CONFORMIS IUNI UNICONDYLAR KNEE REPLACEMENT SYSTEM
Applicant
Conformis, Inc.
Product Code
HSX · Orthopedic
Decision Date
Sep 6, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3520
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The ConforMIS Unicondylar Knee Replacement System (iUni) is intended for use in one compartment of the osteoarthritic knee to replace the damaged area of the articular surface in patients with evidence of adequate healthy bone sufficient for support of the implanted components. Candidates for unicondylar knee replacement include those with: - joint impairment due to osteoarthritis or traumatic arthritis of the knee, - previous femoral condyle or tibial plateau fracture, creating loss of function, - valgus or varus deformity of the knee, - revision procedures provided that anatomic landmarks necessary for alignment and positioning of the implant are identifiable on patient imaging scans. This implant is intended for cemented use only.
Device Story
Patient-specific unicompartmental knee replacement system; inputs include patient MRI or CT scans; proprietary software analyzes images to design personalized femoral and tibial implants; femoral component made of CoCrMo; tibial component all-polyethylene (UHMWPE) or metal-backed (CoCrMo tray with UHMWPE insert); system includes disposable, patient-specific instrumentation for implantation; used in clinical settings by orthopedic surgeons; personalized design matches patient anatomy to restore function; intended for cemented fixation.
Clinical Evidence
No clinical data provided; bench testing not performed as there were no changes to the device design.
Technological Characteristics
Patient-specific design; materials: Cobalt Chrome Molybdenum alloy (CoCrMo) and Ultra High Molecular Weight Polyethylene (UHMWPE); cemented fixation; includes patient-specific disposable instrumentation; design derived from proprietary software analysis of MRI/CT imaging.
Indications for Use
Indicated for patients with knee joint impairment due to osteoarthritis, traumatic arthritis, previous femoral condyle or tibial plateau fracture, or valgus/varus deformity requiring unicondylar knee replacement. Suitable for revision procedures if anatomic landmarks are identifiable on imaging. Requires adequate healthy bone for component support. Cemented use only.
Regulatory Classification
Identification
A knee joint femorotibial metal/polymer non-constrained cemented prosthesis is a device intended to be implanted to replace part of a knee joint. The device limits minimally (less than normal anatomic constraints) translation in one or more planes. It has no linkage across-the-joint. This generic type of device includes prostheses that have a femoral condylar resurfacing component or components made of alloys, such as cobalt-chromium-molybdenum, and a tibial component or components made of ultra-high molecular weight polyethylene and are intended for use with bone cement (§ 888.3027).
{0}------------------------------------------------
K121974 (1/4)
# SEP 6 2012
# 5.0 510(K) SUMMARY (page 1 of 4)
t
.
.
.
.
・・ .
·
| Submitter's Name and Address | ConforMIS Inc.<br>11 North Ave.<br>Burlington, MA 01803 |
|-----------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Establishment Registration Number | 3004153240 and 3008690421 |
| Date of Summary | July 03, 2012 |
| Contact Person | Amita S. Shah, Vice President, Quality Assurance and Regulatory Affairs |
| Telephone Number | (781) 345-9164 |
| Fax Number | (781) 345-0104 |
| Name of the Device | ConforMIS iUni Unicondylar Knee Replacement System |
| Common or Usual Name | Unicondylar Knee Replacement System |
| Classification Name | <ul><li>Prosthesis, knee, femorotibial, non-constrained, cemented, metal/polymer</li><li>Knee Arthroplasty Implantation System</li></ul> |
| Regulation Number | 21 CFR 888.3520 |
| Device Classification | Product Code:<br><ul><li>HSX - Knee joint femorotibial metal/polymer non-constrained cemented prosthesis</li><li>OOG - Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis. Intended to be used to assist in the implantation of a specific knee arthroplasty device or a set of specific knee arthroplasty devices. Indicated to include guiding alignment, making or establishing cuts,</li></ul> |
implant components.
:
selecting, sizing, attaching, positioning or orienting
.
.
.
ન 8
{1}------------------------------------------------
## 510(K) SUMMARY (page 2 of 4)
Indications for Use
Indications for Use:
The ConforMIS Unicondylar Knee Replacement System (iUni) is intended for use in one compartment of the osteoarthritic knee to replace the damaged area of the articular surface in patients with evidence of adequate healthy bone sufficient for support of the implanted components.
Candidates for unicondylar knee replacement include those with:
- joint impairment due to osteoarthritis or traumatic . arthritis of the knee,
- . previous femoral condyle or tibial plateau fracture, creating loss of function,
- valqus or varus deformity of the knee, .
- . revision procedures provided that anatomic landmarks necessary for alignment and positioning of the implant are identifiable on patient imaging scans.
This implant is intended for cemented use only.
ldentification of the Legally Marketed Device (Predicate Device)
ConforMIS iUni Unicondylar Knee Replacement System Device Class: Product Code: HSX, OOG . Regulation Number: 21 CFR 888.3520 510(k) number: K111916, K092441, K072586, K072368, K063432, K043570
Smith & Nephew Journey Unicondylar Device Class: ll Product Code: HSX Regulation Number: 21 CFR 888.3520 K102069 510(k) number:
Zimmer Unicompartmental Knee System Device Class: Product Code: HSX Regulation Number: 21 CFR 888.3520 510(k) number: K033363
ન છ
{2}------------------------------------------------
#### 510(K) SUMMARY (page 3 of 4)
Device Description
Substantial Equivalence: ConforMIS iUni Unicondylar Knee Replacement System ("iUni KRS") is a patient-specific unicompartmental knee replacement system. The iUni is comprised of a set of implants designed from patient images. The implant system consist of:
- 1 Femoral Implant .
