The RxG Distraction System includes devices intended for use in bone stabilization and elongation (lengthening) in the correction of congenital or developmental defects of the midface and alveolar ridge. The RxG Distraction System also includes devices intended for use in bone stabilization and elongation (lengthening) in the correction of congenital or developmental defects of the mandible in patients 2 years old or younger. The RxG Distraction System is not intended for load-bearing applications in adult or adolescent populations.
Device Story
RxG Distraction System is an implantable device for distraction osteogenesis to lengthen maxillary and mandibular bones. System comprises resorbable 85:15 PLLA/PGA footplates, a TI-6AL-4V or stainless steel threaded drive screw, and an activation arm. Footplates are secured to bone via SonicPins RxG on either side of an osteotomy. Activation arm extends through soft tissue for external manual operation by clinician or patient. Turning the arm separates plates to achieve up to 30 mm of distraction. After bone consolidation, drive screw is detached and removed; plates and pins remain to resorb over 12-14 months. Used in hospital settings for reconstructive procedures. Benefits include gradual bone lengthening and stabilization without permanent hardware.
Clinical Evidence
Bench testing only. Comparative mechanical testing performed between RxG distractor and LactoSorb predicate. Devices affixed to sawbone blocks, submerged in Ringer's solution for 48 hours, and subjected to simulated distraction and consolidation over 52 days. Deformation measured at regular intervals; results confirmed substantial equivalence.
Technological Characteristics
Materials: 85:15 PLLA/PGA (plates/pins), TI-6AL-4V or stainless steel (drive screw/activation arm). Resorption time: 12-14 months. Sterilization: Gamma radiation. Form factor: Threaded drive screw with footplates. Mechanical principle: Distraction osteogenesis via manual activation. No software or electronic components.
Indications for Use
Indicated for bone stabilization and elongation in correction of congenital or developmental defects of midface and alveolar ridge in pediatric and adult populations, and mandible in patients 2 years or younger. Not for load-bearing applications in adult or adolescent populations.
Regulatory Classification
Identification
A bone plate is a metal device intended to stabilize fractured bone structures in the oral cavity. The bone segments are attached to the plate with screws to prevent movement of the segments.
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Image /page/0/Picture/1 description: The image shows the text "KLS martin L.P.". The text is in a bold, sans-serif font. The letters "KLS" and "LP" are in black, while the word "martin" is in a textured gray color. The text is horizontally aligned.
P.O. Box 16369 · Jacksonville, FL 32245-6369 904-641-7746 or 800-625-1557 · Fax 904-641-7378 www.klsmartin.com
# MAY 1 5 2014
## 510(k) Summary Section 21 CFR 807.92
| Submitter: | KLS Martin L.P.<br>11201 Saint Johns Industrial Pkwy S<br>Jacksonville, FL 32246 |
|--------------------|---------------------------------------------------------------------------------------------------------------|
| Contact Person: | Jennifer Damato<br>Director of Quality Mgt and Regulatory Affairs<br>Phone: 800-625-1557<br>Fax: 904-641-7378 |
| Date Prepared: | May 13, 2014 |
| Trade Name: | RxG Distraction System |
| Common Name: | Resorbable Distractor |
| Classification: | Bone Plate<br>Class II, 21 CFR 872.4760, Product Code JEY |
| Predicate Devices: | LactoSorb Distraction (K030425, K002083)<br>Resorb-X G (K112064), Zurich Distraction System (K010139) |
### Device Description:
The RxG Distraction System consists of implantable devices used to lengthen or increase the dimension of maxillary and mandibular bones through distraction osteogenesis. It is composed of multiple sizes and shapes of RxG footplates and a threaded drive screw connected to an activation arm. The device is positioned internally with the connected activation arm extending through the soft tissue for external activation. The RxG footplates are secured to the bone on either side of the osteotomy with SonicPins RxG. Distraction is achieved by turning the activation arm with the patient activation driver, causing the plates to separate. Various lengths of drive screws are available to achieve up to 30 mm of distraction. Upon completion of distraction and consolidation of the bone, the drive screw is detached from the RxG footplates and removed, while the RxG footplates and SonicPins RxG remain implanted and are resorbed in 12-14 months.
### Indications for Use:
The RxG Distraction System includes devices intended for use in bone stabilization and elongation (lengthening) in the correction of congenital or developmental defects of the midface and alveolar ridge.
The RxG Distraction System also includes devices intended for use in bone stabilization and elongation (lengthening) in the correction of congenital or developmental defects of the mandible in patients 2 years old or younger.
