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510(k) Data Aggregation

    K Number
    K242637
    Date Cleared
    2025-05-21

    (260 days)

    Product Code
    Regulation Number
    872.5470
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    MEM Clear Aligner System

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    MEM Clear Aligner System is indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e. all second molars). The MEM Clear Aligner System repositions teeth by way of continuous gentle force.

    Device Description

    The MEM Clear Aligner System is a customized plastic orthodontic system, consisting of a series of transparent, removable aligners prescribed by a doctor to correct misaligned or crooked teeth. These customized, removable transparent plastic aligners gradually reposition teeth with continuous gentle pressure.

    The product is a series of transparent, removable orthodontic aligners, custom-made according to the dentist's prescription and designed using the "3Shape A/S (K171634)" software. They are manufactured using thermoforming technology. These aligners are designed to provide a comfortable teeth straightening experience and achieve optimal correction through precise design using advanced technology.

    AI/ML Overview

    The provided FDA 510(k) clearance letter for the MEM Clear Aligner System does not contain any information regarding a study that proves the device meets specific acceptance criteria based on diagnostic performance, reader studies, or AI algorithm performance. This document primarily focuses on establishing substantial equivalence to a predicate device (ULab Systems Dental Aligner Kit, K192596) by comparing intended use, technological characteristics, and material properties.

    The "Non-Clinical Performance Data" section lists various ISO standard tests related to biocompatibility and material properties, along with transportation, packaging, and shelf-life testing. These are primarily for demonstrating the safety of the material and the product's integrity, not its diagnostic efficacy or performance in a clinical setting related to treatment outcomes or accuracy of tooth movement prediction.

    Therefore, based solely on the provided text, I cannot produce a table of acceptance criteria and reported device performance related to a diagnostic or AI-driven study, nor can I answer questions about sample sizes, data provenance, expert panels, MRMC studies, or ground truth types for such a study.

    The document implicitly suggests the "acceptance criteria" for clearance are met by demonstrating:

    • Same Intended Use: Treatment of tooth malocclusion in patients with permanent dentition.
    • Similar Technological Characteristics: Mode of action, principles of operation, method of use, OTC/Rx status, duration of use, method of manufacturing, design, application (removable).
    • Comparable Material Biocompatibility and Mechanical Properties: Demonstrated through ISO and ASTM standards.

    Here's what can be extracted and what cannot:


    1. A table of acceptance criteria and the reported device performance

    Since this is a substantial equivalence submission for a physical medical device (aligners), not an AI/diagnostic device, the "acceptance criteria" are related to equivalence to the predicate, and material/biocompatibility performance rather than diagnostic accuracy.

    Acceptance Criteria (Implied for Substantial Equivalence)Reported Device Performance (as per document)
    Intended Use (Match Predicate)"Same"
    Technological Characteristics (Similar to Predicate)"Same" for most (Mode of Action, Principles of Operation, Method of Use, OTC/Rx, Duration of Use, Method of Manufacturing, Design, Application). "Similar" for Biocompatibility.
    Biocompatibility (Meet ISO 10993 Standards)All listed ISO 10993 tests completed and results meet product specifications. Specific results not provided, only confirmation of testing.
    Material Mechanical Properties (Comparable to Predicate/Adequate)Ultimate Flexural Strength: 50~110 Mpa (ISO 20795-2:2013)
    Flexural Modulus: 1500~1950 Mpa (ISO 20795-2:2013)
    Shore D Hardness: $\ge$ 40 Hd
    Water Sorption: 0.43~0.58% (ASTM D570)
    (Compared to Predicate's 0.10-0.25% for Water Sorption, assessed as "The safety evaluation... the difference should not be too large", implying acceptance.)
    Transportation, Packaging, Shelf-Life (Validated)"validated and completed"
    Design, Validation, Manufacturing (Completed)"completed and provided"

    Note: There are no "acceptance criteria" in the sense of diagnostic performance metrics (e.g., sensitivity, specificity, AUC) because this is not an AI/diagnostic device.

    2. Sample size used for the test set and the data provenance

    • Not Applicable. The document describes tests on the device materials and physical properties, not on a "test set" of patient data for an algorithm. The biocompatibility tests are likely performed on a limited number of animal subjects or cell cultures, and the physical property tests on samples of the material.
    • Data Provenance: Not specified for biocompatibility or material tests beyond the standards referenced. The company is based in Taiwan.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not Applicable. There is no "test set" requiring expert ground truth in the context of this 510(k) submission. The ground truth for material properties is the physical measurement itself according to standard protocols.

    4. Adjudication method for the test set

    • Not Applicable. No human adjudication panel for a test set of data.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • Not Applicable. This is a physical aligner device, not an AI or imaging diagnostic device. No MRMC study would be performed for this product type.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not Applicable. This is a physical aligner device. There is no AI algorithm being evaluated for standalone performance. The design of the aligners uses "3Shape A/S (K171634) software," but the 510(k) is for the physical aligner product, not the software itself or its AI capabilities for treatment planning.

    7. The type of ground truth used

    • For Biocompatibility: In vitro (cytotoxicity, gene mutation), in vivo (animal studies for irritation, toxicity, pyrogenicity, sensitization, implantation).
    • For Mechanical Properties: Measurements derived from standardized laboratory tests (e.g., ISO 20795-2:2013, ASTM D570).

    8. The sample size for the training set

    • Not Applicable. There is no training set for an AI algorithm described in this 510(k). Fabrication is custom for each patient based on a doctor's prescription.

    9. How the ground truth for the training set was established

    • Not Applicable. No training set, thus no ground truth establishment for it.

    In conclusion: The provided document is a 510(k) clearance for a physical medical device (clear aligners), not a software-as-a-medical-device (SaMD) or an AI/diagnostic imaging device. Therefore, the questions related to AI performance metrics, test sets, training sets, human readers, and expert ground truth are not applicable to the information contained within this specific FDA clearance letter. The study described in the document primarily involves materials testing and biocompatibility assessments to demonstrate the safety and equivalence of the aligner product itself.

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