VertebraLINK Fusion Platform

K162693 · Facetlink Dba Linkspine · MAX · Mar 29, 2017 · Orthopedic

Device Facts

• Record ID: K162693
• Device Name: VertebraLINK Fusion Platform
• Applicant: Facetlink Dba Linkspine
• Product Code: MAX · Orthopedic
• Decision Date: Mar 29, 2017
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The VertebraLINK Fusion Platform is indicated for use in patients with degenerative disc disease (DDD) at one or two levels from L2 to S1. These DDD patients may also have up to Grade 1 Spondylolisthesis or retrolisthesis at the involved levels. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had six months of non-operative treatment. These implants may be implanted via an open or a minimally invasive posterior approach. Alternatively, these implants may also be implanted via posterior and/or transforaminal approach. These implants are to be used with autogenous bone graft. These devices are intended to be used with supplemental fixation instrumentation, which has been cleared by the FDA for use in the lumbar spine.

Device Story

VertebraLINK Fusion Platform consists of box-shaped intervertebral body fusion devices; implanted into prepared disc space to facilitate fusion. Devices feature central axial opening for autogenous bone graft; superior/inferior teeth to resist expulsion; tantalum radiographic markers. Manufactured from PEEK Optima LT1 or PEEK Optima HA Enhanced. Offered in various dimensions/lordoses for patient-specific anatomy. Used in lumbar spine (L2-S1) via open, minimally invasive, posterior, or transforaminal approaches. Requires supplemental fixation instrumentation cleared for lumbar spine. Surgeon-operated in clinical/OR settings. Provides structural support to disc space; promotes fusion; benefits patients by addressing discogenic back pain.

Clinical Evidence

Bench testing only. Testing included static and dynamic axial compression (ASTM F2077), expulsion (ASTM Draft Standard F-04.25.02.02), subsidence (ASTM F2267), and Bacterial Amebocyte Lysate (LAL) testing (AAMI ST72). Results demonstrate mechanical strength and safety equivalent to predicate devices.

Technological Characteristics

Materials: PEEK Optima LT1 or PEEK Optima HA Enhanced (ASTM F2026); Tantalum markers (ASTM F560). Form factor: Box-shaped intervertebral cages with central graft aperture and surface teeth. Energy source: None (mechanical). Sterilization: Not specified. Connectivity: None.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) at one or two levels from L2 to S1, including those with up to Grade 1 Spondylolisthesis or retrolisthesis, who have failed six months of non-operative treatment.

Regulatory Classification

Identification

An intervertebral body fusion device is an implanted single or multiple component spinal device made from a variety of materials, including titanium and polymers. The device is inserted into the intervertebral body space of the cervical or lumbosacral spine, and is intended for intervertebral body fusion.

Special Controls

*Classification.* (1) Class II (special controls) for intervertebral body fusion devices that contain bone grafting material. The special control is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intervertebral Body Fusion Device.” See § 888.1(e) for the availability of this guidance document.(2) Class III (premarket approval) for intervertebral body fusion devices that include any therapeutic biologic (e.g., bone morphogenic protein). Intervertebral body fusion devices that contain any therapeutic biologic require premarket approval. (c) *Date premarket approval application (PMA) or notice of product development protocol (PDP) is required.* Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.

Predicate Devices

• Interbody System (K130573)
• AccuLiF® TL-PEEK Cage and AccuLiF® TL and PL (K112095)
• PLIF Cage (K113478)

Reference Devices

• Px HATM PEEK IBF System (K151785)

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

March 29, 2017

FacetLINK dba LINKSpine % Kenneth C. Maxwell II Regulatory and Quality Specialist Empirical Testing Corp. 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K162693

Trade/Device Name: VertebraLINK Fusion Platform Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: March 3, 2017 Received: March 8, 2017

Dear Mr. Maxwell:

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 [phone] or [phone] 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 [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely,

