K120858 · Prismatik Dentalcraft, Inc. · NHA · Dec 6, 2012 · Dental
Device Facts
Record ID
K120858
Device Name
IMPLANT BAR
Applicant
Prismatik Dentalcraft, Inc.
Product Code
NHA · Dental
Decision Date
Dec 6, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3630
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Inclusive® Implant Bridge Framework is indicated for use as a bridge framework in the treatment of partially or totally edentulous jaws for the purpose of restoring chewing function. The Inclusive® Implant Bridge Framework is compatible with the following implant system: Nobel Biocare's Replace 3.5mm, 4.3mm, 5.0mm, and 6.0mm; Nobel Biocare's Branemark System 4.1mm; Nobel Biocare's Active 3.5mm and 4.3mm, Zimmer Dental Screw-Vent 3.5mm, 4.5mm, and 5.7mm; Biomet 3i Certain 3.4mm, 4.1mm, 5.0mm, and 6.0mm; Straumann Bone Level 4.1mm; Astra Tech OsseoSpeed 3.5mm and 4.5mm.
Device Story
Inclusive® Implant Bridge Framework is a patient-specific, precision-milled titanium bridge framework; attaches to endosseous dental implants via titanium screws. Device customized based on patient-specific instructions and models; intended to be finished into a final dental prosthesis using standard laboratory materials. Used by dental professionals in clinical settings to restore chewing function in partially or totally edentulous patients. Provides structural support for prosthetic teeth; benefits patient by restoring oral function. Shipped non-sterile.
Clinical Evidence
Bench testing only. Performed static and fatigue testing per ISO 14801:2007 to evaluate mechanical strength and implant-abutment compatibility. Sterilization validated per ANSI-AAMI ST79-2006. No clinical data presented.
Technological Characteristics
Material: Ti-6Al-4V ELI alloy (ASTM F 136). Design: Precision-milled titanium bars. Energy source: None (mechanical). Connectivity: None. Sterilization: Non-sterile (validated for steam sterilization).
Indications for Use
Indicated for partially or totally edentulous patients requiring bridge frameworks to restore chewing function. Compatible with specific Nobel Biocare, Zimmer, Biomet 3i, Straumann, and Astra Tech 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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K120858
## 005-510 (k) Summary-807.92(c)
# DEC 0 6 2012
This 510 (K) summary of safety and effectiveness information is being submitted in accordance with the requirements of SMDA and 21 CFR 807.92.
#### SUMITTER INFORMATION A.
Company Name:
Company Address:
Prismatik Dentalcraft, Inc.
2212 Dupont Dr., Suite IJK Irvine, CA 92612
Company Phone:
Company FAX:
Primary Contact Person:
Secondary Contact Person:
Date Summary Prepared:
949-399-1940
949-553-0924
Armin Zehtabchi. (949) 225-1234
Marilyn Pourazar, (949) 225-1269
November 28, 2012
#### B. DEVICE IDENTIFICATION
Trade/Proprietary Name:
21 CFR Common Name:
21 CFR Reference:
Classification:
Product Code:
Panel:
Inclusive® Implant Bridge Framework
21 CFR 872.3630
Endosseous Dental Implant Abutment
Class II
NHA
Dental
#### C. IDENTIFICATION OF PREDICATE DEVICE
Trade/Proprietary Name:.
Nobel /Procera Implant Bridge-K091848, Biomet 3i-CAM StructSure Overdenture Bars-K101582
#### DEVICE DESCRIPTION D.
Inclusive® Implant Bridge Framework attaches to implants. The Implant Bridge Framework is intended to be finished into a dental prosthesis using standard laboratory materials. The Inclusive® Implant Bridge Framework is customized by
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following instructions and models specific to each patient.
The Inclusive® Implant Bridge Framework is made of titanium and shipped non-sterile. The Inclusive® Implant Bridge Framework will be attached with titanium screws.
#### E. INDICATION FOR USE
Indications for Use: The Inclusive® Implant Bridge Framework is indicated for use as a bridge framework in the treatment of partially or totally edentulous jaws for the purpose of restoring chewing function.
The Inclusive® Implant Bridge Framework is compatible with the following implant system: Nobel Biocare's Replace 3.5mm, 4.3mm, 5.0mm, and 6.0mm; Nobel Biocare's Branemark System 4.1mm; Nobel Biocare's Active 3.5mm and 4.3mm, Zimmer Dental Screw-Vent 3.5mm, 4.5mm, and 5.7mm; Biomet 3i Certain 3.4mm, 4.1mm, 5.0mm, and 6.0mm; Straumann Bone Level 4.1mm; Astra Tech OsseoSpeed 3.5mm and 4.5mm.
#### SUBSTANTIAL EQUIVALENCE F.
The Inclusive® Implant Bridge Framework is substantially equivalent to the Nobel /Procera Implant Bridge and Biomet 3i-CAM StructSure Overdenture Bars. The Inclusive® Implant Bridge Framework is substantially equivalent in indications for use, material, design and performance.
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| Callery Company of September 1998 to the states of the states of the states of the states of the states of the states of the states of the states of the states of the states | 1 |
Comparison of Predicate Devices
. .
