Who is the manufacturer of TMINI Miniature Robotic System?

THINK Surgical, Inc. filed the 510(k) submission for TMINI Miniature Robotic System (K232802).

What is the FDA product code for TMINI Miniature Robotic System?

OLO. It is classified under 21 CFR 882.4560 as a Class 2 device in the Neurology panel.

What is the regulatory pathway for TMINI Miniature Robotic System?

510(k) clearance (submission type: Special).

Who can help prepare an FDA 510(k) submission like TMINI Miniature Robotic System?

Innolitics — a medical-device software consultancy — provides regulatory and engineering support for FDA 510(k) submissions. See https://innolitics.com/services/510ks/ or contact https://innolitics.com/contact.

TMINI Miniature Robotic System

Q: What are the predicate devices for TMINI Miniature Robotic System?

TMINI™ Miniature Robotic System (K230202).

K232802 · THINK Surgical, Inc. · OLO · Oct 12, 2023 · Neurology

Device Facts

Record ID	K232802
Device Name	TMINI Miniature Robotic System
Applicant	THINK Surgical, Inc.
Product Code	OLO · Neurology
Decision Date	Oct 12, 2023
Decision	SESE
Submission Type	Special
Regulation	21 CFR 882.4560
Device Class	Class 2

Intended Use

TMINI™ Miniature Robotic System is indicated as a stereotaxic instrumentation system for total knee replacement (TKA) surgery. It is to assist the surgeon by providing software-defined spatial boundaries for orientation and reference information to identifiable anatomical structures for the accurate placement of knee implant components. The robotic device placement is performed relative to anatomical landmarks as recorded using the system intraoperatively and based on a surgical plan determined preoperatively using CT based surgical planning tools. It includes a handheld robotic device, an optical sensor navigation system and accessories, software system, surgical instruments and accessories. The targeted population has the same characteristics as the population that is suitable for the implant(s) compatible with the TMINI™ Miniature Robotic System. The TMINI™ Miniature Robotic System is to be used with the following knee replacement systems in accordance with the indications and contraindications: - Enovis™ EMPOWR Knee System® - Ortho Development® BKS® and BKS TriMax® Knee System - Total Joint Orthopedics Klassic® Knee System - United® U2™ Knee Total Knee System

Device Story

TMINI™ Miniature Robotic System assists surgeons in TKA procedures by providing software-defined spatial boundaries for bone preparation. Input: preoperative CT scans used for 3D surface modeling and case templating. Operation: surgeon selects/manipulates implant models on TPLAN workstation; data guides handheld robotic tool. Tool is optically tracked relative to femur/tibia markers; articulates in two degrees-of-freedom to place bone pins. Mechanical guides attach to pins for precise cutting/drilling. Output: spatial guidance for implant component placement. Used in OR by surgeons. Benefits: accurate placement of knee implants relative to anatomical landmarks.

Clinical Evidence

No clinical trials performed. Evidence consists of bench testing for cutting accuracy and cadaver model validation testing. Biocompatibility testing (cytotoxicity, sensitization, intracutaneous reactivity, acute systemic toxicity, pyrogenicity) performed on guide blocks. All tests met acceptance criteria.

Technological Characteristics

System includes TPLAN planning workstation, TNav optical tracking console, and handheld robotic tool. Materials have history of orthopedic use or ISO 10993 compliance. Connectivity: optical sensor navigation. Software: preoperative planning and robot control. Sterilization: reusable and disposable instrumentation.

Indications for Use

Indicated for patients undergoing total knee replacement (TKA) surgery who are candidates for compatible knee implant systems (Enovis EMPOWR, Ortho Development BKS/BKS TriMax, Total Joint Orthopedics Klassic, or United U2).

Regulatory Classification

Identification

A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.

