BT-TITE CV3, MINI IMPLANT, MINI SINGLE, SLOT IMPLANT, MODEL(S) DDDIII BTICV3, 1, AND DDDIIIBTISI
Applicant
Btlock Srl
Product Code
DZE · Dental
Decision Date
Mar 27, 2009
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 872.3640
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
BT-Tite CV3: It is intended to be used in maxilla or mandible, for post-extraction sites and where the implant would be immediately loaded. It is intended to be used in a single stage or two stage surgical procedure. Mini Implant: It is intended to be used in maxilla or mandible for immediate and long-term stabilization of removable prosthesis. Mini Single: It is intended to be used in maxilla or mandible in anterior narrow sites of dental arch, to replace lateral teeth, dental agenesis and inferior incisors. Slot implant: It is intended to be used as temporary intra-oral anchorage unit in the orthodontic treatment in the superior or inferior arch or extra arch in case of edentulous patients, when necessary teeth for the anchorage are absent or the next teeth are compromised from a parodontal point of view. It facilitates the orthodontic movement of teeth. It is removed after orthodontic treatment has been completed. Slot implants are intended for single use only.
Device Story
BTLock system comprises endosseous dental implants (BT-Tite CV3, Mini Implant, Mini Single, Slot Implant) used to support prosthetic devices or provide orthodontic anchorage. Implants are surgically placed in maxilla or mandible by dental professionals. BT-Tite CV3 features titanium construction, deep threads, and platform-switching design. Mini/Mini Single implants provide stabilization for removable prostheses or replace specific teeth in narrow sites. Slot implants serve as temporary anchorage for orthodontic movement. Devices are provided sterile (gamma-ray) for single use. Clinical benefit includes restoration of chewing function or facilitation of orthodontic treatment. Healthcare providers select implants based on patient health, bone quality, and oral hygiene. Prosthetic components (abutments) are attached to fixtures to support artificial teeth or prostheses.
Clinical Evidence
Evidence includes biocompatibility testing (cytotoxicity, sensitization, mutagenicity, intramuscular implantation, intracutaneous reactivity, pyrogenicity, systemic toxicity), sterility validation (ISO 11737-2), and a multi-centered clinical study to support effectiveness. Bench testing included SEM analysis and mechanical testing to verify structural integrity.
Technological Characteristics
Materials: Titanium and titanium alloy. Surface treatment: DMA (double acid-etching) or sand-blasted/acid-etched. Design: Conical-cylindrical, self-threading, or tapered. Sterilization: Gamma-ray. Connectivity: Mechanical connection (proprietary). Form factor: Various diameters (1.6mm to 5.5mm) and lengths (6mm to 16mm).
Indications for Use
Indicated for patients requiring dental implants in maxilla or mandible for: BT-Tite CV3 (post-extraction, immediate loading, single/two-stage); Mini Implant (stabilization of removable prosthesis); Mini Single (anterior narrow sites, lateral teeth replacement, dental agenesis, inferior incisors); Slot Implant (temporary orthodontic anchorage).
Regulatory Classification
Identification
An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.
Special Controls
*Classification.* (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. 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.)(2)
*Classification.* Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.
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Image /page/0/Picture/0 description: The image shows the logo for "BTLock Next Generation System". The logo consists of a circular emblem on the left, containing the letters "BTL" inside. To the right of the emblem is the text "BTLock" in bold, followed by the words "NEXT GENERATION SYSTEM" in a smaller font size.
K083869
MAR 2 7 2009
# ABBREVIATED 510(K) SUMMARY
| Submitter's name: | BTLock S.r.l. |
|-----------------------|------------------------------------------------------|
| Address: | via Madonnetta 97/C |
| | 36075 Montecchio Maggiore |
| | Vicenza |
| | Italy |
| Telephone number: | 0039 0444 492609 |
| Fax number: | 0039 0444 497647 |
| Contact person: | Ester Battilana |
| Email: | info@btlock.com |
| Date of this summary: | December 9th, 2008 |
| Name of the devices: | BT-Tite CV3, Mini Implant, Mini Single, Slot Implant |
| Common or usual name: | BT-Tite CV3, Mini Implant, Mini Single, Slot Implant |
| Classification name: | Endosseous Implant (21 CFR 872.3640) |
Opening remarks: BTLock is located in Alte Ceccato, a minor part of Montecchio Maggiore. In January 2007 Alte Ceccato was inglobated in the main town and since then the relative postal code (36041) is no longer in use. The new one is 36075. This is the reason why you will find some disagreement from this point of view in the documents we are submitting.
