The Aequalis Ascend Flex Shoulder System is intended for use as: · A replacement of shoulder joints in primary anatomic or in primary reverse. · A replacement of other shoulder ioints devices in case of revisions if sufficient bone stock remains. · The Aequalis Ascend Flex Shoulder System also allows for conversions from anatomic to reverse shoulder prosthesis in case of revision. IN ANATOMIC: The stem and head by themselves, as a hemiarthroplasty, if the natural glenoid provides a sufficient bearing surface, or in conjunction with the glenoid, as a total replacement. The Aequalis Ascend Flex Shoulder System is to be used only in patients with an intact or reconstructable rotator cuff, where it is intended to provide increased mobility and stability and to relieve pain. The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints disabled by: · Rheumatoid arthritis with pain · Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascu Jar necrosis) · Correction of functional deformity · Fractures of the humeral head · Traumatic arthritis · Revision of other devices if sufficient bone stock remains IN REVERSE: The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints for patients with a functional deltoid muscle and with massive and non-repairable rotator cuff-tear with pain disabled by: Rheumatoid arthritis; Noninflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis); Correction of functional deformity; Fractures of the humeral head; Traumatic arthritis; Revision of the devices if sufficient bone stock remains. The reversed adapter is indicated for use as components of the Shoulder System total shoulder replacement and for transformation of the Aequalis Assend Flex Shoulder prosthesis without the removal of the humeral stem during revision surgery for patients with a functional deltoid muscle. The components are permitted to be used in the transformation from anatomic to reverse if the humeral stem is well fixed, the patient has a functional deltoid muscle; the arthropatly is associated with a massive and non-repairable rotator cuff-tear.
Device Story
Aequalis Ascend Flex Shoulder System is a modular shoulder prosthesis for anatomic or reverse total shoulder arthroplasty and hemiarthroplasty. System components include humeral stems (titanium, coated/uncoated), humeral heads (cobalt-chrome or titanium), glenoid components (UHMWPE), and reverse adapters (titanium tray/UHMWPE insert). Titanium humeral heads are specifically intended for patients with suspected cobalt alloy sensitivity. Device is implanted by orthopedic surgeons in a clinical/surgical setting. It replaces diseased or damaged shoulder joints to restore mobility, stability, and relieve pain. The system allows for conversion from anatomic to reverse configuration during revision surgery without removing a well-fixed humeral stem. Clinical benefit is achieved through mechanical joint replacement, restoring function to patients with severe joint pathology.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing: wear testing comparing Ti/UHMWPE and CoCr/UHMWPE couples, and fatigue testing for both anatomical and reversed configurations to ensure structural integrity under simulated lifetime loading conditions.
Technological Characteristics
Materials: Ti6Al4V (ISO 5832-3) for humeral heads, CoCr, UHMWPE. Fixation: Cemented or cementless (coated stems). Modular design with male taper geometry. Sterilization: Terminal sterilization. Dimensions: 37-54mm diameter, 13.5-27mm height. Connectivity: None (mechanical implant).
Indications for Use
Indicated for patients requiring shoulder joint replacement due to rheumatoid arthritis, non-inflammatory degenerative joint disease (osteoarthritis, avascular necrosis), functional deformity, humeral head fractures, or traumatic arthritis. Anatomic configuration requires intact/reconstructable rotator cuff. Reverse configuration requires functional deltoid muscle and massive, non-repairable rotator cuff tear. Revision use requires sufficient bone stock.
Regulatory Classification
Identification
A shoulder joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a shoulder joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces. It has no linkage across-the-joint. This generic type of device includes prostheses that have a humeral resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, and is limited to those prostheses intended for use with bone cement (§ 888.3027).
