant<br>Attachment System is designed<br>for use with overdentures or<br>partial dentures, retained in<br>whole or in part, by endosseous<br>implants in the mandible or<br>maxilla. | The LOCATOR Implant Anchor<br>Abutment for Endosseous Dental<br>Implants is appropriate for use<br>with overdentures or partial<br>dentures retained in whole or in<br>part by endosseous implants in<br>the mandible or maxilla. | Astra Tech Implant System Plus<br>abutments are intended to be<br>used in conjunction with Astra<br>Tech Implant System Plus in<br>fully edentulous or partially<br>edentulous maxillary and/or<br>mandibular arches to provide<br>support for crowns, bridges or<br>overdentures. |
| Design | | | |
| Abutment<br>Diameter, mm | 3.0 to 7.0 | 3.25 to 6.5 | 3.0 to 5.4 |
| Abutment Angle | Straight | Straight | Straight |
| Abutment/Implant<br>Interface | Conical, External Hex, Internal<br>Hex, Internal Multi Lobe | Conical, External Hex, Internal<br>Hex, Internal Multi Lobe | Internal Taper |
| Divergence<br>Allowance | 30°/60°<br>(except when prohibited<br>by implant manufacturer) | 20°/40° | 33°/66° |
| Prosthesis<br>Attachment Type | Nylon or PEEK male<br>retention cap | Nylon male retention cap | Screw-retained |
| Material | | | |
| Abutment | Ti-6Al-4V ELI | Ti-6Al-4V ELI | Ti-6Al-4V ELI |
| Prosthetic<br>Retention<br>Component | Nylon or PEEK | Nylon | NA |
The subject device is the same in all features as the primary predicate with the exception of the compatible implant/abutment interface. The subject device has the same divergence allowance as the reference device. The subject device has a resilient overdenture prosthesis attachment and the reference device is for a screw-retained prosthesis.
# CONCLUSION
The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.
Overall, the subject device has the following similarities to the predicate devices:
- has the same intended use, ●
- uses the same operating principle,
- incorporates the same basic design,
- incorporates the same or very similar materials, and
- has similar packaging and is sterilized using the same processes.
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.