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| Elements of Comparison | Prismatik's Inclusive® Implant Bridge Framework | Nobel /Procera Implant Bridge-K091848 | Biomet 3i's CAM StructSure Overdenture Bars-K101582 | Prismatik's Inclusive Mini Implant-K100932 | Biomet 3i's CAM StructSure Precision Milled Bars-K080864 |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Material | Ti-6Al-4V ELI Alloy conforming to ASTM F 136. | Ti-6Al-4V ELI Alloy conforming to ASTM F 136. | Ti-6Al-4V ELI Alloy conforming to ASTM F 136. | Ti-6Al-4V ELI Alloy conforming to ASTM F 136. | Ti-6Al-4V ELI Alloy conforming to ASTM F 136. |
| Indications | The Inclusive® Implant Bridge Framework is indicated for use as a bridge framework in the treatment of partially or totally edentulous jaws for the purpose of restoring chewing function. | The Nobel Procera Implant Bridge is indicated for use as a bridge framework in the treatment of partially or totally edentulous jaws for the purpose of restoring chewing function. | The 3i Patient-Specific CAM StructSure® Precision Milled Bars are intended for use as an accessory to endosseous dental implant to support a prosthetic device in a partially or edentulous patient. | Inclusive® Mini Implants are self-tapping threaded titanium screws indicated for long-term applications. Inclusive® Mini Implants may also be used for provisional applications. These devices will allow immediate loading and long-term stabilization of dentures and provisional stabilization of dentures while standard implants heal.Jo be used for immediate loading only in the presence of primary stability and appropriate occlusal loading. | The CAM StructSURE® Precision Milled Bars are intended for use as an accessory to an endosseous dental implant to support a prosthetic device in a partially or edentulous patient. It is intended for use to support multiple tooth prostheses in the mandible or maxilla. The prostheses can be screw retained. |
| Design | Precision-milled bars made of titanium. | Precision-milled bars made of titanium. Design features and technological characteristics have been previously cleared for market (K091848). | Precision-milled bars made of titanium. Design features and technological characteristics have been previously cleared for market (K101582). | Precision-milled bars made of titanium. | Precision-milled bars made of titanium. |
| Performance | The titanium materials have sufficient mechanical strength for their indicated use. | Performance and technological characteristics have been previously cleared for market (K091848). | Performance and technological characteristics have been previously cleared for market (K101582). | The titanium materials have sufficient mechanical strength for their indicated use. | Performance and technological characteristics have been previously cleared for market (K0808864). |
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#### PERFORMANCE DATA G.
The following FDA's Guidance Document "Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments was used for the purpose of Implant to Abutment Compatibility. Various static and fatigue tests were performed by following the ISO 14801: 2007- Dentistry - Implants -- Dynamic fatigue test for endosseous dental implants. All testing conducted met the acceptance criteria and evaluated the worst case scenario. Performance testing data indicated the compatibility, and the safety and the effectiveness of the proposed device which meets the mechanical properties. In addition, the sterilization tests were validated by following the ANSI-AAMI ST79-2006: Comprehensive guide to steam sterilization and sterility assurance in health care facilities. Furthermore, the use of Titanium alloy as a material with acceptable performance for Inclusive® Implant Bridge Framework is well documented in the dental literature.
### COMPARISON OF TECHNOLOGICAL DIFFERENCES H.
There are no known technological differences between the Inclusive® Implant Bridge Framework and those of the predicate devices.
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Image /page/4/Picture/0 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 symbol featuring three abstract human profiles connected by flowing lines, representing the department's focus on health and human well-being.
## DEPARTMENT OF HEALTH & HUMAN SERVICES
## Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002
## December 6, 2012
Ms. Kathleen Dragovich Manager, Regulatory Affairs / Quality Assurance Prismatik Dentalcraft, Incorporated 2212 Dupont Drive, Suite P Irvine, California 92612
Re: K120858
Trade/Device Name: Inclusive® Implant Bridge Framework Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: II Product Code: NHA Dated: November 16, 2012 Received: November 19, 2012
Dear Ms. Dragovich:
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. Iisting 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 (reporting of medical device-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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Kwame O. Ulmer for
Anthony D. Watson, B.S., M.S., M.B.A. 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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## 004-Indications for Use Statement
510 (K) Number (if known): To be determined
Inclusive® Implant Bridge Framework Device Name:
Indications for Use: The Inclusive® Implant Bridge Framework is indicated for use as a bridge framework in the treatment of partially or totally edentulous jaws for the purpose of restoring chewing function.
The Inclusive® Implant Bridge Framework is compatible with the following implant system: Nobel Biocare's Replace 3.5mm, 4.3mm, and 6.0mm; Nobel Biocare's Branemark System 4.1mm; Nobel Biocare's Active 3.5mm and 4.3mm, Zimmer Dental Screw-Vent 3.5mm, 4.5mm, and 5.7mm; Biomet 3i Certain 3.4mm, 4.1mm, 5.0mm, and 6.0mm; Straumann Bone Level 4.1mm; Astra Tech OsseoSpeed 3.5mm and 4.5mm.
Prescription Use: Yes X No
Over-the-Counter Use: Yes |_ No X
(Part 21 CFR 801 Subpart D)
(Part 21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
2012.12.06 13:40:31 Susan Runner DDS, MA 2012.1
(Division Sign-Off)
Division of Anesthesiology, General Hospita,
Infection Control, Dental Devices
| 510(k) Number: | K120 858 |
|----------------|----------|
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Page 6 of 12
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.