K123401 · Stryker Trauma AG · HSB · Jan 23, 2013 · Orthopedic
Device Facts
Record ID
K123401
Device Name
GAMMA3 AND T2 RECON TARGETING DEVICES
Applicant
Stryker Trauma AG
Product Code
HSB · Orthopedic
Decision Date
Jan 23, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3020
Device Class
Class 2
Indications for Use
The Gamma3 Target Devices are intended for use with the Trochanteric Nail or Long Length Gamma3 Nail. The Gamma3 and T2 Recon Distal Targeting Devices are intended for use with the Long Length Gamma3 Nail and T2 Recon Nail System. Gamma3 Nail System: The Trochanteric Gamma3 Nail is indicated for fixation of stable and unstable intertrochanteric fractures, including but not limited to nonunion, malunion and tumor resections, while the Long Length Gamma3 Nail inidcation may include fractures resulsting from trauma, nonunion, malunion, pathological fractures, impending pathological fractures, turnor resections and revision procedures. T2 Recon Nail System: T2 Recon Nail System indications include fixation of subtrochanteric, intertrochanteric, ipsilateral neck/shaft, communited proximal femoral shaft fractures, femoral fixation required as a result of pathological disease, and temporary stabilization of the femoral shaft ranging from the femoral neck to the supracondylar regions of the femur.
Device Story
Gamma3 and T2 Recon Target Devices are surgical accessories for intramedullary nail systems. Devices facilitate accurate placement of distal locking screws during orthopedic surgery. Operated by surgeons in clinical/OR settings. Input consists of mechanical alignment with the nail system; output is physical guidance for drill/screw placement. Enhances surgical precision; reduces potential for malalignment during fracture fixation. No software or electronic components involved.
Clinical Evidence
No clinical data; bench testing only. Engineering evaluations and laboratory testing (targeting accuracy, stiffness, and nail accommodation) demonstrated substantial equivalence.
Technological Characteristics
Mechanical surgical targeting accessories for intramedullary fixation rods. Materials and design are consistent with predicate Gamma3 and T2 Recon systems. No energy source, software, or connectivity. Sterilization via standard hospital methods.
Indications for Use
Indicated for patients requiring fixation of stable/unstable intertrochanteric fractures, femoral shaft fractures (including subtrochanteric, neck/shaft, comminuted), pathological fractures, impending pathological fractures, or revision procedures. Used for trauma, nonunion, malunion, and tumor resections. Applicable to femoral shaft stabilization from femoral neck to supracondylar regions.
Regulatory Classification
Identification
An intramedullary fixation rod is a device intended to be implanted that consists of a rod made of alloys such as cobalt-chromium-molybdenum and stainless steel. It is inserted into the medullary (bone marrow) canal of long bones for the fixation of fractures.
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### 510(k) Summary
### Gamma3 and T2 Recon Target Devices Proprietary Name: Common Name: Intramedullary Fixation Rod Classification Name and Reference: Intramedullary Fixation Rod 21 CFR §888.3020 Regulatory Class: Class II Product Codes: 87HSB: Rod, Fixation, Intramedullary and Accessory Estela Celi, Regulatory Affairs Specialist For Information contact: Stryker Trauma AG Bohnackerweg 1
Date Prepared:
November 2, 2012
estela.celi@stryker.com
Phone: (201) 831-6461 Fax: (201) 831-3461
CH-2545 Selzach Switzerland
### Description
This Traditional 510(k) submission is being supplied to the US FDA to address modifications made to the Gamma3 Target Device and addition of a new Distal Targeting Device to the Gamma3 (K043431) and T2 Recon Nail Systems (K102992) as well as the inclusion of the existing target devices in the Gamma3 and T2 Recon Nail Systems.
#### Intended Use
The Gamma3 Target Devices do not alter the intended use of the predicate Gamma3 Nail System as cleared in K043431. The indications for use for the subject device is provided below.
The Distal Targeting Devices do not alter the intended use of the predicate Gamma3 and T2 Recon Nail Systems as cleared in K043431 and K102992, respectively. The indications for use for the subject devices are provided below.
# JAN 2 3 2013
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### Indications
The line extension to the T2 Recon Nail System and Gamma3 Nail System does not alter the indications for use of the predicate system as cleared in its' respective premarket notifications.