The RxG Distraction System is not intended for load-bearing applications in adult or adolescent populations.
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P.O. Box 16369 • Jacksonville, FL 32245-6369
904-641-7746 or 800-625-1557 • Fax 904-641-7378
www.klsmartin.com
kts martin L.P.
| Characteristic | RxG Distraction System | LactoSorb Distraction | Resorb-X G | Zurich Distraction System |
|---------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | The RxG Distraction System<br>includes devices intended for use in<br>bone stabilization and elongation<br>(lengthening) in the correction of<br>congenital or developmental defects<br>of the midface and alveolar ridge.<br><br>The RxG Distraction System also<br>includes devices intended for use in<br>bone stabilization and elongation<br>(lengthening) in the correction of<br>congenital or developmental defects<br>of the mandible in patients 2 years<br>old or younger.<br><br>The RxG Distraction System is not<br>intended for load-bearing<br>applications in adult or adolescent<br>populations. | The Lorenz Resorbable Distraction System<br>includes devices intended for use in bone<br>stabilization and elongation (lengthening)<br>when correction of oral (alveolar ridge),<br>cranial, maxillofacial deficiencies or post-<br>traumatic defects require gradual bone<br>distraction. The Lorenz Resorbable<br>Distraction System also includes devices<br>intended for use in bone stabilization and<br>elongation (lengthening) when correction<br>of mandibular deficiencies or post-<br>traumatic defects require gradual bone<br>distraction patients two (2) years old or<br>younger. The mid-face distractor is<br>intended primarily for LeFort III<br>osteotomies. | Resorb-X G is intended for use in non-<br>load bearing fracture repair and<br>reconstructive procedures in<br>adolescent and adult populations. In<br>addition, resorbable meshes, plates<br>and pins may be used in non-loading<br>bearing applications for maintaining<br>the relative position of, and/or<br>containing, bony fragments, bone<br>grafts (autograft or allograft), or bone<br>graft substitutes in oral and<br>maxillofacial reconstruction. | The Zurich Distraction System<br>includes devices intended as a bone<br>stabilizer and lengthening (and or<br>transport) device when correction of<br>congential deficiencies or post<br>traumatic defects of the mandible<br>(including ramus, body, alveolar ridge,<br>palate, symphisis), mid-face, and<br>cranial bones require gradual<br>distraction. |
| Contraindications | 1. Active infection<br>2. Foreign body sensitivity | 1. Active infection<br>2. Foreign body sensitivity. Where<br>material sensitivity is suspected,<br>testing is to be completed prior to<br>implantation.<br>3. Patients with limited blood supply,<br>insufficient quantity or quality of<br>bone, or latent infection.<br>4. Patients, or parents/guardians of<br>patients are unwilling or incapable of<br>following postoperative care<br>instructions.<br>5. Patients with bleeding disorders or<br>poor wound healing.<br>6. Patients with metabolic disorders. | 1. High-load regions in the absence<br>of traditional rigid fixation<br>2. Active or latent infections<br>3. Patients in a bad general state of<br>health or suffering from<br>metabolic disorders | 1. Active infection<br>2. Patient conditions including:<br>blood supply limitations,<br>insufficient quantity or quality of<br>bone or latent infections<br>3. Patients with mental or<br>neurologic conditions who are<br>unwilling or incapable of<br>following postoperative care<br>instructions<br>4. Foreign body sensitivity - where<br>material sensitivity is suspected,<br>tests are to be made prior to<br>implantation |
| Target Population | Pediatrics and Adults | Pediatrics and Adults | Adolescents and Adults | Pediatrics and Adults |
| Anatomical Sites | Oral, Mandibular and Maxillofacial<br>Areas | Cranial, Oral, Mandibular and<br>Maxillofacial Areas | Oral, Mandibular and Maxillofacial<br>Areas | Cranial, Oral, Mandibular and<br>Maxillofacial Areas |
| Characteristic | RxG Distraction System | LactoSorb Distraction | Resorb-X G | Zurich Distraction System |
| Materials | | | | |
| Bone Plates | 85:15 PLLA/PGA | 82:18 PLLA/PGA | 85:15 PLLA/PGA | TI-6AL-4V or CP Titanium |
| Bone<br>Pins/Screws | 85:15 PLLA/PGA | 82:18 PLLA/PGA | 85:15 PLLA/PGA | TI-6AL-4V |
| Drive Screw | TI-6AL-4V or Stainless Steel | Stainless Steel | N/A | TI-6AL-4V |
| Activation Arm | TI-6AL-4V or Stainless Steel | TI-6AL-4V, Stainless Steel | N/A | TI-6AL-4V |
