Stratasys TrueDent™ is a light-curable resin indicated for the fabrication of dental appliances including removable full and partial dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays, and veneers in dental laboratories. The material is an alternative to traditional heat-curable and auto polymerizing resins. Stratasys TrueDent™ is intended exclusively for professional dental work.
Device Story
Stratasys TrueDent is a light-curable, methacrylate-based resin for additive manufacturing of dental appliances (dentures, crowns, bridges, etc.). Used in dental laboratories by trained professionals. Input: digital dental files from impressions. Process: Stratasys J5 Series 3D printer (PolyJet drop-on-demand inkjet technology) jets photopolymer droplets; UV LED (395nm) curing; multi-color resin mixing allows simultaneous printing of aesthetic denture bases and teeth. Output: monolithic dental appliance, post-processed in TrueDent Cure chamber. Benefits: eliminates secondary manual coloring steps; provides high-quality, aesthetic, functional restorations. Healthcare providers use output for patient try-in and final adjustment.
Clinical Evidence
Bench testing only. No clinical data. Performance evaluated via ISO 20795, ISO 4049, and ISO 10477 standards for flexural strength, flexural modulus, sorption, and solubility. Biocompatibility evaluated per ISO 10993-1 and ISO 7405 (cytotoxicity, sensitization, irritation, systemic toxicity, implantation, genotoxicity). Additive manufacturing validation performed per FDA guidance.
Technological Characteristics
Methacrylate-based light-curable resin. Additive manufacturing (PolyJet drop-on-demand inkjet). UV LED (395nm) curing. Non-sterile. 5 base colors (clear, white, cyan, magenta, yellow). Compatible with Stratasys J5 Series printers and TrueDent Cure chamber. Standards: ISO 10477, ISO 4049, ISO 20795.
Indications for Use
Indicated for dental laboratory fabrication of removable full/partial dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays, and veneers. Intended for professional dental use as an alternative to traditional heat-curable/auto-polymerizing resins.
Regulatory Classification
Identification
A denture relining, repairing, or rebasing resin is a device composed of materials such as methylmethacrylate, intended to reline a denture surface that contacts tissue, to repair a fractured denture, or to form a new denture base. This device is not available for over-the-counter (OTC) use.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the FDA logo is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
July 7, 2022
Stratasys Ltd % Melissa Burbage Senior Regulatory Specialist PaxMed International, LLC 12264 El Camino Real, Suite 400 San Diego, California 92130
Re: K220771
Trade/Device Name: Stratasys TrueDent Regulation Number: 21 CFR 872.3760 Regulation Name: Denture Relining, Repairing, Or Rebasing Resin Regulatory Class: Class II Product Code: EBI, EBG, PZY, EBF Dated: April 7, 2022 Received: April 8, 2022
Dear Melissa Burbage:
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
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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) 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 (OS) 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) K220771
Device Name
Stratasys TrueDent™
Indications for Use (Describe)
Stratasys TrueDent™ is a light-curable resin indicated for the fabrication of dental appliances including removable full and partial dentures, denture bases, denture teeth, bridges, crowns, inlays, and veneers in dental laboratories. The material is an alternative to traditional heat-curable and auto polymerizing resins. Stratasys TrueDent™ is intended exclusively for professional dental work.
| Type of Use (Select one or both, as applicable) | | |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------|
| <table style="border:none;"><tr><td><div style="display:inline-block;"> <span style="text-decoration:overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) </div></td><td><div style="display:inline-block;"> Over-The-Counter Use (21 CFR 801 Subpart C) </div></td></tr></table> | <div style="display:inline-block;"> <span style="text-decoration:overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div style="display:inline-block;"> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
| <div style="display:inline-block;"> <span style="text-decoration:overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div style="display:inline-block;"> Over-The-Counter Use (21 CFR 801 Subpart C) </div> | |
