K171576 · Panthera Dental, Inc. · LRK · Feb 22, 2018 · Dental
Device Facts
Record ID
K171576
Device Name
The Panthera Anti-Snoring X3 Device
Applicant
Panthera Dental, Inc.
Product Code
LRK · Dental
Decision Date
Feb 22, 2018
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 872.5570
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Panthera Anti-Snoring X3 Device is intended to reduce or alleviate snoring and mild to moderate obstructive sleep apnea (OSA) in adults.
Device Story
The Panthera Anti-Snoring X3 Device is a custom-fit, removable intraoral mandibular repositioning device. It consists of two splints (upper and lower) fabricated via CAD/CAM and selective laser sintering. The device functions by maintaining the mandible in a forward position during sleep, which increases pharyngeal space to improve airflow. It is a push-based system featuring an adjustable clip assembly on the maxillary splint; the dentist or physician adjusts the clip length to set the degree of mandibular advancement (up to 5 mm in 1 mm increments). The device is used by patients at home during sleep. By mechanically repositioning the jaw, the device helps alleviate snoring and mild to moderate OSA, potentially improving patient sleep quality.
Clinical Evidence
No clinical testing was performed. Substantial equivalence is supported by non-clinical bench testing, including biocompatibility assessments (ISO 10993-1, -5, -10), fatigue testing of the stop-clip assembly, and 3D printing build location validation (ASTM D638, NISTIR 8059).
Technological Characteristics
Materials: Polyamide type 12 (biocompatible polymer). Fabrication: CAD/CAM and selective laser sintering. Design: Two-piece custom splint system with adjustable clip-based mandibular advancement mechanism. Dimensions: Up to 5 mm advancement, up to 6 mm vertical opening. Connectivity: None. Sterilization: Non-sterile.
Indications for Use
Indicated for adult patients with snoring and mild to moderate obstructive sleep apnea (OSA).
Regulatory Classification
Identification
Intraoral devices for snoring and intraoral devices for snoring and obstructive sleep apnea are devices that are worn during sleep to reduce the incidence of snoring and to treat obstructive sleep apnea. The devices are designed to increase the patency of the airway and to decrease air turbulence and airway obstruction. The classification includes palatal lifting devices, tongue retaining devices, and mandibular repositioning devices.
Special Controls
*Classification.* Class II (special controls). The special control for these devices is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intraoral Devices for Snoring and/or Obstructive Sleep Apnea; Guidance for Industry and FDA.”
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Panthera Dental Inc. Martine Fortin Regulatory Affairs and Quality Assurance Director 2035. rue du Haut-Bord Quebec City, G1N 4N7 Canada
February 22, 2018
#### Re: K171576
Trade/Device Name: The Panthera Anti-Snoring X3 Device Regulation Number: 21 CFR 872.5570 Regulation Name: Intraoral Devices For Snoring And Intraoral Devices For Snoring And Obstructive Sleep Apnea Regulatory Class: Class II Product Code: LRK Dated: January 26, 2018 Received: January 29, 2018
Dear Martine Fortin:
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 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);
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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# Mary S. Runner -S
for Tina Kiang, Ph.D. Acting 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)
K171576
Device Name The Panthera Anti-Snoring X3 Device
Indications for Use (Describe)
The Panthera Anti-Snoring X3 Device is intended to reduce or alleviate snoring and mild to moderate obstructive sleep apnea (OSA) in adults.
Type of Use (Select one or both, as applicable)
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) |
|----------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the logo for Panthera Dental. The logo features a black silhouette of a panther in a crouching position, ready to pounce. Below the panther, the word "PANTHERA" is written in a stylized, sans-serif font, with the word "DENTAL" underneath in a smaller font. The text is in a purple color.
## 5. 510 (k) Summary
[As required by 21 CFR 807.92]
| Date Prepared: | February 21, 2018 |
|----------------------|------------------------------------------------------------------------------------------------------------------------------|
| Submitter: | Panthera Dental Inc.<br>2035 rue du Haut-Bord<br>Québec (QC) G1N 4R7<br>Canada<br>Tel: (418) 527-0388<br>Fax: (418) 431-9942 |
| Official Contact: | Martine Fortin<br>Quality Assurance and Regulatory Affairs Director<br>regulatory@pantheradental.com<br>Tel: (418) 527-0388 |
| Device Trade Name: | Panthera Anti-Snoring X3 Device |
| Device Common Name: | Mandibular repositioning device |
| Classification: | 21 CFR 872.5570 (Class II) |
| Classification Name: | Intraoral devices for snoring and intraoral devices for<br>snoring and obstructive sleep apnea |
| Product code: | LRK |
| Primary Predicate: | The Panthera Anti-Snoring Device (K143244) |
SomnoDent Flex™ (K073004) Reference Devices: DynaFlex Anti-Snoring & Sleep Apnea Devices (K103076) MicrO2 Obstructive Sleep Apnea Device (K133683)
Description: The Panthera Anti-Snoring X3 Device is a removable intraoral device used for treating snoring and mild to moderate obstructive sleep apnea. It consists of two customized splints that fit separately over the upper and lower teeth.
