K213201 · DMG Chemisch-Pharmazeutische Fabrik GmbH · EMA · Jun 1, 2022 · Dental
Device Facts
Record ID
K213201
Device Name
DeltaFil, DeltaFil Conditioner
Applicant
DMG Chemisch-Pharmazeutische Fabrik GmbH
Product Code
EMA · Dental
Decision Date
Jun 1, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3275
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
DeltaFil (in capsule) is used for geriative filling procedures. The procedures. The product is designed for use in final restorations of Class I, II, III, and V of deciduous teeth and as a long - term restorative in non-load bearing areas of Class I and II carious lesions. It is also used as a restorative and sandwich material for heavy stress in Class I and II cavities. DeltaFil can also be used as a core build-up material. DeltaFil Conditioner: - Treatment of the smear layer · Conditioning of the cavity
Device Story
DeltaFil is a radiopaque glass ionomer restorative material supplied in disposable capsules; used with a compatible 10% aqueous polyacrylic acid conditioner. The conditioner is applied to the prepared tooth surface to remove the smear layer and condition the cavity, improving the adhesive bond between tooth tissue and the restorative cement. The restorative material is a two-part powder/liquid glass polyalkenoate cement mixed in a standard dental capsule dispenser. Used in dental offices/clinics by dental professionals for permanent or temporary restorations. The device provides a restorative filling or core build-up, benefiting patients by restoring tooth structure and function in carious lesions or cavities. The healthcare provider applies the conditioner, then the mixed cement, to the prepared cavity.
Clinical Evidence
Bench testing only. Performance data confirmed compliance with ISO 9917-1:2007 for water-based cements, including compressive strength (≥ 180 MPa), radiopacity (200 %Al), acid erosion (≤ 0.1 mm), and acid-soluble lead content (≤ 100 ppm). Shear bond strength on dentin (4.9 ± 1.3 MPa) and enamel (13.6 ± 2.4 MPa) was evaluated. Biocompatibility was assessed per ISO 10993.
Technological Characteristics
Two-part powder/liquid glass polyalkenoate restorative cement (ISO 9917-1:2007) and 10% aqueous polyacrylic acid conditioner. Supplied in disposable 'Applicap' capsules for use with a mechanical capsule dispenser. Radiopaque. Non-sterile. No software or electrical components.
Indications for Use
Indicated for geriatric and pediatric restorative filling procedures, including final restorations of Class I, II, III, and V of deciduous teeth, long-term restoration of non-load bearing Class I and II carious lesions, heavy stress Class I and II cavities (as restorative/sandwich material), and core build-ups.
Regulatory Classification
Identification
Zinc oxide-eugenol is a device composed of zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp. Dental cement other than zinc oxide-eugenol is a device composed of various materials other than zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.
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DMG Chemisch-Pharmazeutische Fabrik GmbH Pamela Papineau Consultant Delphi Medical Device Consulting, Inc. 5 Whitcomb Ave Ayer, Massachusetts 01432
## Re: K213201
Trade/Device Name: DeltaFil, DeltaFil Conditioner Regulation Number: 21 CFR 872.3275 Regulation Name: Dental Cement Regulatory Class: Class II Product Code: EMA Dated: April 21, 2022 Received: April 27, 2022
## Dear Pamela Papineau:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For Michael E. Adjodha, M.ChE. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K213201
Device Name DeltaFil, DeltaFil Conditioner
#### Indications for Use (Describe)
DeltaFil (in capsule) is used for geriative filling procedures. The procedures. The product is designed for use in final restorations of Class I, II, III, and V of deciduous teeth and as a long - term restorative in non-load bearing areas of Class I and II carious lesions. It is also used as a restorative and sandwich material for heavy stress in Class I and II cavities. DeltaFil can also be used as a core build-up material.