Special Controls
*Classification.* Class II. The special controls for this device are:(1) FDA's:
(i) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(ii) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),”
(iii) “Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement,”
(iv) “Guidance Document for the Preparation of Premarket Notification (510(k)) Application for Orthopedic Devices,” and
(v) “Guidance Document for Testing Non-articulating, ‘Mechanically Locked’ Modular Implant Components,”
(2) International Organization for Standardization's (ISO):
(i) ISO 5832-3:1996 “Implants for Surgery—Metallic Materials—Part 3: Wrought Titanium 6-aluminum 4-vandium Alloy,”
(ii) ISO 5832-4:1996 “Implants for Surgery—Metallic Materials—Part 4: Cobalt-chromium-molybdenum casting alloy,”
(iii) ISO 5832-12:1996 “Implants for Surgery—Metallic Materials—Part 12: Wrought Cobalt-chromium-molybdenum alloy,”
(iv) ISO 5833:1992 “Implants for Surgery—Acrylic Resin Cements,”
(v) ISO 5834-2:1998 “Implants for Surgery—Ultra-high Molecular Weight Polyethylene—Part 2: Moulded Forms,”
(vi) ISO 6018:1987 “Orthopaedic Implants—General Requirements for Marking, Packaging, and Labeling,” and
(vii) ISO 9001:1994 “Quality Systems—Model for Quality Assurance in Design/Development, Production, Installation, and Servicing,” and
(3) American Society for Testing and Materials':
(i) F 75-92 “Specification for Cast Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implant Material,”
(ii) F 648-98 “Specification for Ultra-High-Molecular-Weight Polyethylene Powder and Fabricated Form for Surgical Implants,”
(iii) F 799-96 “Specification for Cobalt-28 Chromium-6 Molybdenum Alloy Forgings for Surgical Implants,”
(iv) F 1044-95 “Test Method for Shear Testing of Porous Metal Coatings,”
(v) F 1108-97 “Specification for Titanium-6 Aluminum-4 Vanadium Alloy Castings for Surgical Implants,”
(vi) F 1147-95 “Test Method for Tension Testing of Porous Metal,”
(vii) F 1378-97 “Standard Specification for Shoulder Prosthesis,” and
(viii) F 1537-94 “Specification for Wrought Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implants.”
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized depiction of an eagle or bird-like figure with three curved lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 2, 2016
Tornier SAS Mr. Aymen Azaiez Regulatory Affairs Specialist 161 rue Lavoisier 38334 Montbonnot Cedex FRANCE
Re: K140082
Trade/Device Name: Aequalis™ Ascend™ Flex Shoulder System Regulation Number: 21 CFR 888.3660 Regulation Name: Shoulder joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: PHX, KWS, KWT, HSD Dated: June 17, 2014 Received: June 19, 2014
Dear Mr. Azaiez:
This letter corrects our substantially equivalent letter of July 18, 2014.
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
{1}------------------------------------------------
Page 2 - Mr. Aymen Azaiez
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical 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 contact the Division of Industry and Consumer Education 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. 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 Industry and Consumer Education 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,
## Lori A. Wiggins -S
for Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known) Ki40082
Device Name
AequalisTM AscendTM Flex Shoulder System
Indications for Use (Describe)
SYSTEM INTENDED USE:
The Aequalis Ascend Flex Shoulder System is intended for use as:
· A replacement of shoulder joints in primary anatomic or in primary reverse.
· A replacement of other shoulder ioints devices in case of revisions if sufficient bone stock remains.
· The Aequalis Ascend Flex Shoulder System also allows for conversions from anatomic to reverse shoulder prosthesis in case of revision.
IN ANATOMIC: The stem and head by themselves, as a hemiarthroplasty, if the natural glenoid provides a sufficient bearing surface, or in conjunction with the glenoid, as a total replacement.
The Aequalis Ascend Flex Shoulder System is to be used only in patients with an intact or reconstructable rotator cuff, where it is intended to provide increased mobility and stability and to relieve pain.
The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints disabled by:
· Rheumatoid arthritis with pain
· Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascu Jar necrosis)
· Correction of functional deformity
· Fractures of the humeral head
· Traumatic arthritis
· Revision of other devices if sufficient bone stock remains
IN REVERSE: The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints for patients with a functional deltoid muscle and with massive and non-repairable rotator cuff-tear with pain disabled by: Rheumatoid arthritis; Noninflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis); Correction of functional deformity; Fractures of the humeral head; Traumatic arthritis; Revision of the devices if sufficient bone stock remains.