Predicate Devices

TMINI™ Miniature Robotic System (K230202)

Related Devices

K230202 — TMINI Miniature Robotic System · THINK Surgical, Inc. · Apr 25, 2023
K242264 — TMINI Miniature Robotic System · THINK Surgical, Inc. · Aug 23, 2024
K243285 — TMINI Miniature Robotic System · THINK Surgical, Inc. · Nov 15, 2024
K253661 — TMINI Miniature Robotic System · THINK Surgical, Inc. · Dec 22, 2025
K241031 — TMINI Miniature Robotic System (TMINI 1.1) · THINK Surgical, Inc. · Jul 12, 2024

Submission Summary (Full Text)

{0}------------------------------------------------ October 12, 2023 Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left side of the logo is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue. Think Surgical, Inc. Anand Patel Manager, Regulatory Affairs 47201 Lakeview Blvd. Fremont, California 94538 Re: K232802 Trade/Device Name: TMINI™ Miniature Robotic System Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: September 8, 2023 Received: September 12, 2023 Dear Anand Patel: 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 (the 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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database available at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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. Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download). {1}------------------------------------------------ Your device is also subject to, among other requirements, the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181). Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems. For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100). Sincerely, Shumaya Ali-S Shumaya Ali, M.P.H. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health {2}------------------------------------------------ # Indications for Use 510(k) Number (if known) K232802 Device Name TMINI™ Miniature Robotic System #### Indications for Use (Describe) TMINI™ Miniature Robotic System is indicated as a stereotaxic instrumentation system for total knee replacement (TKA) surgery. It is to assist the surgeon by providing software-defined spatial boundaries for orientation and reference information to identifiable anatomical structures for the accurate placement of knee implant components. The robotic device placement is performed relative to anatomical landmarks as recorded using the system intraoperatively and based on a surgical plan determined preoperatively using CT based surgical planning tools. It includes a handheld robotic device, an optical sensor navigation system and accessories, software system, surgical instruments and accessories. The targeted population has the same characteristics as the population that is suitable for the implant(s) compatible with the TMINI™ Miniature Robotic System. The TMINIM Miniature Robotic System is to be used with the following knee replacement systems in accordance with the indications and contraindications: - · Enovis™ EMPOWR Knee System® - · Ortho Development® BKS® and BKS TriMax® Knee System - · Total Joint Orthopedics Klassic® Knee System - · United® U2™ Knee Total Knee System | Type of Use (Select one or both, as applicable) | | |---------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------| | <div> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div> Over-The-Counter Use (21 CFR 801 Subpart C) </div> | #### CONTINUE ON A SEPARATE PAGE IF NEEDED. 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, 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 PRAStaff(@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ Image /page/3/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in a bold, sans-serif font, with a blue triangle replacing the "I". Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. The logo is simple and modern, and the blue triangle adds a touch of color and visual interest. # 510(k) SUMMARY K232802 ## Applicant Information: | Owner Name: | THINK Surgical, Inc. | |------------------------------------|-----------------------------------------| | Address: | 47201 Lakeview Blvd., Fremont, CA 94538 | | Phone number: | 443-756-9392 | | Fax number: | 510-249-2396 | | Establishment Registration Number: | 3000719653 | | Contact Person: | Anand Patel | | Date Prepared: | 08 September 2023 | ## Device Information: | Device Classification: | Class II | |------------------------|-----------------------------------| | Trade Name: | TMINITM Miniature Robotic System | | Common name: | Orthopedic Stereotaxic Instrument | | Classification name: | Stereotaxic Instrument | | Regulation number: | 882.4560 | | Product Code: | OLO | ## Predicate Device: The TMINI™ Miniature Robotic System (Additional Knee Systems) is substantially equivalent in intended use, Indications for Use, design, materials, technology, operational principles and performance to the predicate, TMINI™ Miniature Robotic System, cleared via K230202. #### Device Modification: The purpose of this submission is to add three additional FDA cleared knee implant systems that are compatible with the TMINI™ Miniature Robotic System to the Enovis™ EMPOWR Knee System® that is already cleared for use with the device. The