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## 510(k) Summary
# K220771
# Stratasys TrueDent™
# Stratasys Ltd.
July 6, 2022
ADMINISTRATIVE INFORMATION
| Manufacturer Name | Stratasys Ltd. | | |
|---------------------------|--------------------------------------------------|---------------------|--|
| | 1 Holtzman Street St. Science Park | | |
| | P.O. Box 2496 Rehovot, | | |
| | 7612401, Israel | | |
| | Telephone: | +972-74-745-4000 | |
| | Fax: | +972-74-745-4001 | |
| Official Contact | Melanie Glennon, VP Quality & Regulatory Affairs | | |
| Representative/Consultant | Melissa Burbage, Senior Regulatory Specialist | | |
| | Kevin A. Thomas, PhD; Floyd G. Larson, MS, MBA | | |
| | PaxMed International, LLC | | |
| | 12264 El Camino Real, Suite 400 | | |
| | San Diego, CA 92130 | | |
| | Telephone: | +1 858-792-1235 | |
| | Fax: | +1 858-792-1236 | |
| | Email: | mburbage@paxmed.com | |
| | kthomas@paxmed.com, flarson@paxmed.com | | |
#### DEVICE NAME AND CLASSIFICATION
| Trade/Device Name | Stratasys TrueDent™ |
|-------------------------|-------------------------------------------------------------------------------------------------------|
| Common Name | Resin, Denture, Relining, Repairing, rebasing |
| Regulation Number | 21 CFR 872.3760 |
| Regulation Name | Denture Relining, Repairing, or Rebasing Resin |
| Regulatory Class | Class II |
| Product Code | EBI |
| Secondary Product Codes | EBG, PZY, EBF |
| Classification Panel | Dental |
| Reviewing Office | Office of Health Technology 1<br>(OHT 1: Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices) |
| Reviewing Division | Division of Health Technology 1 B (Dental and ENT Devices) |
#### PREDICATE DEVICE INFORMATION
Primary Predicate: K210977, E-Dent 1000 (Flexcera Base & Smile), EnvisionTEC GmbH
Reference Devices: K203641, E-Denture Pro Resin, EnvisionTEC E-Denture Pro K201827, GR-17 Resin System, Pro3dure Medical GmbH
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510(k) Summary Page 2 of 7
### INDICATIONS FOR USE STATEMENT
Stratasys TrueDent™ is a light-curable resin indicated for the fabrication of dental appliances including removable full and partial dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays, and veneers in dental laboratories. The material is an alternative to traditional heat-curable and auto polymerizing resins. Stratasys TrueDent™ is intended exclusively for professional dental work.
### SUBJECT DEVICE DESCRIPTION
Stratasys TrueDent™ is a light-curable methacrylate-based resin, that enables fabrication of monolithic, high quality, functional, and aesthetic dental appliances, including full and partial removable dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays and veneers in a CAD/CAM additive manufacturing process. This material is intended to be used by trained dental professionals for the fabrication of various dental appliances in a CAD/CAM additive manufacturing process that includes the following components: digital dental files based on a digital impression, a Stratasys Poly Jet 3D printer, and curing light equipment. It is an alternative to traditional heat cured and auto polymerization resins. The predesigned color of the dental appliance is achieved by digitally mixing colored resins. The resins are available in five (5) different base colors (clear, white, cyan, magenta, and yellow). Stratasys TrueDent can be used only with Stratasys J5 Series printers. Stratasys J5 Series printers include a 3D printing system that utilizes PolyJet technology, with drop-on-demand inkjet printing process, 3 print heads, and a UV LED (395nm) curing process. The dental appliance is then cured in the Stratasys TrueDent™ Cure curing chamber and sent back to the dentist for try-in and final adjustment.
#### PERFORMANCE DATA
Non-clinical testing data submitted to demonstrate substantial equivalence included: shelf life testing, biocompatibility testing, performance testing according to ISO 10477, ISO 4049, and ISO 20795, and other performance tests based on internal procedures. Biological test considerations for this categorization include cytotoxicity, sensitization, acute systemic toxicity, sub-chronic toxicity, implantation, and genotoxicity.