| Sterility | Provided Sterile (Gamma Radiation) | Provided Sterile (ETO) | Provided Sterile (Gamma Radiation) | Provided Non-Sterile (Steam) |
| Where used (hospital, home, ambulance, etc) | Health Care Facilities/ Hospitals | Health Care Facilities/ Hospitals | Health Care Facilities/ Hospitals | Health Care Facilities/Hospitals |
| Breakdown Products (Plates, Pins/Screws) | H₂O and CO₂ | H₂O and CO₂ | H₂O and CO₂ | Not applicable |
| Resorption Time | 12-14 months | 12 months | 12-14 months | Not applicable |
| Max. Distraction Distance | | | | |
| Alveolar Ridge Distractor | 25 mm | 25 mm | N/A | 15 mm |
| Midface Distractor | 30 mm | 40 mm | N/A | 30 mm |
| Mandibular Distractor | 30 mm | 25 mm | N/A | 30 mm |
| Plate Thickness | 2-5 mm | 2-5 mm | 0.6 - 1.0 mm | 0.6 mm |
| Cumulative Max. Plate Volume | 7840 mm³ | Unknown | 15876 mm³ | Not applicable |
| Pin/Screw Diameter | 2.1 mm | 1.5-2.5 mm | 1.6 mm | 1.5 mm |
| Pin/Screw Length | 3-7 mm | 6-9 mm | 5 mm | 3.5-6 mm |
.
RxG Distraction System, K13330
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KUS MONTEN L.P. P.O.Box 18389 v Jacksonille, FL 3224-6369
Kiloman Can L.P. P.O.Box 16389 v Jacksonille, FL 3245-6369
www.klsmarti.com L. P. www.klsmartin.com
RxG Distraction System, K133304
.
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Image /page/3/Picture/0 description: The image shows the logo for KLS Martin L.P. The text is in a bold, sans-serif font. The letters are black and have a textured appearance.
## Performance Testing:
Comparative mechanical testing was performed between the RxG distractor and the LactoSorb distractor. The devices were affixed to abutted sawbone blocks to simulate an osteotomy and placed in a waterbath of Ringers solution for 48 hrs. Distraction and consolidation were then simulated over a period of 52 days. Deformation measurements were taken at regular intervals. The results of the mechanical testing showed that the RxG Distractor is substantially equivalent to the predicate.
#### Pyrogenicity:
No claim of "pyrogen free" is made.
#### Conclusion:
The RxG Distraction System has the same intended use as the predicate, the LactoSorb Distractor. The performance testing results and similarities in technological characteristics do not raise new issues of safety or effectiveness and demonstrate substantial equivalence to the predicate devices.
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Image /page/4/Picture/1 description: The image shows a circular seal with an emblem in the center. The emblem features a stylized bird with three curved lines representing its wings or feathers. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged around the upper half of the circle, following its curvature.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 15, 2014
KLS-Martin, LP Jennifer Damato Director of Quality Management and Regulatory Affairs 11201 Saint Johns Industrial Pkwy S Jacksonville, FL 32246 US
Re: K133304
> Trade/Device Name: RxG Distraction System Regulation Number: 21 CFR 872.4760 Regulation Name: Bone Plate Regulatory Class: Class II Product Code: JEY Dated: April 14, 2014 Received: April 17, 2014
Dear Ms. Damato:
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.
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Page 2 - Ms. Damato
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 of medical devicerelated 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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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
http://www.fda.gov/MedicalDevices/Safety/Reportal?roblem/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.
# Mary S: Runner -S
Erin I. Keith. M.S. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
# SECTION 4
510(k) Number (if known):
K133304
RxG Distraction System Device Name:
### Indications for Use:
The RxG Distraction System includes devices intended for use in bone stabilization and elongation (lengthening) in the correction of congenital or developmental defects of the midface and alveolar ridge.
The RxG Distraction System also includes devices intended for use in bone stabilization and elongation (lengthening) in the correction of congenital or developmental defects of the mandible in patients 2 years old or younger.
The RxG Distraction System is not intended for load-bearing applications in adult or adolescent populations.
イ Prescription Use (Part 21 CFR 801 Subpart D) AND/OR Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Sheena A Green S
2014.05.15 08.37.50 -04'00'
RxG Distraction System 510(k)
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.