The device functions as a mandibular repositioner, maintaining the lower jaw in a forward position during sleep. This mechanical protrusion acts to increase the patient's pharvngeal space, improving their ability to exchange air during sleep.
K171576
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Image /page/4/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black silhouette of a panther in a crouching position, with its tail curled upwards. Below the panther, the word "PANTHERA" is written in a bold, sans-serif font, with a purple line underneath it. Below "PANTHERA", the word "DENTAL" is written in a smaller, sans-serif font.
The device is a prescription customized for each patient and has an adjustment mechanism enabling the amount of mandibular advancement to be set by the dentist or physician at the time of fitting the device. The maximum protrusion of the device is 5 mm in 1 mm increments.
Indications for Use: The Panthera Anti-Snoring X3 Device is intended to reduce or alleviate snoring and mild to moderate obstructive sleep apnea (OSA) in adults.
Technological: The following table displays the differences and similarities between the Panthera Anti-Snoring X3 Device and four (4) other previously marketed devices. Equivalence is based on similarities in indications for use, materials of construction, design, operating principles, etc.
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Image /page/5/Picture/0 description: The image shows a black panther above the words "PANTHERA DENTAL" in purple. The panther is in a crouching position, with its tail curled up. The word "PANTHERA" is in a larger font than the word "DENTAL", and there is a horizontal line above the word "DENTAL".
Table 5.1: Comparison chart between the submitted device and the predicates.
| | The Panthera Anti-<br>Snoring X3 Device | Primary Predicate<br>The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | Reference Devices | | | |
|---------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------|--|
| Feature | | | | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | | |
| Picture of the<br>device | Image: The Panthera Anti-Snoring X3 Device | Image: The Panthera Anti-Snoring Device | Image: SomnoDent Flex | Image: DynaFlex Anti-Snoring & Sleep Apnea Devices | Image: MicrO2 Obstructive Sleep Apnea Device | N/A | |
| Regulation<br>description | Intraoral device for<br>snoring and<br>obstructive sleep<br>apnea | Intraoral device for<br>snoring and<br>obstructive sleep<br>apnea | Intraoral device for<br>snoring and<br>obstructive sleep<br>apnea | Intraoral devices for<br>snoring and<br>obstructive sleep<br>apnea | Intraoral device for<br>snoring and<br>obstructive sleep<br>apnea | Same for all | |
| Class | Class II | Class II | Class II | Class II | Class II | Same for all | |
| Indications<br>for Use | To reduce or alleviate<br>snoring and mild to<br>moderate obstructive<br>sleep apnea (OSA) in<br>adults | To reduce or alleviate<br>snoring and mild to<br>moderate obstructive<br>sleep apnea (OSA) in<br>adults | To reduce or alleviate<br>night time snoring and<br>mild to moderate<br>obstructive sleep<br>apnea | To reduce night time<br>snoring and mild to<br>moderate obstructive<br>sleep apnea (OSA) in<br>adults.<br>The devices are worn<br>while sleeping to<br>support the lower jaw | To reduce night time<br>snoring and mild to<br>moderate obstructive<br>sleep apnea (OSA) in<br>adults. | Same as<br>primary<br>predicate and<br>similar to the<br>reference<br>predicates | |
| | | Primary Predicate | Reference Devices | | | | |
| Feature | The Panthera Anti-<br>Snoring X3 Device | The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | | |
| | | | | in a forward position<br>prescribed by the<br>dentist, and is<br>removable by the<br>patient | | | |
| Materials of<br>construction | Made from polymers<br>(polyamide type 12),<br>supplied by EOS.<br>The device is metal-<br>free.<br>Highly resilient and<br>durable biocompatible<br>polymer material | Made from polymers<br>(polyamide type 12),<br>supplied by EOS.<br>The device is metal-<br>free.<br>Highly resilient and<br>durable biocompatible<br>polymer material | Made from SMH<br>BFlex which is a<br>proprietary soft<br>polymer that is<br>molecularly bonded to<br>the device's hard<br>surface acrylic.<br>Includes two metal<br>screws in the<br>maxillary appliance | Made from hard<br>acrylic outer shell and<br>soft vinyl liner inside.<br>Includes two metal<br>screws in the<br>maxillary appliance | Hard PMMA material | Same as<br>primary<br>predicate | |
