K151068 · Cayenne Medical, Inc. · MBI · Jul 24, 2015 · Orthopedic
Device Facts
Record ID
K151068
Device Name
SureLock W Suture Anchor
Applicant
Cayenne Medical, Inc.
Product Code
MBI · Orthopedic
Decision Date
Jul 24, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3040
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Cayenne Medical, Inc. SureLock™ W Suture Anchors is intended to be used for the reattachment of soft tissue to bone in rotator cuff repairs.
Device Story
SureLock™ W Suture Anchor is a sterile, manually operated, single-use device for reattaching soft tissue to bone. It consists of a 2.5mm anchor preloaded with two floating UHMWPE sutures on a disposable inserter. Used in arthroscopic, open, or limited access procedures by orthopedic surgeons. The inserter places the anchor into a pre-drilled bone hole; rotating a knob on the inserter handle tensions the floating sutures, expanding and deploying the anchor within the bone tunnel. Once deployed, the suture limbs are released, and the inserter is removed. The device facilitates secure soft tissue fixation, aiding in rotator cuff repair and patient recovery.
Clinical Evidence
No clinical data. Substantial equivalence established via non-clinical performance testing, including biocompatibility and mechanical testing in two bone block densities.
Indicated for reattachment of soft tissue to bone in rotator cuff repairs.
Regulatory Classification
Identification
A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.
Predicate Devices
Cayenne Medical SureLock™ All-Suture Anchor (K132867)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 24, 2015
Cayenne Medical, Incorporated Shima Hashemian RA/QA Director 16597 N 92nd Street, Suite 101 Scottsdale, Arizona 85260
Re: K151068
Trade/Device Name: Surelock™ W Suture Anchor Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: MBI Dated: July 6, 2015 Received: July 14, 2015
Dear Shima Hashemian:
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) 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" (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/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,
# Mark N. Melkerson -S
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# K151068 Indications for Use
Device Name: SureLock™ W Suture Anchor
Indications for Use:
The Cayenne Medical, Inc. SureLock™ W Suture Anchors is intended to be used for the reattachment of soft tissue to bone in rotator cuff repairs.
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 IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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# 510(k) Summary
# Cayenne Medical, Inc.
SureLock™ W Suture Anchor
## Administrative Information
| Date of summary: | 04/16/2015 |
|--------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer Name: | Cayenne Medical, Inc.<br>16597 N. 92nd St., Suite 101<br>Scottsdale, AZ 85260<br>Telephone (480) 502-3661<br>FAX (480) 502-3670 |
| Official Contact: | Shima Hashemian<br>16597 N. 92nd St., Suite 101<br>Scottsdale, AZ 85260<br>shashemian@cayennemedical.com<br>Telephone (480) 502-3661<br>FAX (480) 502-3670 |
# Device Name
| Classification Name: | Smooth or threaded metallic bone fixation fastener |
|-------------------------|----------------------------------------------------|
| Trade/Proprietary Name: | SureLockTM W Suture Anchor |
| Common Name: | Suture Anchor |
## Device Classification
FDA has classified bone screws as Class II devices (21 CFR 888.3040). The product code for Fastener, Fixation, Nondegradable, and Soft Tissue is MBI.
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#### Device Description
The SureLock™ W Suture Anchor is a sterile, manually operated, single procedure suture anchor device for reattachment of soft tissue to bone. The suture anchor is preloaded with floating suture and loaded on a disposable inserter. The SureLock™ W Suture Anchor incorporates design features that facilitate suture anchor placement under arthroscopic, open, or limited access conditions in soft tissue to bone reattachment procedures.
The SureLock™ W Suture Anchor is offered in one size, 2.5mm. The anchors are made out of non-absorbable Ultra High Molecular Weight Polyethylene (UHMWPE) surgical suture, PolyEtherEtherKetone (PEEK), and L-lactide/glycolide copolymer (PLGA). The floating sutures are made out of size 2 non-absorbable UHMWPE surgical sutures. The suture anchor is pre-loaded with two floating sutures.
The disposable inserter has a working shaft length of 22.2 cm with an outer shaft diameter of 4.6mm. The inserter shaft is made out of surgical grade stainless steel and the handle and knob are made out of ABS plastic. The inserter pushes the suture anchor into a hole drilled in the bone. The knob on the inserter handle is rotated to apply tension to the floating sutures to expand and deploy the anchor in the bone tunnel. When the knob is fully rotated, the floating suture limbs are released from the inserter and the inserter is removed.
#### Intended use
The Cayenne Medical, Inc. SureLock™ W Suture Anchor is intended to be used for the reattachment of soft tissue to bone in rotator cuff repairs.
#### Technological Differences
The SureLock™ W Suture Anchor is similar in indications for use, intended use, design features, technology, and materials to the predicate device.
The subject SureLock™ W device has the same intended use as the predicate device, the Cayenne Medical SureLock™ All-Suture Anchor. The predicate device has a broader indication for use compared to the subject device. The subject device is only indicated for soft tissue to bone attachment in rotator cuff revairs but the predicate device is indicated for soft tissue to bone attachment in shoulder, foot and ankle, elbow, hand and wrist, hip, and knee procedures. Cayenne Medical tested both predicate and subject devices for the subject device indication using two bone block densities.
The subject device differs from the predicate device, Cayenne Medical SureLock™, in terms of the anchor materials, design features (wick component), and the offered sizes.
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## Non-clinical Testing
Non-clinical testing data submitted, referenced, or relied upon to demonstrate substantial equivalence is included. The results of performance testing, including biocompatibility, and mechanical testing demonstrated that the functionality and safety of the SureLock™ W Suture Anchor are adequate for its intended use and determination of substantial equivalence to the predicate device.
## Clinical Testing
Clinical testing was not used to establish substantial equivalence to predicate device.
### Equivalence to Marketed Product
Cayenne Medical, Inc. demonstrated that, for the purposes of FDA's regulation of medical devices, the SureLock™ W Suture Anchor is substantially equivalent in indication and design principles to the predicate device, which has been determined by FDA to be substantially equivalent to preamendment devices: Cayenne Medical SureLock™ All-Suture Anchor (K132867). The substantial equivalence of SureLock™ W Suture Anchor is based on similarities in indications for use, intended use, design features, technology, and materials to the predicate device.
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.