The reversed adapter is indicated for use as components of the Shoulder System total shoulder replacement and for transformation of the Aequalis Assend Flex Shoulder prosthesis without the removal of the humeral stem during revision surgery for patients with a functional deltoid muscle. The components are permitted to be used in the transformation from anatomic to reverse if the humeral stem is well fixed, the patient has a functional deltoid muscle; the arthropatly is associated with a massive and non-repairable rotator cuff-tear.
Notes: All components are single use. The coated humeral stem is intented or cementless use, The non-coated humeral stem is intended for cemented use only, All poly glenoid components are intended use only; The glenoid sphere implant is anchored to the bone with screws and is for non-cemented fixation humeral heads are intended for patients with suspected cobalt alloy material sensitivity. The wear properties of Titanium alloys are inferior to that of cobalt alloy. A titanium humeral head is not recommended for patients who lack a suspected material sensitivity to cobalt alloy.
Type of Use (Select one or both, as applicable) O Over-The-Counter Use (21 CFR 801 Subpart C) Prescription Use (Part 21 CFR 801 Subpart D)
## PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON A SEPARATE PAGE IF NEEDED.
### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.
{3}------------------------------------------------
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.•
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, induding suggestions for reducing this burden, to:
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# 510(k) SUMMARY
JUL 1 8 2014
## Summary of Safety and Effectiveness information
510(k) Premarket Notification - Aequalis™ Ascend™ Flex Shoulder System
Date prepared: July 17, 2014
Regulatory authority: Safe Medical Devices Act of 1990, 21 CRF 807.92
#### 1) Device name
#### Trade name: Aequalis™ Ascend™ Flex Shoulder System Common name: Shoulder Prosthesis Classification name:
Classification name.
- Shoulder joint metal/polymer non-constrained
- · Shoulder joint metal/polymer non-constrained cemented prosthesis are class II devices under 21 CFR 888.3650 (product code KWT) and are classified by the Orthopedic Devices Panel
- · Shoulder joint metal/polymer semi-constrained cemented prosthesis are class II devices under 21 CFR 888.3660 (product code KWS) and are classified by the Orthopedic Devices Panel
- · Shoulder joint humeral (hemi-shoulder) metallic uncemented prosthesis are class II devices under CFR 888.3690 (product code HSD) and are classified by the Orthopedic Devices Panel
#### 2) Submitter
TORNIER SAS 161 rue Lavoisier 38330 Montbonnot Saint Martin- France Registration Number: 3000931034
#### 3) Company contact
Tornier Mr Aymen AZAIEZ Regulatory Affairs Specialist Tornier 161 rue Lavoisier 38330 Montbonnot Saint Martin- France
Fax: 00 33 4 76 61 35 59 Tel: 00 33 4 76 61 35 00 E-mail: aymen.azaiez@tornier.com
#### 4) Classification
Device class: Classe II Classification panel: Orthopedic Product code: KWT; KWS; HSD:
#### 5) Equivalent / Predicate device
Tornier SAS: Aequalis™ Ascend™ Flex Shoulder System (K122698)
Tornier SAS: Aequalis® Shoulder System (K952928)
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#### K 140082 Page 2 of 5
#### 6) Device description
The Aequalis Ascend Flex Shoulder System consists of:
- . In a Anatomic configuration: A titanium humeral stem offered in Titanium Plasma Spray (Ti PS) coated and un-coated stem versions, a compatible humeral head (COCr) with a compatible UHMWPE Aequalis glenoid; or UHMWPE Affiniti Anatomic glenoid. The Aequalis Ascend Flex Shoulder System stem and head may be used by themselves, as a hemiarthroplasty, if the natural glenoid provides a sufficient bearing surface, or in conjunction with a glenoid, as a total shoulder joint replacement.
- In a Reversed configuration: a titanium humeral stem offered in Titanium Plasma Spray (Ti PS) . coated and un-coated stem versions, a reversed adapter with compatible Aequalis Reversed glenoid implants.
The reversed adapter is comprised of two components: a titanium tray and a UHMWPE reversed insert.
The Aequalis Reversed glenoid implants is comprised of four components: Baseplate: made from Titanium; Glenoid sphere; made from of CoCr; Screw (baseplate/to glenoid sphere): made from CoCr and Fixation screws: made from Titanium.