Testing, according to FDA's guidance Technical Considerations for Additive Manufactured Medical Devices, was performed and results were provided in the 510(k). These tests included evaluation of all relevant properties of the printed resin using the permitted machines. Further, tests based on considerations of the orientation during manufacturing were performed. Additional equipment post-510(k) clearance will be added to the labeling by means of the Quality System and within the company's validation plan.
Stratasys TrueDent has a shelf life of 12 months with on-going real-time validation testing for an ultimate shelf life of 24 months. The shelf-life testing is conducted with bench tests from ISO 20795 and other performance tests based on internal procedures.
## EQUIVALENCE TO MARKETED DEVICES
Indications for Use Statements
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The subject device is indicated for fabrication of dental appliances, including removable full and partial dentures, denture bases, denture teeth and temporary bridges, in dental laboratories. The primary predicate (K210977) also has indications for individual and fixed permanent full single crowns, permanent partial crowns (also known as inlays and onlays) in anterior and posterior region, individual and fixed single veneers, artificial teeth for dental prostheses, individual and removable monolithic full and partial dentures. The slight differences in the language of the subject and primary predicate Indications for Use statements, however, do not affect the intended use. The main difference is that the subject device includes indications for bridges, which is not included in the indications of the primary predicate but is addressed by the reference device K201827. The Indications for Use for both the subject device and primary predicate include statements that the maternative to traditional lightcurable resin and is intended exclusively for professional dental work. Both the subject device and primary predicate require fabrication of these devices using a computer aided design and manufacturing (CAD/CAM) system. The subject device Indications for Use Statement does not list the process components, as it is not necessary that such components be listed in the Statement,
The indications for the reference device K203641 include fabrication of denture bases in dental laboratories for full removable dentures. This is the same indication as the subject device for full removable dentures. Slight differences in the language of the Indications for Use statements for the subject device and the reference device K203641 do not affect the intended use. Both the subject device and the reference device K203641 include statements that the maternative to traditional lightcurable and is intended exclusively for professional dental work. Both the subject device and the reference device K203641 require fabrication of these devices using a computer aided design and manufacturing (CAD/CAM) system.
The indications for the reference device K201827 include fabrication of temporary anterior dental restorations, temporary dental restorations and preformed denture teeth to be used in a denture. This is the same as the subject device for bridges and denture teeth, however, different language is used. Both the subject device and reference device K201827 include statements that the material is an alternative to traditional light-curable resin and is intended exclusively for professional dental work. Both the subject device and reference device K201827 require fabrication of these devices using a computer aided design and manufacturing (CAD/CAM) system, also known as additive manufacturing. The system component that is specified for reference device K201827 is an extra-oral curing light equipment.
#### Mechanical and Biological Properties
The physical, mechanical, and chemical properties of the subject device, the primary predicate device (K210977) and the two reference devices (K203641 and K201827) are very similar. They all are light-curable, methacrylate-based resins that are cured by UV light. They are all delivered in the form of a liquid intended to be used in additive manufacturing.
The subject device, the primary predicate device (K210977), and the two reference devices (K203641 and K201827) are all used in additive manufacturing processes. The type of printing process for reference device K201827 is unknown as it is not stated in the 510(k) Summary. The subject device, the primary predicate device (K210977), and reference device K203641 utilize a photopolymer resin 3D printing process that prints the material layer by layer. These are similar in that the print geometry is exposed to UV light that cures the material. The subject device is different in that it uses drop on demand (DOD) printing and the primary predicate device (K210977) and reference device K203641 use digital light processing (DLP) printing. DOD and DLP printing are similar in that they both use voxels for printing
{6}------------------------------------------------
resolution, print using similar materials (resin), cure the resin with UV light, and print support structures that are removed after printing. The main difference is how the material is printed.