three new implant systems are: the Ortho Development® BKS® and BKS TriMax® Knee System, the Total Joint Orthopedics Klassic® Knee System, and the United® U2™ Knee System. As part of this change the labeling has been modified to show that the Indications for Use of the device has been updated to include compatibility with these three additional knee implant systems. #### Device Description: Like its predicate, the TMINI™ Miniature Robotic System consists of three primary components: a three-dimensional, graphical, Preoperative Planning Workstation (TPLAN Planning Station), an Optical Tracking Navigation Console (TNav) and a Robotically {4}------------------------------------------------ Image /page/4/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in a bold, sans-serif font, with the "I" represented by a blue, elongated triangle pointing downwards. Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. A registered trademark symbol is located to the right of the letter K. Controlled Hand-held Tool (TMINI Robot) that assists the surgeon in preparing the bone for implantation of TKA components. The TPLAN Planning Station uses preoperative CT scans of the operative leg to create 3D surface models for case templating and intraoperative registration purposes. The Planning Workstation contains a library of 510(k) cleared knee replacement implant(s). The surgeon can select an implant model from this library and manipulate the 3D representation of the implant in relation to the bone model to place the implant. Once the surgeon is satisfied with the implant location and orientation, the data is written to a file that is used to guide the robotically controlled hand-held tool. The handheld robotic tool is optically tracked relative to optical markers placed in both the femur and tibia and articulates in two degrees-of-freedom, allowing the user to place bone pins in a planar manner in both bones. Mechanical guides are clamped to the bone pins, resulting in subsequent placement of cut slots and drill quide holes such that the distal femoral and proximal tibial cuts can be made in the pre-planned positions and orientations, and such that the implant manufacturer's multi-planer cutting block can be placed relative to drilled distal femoral pilot holes. #### Intended Use: Like the predicate, the TMINI™ Miniature Robotic System is intended to assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures. #### Indications for Use: The only difference between the indications for use of the current device and the predicate is the addition of the three additional knee systems. See Table-1 below. | Product | TMINI™ Miniature Robotic System (Additional Knee Systems) | TMINI™ Miniature Robotic System | Conclusion | |---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------| | 510(k) number | Subject Device | K230202 | | | Manufacturer | THINK Surgical, Inc | THINK Surgical, Inc | | | Product Code | OLO | OLO | SAME | | Regulation | 21 CFR 882.4560 | 21 CFR 882.4560 | SAME | | Intended Use | Intended to assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures. | Intended to assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures. | SAME | | Indications for Use | The TMINI™ Miniature Robotic System is indicated as a stereotaxic instrumentation system for total knee replacement (TKA) surgery. It is to assist the surgeon by providing | The TMINI™ Miniature Robotic System is indicated as a stereotaxic instrumentation system for total knee replacement (TKA) surgery. It is to assist the surgeon by providing | Substantially Equivalent (Adds Compatibility with three additional total knee implant systems) | | Product | TMINI™ Miniature Robotic System (Additional Knee Systems) | TMINI™ Miniature Robotic System | Conclusion | | | software-defined spatial boundaries for orientation and reference information to identifiable anatomical structures for the accurate placement of knee implant components. | software-defined spatial boundaries for orientation and reference information to identifiable anatomical structures for the accurate placement of knee implant components. | | | | The robotic device placement is performed relative to anatomical landmarks as recorded using the system intraoperatively and based on a surgical plan-determined preoperatively using CT based surgical planning tools. | The robotic device placement is performed relative to anatomical landmarks as recorded using the system intraoperatively and based on a surgical plan-determined preoperatively using CT based surgical planning tools. | | | | It includes a handheld robotic device, an optical sensor navigation system and accessories, software system, surgical instruments and accessories. | It includes a handheld robotic device, an optical sensor navigation system and accessories, software system, surgical instruments and accessories. | | | | The targeted population has the same characteristics as the population that is suitable for the implant(s) compatible with the TMINI™ Miniature Robotic System. | The targeted population has the same characteristics as the population that is suitable for the implant(s) compatible with the TMINI™ Miniature Robotic