You will find different names of the company in the submission as well. You will see BTLock and Fidelm. It is the same company: Fidelm changed its name in BTLock in 2003 (see attachment n° 12).
Probably in the attachments and in the catalogues you will find different kind of surfaces (HA Coated, Acid-etched): we are not going to export them in the USA and therefore they are not part of this submission.
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The major part of the products you see in the catalogue have already been approved by the FDA with the K073458. We registered recently at FURLS. This is our owner operator number: 10027925.
K083869
2
BTLock system is already registered as medical device in European union (CE, see attachment n° 41), Taiwan (DOH, see attachment nº 46), Brasil (ANVISA, see attachment nº 47, we are at pp.41), South Korea (KFDA, see attachment nº 48). BTLock quality system is certified by DNV (ISO 9001 and 13485, see attachments nº 43 and 44).
All products codes are included in BTLock Free Trade certificate (see attachment nº 45).
The legally marketed devices to which we are claiming substantial equivalence, according to 807.92, are the following: BT-Tite CV3, Mini Implant, Mini Single, Slot implant.
# BT-Tite CV3
| BTLock device | Reference | Device name | Manufacturer |
|---------------|-----------|-------------|---------------|
| BT-Tite CV3 | K073458 | BT-Tite CV2 | BTLock S.r.l. |
#### Description of the device
BTLock implant are intended for use in the upper and/or lower jaw to support prosthetic devices. such as artificial teeth, in order to restore chewing function to partially or fully edentulous patients. The main feature of BTLock implant system is an original and patented connection (US patent n° 6659700 B2 dated December 9th 2003, attachment nº 11). This connection has no compatibility with other systems. All prosthetic components and accessories are exclusive for BTLock implant system. It included BT-Tite CV2 and BT-Tite Standard lines which have been approved by the FDA with the 510(K) number 073458.
BT-Tite CV3 is an implant line which includes fixture and abutment joined together by a through screw. CV3 fixture is machined from titanium, with a deep thread, micro-grooves on the collar, 6 longitudinal long grooves along the body till the collar, DMA surface and a platform designed for the platform-switching. The surface treatment called DMA (which stands for doppia mordenzatura acida, that is double acid-etching) is obtained by the combination of sand-blasting and double acid-
Sede Commerciale: Via Madonnetta, 97/C 36075 Montecchio Maggiore (VI) Tel. +39 0444 497647 Part. IVA n. 02530390794 Indirizzo Internet: www.btlock.com e-mail info@btlock.com
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etching. This treatment is absolutely equivalent to BT-Tite (no material is added, no changes in the material used for the treatment: just acid-etching is performed twice instead than once).
This line features a conical-cylindrical shape as the other fixtures of BTLock system. Therefore, because of this equivalence, I submitted the same tests carried for the other lines (BT-Tite One, BT-Tite CV2, BT-Tite Standard).
It is available in 3 diameters (3,75 - 4,5 - 5,5 mm) and 5 lengths (8 - 10 - 11,5 - 13 -16 mm). The technical details of the product are included in its own drawing (see attachment nº 18).
See attachment nº 07 for the brochure of BT-Tite CV3 and the surgical handbook (attachment nº 10) for reference about the surgical protocol which is equivalent to that of the other fixtures of BTLock system.
#### Intended use
This fixture is intended to be used in maxilla or mandible, for single or multiple replacement, for post-extraction sites and where the implant would be immediately loaded. In case of post-extraction sites it has to be inserted some millimetres under the bone crest. It can be placed in the oral cavity in one or two stage surgical procedure. It is intended for single use only.
When selecting a candidate to implant treatment, some aspects should be carefully considered: patient's expectations and motivations, his/her general health conditions, and the oral hygiene.
