The Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters are intended to be used for the reduction and fixation of fractures and/or creation of a void in cancellous bone in the spine. This includes use during percutaneous vertebral augmentation. This system is to be used with cleared spinal polymethylmethacrylate (PMMA) bone cements for use during percutaneous vertebral augmentation, such as kyphoplasty.
Device Story
Balloon catheter system for percutaneous vertebral augmentation; used to treat spinal fractures. Device consists of 11-gauge catheter with low-pressure elastomeric balloon at distal end. Inserted via 10-gauge cannula into vertebral body. Balloon inflation compresses cancellous bone to create cavity; reduces fracture; facilitates controlled delivery of cleared PMMA bone cement. Physician-operated in clinical setting. Inflation by volume creates cavity; balloon recovers near-original profile upon deflation for removal. Benefits include fracture reduction, prevention of cement leakage, and support for cement interdigitation.
Clinical Evidence
Bench testing only. Design FMECA used to identify verification and validation testing requirements. Testing demonstrated that the modified catheters meet all original performance specifications.
Technological Characteristics
Catheter composed of polyurethane, polycarbonate, and polyether/polyamide. Features low-pressure elastomeric tubular balloon laser-bonded to shaft. 11-gauge size fits through 10-gauge cannula. Silicone lubricant used for insertion. Inflation is volume-based. Sterilization method not specified.
Indications for Use
Indicated for patients requiring reduction and fixation of spinal fractures or creation of a void in cancellous bone during percutaneous vertebral augmentation (kyphoplasty).
Regulatory Classification
Identification
Polymethylmethacrylate (PMMA) bone cement is a device intended to be implanted that is made from methylmethacrylate, polymethylmethacrylate, esters of methacrylic acid, or copolymers containing polymethylmethacrylate and polystyrene. The device is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement.”
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
G-21 S.R.L. % Mr. Paul Speidel Senior Regulatory/Quality Consultant ROMIS. Inc. 110 Haverhill Road Suite 526 Amesbury, Massachusetts 01913
August 23, 2017
Re: K172214
Trade/Device Name: Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters Regulation Number: 21 CFR 888.3027 Regulation Name: Polymethylmethacrylate (PMMA) bone cement Regulatory Class: Class II Product Code: NDN, HRX Dated: July 21, 2017 Received: July 24, 2017
Dear Mr. Speidel:
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
Image /page/0/Picture/11 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.
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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 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.
# 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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#### INDICATIONS FOR USE
510(k) Number (if known): K172214
#### Device Name: Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters
Indications for Use:
The Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters are intended to be used for the reduction and fixation of fractures and/or creation of a void in cancellous bone in the spine. This includes use during percutaneous vertebral augmentation. This system is to be used with cleared spinal polymethylmethacrylate (PMMA) bone cements for use during percutaneous vertebral augmentation, such as kyphoplasty.
Prescription Use ____X________________________________________________________________________________________________________________________________________________________ AND/OR Over-The-Counter Use ________ (Part 21 CFR 801 Subpart D) (21 CFR 807 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
# G-21 S.R.L.'s Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters
| Submitter | G-21 S.R.L.<br>Maurizio Foroni<br>Via S. Pertini, 8<br>San Possidonio, Italy 41039<br>Phone: +39 0535 30312 |
|--------------------------|-------------------------------------------------------------------------------------------------------------|
| Contact Person: | Barry Sands<br>RQMIS, Inc.<br>110 Haverhill Road, Suite 526<br>Amesbury, MA 01913<br>Phone: 978-358-7307 |
| Date Prepared: | July 21, 2017 |
| Name of Device | Modified Winch Kyphoplasty<br>(15 and 20 mm) 11 Gauge<br>Balloon Catheters |
| Name/Address of Sponsor: | G-21<br>Maurizio Foroni<br>Via S. Pertini, 8<br>San Possidonio, Italy 41039 |
#### Common or Usual Name
Kyphoplasty Balloon Catheter
# Classification Name
Cement, Bone, Vertebroplasty, Class II (21 CFR 888.3027) Arthroscope, Class II (21 CFR, Sec. 888.1100)
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# Product Codes
HRX and NDN
# Predicate Device
K152557, Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters
# Intended Use / Indications for Use
# Indications for Use:
The Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters are intended to be used for the reduction and fixation of fractures and/or creation of a void in cancellous bone in the spine. This includes use during percutaneous vertebral augmentation. This system is to be used with cleared spinal polymethylmethacrylate (PMMA) bone cements for use during percutaneous vertebral augmentation, such as kyphoplasty.
# Technological Characteristics
The Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters are primarily composed of polyurethane, polycarbonate, and polyether/polyamide materials. A Silicone lubricant is provided to facilitate insertion of the catheters. This premarket submission represents a change to the balloon material to a different type of polyurethane.
# Device Description
The inflation of the balloon serves to create a cavity in the vertebral body, compressing the cancellous bone and/or move cortical bone, thereby reducing the fracture and preventing cement leakage, while still allowing for cement interdigitation.
Modified Winch Kypholplasy (15 and 20 mm) 11 Gauge balloon catheters fit through a 10 Gauge cannula allowing a minimally invasive kyhoplasty procedure. The low pre-inflation profile (low wrapping profile of folded balloon) enables their insertion into these small working cannulas.
Image /page/4/Picture/12 description: The image shows a medical device, possibly a catheter or similar instrument, laid out horizontally. It features a connector at one end, a long, slender tube, and a tip at the opposite end, which is encircled and labeled 'A'. The device appears to be designed for insertion into the body, with the connector facilitating attachment to other medical equipment.
Figure 1: Modified Winch Kyphoplasty 11 Gauge Balloon Catheter
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Image /page/5/Picture/0 description: This image is a figure that shows an isometric view of the modified winch kyphoplasty 11 gauge balloon catheter. The catheter is long and thin, with a balloon at the end. The catheter is used to treat vertebral compression fractures. The figure is labeled as Figure 2.
The stiff distal end of the balloon catheter provides rigidity for smooth insertion while the flexible proximal catheter allows for easy maneuverability. The inflating component, laserbonded to the shaft, is a low-pressure elastomeric balloon of tubular shape (which is inflated by volume, not pressure). The inflation can expand the balloon several times its original size, it can be inflated to precise dimensions and retain well defined shapes and high pressures and when the pressure is released, it recovers close to its original size and shape, re-folding back to similar original profiles.
# Performance Data
Using design FMECA, G21 identified the necessary verification and validation testing to assure the new balloon met the catheters original performance specifications. All testing demonstrated that the modified catheters continues to meet all performance specifications.
#### Substantial Equivalence
G-21 used dFMECA to determine substantial equivalence. The Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters and the K152557 predicate device have the same intended use/indications for use, equivalent technical characteristics, and identical principles of operation.
G-21 submits the information in this Premarket Notification to demonstrate that, for the purposes of FDA's regulation of medical devices, the Modified Winch Kyphoplasty (15 and 20 mm) 11 Gauge Balloon Catheters is substantially equivalent in indications, design principles, and performance standards 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.