DLP uses a vat of resin and a digital light projector to build parts. The projector flashes UV light onto the layer of resin, selectively solidifying the part. This exposure cures and solidifies the pattern and joins the material to the layer below as the build platform is lowered to create the next layer. To ensure good print quality in monolithic full dentures support structures are built using the same material as the printed part and are removed during post processing. DLP uses the same material color for the entire fabrication, which requires post-processing to apply esthetic treatment (coloring).
DOD printing, as used for the subject device resin, works like an inkjet printer. The printer builds parts by jetting photopolymer droplets onto a build platform and solidifying them with UV light. The printer builds layer on top of layer. Similarly to DLP, support structures are also built to ensure good print quality. however a different material is used for the support material. which is also removed after the printing process. DOD printing allows different colors (same base resin with color agent) to be printed at the same time, which allow esthetic denture bases and teeth to be printed together, eliminating the secondary step of applying light curing color composite pastes or liquids to provide an esthetic result.
The differences in printing technology do not raise different questions of safety and effectiveness, as all manufacturing technologies produce a dental device from light-curing acrylic resins that may appropriately be characterized using standard FDA-recognized mechanical testing and biocompatibility evaluation. Performance testing and biocompatibility testing and evaluation were conducted 220771as appropriate mitigation measures for evaluation of substantial equivalence of the subject device, predicate device and reference devices, and the results demonstrate that the subject device is substantially equivalent.
For mechanical properties, the subject device as well as the primary predicate and both reference devices were tested in accordance with ISO 20795. ISO 4049, and ISO 10477. The subject device meets the requirements of these standards for flexural strength, flexural modulus, sorption, and solubility, similar to the primary predicate and both reference devices. The flexural strength meets the requirements of ISO 20795, ISO 4049, and ISO 10477, and results are similar to those of the primary predicate. The flexural modulus meets the requirements of ISO 20795 and ISO 4049, and results are similar to those of reference device K201827. The sorption and solubility meet the requirements of ISO 20795, ISO 4049. and ISO 10477, and results are similar to those of reference device K201827 (these values are not available for the primary predicate device and reference device K203641). The mechanical properties results demonstrate that the subject device is substantially equivalent to the predicate and reference devices.
Biocompatibility studies were performed on the subject device in accordance with ISO 7405 and ISO 10993. The subject device is categorized, according to ISO 7405 as a surface device with permanent contact. Biological test considerations for this categorization include cytotoxicity, sensitization, irritation, acute systemic toxicity, sub-chronic toxicity, implantation, and genotoxicity. The subject device was successfully evaluated for all such considerations using testing and scientific rationale. Based on the completed test results, the subject device is deemed biocompatible and meets the requirements of ISO 10993-1. Results of biocompatibility evaluation and testing demonstrate that the subject device is substantially equivalent to the predicate and reference devices.