## Labeling
As the other BTLock lines, BT-Tite CV3 fixtures are packed together with a surgical screw, an assembling screw, and the implant carrier. Once these parts are assembled, they are put in a crystal vial, which is inserted in a blister pack. It is then sent to the gamma-ray sterilization. On the blister pack two little labels are sticked: one for the dentist's record and one for the patient's sheet. The blister pack is then put in a pasteboard package together with an information sheet (which is written in 4 languages: Italian, English, Spanish, Portuguese). On the pasteboard package another label is sticked, which contains the following information about: product description, product code, size (diameter, length), the colour-code (which refers to the diameter), expiry date, manufacturing date, batch number, CE mark, sterile mark, one-time use mark, the indication to read the information sheet, Rx Only, and details of manufacturing company.
For a more detailed description of the labelling and the package please see attachment n° 28 (label symbols), 27 (packaging), 29 (a sample of the external label we paste on the package), and 33 (a sample of the internal label we paste on the package). I attached the English version (attachment n°
ਤ
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15) and the Italian-English version of the information sheet we put in the packages (att 14).
| BTLock device | Reference | Device name | Manufacturer |
|---------------|-----------|-------------|--------------|
| Mini Implant | K031106 | MDI | Imtec Sendac |
# Mini Implant
## Description of the device
The fixture of the mini implant line is machined from titanium and self-threading. They are available in 3 diameters (2 - 2,5 - 3 mm) and 3 lengths (11,5 - 13 - 16 mm). The implant length includes the machine-cut collar (1,5 mm) and the threaded part which features a surface treatment called BT-Tite, which is obtained by the combination of sand-blasting and acid-etching.
It is available in 3 diameters (2 - 2,5 - 3 mm) and 3 lengths (11,5 - 13 - 16 mm).
The technical details of the product are included in its own drawing (see attachment nº 19).
See attachment nº 08 for the brochure of BTLock Mini Implants.
## Intended use
BTLock mini implant is intended for use in the upper and/or lower jaw for immediate and long-term stabilization of removable prosthesis in order to restore chewing function to fully edentulous patients. It is intended for single use only. According to the manufacturer's surgical protocol, 4 mini implants should be inserted in order to assure the stabilization of the prosthesis.
Once the implant has been inserted, the surgeon can choose among different prosthetic components: metal ring (in case of low chewing dimension), teflon cap with plastic o-ring, metal cap with o-ring, and retaining cap.
When selecting a candidate to implant treatment, some aspects should be carefully considered: patient's expectations and motivations, his/her general health conditions, and the oral hygiene.
## Labeling
The labelling for the Mini Implants is exactly the same as for the BT-Tite CV3.
For a more detailed description of the labelling and the package please see attachment nº 28 (label symbols), 27 (packaging), 30 (a sample of the external label we paste on the package), and 34 (a sample of the internal label we paste on the package). I attached the English version (attachment nº 17) and the Italian-English version of the information sheet we put in the packages (attachment n° 16).
4
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K083869
# Mini Single
| BTLock device | Reference | Device name | Manufacturer |
|---------------|-----------|------------------|---------------|
| Mini Single | K031345 | Nobel Direct 3.0 | Nobel Biocare |
#### Description of the device
It is a self-threaded and tapered implant made of titanium alloy. The fixture's body features BT-Tite as surface treatment (already approved by FDA, see K073458). This implant has a one-piece design, that is the abutment is integrated to the implant, and an anatomic design. The implant and the abutment are made of the same material.
It is available in 2 diameters (2,5 - 3 mm) and 4 lengths (10 - 11,5 - 13 - 16 mm). The technical details of the product are included in its own drawing (see attachment nº 20). See attachment nº 08 for the brochure of BTLock Mini Implants.
#### Intended use
This device it is intended to be used in maxilla or mandible in anterior narrow sites of dental arch to replace lateral teeth, dental agenesis and inferior incisors to support prosthetic devices, such as artificial teeth, in order to restore chewing function in partially edentulous patients. It is intended for single use only.
It requires a minimally invasive surgery and are designed for one-stage surgical procedure.
When adequate bone and attached gingival are present they can be placed by a flapless surgery, When selecting a candidate to implant treatment, some aspects should be carefully considered: patient's expectations and motivations, his/her general health conditions, and the oral hygiene.
## Labeling
.
The labelling for the Mini Single implants is exactly the same as for the Mini Implants.
For a more detailed description of the labelling and the package please see attachment n° 28 (label symbols), 27 (packaging), 31 (a sample of the external label we paste on the package), and 35 (a sample of the internal label we paste on the package). I attached the English version (attachment n° 17) and the Italian-English version of the information sheet we put in the packages (attachment n° 16).