| Design | Uses computer-aided<br>design (CAD) and<br>computer-aided<br>manufacturing<br>(CAM).<br>Uses CAD that<br>enables a high degree<br>of customization<br>according to the | Uses computer-aided<br>design (CAD) and<br>computer-aided<br>manufacturing<br>(CAM).<br>Uses CAD that<br>enables a high degree<br>of customization<br>according to the | Information not found | Information not found | Uses computer-aided<br>design (CAD) and<br>computer-aided<br>manufacturing<br>(CAM). | CAD/CAM<br>same as<br>primary<br>predicate and<br>Micro2 | |
| | | Primary Predicate | Reference Devices | | | | |
| Feature | The Panthera Anti-<br>Snoring X3 Device | The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | | |
| | physician or dentist<br>prescription.<br>The CAM and<br>selective laser<br>sintering guarantee<br>precision, accuracy<br>and consistency for<br>each patient. | physician or dentist<br>prescription.<br>The CAM and<br>selective laser<br>sintering guarantee<br>precision, accuracy<br>and consistency for<br>each patient. | | | | | |
| | Two customized<br>splints that fit<br>separately over the<br>upper and lower teeth<br>inside the mouth. | Two customized<br>splints that fit<br>separately over the<br>upper and lower teeth<br>inside the mouth. | Two customized<br>splints that fit<br>separately over the<br>upper and lower teeth<br>inside the mouth. | Two customized<br>splints that fit<br>separately over the<br>upper and lower teeth<br>inside the mouth. | Two customized<br>splints that fit<br>separately over the<br>upper and lower teeth<br>inside the mouth. | Same for all<br>(customized<br>splints) | |
| | The mandible splint<br>contains wing<br>protrusions that<br>interface with the<br>incline blocks built<br>into the buccal of the<br>maxillary splint | The mandible splint<br>contains triangular<br>protrusions allowing<br>the splints to engage<br>by means of<br>interlocking rods on<br>the side. | The mandible splint<br>contains triangular<br>protrusions that<br>interface with the<br>incline blocks built<br>into the buccal of the<br>maxillary splint | The mandible splint<br>contains triangular<br>protrusions that<br>interface with the<br>incline blocks built<br>into the buccal of the<br>maxillary splint | The mandible splint<br>contains protrusions<br>that interface with the<br>block built into the<br>buccal of the<br>maxillary splint | Similar to<br>SomnoDent<br>and DynaFlex<br>which use<br>screw instead<br>of clip;<br>Similar to<br>primary<br>predicate<br>which uses | |
| | | Primary Predicate | Reference Devices | | | | |
| Feature | The Panthera Anti-<br>Snoring X3 Device | The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | | |
| • Upper<br>splint | Bears on the posterior<br>teeth | Bears on the posterior<br>teeth | Stops after the first<br>molar, sometimes<br>after the second<br>premolar | Information not found | Information not found | rods instead of<br>clip<br>Same as<br>primarv<br>predicate | |
| • The<br>orientation of<br>the wings on<br>the lower<br>splint | Two wings at either<br>70°, 90° or 110°<br>(depending on the<br>model device chosen) | Two wings at 110° | Two wings at 70° | Two wings at 70° for<br>the Dorsal and 110°<br>for the Dorsal AirPlus | Two wings at 90° | Same as<br>predicates | |
| • Occlusion<br>trays | It stops after premolar<br>teeth | It stops after premolar<br>teeth | It covers the entire<br>occlusal surface of<br>upper and lower<br>retainers | It covers the entire<br>occlusal surface of<br>upper and lower<br>retainers | Information not found | Same as<br>primarv<br>predicate | |
| Principle of<br>operation/<br>means of<br>mandibular<br>advancement | Adjustment of the<br>relative position of the<br>splints guides the<br>mandible forward and<br>maintains<br>advancement thus<br>enlarging the airway. | Adjustment of the<br>relative position of the<br>splints guides the<br>mandible forward and<br>maintains<br>advancement thus<br>enlarging the airway. | Adjustment of the<br>relative position of the<br>splints guides the<br>mandible forward and<br>maintains<br>advancement thus<br>enlarging the airway. | Adjustment of the<br>relative position of the<br>splints guides the<br>mandible forward and<br>maintains<br>advancement thus<br>enlarging the airway. | Adjustment of the<br>relative position of the<br>splints guides the<br>mandible forward and<br>maintains<br>advancement thus<br>enlarging the airway. | Same for all | |
| | | Primary Predicate | Reference Devices | | | | |
| Feature | The Panthera Anti-<br>Snoring X3 Device | The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | | |
| | The vertical opening<br>of the jaw is not fixed<br>in a single position | The vertical opening<br>of the jaw is not fixed<br>in a single position. | The vertical opening<br>of the jaw is not fixed<br>in a single position | The vertical opening<br>of the jaw is not fixed<br>in a single position | The vertical opening<br>of the jaw is not fixed<br>in a single position | | |