DeltaFil Conditioner:
- Treatment of the smear layer
· Conditioning of the cavity
| Type of Use (Select one or both, as applicable) | <div> <input type="checkbox"/> </div> <div> <input type="checkbox"/> </div> |
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> Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
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## K213201
## DeltaFil 510(k) Summary (revised)
| General Information | |
|-------------------------|------------------------------------------------------------------------|
| Preparation date: | 31 May 2022 |
| Owner's Name: | DMG Chemisch-Pharmazeutische Fabrik GmbH<br>(FDA Registration 8044164) |
| Address: | Elbgaustrasse 248<br>22547 Hamburg<br>Germany |
| Telephone Number: | 011-49-40-84006-0 |
| Fax Number: | 011-49-40-84006-222 |
| Contact Person: | Stephan Schaefer |
| Subject Device Name: | DeltaFil |
| Trade Name: | DeltaFil, DeltaFil Conditioner |
| Common/Usual Name: | Dental Cement and Conditioner |
| Product Codes: | EMA |
| Regulations: | 21 CFR 872.3275 (Dental Cement) |
| Device Classification: | II |
| Predicate Devices: | |
| Trade Name: | Fuji IX GP (GC America, Inc.) |
| Common/Usual Name: | Dental Cement |
| Product Code: | EMA |
| Regulation: | 21 CFR 872.3275 (Dental Cement) |
| Device Classification: | II |
| Premarket Notification: | K961448 |
| Trade Name: | Ketac Conditioner (3M ESPE GmbH) |
| Common/Usual Name: | Tooth Conditioner |
| Product Code: | EMA |
| Regulation: | 21 CFR 872.3275 (Dental Cement) |
| Device Classification: | II |
| Premarket Notification: | K872984 |
| Reference Device: | |
| Trade Name: | DiaEtch (Diadent Group International) |
| Common/Usual Name: | Resin Tooth Bonding Agent |
| Product Code: | KLE |
| Regulation: | 21 CFR 872.3200 (Resin Tooth Bonding Agent) |
| Device Classification: | II |
| Premarket Notification: | K192273 |
| Device Description | |
DeltaFil consists of a radiopaque glass ionomer restorative material supplied in capsule form (DeltaFil in capsule), and a compatible tooth conditioner (DeltaFil Conditioner). DeltaFil Conditioner
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and DeltaFil (in capsule) are used together for the creation of permanent or temporary dental restorations as described in the device labelling. DeltaFil is available in Vita shades A1, A2, A3, A3.5, and A4.
DeltaFil (in capsule) is a two-part powder/liguid glass polyalkenoate restorative cement as defined in ISO 9917-1:2006 Dentistry - Water-Based Cements - Part 1: powder/liquid acid-base cements. The powder and liquid components are supplied in the correct mixing ratio in disposable "Applicap" capsules for use with the DMG Applicap Dispenser. DeltaFil Conditioner is a 10% aqueous polyacrylic acid solution, which is applied to the prepared tooth surface prior to placement of the mixed DeltaFil (in capsule) material. DeltaFil Conditioner improves the adhesive bond between the tooth tissue and the restorative cement material by treating the smear layer and conditioning the prepared cavity.
## Indications for Use
DeltaFil (in capsule) is used for geriatric and pediatric restorative filling procedures. The product is designed for use in final restorations of Class I, II, III, and V of deciduous teeth and as a long - term restorative in non-load bearing areas of Class I and II carious lesions. It is also used as a restorative and sandwich material for heavy stress in Class I and II cavities. DeltaFil can also be used as a core build-up material.
DeltaFil Conditioner:
- Treatment of the smear layer ●
- . Conditioning of the cavity
Substantial Equivalence / Comparison of Technical Characteristics with the Predicate Device The predicate devices are the GC Fuji IX GP cleared in K961448, and the 3M Espe Ketac Conditioner cleared in K872984. A summary comparison of the subject and predicate device systems is provided in the substantial equivalence table below.
| Attribute | Proposed Device<br>DMG DeltaFil (in capsule)<br>(current submission) | Predicate Device<br>GC Fuji IX GP (K961448) | Similarities and<br>Differences |
|--------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|
| Common Name | Restorative Dental Cement<br>and Tooth Conditioner | Restorative Dental Cement and<br>Tooth Conditioner | Same |
| Classification<br>Name | Dental Cement | Dental Cement | Same |
| Device Class | II | II | Same |
| Regulation | 21 CFR 872.3275 | 21 CFR 872.3275 | Same |
| Regulation<br>Name | Dental Cement | Dental Cement | Same |
| Product Code | EMA | EMA | Same |
| Attribute | Proposed Device<br>DMG DeltaFil (in capsule)<br>(current submission) | Predicate Device<br>GC Fuji IX GP (K961448) | Similarities and<br>Differences |