# 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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K162693 Page 1 of 1

| DEPARTMENT OF HEALTH AND HUMAN SERVICES | Form Approved: OMB No. 0910-0120 |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Food and Drug Administration | Expiration Date: January 31, 2017 |
| Indications for Use | See PRA Statement on last page. |
| 510(k) Number (if known) | K162693 |
| Device Name | VertebraLINK Fusion Platform |
| Indications for Use (Describe) | The VertebraLINK Fusion Platform is indicated for use in patients with degenerative disc disease (DDD) at one or two levels from L2 to S1. These DDD patients may also have up to Grade 1 Spondylolisthesis or retrolisthesis at the involved levels. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had six months of non-operative treatment. These implants may be implanted via an open or a minimally invasive posterior approach. Alternatively, these implants may also be implanted via posterior and/or transforaminal approach. These implants are to be used with autogenous bone graft. These devices are intended to be used with supplemental fixation instrumentation, which has been cleared by the FDA for use in the lumbar spine. |
| Type of Use (Select one or both, as applicable) | <div style="display:flex; flex-direction:row; align-items:center;"><span style="margin-right: 5px;"> Prescription Use (Part 21 CFR 801 Subpart D)</span> <span> Over-The-Counter Use (21 CFR 801 Subpart C)</span></div> |
| PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON A SEPARATE PAGE IF NEEDED. | |
| FOR FDA USE ONLY | |
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| *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 | |

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, including suggestions for reducing this burden, to: Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff

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FORM FDA 3881 (9/13)

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# 510(K) SUMMARY

| Submitter's Name: | FacetLINK dba LINKSpine |
|----------------------------|------------------------------------------------------------------|
| Submitter's Address: | 101 Roundhill Drive<br>Rockaway, NJ 07866 |
| Submitter's Telephone: | 973.627.4171 |
| Contact Person: | Kenneth C. Maxwell II<br>Empirical Testing Corp.<br>719.291.6874 |
| Date Summary was Prepared: | 23 March2016 |
| Trade or Proprietary Name: | VertebraLINK Fusion Platform |
| Common or Usual Name: | Intervertebral Fusion Device With Bone Graft, Lumbar |
| Classification: | Class II per 21 CFR §888.3080 Device Classification |
| Product Code: | MAX |
| Classification Panel: | Division of Orthopedic Devices |

# DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION

The VertebraLINK Fusion Platform is a comprehensive suite of generally box shaped devices which can be implanted into the prepared disc space when performing an intervertebral body fusion. The devices are manufactured from Invibio's PEEK Optima LT1 or PEEK Optima HA Enhanced per ASTM F2026. The devices contain a central axial opening for packing of bone graft material as well as teeth on the inferior and superior surfaces to resist expulsion. The platform will be offered in multiple lengths, widths, heights and lordoses to accommodate varying anatomies, pathologies, surgeon preferences, or techniques (i.e., TLIF, PLIF, or Oblique PLIF). Additionally, the device contains radiographic markers made from tantalum per ASTM F560.

#### INDICATIONS FOR USE

The VertebraLINK Fusion Platform is indicated for use in patients with degenerative disc disease (DDD) at one or two levels from L2 to S1. These DDD patients may also have up to Grade 1 Spondylolisthesis or retrolisthesis at the involved levels. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had six months of non-operative treatment. These implants may be implanted via an open or a minimally invasive posterior approach. Alternatively, these implants may also be implanted via posterior and/or transforaminal approach. These implants are to be used with autogenous bone graft. These devices are intended to be used with supplemental fixation instrumentation, which has been cleared by the FDA for use in the lumbar spine.

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| 510k Number | Trade or Proprietary or<br>Model Name | Manufacturer | Predicate Type |
|-------------|-------------------------------------------------|--------------------|----------------|
| K130573 | Interbody System | Tyber Medical | Primary |
| K112095 | AccuLiF® TL-PEEK Cage<br>and AccuLiF® TL and PL | CoAlign Innovation | Additional |
| K113478 | PLIF Cage | Eisertech | Additional |
| K151785 | Px HATM PEEK IBF<br>System | Innovasis | Reference |

Table 5-1: Predicate Devices

### PERFORMANCE DATA

The following testing has been completed as part of the VertebraLINK Fusion Platform submission:

- . Static axial compression per ASTM F2077
- Dynamic axial compression per ASTM F2077 ●
- Expulsion per ASTM Draft Standard F-04.25.02.02 ●
- . Subsidence per ASTM F2267
- . Bacterial Amebocyte Lysate (LAL) testing per AAMI ST72

The results of this non-clinical testing show that the strength of the VertebraLINK Fusion Platform is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

#### TECHNOLOGICAL CHARACTERISTICS

The following technological characteristics are similar between the VertebraLINK Fusion Platform and the predicate devices:

- Principles of Operation ●
- Indications for Use
- Materials ●
- Sterility ●
- Dimensional Features ●

# CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the VertebraLINK Fusion Platform is substantially equivalent to the predicate device.