The Gamma3 Target Devices are intended for use with the Trochanteric Nail or Long Length Gamma3 Nail.
The Gamma3 and T2 Recon Distal Targeting Devices are intended for use with the Long Length Gamma3 Nail and T2 Recon Nail System. '
#### Gamma3 Nail System
The Trochanteric Gamma3 Nail is indicated for fixation of stable and unstable intertrochanteric fractures, including but not limited to nonunion, malunion and tumor resections, while the Long Length Gamma3 Nail inidcation may include fractures resulsting from trauma, nonunion, pathological fractures, impending pathological fractures, turnor resections and revision procedures.
### T2 Recon Nail System
The T2 Recon Nail System indications include fixation of subtrochanteric. intertrochanteric, ipsilateral neck/shaft, communited femoral shaft fractures, femoral fixation required as a result of pathological disease, and temporary stabilization of fractures of the femoral shaft ranging from the femoral neck to the supracondylar regions of the femur.
#### Summary of Technologies
Device comparison showed that the proposed device is substantially equivalent in intended use, materials and performance characteristics to the following predicate devices and that the target devices as an accessory to the Gamma3 and T2 Recon Nail System does not alter the technology.
- K043431 Gamma3 Nail System .
- K102992 T2 Recon Nail System .
### Non-Clinical Testing
Non-clinical laboratory testing and engineering evaluations were performed on the target devices to determine substantial equivalence. Testing and evaluations demonstrated that the subject target devices are substantially equivalent to devices currently cleared for marketing.
The following testing was performed:
- Conditioning
- Targeting Accuracy and Stiffness ●
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Engineering Evaluations were completed for the following:
- Accomodation for 480mm Nails in Distal Targeting Device ◆
### Clinical Testing
Clinical testing was not required for this submission.
### Conclusion
The Gamma3 Target Devices and the Gamma3 and T2 Recon Distal Targeting Devices are substantially equivalent to the predicate devices identified in this premarket notification.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three overlapping wings, symbolizing health, services, and people. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged in a circular fashion around the eagle.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
Letter dated: January 23, 2013
Stryker Trauma AG % Howmedica Osteonics Corporation Ms. Estela Celi 325 Corporate Drive Mahwah, New Jersey 07430
Re: K123401
Trade/Device Name: Gamma3 and T2 Recon Target Devices Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary fixation rod Regulatory Class: Class II Product Code: HSB Dated: November 2, 2012 Received: November 28, 2012
Dear Ms. Celi:
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 Or ic Fat 607); acomig (21 CFR 803); good manufacturing practice requirements as set
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### Page 2 -- Ms. Estela Celi
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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Mark N. Melkerson
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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### Indications for Use
510(k) Number (if known): K123401
## Device Name: Gamma3 and T2 Recon Target Devices
The Gamma3 Target Devices are intended for use with the Trochanteric Nail or Long Length Gamma3 Nail.
The Gamma3 and T2 Recon Distal Targeting Devices are intended for use with the Long Length Gamma3 Nail and T2 Recon Nail System.
#### Gamma3 Nail System
The Trochanteric Gamma3 Nail is indicated for fixation of stable and unstable intertrochanteric fractures, including but not limited to nonunion, malunion and tumor mesections, while the Long Length Gamma3 Nail inidcation may include fractures resulsting from trauma, nonunion, malunion, pathological fractures, impending pathological fractures, turnor resections and revision procedures.
### T2 Recon Nail System
T2 Recon Nail System indications include fixation of subtrochanteric, The intertrochanteric, ipsilateral neck/shaft, communited proximal femoral shaft fractures, microonameric, 'ipshatera' neesult of pathological disease, and temporary stabilization femoral namen of the femoral shaft ranging from the femoral neck to the supracondylar regions of the femur.
Over-The-Counter Use Prescription Use X AND/OR (21 CFR 807 Subpart C) (Part 21 CFR 801 Subpart D) (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
> Concurrence of CDRH, Office of Device Evaluation (ODE) 2013.01.18 11:16:42 Anton E. Dmitriev, PhD Division of Orthopedic Devices -05'00'
> > 35
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.