The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints for patients with a functional deltoid muscle and with massive and non-repairable rotator cuff-tear. This submission corresponds to the addition of Titanium Humeral Heads in anatomic to the Aequalis™ Ascend™ Flex Shoulder System.
#### 7) Materials
The Aequalis™ Ascend™ Flex Shoulder System titanium humeral head is manufactured from Ti6Al/4 according to ISO 5832-3 standard.
#### 8) Indications for use
#### SYSTEM INTENDED USE:
The Aequalis Ascend Flex Shoulder System is intended for use as:
- A replacement of shoulder joints in primary anatomic or in primary reverse. .
- A replacement of other shoulder joints devices in case of revisions if sufficient bone stock remains. .
- The Aequalis Ascend Flex Shoulder System also allows for conversions from anatomic to reverse shoulder prosthesis in case of revision.
IN ANATOMIC: The stem and head may be used by themselves, as a hemiarthroplasty, if the natural glenoid provides a sufficient bearing surface, or in conjunction with the glenoid, as a total replacement. The Aequalis Ascend Flex Shoulder System is to be used only in patients with an intact or reconstructable rotator cuff. where it is intended to provide increased mobility and stability and to relieve pain. The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints disabled bv:
- Rheumatoid arthritis with pain .
- Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis) .
- Correction of functional deformity .
- Fractures of the humeral head .
- Traumatic arthritis ●
- Revision of other devices if sufficient bone stock remains .
IN REVERSE: The Aequalis Ascend Flex Shoulder System is indicated for use as a replacement of shoulder joints for patients with a functional deltoid muscle and with massive and non-repairable rolator cuff-tear with pain disabled by:
- Rheumatoid arthritis .
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- Non-inflammatory degenerative joint disease (i.e. osteoarthritis and avascular necrosis) .
- . Correction of functional deformity
- Fractures of the humeral head .
- Traumatic arthritis ●
- Revision of the devices if sufficient bone stock remains .
The reversed adapter is indicated for use as components of the Aequalis Ascend Flex Shoulder System total shoulder replacement and for transformation of the Aequalis Ascend Flex Shoulder System into a reverse shoulder prosthesis without the removal of the humeral stem during revision surgery for patients with a functional deltoid muscle. The components are permitted to be used in the transformation from anatomic to reverse if the humeral stem is well fixed, the patient has a functional deltoid muscle: the arthropathy is associated with a massive and non-repairable rotator cuff-tear.
Notes:
- All components are single use. .
- The coated humeral stem is intended for cemented or cementless use. .
- The non-coated humeral stem is intended for cemented use only. .
- All poly glenoid components are intended for cemented use only. .
- The glenoid sphere implant is anchored to the bone with screws and is for non-cemented fixation. .
- · · Titanium humeral heads are intended for patients with suspected cobalt alloy material sensitivity. The wear properties of Titanium and Titanium alloys are inferior to that of cobalt alloy. A titanium humeral head is not recommended for patients who lack a suspected material sensitivity to cobalt alloy.