{7}------------------------------------------------
| Feature | Subject Device | Primary Predicate<br>Device | Reference Device | Reference Device | Conclusion |
|------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| | Stratasys TrueDent™<br>Stratasys, Ltd. | E-Dent 1000<br>EnvisionTEC GmbH<br>K210977 | E-Denture Pro Resin<br>EnvisionTEC GmbH<br>K203641 | GR-17 Resin System<br>Pro3dure Medical GmbH<br>K201827 | |
| Product Code | EBI, EBG, PZY, EBF | EBF, EBI, ELM | EBI | EBG, PZY | Similar |
| Regulation | 872.3760: Resin,<br>Denture, Relining,<br>Repairing, Rebasing<br>872.3770: Crown And<br>Bridge, Temporary<br>Resin<br>872.3590: Denture,<br>Plastic, Teeth<br>872.3690: Material,<br>Tooth Shade, Resin | 872.3690: Material,<br>Tooth Shade, Resin<br>872.3760: Resin,<br>Denture, Relining,<br>Repairing, Rebasing<br>872.3590: Denture,<br>Plastic, Teeth | 872.3760: Resin,<br>Denture, Relining,<br>Repairing, Rebasing | 872.3770: Crown and<br>Bridge, Temporary Resin<br>872.3590: Additively<br>Manufacture, Preformed,<br>Resin Denture Teeth | Similar |
| Intended Use | Removable full and<br>partial dentures, denture<br>bases, denture teeth,<br>bridges, crowns, inlays,<br>onlays, and veneers<br>dental laboratories. | • Individual and fixed<br>permanent full single<br>crowns, permanent<br>partial crowns in front<br>and posterior area,<br>• Individual and fixed<br>single veneers,<br>• Artificial teeth for<br>dental prostheses, which<br>are used for removable<br>permanent full dentures,<br>• Individual and<br>removable monolithic<br>full and partial dentures | Removable full dentures | Temporary anterior<br>dental restorations (crown<br>and bridge) and denture<br>teeth. | Similar |
| Indications | Stratasys TrueDent™ is<br>a light-curable resin<br>indicated for the<br>fabrication of dentalremovable full and<br>partial dentures, denture<br>bases, denture teeth,<br>bridges, crowns, inlays,<br>onlays, and veneers in<br>dental laboratories. The<br>material is an<br>alternative to traditional<br>heat-curable and auto<br>polymerizing resins.<br>Stratasys TrueDent™ is<br>intended exclusively for<br>professional dental<br>work. | E-Dent 1000 is a light-<br>curable resin indicated<br>for the fabrication of:<br>• individual and fixed<br>permanent full single<br>crowns, permanent<br>partial crowns in front<br>and posterior area,<br>• individual and fixed<br>single veneers,<br>• artificial teeth for<br>dental prostheses, which<br>are used for removable<br>permanent full dentures,<br>• individual and<br>removable monolithic<br>full and partial dentures<br>in dental laboratories.<br>The material is an<br>alternative to traditional<br>restorative dental<br>material. E-Dent 1000 is<br>intended exclusively for<br>professional dental<br>work. Fabrication of<br>dental applications with<br>E-Dent 1000 requires a<br>computer aided and<br>manufacturing<br>(CAD/CAM) system<br>that includes the<br>following components:<br>digital dental files based<br>on a digital impression<br>or in case of artificial<br>teeth for dental<br>prostheses the digital<br>dental files based on<br>manufacturer's data, a<br>digital light processing<br>(DLP) printer, and<br>curing light equipment. | E-Denture Pro is a light-<br>curable resin indicated<br>for the fabrication of<br>denture bases fabricated<br>in dental laboratories for<br>full removable dentures.<br>The material is an<br>alternative to traditional<br>heat-curable and auto<br>polymerizing resins. E-<br>Denture Pro is intended<br>exclusively for<br>professional dental<br>work. Fabrication of<br>denture bases with E-<br>Denture Pro requires a<br>computer-aided and<br>manufacturing<br>(CAD/CAM) system<br>that includes the<br>following components:<br>digital denture base files<br>based on a digital<br>impression, a digital<br>light processing (DLP)<br>printer, and curing light<br>equipment. | The GR-17 Resin System<br>is a light-curable<br>polymerizable resin<br>intended to be used in<br>conjunction with extra-<br>oral curing light<br>equipment.<br>The GR-17 temporary is<br>indicated for the<br>fabrication, by additive<br>manufacturing, of<br>temporary anterior dental<br>restorations.<br>The GR-17.1 temporary<br>is indicated for the<br>fabrication, by additive<br>manufacturing, of<br>temporary dental<br>restorations, and for the<br>fabrication, by additive<br>manufacturing, of<br>preformed denture teeth<br>to be used in a denture. | Similar |