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K083869
| BTLock device | Reference | Device name | Manufacturer |
|---------------|-----------|--------------|--------------|
| Slot Implant | K052471 | Spider Screw | HDC S.r.l. |
#### Description of the device
This device is made of titanium alloy, has a tapered and self-tapping shape. The head has 2 slots, one hole and one neck. The neck is polished (in order not to interfere with soft tissue). It can be loaded immediately.Its smooth threaded surface allows easy removal at the end of treatmet: as a matter of fact because complete osteointegration is neither expected nor desired with this anchorage system because its utilization is temporary.
It is available in 2 diameters (1,6 - 2 mm) and 3 lengths (6 - 7,5 - 9 mm).
See attachment nº 09 (page 58) for the description we provide of BTLock Slot Implants to our customers. The technical details of the product are included in its own drawing (see attachment nº 21).
#### Intended use
It is intended to be used as temporary intra-oral anchorage unit in the orthodontic treatment in the superior or inferior arch or extra arch in case of edentulous patients, when necessary teeth for the anchorage are absent or the next teeth are compromised from a parodontal point of view. It facilitates the orthodontic movement of teeth. It is removed after orthodontic treatment has been completed. It is intended for single use only. When selecting a candidate to implant treatment, some aspects should be carefully considered: patient's expectations and motivations, his/her general health conditions, and the oral hygiene.
#### Labeling
The labelling for the Slot implants is exactly the same as for the Mini Implants.
For a more detailed description of the labelling and the package please see attachment nº 28 (label symbols), 27 (packaging), 32 (a sample of the external label we paste on the package), and 36 (a sample of the internal label we paste on the package). I attached the English version (attachment n° 17) and the Italian-English version of the information sheet we put in the packages (attachment n° 16).
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K083869
## Identification of the risk analysis method
BTLock risk management is carried on according to standard 14971 UNI CEI EN ISO.
BTLock products' risks are exactly the same of predicate devices, because materials used, treatments and general mechanical properties are substancially equivalent.
Anyway, BTLock has carried on biocompatibility, mechanical tests by the Milan University (see attachment nº 38 (justification of our worst case scenario) and 39) and a multi-centred clinical study (see attachment nº 40) to prove the effectiveness of the devices before commercialization,
Biocompatibility tests include:
- · Citotoxicity Evaluation test (see attachment nº 49)
- · Skin sensitization test (see attachment nº 49)
- · Salmonella typhirium reverse mutation assay (see attachment nº 49)
- · Intramuscular implantation test (see attachment nº 49)
- · Intracutaneous reactivity test (see attachment nº 50)
- · Pyrogenicity test (USP 151) (see attachment nº 51)
- · Sterility (ISO 11737-2) (see attachment nº 52)
- · Systemic toxicity test (see attachment nº 53)
- · Evaluation of sterilization efficacy fixture (see attachment n° 54)
- · Evaluation of sterilization efficacy abutment (see attachment n° 55)
- Our quality system implies a series of internal and external checks over our products.
Internal checks are described in our quality system handbook and especially in our POS (standard operational procedures) documents. External checks are the followings:
- SEM analysis (see attachment nº 57 - 58 - 59)
- Bioburden (see attachment nº 54), equivalent to Evaluation of sterilization efficacy for fixture.
We attach also the sterilization contract specifications referred to all fixtures and healing-screws (see attachment nº 56).
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K083869
8
## TEMPORARY MILLABLE ABUTMENT (BTIMCL1)
Image /page/7/Picture/3 description: The image shows a black and white rendering of a lightbulb. The lightbulb has a standard shape, with a rounded top and a screw base. The image is grainy and has a lot of noise, which makes it difficult to see the details of the lightbulb. The screw base is more clearly defined than the rest of the lightbulb.
Description: abutment for the exclusive BTLock system made of plexyglass, available in 5 diameters (3,3 - 3,75 - 4,5 - 5,5 - 6,5 mm). See attachment nº 22 for technical details.
Use: it has to be used as temporary millable abutment in single or multiple restorations.
Differences from other abutments: among the BTLock abutments made of plexiglass, it is the only one that can be used as temporary.