| | Push-based<br>mandibular<br>repositioning device,<br>allows for nasal and/or<br>oral breathing | Traction-based<br>mandibular<br>repositioning device,<br>allows for nasal and/or<br>oral breathing | Push-based<br>mandibular<br>repositioning device,<br>allows for nasal and/or<br>oral breathing | Push-based<br>mandibular<br>repositioning device,<br>allows for nasal and/or<br>oral breathing | Push-based<br>mandibular<br>repositioning device,<br>allows for nasal and/or<br>oral breathing | Same as<br>reference<br>predicates | |
| Fixed/<br>removable | Removable | Removable | Removable | Removable | Removable | Same for all | |
| Adjustment | Adjusted via the<br>adjustable clip<br>assembly placed on<br>each side of the<br>maxillary splint. The<br>longer the stop-clip is,<br>the further the<br>mandible is advanced.<br>The dentist can select<br>a longer stop-clip until<br>optimal advancement<br>is achieved. | Adjusted via the use<br>of interlocking rods<br>placed on each side of<br>the mandible splint.<br>The shorter the rod,<br>the further the<br>mandible is advanced.<br>The dentist can select<br>a shorter connecting<br>rod until optimal<br>advancement is<br>achieved. | Adjusted via the use<br>of the supplied<br>adjustment key when<br>inserting it in the<br>adjustable screw. The<br>adjustable screws are<br>placed on each side of<br>the maxillary splint.<br>The more it is<br>unscrewed, the further<br>the mandible is<br>advanced. The dentist<br>can select the proper | Adjusted via the use<br>of the supplied<br>adjustment key when<br>inserting it in the<br>adjustable screw. The<br>adjustable screws are<br>placed on each side of<br>the maxillary splint.<br>The more it is<br>unscrewed, the further<br>the mandible is<br>advanced. The dentist<br>can select the proper | Advancements can be<br>achieved by simply<br>removing the current<br>upper or lower device<br>and inserting the next<br>upper or lower device<br>in the mandibular<br>advancing series. | Similar to<br>SomnoDent<br>and DynaFlex<br>predicates | |
| | The Panthera Anti-<br>Snoring X3 Device | Primary Predicate | Reference Devices | | | | |
| Feature | The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | | | |
| | Image: The Panthera Anti-Snoring X3 Device | | until optimal<br>advancement is<br>achieved.<br>Image: SomnoDent Flex | until optimal<br>advancement is<br>achieved.<br>Image: DynaFlex Anti-Snoring & Sleep Apnea Devices | Image: MicrO2 Obstructive Sleep Apnea Device | | |
| Mandibular<br>adjustment | Performed by dentist<br>or physician | Performed by dentist<br>or physician | Performed by dentist<br>or physician | Performed by dentist<br>or physician | Information not found | Same for all | |
| Mandibular<br>advancement<br>range | Up to 5 mm at 1 mm<br>increments | Up to 15 mm at 1 mm<br>increments | Up to 6.0 mm at 0.1<br>mm increments | Information not found | Up to 6.0 mm | Similar to<br>predicates<br>except<br>DynaFlex | |
| Supplied<br>sterile/non<br>sterile | Non sterile | Non sterile | Non sterile | Non sterile | Non sterile | Same for all | |
| Target<br>population | Adult patients | Adult patients | Adult patients | Adult patients | Adult patients | Same for all | |
| Single Use/<br>reusable | Reusable | Reusable | Reusable | Reusable | Reusable | Same for all | |
| Vertical<br>opening | Up to 6 mm | Up to 4 mm | Up to 4 mm | Information not found | Information not found | Similar to the<br>primary | |
| Feature | The Panthera Anti-<br>Snoring X3 Device | Primary Predicate | The Panthera Anti-<br>Snoring Device<br>(K143244) | SomnoDent Flex™<br>(K073004) | DynaFlex Anti-<br>Snoring & Sleep<br>Apnea Devices<br>(K103076) | MicrO2 Obstructive<br>Sleep Apnea Device<br>(K133683) | |
| Prescription/<br>OTC | Prescription only | Prescription only | Prescription only | Prescription only | Prescription only | Same for all | |
| Cleaning and<br>Maintenance | Clean daily in<br>lukewarm water with<br>a soft toothbrush.<br>Rinse, dry and store in<br>case provided. Twice<br>a week use<br>antibacterial<br>orthodontic cleansing<br>solution that are<br>chlorine-free | Clean daily in<br>lukewarm water with<br>a soft toothbrush.<br>Rinse, dry and store in<br>case provided. Twice<br>a week use<br>antibacterial<br>orthodontic cleansing<br>solution that are<br>chlorine-free | Clean daily in cold or<br>lukewarm water with<br>the brush provided or<br>a soft toothbrush and<br>mild detergent. Rinse,<br>dry, and store in case<br>provided. | Information not found | Clean daily | Same as<br>primary<br>predicate | |
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Image /page/6/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black silhouette of a panther in a crouching position, with its tail curled upwards. Below the panther is the word "PANTHERA" in a bold, sans-serif font, with the word "DENTAL" underneath in a smaller font.