| Chemical<br>Description | Methacrylate-based<br>resin | Methacrylate-based<br>resin | Methacrylate-based<br>resin | Methacrylate-based resin | Same |
| Material Type | Light-curable Resin | Light-curable Resin | Light-curable Resin | Light-curable Resin | Same |
| Curing Method | UV Light | UV Light | UV Light | UV Light | Same |
| Product State | Liquid | Liquid | Liquid | Liquid | Same |
| Manufacturing<br>Technology Type | Additive | Additive | Additive | Additive | Same |
| Product Characteristics | | | | | |
| Standards | ISO 10477<br>ISO 4049<br>ISO 20795 | ISO 10477<br>ISO 4049<br>ISO 20795 | ISO 20795 | ISO 10477<br>ISO 4049<br>ISO 22112 | Similar |
| Physical and<br>Mechanical<br>Properties | Flexural Strength<br>Flexural Modulus<br>Sorption<br>Solubility | Flexural Strength<br>Flexural Modulus<br>Sorption<br>Solubility | Flexural Strength<br>Flexural Modulus<br>Sorption<br>Solubility | Flexural Strength<br>Flexural Modulus<br>Sorption<br>Solubility | Same |
| Biocompatibility<br>Standards | ISO 7405<br>ISO 10993 | ISO 10993 | ISO 10993 | ISO 7405<br>ISO 10993 | Similar |
| | Cytotoxicity (Part 5)<br>Sensitization (Part 10)<br>Irritation (Part 10)<br>Systemic Toxicity (Part<br>11) Genotoxicity (Part<br>3) | Cytotoxicity (Part 5)<br>Sensitization (Part 10)<br>Irritation (Part 10)<br>Systemic Toxicity (Part<br>11) | Cytotoxicity (Part 5)<br>Sensitization (Part 10)<br>Irritation (Part 10)<br>Systemic Toxicity (Part<br>11) | | |
| Workflow | | | | | |
| Additive<br>Manufacturing | Testing, according to<br>FDA's guidance<br>Technical<br>Considerations for<br>Additive Manufactured<br>Medical Devices, was<br>performed and results<br>were provided in the<br>510(k). These tests<br>included evaluation of<br>all relevant properties of<br>the printed resin using<br>the permitted machines.<br>Further, tests based on<br>considerations of the<br>orientation during<br>manufacturing were<br>performed. | Testing, according to<br>FDA's guidance<br>Technical<br>Considerations for<br>Additive Manufactured<br>Medical Devices, was<br>performed and results<br>were provided in the<br>510(k). These tests<br>included evaluation of<br>all relevant properties of<br>the printed resin using<br>the permitted machines.<br>Further, tests based on<br>considerations of the<br>orientation during<br>manufacturing were<br>performed. | Testing, according to<br>FDA's guidance<br>Technical<br>Considerations for<br>Additive Manufactured<br>Medical Devices, was<br>performed and results<br>were provided in the<br>510(k). These tests<br>included evaluation of<br>all relevant properties of<br>the printed resin using<br>the permitted machines.<br>Further, tests based on<br>considerations of the<br>orientation during<br>manufacturing were<br>performed. | Not stated in summary | Similar |
| Printer | Stratasys J5 DentaJet | EnvisionTECs<br>Perfactory® 3D-Printer<br>DLP models designed<br>and validated for use<br>with the E-Dent 1000<br>light cured resin are:<br>• EnvisionOne<br>cDLM,with LED<br>• Micro series, with<br>LED<br>• Vida Series, with LED<br>• P4K Series, with LED<br>• D4K Series, with LED | EnvisionTECs<br>Perfactory® 3D-Printer<br>models designed and<br>validated for use with<br>the E-Denture Pro light<br>cured resin are:<br>EnvisionOne cDLM,<br>with LED<br>Vida Series, with LED<br>P4K Series, with LED<br>D4K Series, with LED | Not stated in summary | Similar |
| Post Cure | TrueDent™ Cure | Not listed in summary…
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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.