## SCREWABLE LOCK ABUTMENT (BTIMP2)
Image /page/7/Picture/8 description: The image shows a close-up of a metal pipe fitting. The fitting has a cylindrical shape with a wider section in the middle and narrower sections at the top and bottom. The surface of the fitting appears rough and textured, suggesting it may be made of cast iron or a similar material.
Description: lock straight neck made if titanium alloy, available in 5 diameters.
Use: indicated for disparallelism, in case of high occlusal stress and in single restorations, for barretained restorations and screwable technique.
Differences from other abutments: it is the straight version of BTLock abutments for screwable technique.
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K083869
#### SCREWABLE ANGLED ABUTMENT (A/B BTIMPI15/25)
Image /page/8/Picture/2 description: The image shows a close-up of a small, multi-tiered architectural model or sculpture. The structure consists of stacked, geometric shapes, including cylindrical and angular forms. The top section features a wing-like or roof-like element that extends outward, creating a sense of projection. The overall aesthetic is minimalist and abstract, with a focus on the interplay of light and shadow on the various surfaces.
Description: lock neck made of titanium alloy. It is available in 2 inclinations (15° - 25°) and 2 heights (1 - 2,5 mm) according to the gingival thickness. See attachment nº 23 for technical details.
Use: it has to be used for disparallelism, in case of high occlusal stress and in single or multiple restorations.
Differences from other abutments: as the lock screwable abutment, it has to be used for the screwable technique.
#### LOCK PASSIVE ABUTMENT (BTIMP1)
Image /page/8/Picture/7 description: The image shows a close-up of a cylindrical object with a threaded base. The top portion of the cylinder appears to be transparent or translucent, while the lower part is opaque and darker in color. The object has a stepped design, with the diameter decreasing towards the threaded base.
Description: passive abutment in titanium alloy, antirotational, available in 5 diameters and 3 heights (0 - 1 - 2 mm) according to the gingival thickness.
Use: suitable for single, multiple restorations and bar-retained solutions in the anterior and posterior areas.
Differences from other abutments: among the passive abutments this is the lock version.
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A083869
## ROTATIONAL PASSIVE ABUTMENT (BTIMPR1)
Image /page/9/Picture/2 description: The image shows a close-up of a small, cylindrical device with a threaded base. The top portion of the device appears to be transparent or translucent, allowing a view of internal components. The middle section has a more solid, opaque appearance, and the bottom section features a screw thread, suggesting it is designed to be attached to something. The image is in black and white and has a grainy texture.
Description: passive abutment in titanium alloy, rotational, available in 5 diameters and 3 heights (0 -1-2 mm) according to the gingival thickness.
Use: suitable for multiple restorations and barretained solutions in the anterior and posterior areas.
Differences from other abutments: among the passive abutments this is the rotational version.
## IMMEDIATE-LOADING ABUTMENT WITH ROTATIONAL CAP (BTIMP3)
Image /page/9/Picture/7 description: The image shows a close-up of a small, cylindrical object with a threaded end. The object appears to be made of metal and has a smooth, polished surface on the top portion. The bottom portion has a darker color and a more complex shape, with a series of ridges and grooves leading to the threaded end. The threads are fine and evenly spaced, suggesting that the object is designed to be screwed into something.
Description: lock abutment in titanium alloy. Cementable cap included in the package. Available in five diameters.
Use: suitable for provisional prosthetic solutions for single and multiple restorations and immediateloading.
Differences from other abutments: in this version the
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Image /page/10/Picture/0 description: The image shows a handwritten number, K083869, in black ink. The numbers are written in a cursive style, with some of the numbers connected to each other. A line is drawn underneath the number.
## IMMEDIATE-LOADING ABUTMENT WITH FIXED CAP (BTIMP4)
Image /page/10/Picture/2 description: The image shows a dental implant and a white, blurry object above it. The implant is made of metal and has a screw-like structure at the bottom. The implant has a cylindrical shape with several horizontal grooves. The white object above the implant is blurry and its shape is not clear.
Description: lock abutment in titanium alloy. Cementable cap included in the package. Available in five diameters.
Use: suitable for provisional prosthetic solutions for single and multiple restorations and immediateloading.
Differences from other abutments: in this version the cap is fixed.