## 9) Summary of technological characteristics
| Main features or system<br>characteristics | | Aequalis Ascend Flex Shoulder<br>System<br>Humeral Heads (titanium) | | Aequalis Ascend Flex Shoulder<br>System<br>Humeral Heads (Cobalt Chrome) | | Aequalis<br>Shoulder<br>System<br>Aequalis<br>Humeral Heads | SE? |
|--------------------------------------------|--------------|---------------------------------------------------------------------|----------------------------------------------------|--------------------------------------------------------------------------|----------------------------------------------------|-------------------------------------------------------------|-----|
| | | Aequalis<br>Humeral<br>Heads | Soft Tissue<br>Balancing<br>(STB) Humeral<br>Heads | Aequalis<br>Humeral<br>Heads | Soft Tissue<br>Balancing<br>(STB) Humeral<br>Heads | | |
| Material | | Ti6Al4V | | CoCr | | Ti6Al4V | Yes |
| Standard | | ISO 5832-3 | | ISO 5832-7 or<br>ISO 5832-12 | | ISO 5832-3 | Yes |
| Dimensions | Diameter | 37mm to<br>54mm | 39mm to<br>55.4mm | 37mm to<br>54mm | 39mm to<br>55.4mm | 39mm to<br>50mm | Yes |
| | Height | 13.5mm to<br>27mm | 13mm to<br>24mm | 13.5mm to<br>27mm | 13mm to<br>24mm | 14mm to<br>16mm | Yes |
| | Eccentricity | 1.5mm; 3.5mm and 4mm | | 1.5mm; 3.5mm and 4mm | | 2mm; 2.2mm;<br>2.3mm;<br>3mm;3.9mm et<br>4.7mm | Yes |
| Taper gender geometry | | Male | | Male | | Female | Yes |
| Manufacturer | | Tornier | | Tornier | | Tornier | Yes |
| Terminal sterilization | | Yes | | Yes | | Yes | Yes |
| K-number | | Pending | | K122698 | | K952928 | Yes |
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#### K140082 Page 4 of 5
The indications for use, the technical characteristics (manufacturing principle and method of fixation), the packaging and the sterilization process of they are similar or identical to the predicate devices.
#### 10) Non-clinical testing
Three non-clinical testing were realized on the titanium humeral heads:
- Wear test:
The aim of the test is to demonstrate that the Titanium humeral head remain intact during its lifetime. Therefore, we have tested the wear of the frictional couple Ti / UHMWPE and compared the results with those of the frictional couple CoCr/UHMWPE.
The results of this test are equivalent between the two frictional couples CoCr / UHMWPE (already used in the predicate device "Aequalis Ascend Flex Shoulder System") and TI / UHMWPE in terms of: weight loss, wear rate and shape and size of the particles generated.
Anatomical Fatigue Test:
The aim of the test is to show that the AequalisTM Ascend Flex Shoulder System in anatomical configuration remains intact during its lifetime. The assembly humeral head/ stem must resist in normal conditions of use.
After applying a load for SM cycles, we have observed neither fracture nor damage. Thus, the Aequalis™ Ascend Flex Shoulder System in anatomical configuration is validated with the titanium humeral head as is the case with the CoCr humeral head (predicate device).
Reversed fatique test: -
The aim of the test is to show that the Aequalis™ Ascend Flex Shoulder System in reversed configuration remains intact during its lifetime after revision from an anatomical configuration to a reversed configuration after a first lifetime in an anatomical configuration. The assembly humeral headl stem must resist in normal conditions of use.
After applying a load for SM cycles. we have observed neither fracture nor damage. Thus, the Aequalis™ Ascend Flex Shoulder in reversed configuration after revision from an anatomical configuration to a reversed configuration after a first lifetime in anatomical configuration with the titanium humeral head is validated as is the case with the CoCr humeral head (predicate device).
#### 11) Substantial equivalence conclusion
Substantial equivalence of the Aequalis Ascend Flex Shoulder System titanium humeral heads to the already cleared components of the predicates can be demonstrated on the following grounds, according to the FDA's Guidelines for Substantial Equivalence Decision Making Process:
- The Aequalis Ascend Flex Shoulder System titanium humeral heads are compared to the predicate . devices.
- The Aequalis Ascend Flex Shoulder System Tianium humeral heads have the same intended use and l the same indications for use as the cleared Aequalis Ascend Flex Shoulder System Cobals Chrome humeral heads.
- The Aequalis Ascend Flex Shoulder System titanium humeral heads have equivalent intended use and indications for use as Aequalis Shoulder System Aequalis Humeral Head in titunium.
Tomier
{8}------------------------------------------------
- Major technological characteristics are equivalent between the Aequalis Ascend Flex Shoulder System titanium humeral heuds and the predicate devices:
- Equivalence of general features -
- Equivalent technological features: materials •
- Equivalent biomechanical features: mechanical characteristics, congruence of articular surfaces.
- Equivalent means of fixation (Taper gender geometry) -
- Equivalent prosthetic dimensions -
Therefore, in light of the above information, the company believes that the Aequalis Ascend Flex Shoulder System with itanium humerul heads may be cleared via the 510(k) notification process for use as shoulder prosthesis.
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.