- 1 Tibial Component (all-polyethylene or metal backed)
The implants of the iUni KRS will be composed of individually packaged femoral and tibial components and will be provided with ancillary instrumentation to assist in the implantation procedure.
The patient-specific femoral implant will be made of Cobalt Chrome Molybdenum alloy (CoCrMo) and will be personalized to match a patient's anatomy.
The all poly tibial component is made from UHMWPE. The metal backed tibial component will consist of a CoCrMo tibial tray and with an Ultra High Molecular Weight Polyethylene (UHMWPE) tibial insert. Multiple inserts of varying thicknesses may be provided to accommodate surgeon preferences.
The outline bone contacting and articular surfaces of the femoral component as well as the outline of both tibial components are personalized to match the patient's femoral and tibial anatomy. The design of the implant is derived from an analysis, using proprietary software, of images obtained by MRI or CT scan.
Disposable, patient-specific instrumentation is provided to assist in the implantation of the iUni Unicondylar Knee Replacement System.
The product subject of this premarket notification is substantially equivalent to the iUni Unicondylar Knee Replacement System (K111916 cleared September 29, 2011, K092441 cleared September 09, 2009, K072586 cleared November 08, 2007, K072368 cleared September 20, 2007, K063432 cleared March 16, 2007, and K043570 cleared March 14, 2005); Smith & Nephew Journey Unicondylar (K102069 cleared October 05, 2010); and Zimmer Unicompartmental Knee System (K033363 cleared January 16, 2004).
The purpose of this submission is to clarify the indications for use statement and make it consistent with predicate devices and FDA guidance.
20
{3}------------------------------------------------
### 510(K) SUMMARY (page 4 of 4)
Description and Conclusion of Testing The determination of substantial equivalence for this device was based on the indications for use statements and the device design. The design of the iUni KRS was previously determined to be substantially equivalent to predicate devices. A comparison of the designs and the indications for use statements confirmed that the modification to the indications for use does not affect device performance and is, therefore, also substantially equivalent.
#### Safety and Performance
Conclusion
The determination of substantial equivalence for this device was based on detailed device description and indications for use statement comparisons. Non-clinical laboratory testing was not performed as there is no change to the device. Clinical data is not necessary to demonstrate substantial equivalence.
Based on device description and indications for use statement comparisons, it is concluded that the ConforMIS iUni Unicondylar Knee Replacement System with the updated indications for use statement is substantially . equivalent to the iUni Unicondylar Knee Replacement System (K111916 cleared September 29, 2011, K092441 cleared September 09, 2009, K072586 cleared November 08, 2007, K072368 cleared September 20, 2007, K063432 cleared March 16, 2007, and K043570 cleared March 14, 2005); Smith & Nephew Journey Unicondylar (K102069 cleared October 05, 2010); and Zimmer Unicompartmental Knee System (K033363 cleared January 16, 2004)
21
{4}------------------------------------------------
Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle with its wings spread, and three wavy lines below the eagle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circle around the eagle.
# DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Conformis, Incorporated % Ms. Amita S. Shah Vice President, Quality Assurance and Regulatory Affairs 11 North Ave Burlington, Massachusetts 01803
SEP 6 2012
Re: K121974
Trade/Device Name: ConforMIS® Unicondylar Knee Replacement System (iUni) Regulation Number: 21 CFR 888.3520 Regulation Name: Knee joint femorotibial metal/polymer non-constrained cemented prosthesis Regulatory Class: Class II Product Code: HSX Dated: July 3, 2012 Received: July 9, 2012
Dear Ms. Shah:
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 (reporting of medical
{5}------------------------------------------------
### Page 2 - Ms. Amita S. Shah
device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR 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.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/deffault.htm
Sincerely yours.
Mark N. Melkerson
Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{6}------------------------------------------------
## Indications for Use
510(k) Number (if known): ***_***
#### Device Name:
ConforMIS® Unicondylar Knee Replacement System (iUni)
### Indications for Use:
The ConforMIS Unicondylar Knee Replacement System (iUni) is intended for use in one compartment of the osteoarthritic knee to replace the damaged area of the articular surface in patients with evidence of adequate healthy bone sufficient for support of the implanted components.
Candidates for unicondylar knee replacement include those with:
- joint impairment due to osteoarthritis or traumatic arthritis of the knee, ●
- previous femoral condyle or tibial plateau fracture, creating loss of function, .
- valgus or varus deformity of the knee, .
- revision procedures provided that anatomic landmarks necessary for alignment � and positioning of the implant are identifiable on patient imaging scans.
This implant is intended for cemented use only.
Prescription Use *X*
(Part 21 CFR 801 Subpart D)
Over-The-Counter Use AND/OR (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE) mxm ditional 510(k) - Conformis Tom KRS - Clarification of Indications For Use Statement 17
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.