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Image /page/7/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black panther in a crouching position above the words "PANTHERA DENTAL" in purple. The word "PANTHERA" is in a larger font than the word "DENTAL", and the two words are stacked on top of each other.
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Image /page/9/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black silhouette of a panther in a stalking pose, with its tail curled upwards. Below the panther is the text "PANTHERA" in a bold, sans-serif font, with the word "DENTAL" underneath in a smaller font.
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Image /page/10/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black panther in a crouching position, with its tail curved upwards. Below the panther, the word "PANTHERA" is written in a purple, sans-serif font, with the word "DENTAL" written in a smaller font size below it.
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Image /page/11/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black panther in a stalking pose above the words "PANTHERA DENTAL" in a stylized font. The word "PANTHERA" is in a larger font and a purple color, while "DENTAL" is in a smaller font and a darker color.
Confidential
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Image /page/12/Picture/0 description: The image shows a logo for a dental company called Panthera Dental. The logo features a black panther in a crouching position, with its tail curled up. Below the panther is the word "PANTHERA" in a stylized purple font, with the word "DENTAL" in a smaller font underneath.
Non-Clinical Testing: The non-clinical testing includes assessment of the physical properties of the Panthera Anti-Snoring X3 Device and its ability to achieve its intended use. The Panthera Anti-Snoring X3 Device meets criteria to support substantial equivalence to the primary and reference predicate devices. The Panthera Anti-Snoring X3 Device and the Panthera Anti-Snoring Device are substantially equivalent based on the fact that both devices use the same raw material, have the same indications for use, type and duration of patient contact as well as the same Selective Laser Sintering fabrication process including the proprietary manufacturing. Therefore, the performance testing provided in the primary predicate submission K143244 (Panthera Anti-Snoring Device) serves in lieu of performing the two (2) performance tests for the proposed device: orthosis polishing and static and dynamic compression resistance. A test was conducted to determine the build locations for 3-D printing in accordance with the FDA Guidance Document, Technical Considerations for Additive Manufactured Medical Devices and following the standards ASTM D638 and NISTIR 8059.
Biocompatibility: A biocompatibility assessment of the device was performed. The purpose of this assessment was to ensure that biocompatibility had been established for the proposed device following the standards of ISO 14971, ISO 10993-1, ISO 10993-5 and ISO 10993-10. The Panthera Anti-Snoring X3 Device is biocompatible, based on the use of the same materials of construction, the same supplier and the same proprietary manufacturing process as the primary predicate device, the Panthera Anti-Snoring Device, marketed by Panthera Dental Inc.
Fatigue Testing: Considering that the mechanism of action for the protrusion of the lower iaw is different between the Panthera AS X3 and the mechanism of the Panthera AS, performance testing were conducted on the stop-clip system assembly. The results have demonstrated that the Panthera AS X3 has sufficient mechanical strength for its intended clinical application.
Clinical Testing: Human clinical study was not deemed necessary to support substantial equivalence. The Panthera AS X3 does not use design dissimilar from the reference predicate devices, does not use new technologies different from the primary and reference predicate devices, and does not deviate from the indications for use identified in the primary and reference predicate devices.
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Image /page/13/Picture/0 description: The image shows a logo for Panthera Dental. The logo features a black panther in a crouching position above the words "PANTHERA DENTAL" in purple. The word "PANTHERA" is in a larger font than the word "DENTAL". The panther is facing left and has a long, curved tail.
Substantial Equivalence Conclusion: The Panthera Anti-Snoring X3 Device is considered to be substantially equivalent to the primary predicate and any differences have been identified in other previously cleared reference devices and do not impact safety and effectiveness.
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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.