| Indications<br>for Use | DeltaFil (in capsule) is used for geriatric and pediatric restorative filling procedures. The product is designed for use in final restorations of Class I, II, III, and V of deciduous teeth and as a long - term restorative in non-load bearing areas of Class I and II carious lesions. It is also used as a restorative and sandwich material for heavy stress in Class I and II cavities. DeltaFil can also be used as a core build-up material. | GC Fuji IX GP is used for geriatric and pediatric restorative filling procedures. The product is designed for use in final restorations of Class I, II, III, and V of deciduous teeth and as a long - term restorative in non-load bearing areas of Class I and II carious lesions. It is also used as an immediate restorative and sandwich material for heavy stress in Class I and II cavities. FUJI IX GP can also be used as a core build-up material. | Same |
| Use<br>Environment | Dental office/clinic | Dental office/clinic | Same |
| Material<br>Composition | Radiopaque glass ionomer cement supplied in capsules | Radiopaque glass ionomer cement supplied in capsules | Same |
| Principle of<br>Operation | DeltaFil (in capsule) is a two-part powder-liquid glass ionomer polyalkenoate restorative dental cement as defined in ISO 9917-1:2007 <i>Dentistry – Water-Based Cements – Part 1:</i> powder/liquid acid-base cements. DeltaFil Conditioner is applied to condition the prepared tooth surface prior to placement of the mixed DeltaFil Capsule material. | GC Fuji IX GP is a two-part powder-liquid glass ionomer polyalkenoate restorative dental cement as defined in ISO 9917-1:2007 <i>Dentistry – Water-Based Cements – Part 1:</i> powder/liquid acid-base cements. | Same |
| Supplied in<br>Mixing<br>Capsules? | Yes | Yes | Same |
| Capsule<br>Dispenser<br>Available? | Yes | Yes | Same |
| Powder:Liquid<br>Ratio | 4.96:1 | 0.40:0.11 | Similar |
| Mixing Time<br>(sec) | 10 | 10 | Same |
| Attribute | Proposed Device<br>DMG DeltaFil (in capsule)<br>(current submission) | Predicate Device<br>GC Fuji IX GP (K961448) | Similarities and<br>Differences |
| Working Time<br>(min.) at 23°C,<br>inclusive of<br>mixing time (sec) | 120 | 120 | Same |
| Net Setting Time<br>(max.) at 37°C,<br>exclusive of<br>mixing time (sec) | 240 | 140 | Similar |
| Compressive<br>Strength (MPa)<br>(after 24 hrs) | $\ge$ 180 | 220 | Similar; both meet<br>ISO 9917-1<br>requirement ( $\ge$ 100<br>MPa) |
| Radiopacity | 200 %Al | 3.7 mm | Similar; both meet<br>ISO 9917-1<br>requirement (200 %Al<br>= 2 mm) |
| Acid Erosion<br>(mm) | $\le$ 0.1 | 0.21 | Similar; DeltaFil<br>meets ISO 9917-1<br>requirement ( $\le$ 0.17<br>mm) |
| Shear Bond<br>Strength on<br>Dentin (MPa)<br>(after 24 hrs) | 4.9 ± 1.3 | 5.1 ± 2.1 | Similar for samples<br>prepared with<br>compatible<br>Conditioner; no<br>applicable ISO 9917-1<br>requirement |
| Shear Bond<br>Strength on<br>Enamel (MPa)<br>(after 24 hrs) | 13.6 ± 2.4 | 11.8 ± 7.7 | Similar for samples<br>prepared with<br>compatible<br>Conditioner; no<br>applicable ISO 9917-1<br>requirement |
| Acid Soluble<br>Lead Content<br>(ppm) | $\le$ 100 | unknown | Similar; DMG<br>material meets ISO<br>9917-1 requirement ( $\le$<br>100 ppm) |
| Opacity C0,70<br>(%) | 0.35 – 0.9 | unknown | Similar; DMG<br>material meets ISO<br>9917-1 requirement<br>(0.35 – 0.9 %) |
| Biocompatibility | ISO 10993 | ISO 10993 | Same |
| Single Use /<br>Reusable | Single Use | Single Use | Same |
| Sterilization /<br>Reprocessing<br>Software | Non-sterile device; no<br>reprocessing requirements<br>Device does not contain<br>software | Non-sterile device; no<br>reprocessing requirements<br>Device does not contain<br>software | Same |
| Attribute | Proposed Device<br>DMG DeltaFil (in capsule)<br>(current submission) | Predicate Device<br>GC Fuji IX GP (K961448) | Similarities and<br>Differences |
| Electrical Safety<br>& EMC | Not applicable | Not applicable | Same |
## Substantial Equivalence Comparison Table: DeltaFil (in capsules)
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## Substantial Equivalence Comparison Table: DeltaFil Conditioner
| | Proposed Device | Predicate Device | Similarities and |
|-----------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Attribute | DeltaFil Conditioner<br>(current submission) | 3M Espe Ketac Conditioner<br>(K872984) | Differences |
| Common Name | Tooth Conditioner | Tooth Conditioner | Same |
| Classification<br>Name | Dental Cement | Dental Cement | Same |
| Device Class | II | II | Same |
| Regulation | 21 CFR 872.3275 | 21 CFR 872.3275 | Same |
| Regulation<br>Name | Dental Cement | Dental Cement | Same |
| Product Code | EMA | EMA | Same |
| Indications<br>for Use | • Treatment of the smear layer<br>• Conditioning of the cavity | Dentin pretreatment prior to<br>filling with glass ionomer<br>cement | Same |