## PROVISIONAL LOCK ABUTMENT FOR IMMEDIATE LOAD (BTIPML1)
Image /page/10/Picture/7 description: In the image, there is a close-up of a metal object that appears to be a type of fastener or connector. The object has a cylindrical shape with multiple stacked sections, each slightly wider than the one below it, creating a stepped appearance. The bottom of the object features a threaded section, indicating it is designed to be screwed into a corresponding part. The overall impression is of a sturdy, machined component, possibly used in mechanical or engineering applications.
Description: lock abutment in titanium alloy. The retention grooves help to fix the acrylic material of the provisional prosthesis. Available in five diameters. See attachment nº 24 for technical details.
Use: to be used for provisional prosthesis in single restorations and for immediate-loading.
Differences from other abutments: this lock version * is for single restorations.
Sede Commerciale: Via Madonnetta, 97/C 36075 Montecchio Maggiore (VI) Tel. +39 0444 492609 - Fax +39 0444 497647 Part. IVA n. 02530390794 Indirizzo Internet: www.btlock.com e-mail info@btlock.com
II
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K083869
## PROVISIONAL ROTATIONAL ABUTMENT FOR IMMEDIATE LOAD (BTIPMR1)
Image /page/11/Picture/2 description: The image shows a metal object with a cylindrical shape. The object has a series of stacked, disc-like sections at the top, which gradually taper down to a narrower base. At the very bottom, there is a threaded screw-like component. The object appears to be a mechanical part, possibly a component used in machinery or engineering applications.
Description: rotational abutment in titanium alloy. The retention grooves help to fix the acrylic material of the provisional prosthesis. Available in five diameters. See attachment nº 25 for technical details.
Use: to be used for provisional prosthesis in multiple restorations and for immediate-loading.
Differences from other abutments: the rotational version is for multiple restorations.
Please, see attachment nº 37 for a sample of the labelling for prosthetic components (which reports information about: the product description, product code, size (diameter and length), manufacturing date, batch number, CE mark, one time use mark, details of manufacturing company) and the information sheet. For these devices gamma-ray sterilization is not necessary, this is the reason why labelling is much more simpler.
Instrumentation is exempt from 510K. Anyway, in case you need the technical drawings or some information about the accessories necessary to insert these implants, do not hesitate to contact me.
Ester Battilana BTLock S.r.l.
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Image /page/12/Picture/1 description: The image shows the seal of the U.S. Department of Health & Human Services. The seal features a stylized caduceus, a symbol often associated with medicine and healthcare. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus.
MAR 2 7 2009
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Ms. Ester Battilana BTLock s.r.1. Via Madonnetta, 97/C 36041 ALTE di MONTECCHIO MAGGIORE VICENZA, ITALY
Re: K083869
> Trade/Device Name: BT-Tite CV3. Mini Implant, Mini Single, Slot Implant Regulation Number: 21 CFR 872.3640 Regulation Name: Endosscous Dental Implant Regulatory Class: II Product Code: DZE & NHA Dated: March 18, 2009 Received: March 18, 2009
Dear Ms. Battilana:
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 ffor 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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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#### Page 2 - Battilana
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); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to procced to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Saigle Y. Michael Davis
Ginette Y. Michaud, M.D. Acting Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
#### Enclosure
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K083869
# Indications for Use
Device Name: BT-Tite CV3, Mini Implant, Mini Single, Slot Implant
Indications for Use:
BT-Tite CV3: It is intended to be used in maxilla or mandible, for post-extraction sites and where the implant would be immediately loaded. It is intended to be used in a single stage or two stage surgical procedure.
Mini Implant: It is intended to be used in maxilla or mandible for immediate and long-term stabilization of removable prosthesis.
Mini Single: It is intended to be used in maxilla or mandible in anterior narrow sites of dental arch, to replace lateral teeth, dental agenesis and inferior incisors.
Slot implant: It is intended to be used as temporary intra-oral anchorage unit in the orthodontic treatment in the superior or inferior arch or extra arch in case of edentulous patients, when necessary teeth for the anchorage are absent or the next teeth are compromised from a parodontal point of view. It facilitates the orthodontic movement of teeth. It is removed after orthodontic treatment has been completed. Slot implants are intended for single use only.
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use AND/OR (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of In Vitro Diagnostic Devices (OIVD)
Susan Turner
Page 1 of 1
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: K082869
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Learn the FDA Browser
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.