| Use Environment | Dental office/clinic | Dental office/clinic | Same |
| Material<br>Composition | 10% aqueous polyacrylic acid<br>Blue colorant | 20 - 30% aqueous polyacrylic<br>acid<br>Blue colorant | Same |
| Principle of<br>Operation | DeltaFil Conditioner improves<br>the adhesive bond between the<br>tooth tissue and the restorative<br>cement material by treating the<br>smear layer and conditioning the<br>prepared cavity. | Ketac Conditioner improves the<br>adhesive bond between the tooth<br>tissue and the restorative cement<br>material by treating the smear<br>layer and conditioning the<br>prepared cavity. | Same |
| Technological<br>Characteristics | Mild PAA acid solution applied<br>to the prepared tooth surface<br>removes the smear layer,<br>thereby improving direct contact<br>between the restorative material<br>and intact dentin structure.<br>Evidence is demonstrated<br>through increased bond strength<br>for finished DeltaFil restorations<br>using DeltaFil Conditioner. | Mild PAA acid solution applied<br>to the prepared tooth surface<br>removes the smear layer,<br>thereby improving direct contact<br>between the restorative material<br>and intact dentin structure. | Same |
| Shear Bond Strength<br>on Dentin* | $4.9 \pm 1.3$ (with Conditioner)<br>$4.4\pm 3.7$ (without Conditioner) | $5.1 \pm 2.1$ (with Conditioner*)<br>$6.5 \pm 1.5$ (without Conditioner) | Similar |
| | Proposed Device | Predicate Device | Similarities and<br>Differences |
| Attribute | DeltaFil Conditioner<br>(current submission) | 3M Espe Ketac Conditioner<br>(K872984) | |
| Shear Bond Strength<br>on Enamel* | $13.6 \pm 2.4$ (with Conditioner)<br>$13.6 \pm 6.5$ (without Conditioner) | $11.8 \pm 7.7$ (with Conditioner*)<br>$10.6 \pm 4.5$ (without Conditioner) | Similar |
| Biocompatibility | ISO 10993 | ISO 10993 | Same except for blue<br>colorant. Reference<br>device K192273<br>(Diadent DiaEtch)<br>used to confirm<br>biological safety of<br>methylene blue<br>colorant. |
| Single Use /<br>Reusable | Single Use | Single Use | Same |
| Sterilization /<br>Reprocessing | Non-sterile device; no<br>reprocessing requirements | Non-sterile device; no<br>reprocessing requirements | Same |
| Software | Device does not contain<br>software | Device does not contain<br>software | Same |
| Electrical Safety &<br>EMC | Not applicable | Not applicable | Same |
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* Predicate SBS data for GC Fuji IX GP with and without the compatible GC Cavity Conditioner
## Non-clinical Performance Testing
Performance data demonstrated that DeltaFil (in capsule) and DeltaFil Conditioner meet all predetermined acceptance criteria contained in the product specification and are suitable for their intended use. The risks associated with the use of the new devices were found acceptable when evaluated in accordance with ISO 14971. Risks and benefits associated with the proposed and the predicate device are the same. Design verification and validation activities consisted of physical testing, biocompatibility evaluation, and stability (shelf life) validation.
## Comparison of Technological Characteristics with the Predicate Devices
The general material type, intended use, and performance specifications of DeltaFil (in capsule) and DeltaFil Conditioner are substantially equivalent to the predicate devices, GC Fuji IX GP and 3M Espe Ketac Conditioner. DeltaFil (in capsule) and GC Fuji IX GP are two-part powder-liquid glass ionomer polyalkenoate restorative dental cement as defined in ISO 9917-1:2007 Dentistry - Water-Based Cements – Part 1: powder/liquid acid-base cements. Both DeltaFil (in capsule) and GC Fuji IX GP are supplied in capsules that are briefly mixed by the user in a standard dental capsule mixer prior to dispensing.
DeltaFil Conditioner and 3M Espe Ketac Conditioner are both mild, blue-tinted aqueous solutions of polyacrylic acid intended to enhance the bond between the glass ionomer restorative cement and the tooth surface by treating the smear layer to condition the cavity. DeltaFil Conditioner is intended for use prior to the application of DeltaFil (in capsule). The Diadent DiaEtch cleared in K192273 is cited
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as a reference device to confirm biological safety for methlylene blue pigment used to enhance the visibility of dental cavity pretreatments.
## Conclusion
The DMG Chemisch-Pharmazeutische Fabrik GmbH DeltaFil (in capsule) and DeltaFil Conditioner meet all pre-determined acceptance criteria of the testing performed to confirm substantial equivalence to the predicate devices.
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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.