System. | | | | The TMINI™ Miniature Robotic System is to be used with the following knee replacement system(s) in accordance with the indications and contraindications: - Enovis™ EMPOWR Knee System® -Ortho Development BKS® and BKS TriMax® Knee System -Total Joint Orthopedics Klassic® Knee System -United U2™ Knee Total Knee System | The TMINI™ Miniature Robotic System is to be used with the following knee replacement system(s) in accordance with the indications and contraindications: - Enovis™ EMPOWR Knee System® | | Table 1: Comparison of Intended Use and Indications for Use {5}------------------------------------------------ Image /page/5/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in large, bold, dark gray letters, with a blue triangle in place of the "I". Below the word "THINK" is the word "SURGICAL" in smaller, lighter gray letters. ## TMINI™ Miniature Robotic System Special 510(k) Submission ## Substantial Equivalence: Both the TMINI™ Miniature Robotic System (Additional Knee Systems), the subject of this submission, and the predicate device have the same intended use. Both are indicated as a stereotaxic instrumentation system for total knee replacement (TKA) surgery. It is to assist the surgeon by providing software-defined spatial boundaries for orientation and reference {6}------------------------------------------------ Image /page/6/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in a bold, sans-serif font, with the "I" replaced by a blue, downward-pointing triangle. Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. information to identifiable anatomical structures for the accurate placement of knee implant components during orthopedic procedures. The robotic device placement is performed relative to anatomical landmarks as recorded using the system intraoperatively and based on a surgical plan determined preoperatively using CT based surgical planning tools. The difference between the new device and the predicate is that the new device includes compatibility with three additional knee implant systems. None of these changes either individually or in the aggregate alter the intended use, indications for use (other than the addition of the three new implant systems), design, materials, technology, or operational principles of the TMINI™ Miniature Robotic System. The Indications for Use of the new device and its predicate are identical except for the addition of the three new implant systems to the list of compatible implant systems. Performance testing to verify the cutting accuracy of the subject device was conducted following similar test methods and acceptance criteria to those used for the predicate device. This testing demonstrated that the TMINI™ Miniature Robotic System met all test criteria and specifications. Validation testing, with methods and acceptance criteria similar to that used for the predicate device, was conducted using simulated surgical testing in a cadaver model and all test criteria were met. Biocompatibility information for patient contacting materials and testing for the TMINI™ Miniature Robotic System were presented in predicate device submission K230202. There are no material changes to any of the direct patient contact components of the TMINI Miniature Robotic System. All four of the Guide Blocks for the TMINI™ Miniature Robotic System (Additional Knee Systems) have text printed on the Indirect Patient Contact Surface of the blocks using Pad printing ink. Biocompatibility testing was provided to assess these materials and included: Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity and Pyrogenicity. All 5 tests passed the acceptance criteria of the test protocol. Substantial equivalence in technological characteristic and performance of the TMINI™ Miniature Robotic System to the predicate device is outlined in Table-2 below: {7}------------------------------------------------ Image /page/7/Picture/0 description: The image shows the logo for Think Surgical. The logo is composed of the word "THINK" in a bold, sans-serif font, with the "I" replaced by a blue, elongated triangle pointing downwards. Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. | Product | TMINI™ Miniature Robotic System (Additional Knee Systems) | TMINI™ Miniature Robotic System | Substantial Equivalence Conclusion | |--------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------| | 510(k) number | Subject Device | K230202 | | | Manufacturer | THINK Surgical Inc. | THINK Surgical Inc. | | | Materials | | | | | -Materials Used | Uses materials with a long history of use in orthopedic procedures or provided biocompatibility data consistent with ISO 10993 requirements. | Uses materials with a long history of use in orthopedic procedures or provided biocompatibility data consistent with ISO 10993 requirements. | SAME | | Technological Characteristics | | | | | -Major System Components | Planning and robot control software, robotic positioning device, navigation system, reusable and disposable instrumentation | Planning and robot control software, robotic positioning device, navigation system, reusable and disposable instrumentation | SAME | | -Patient Imaging | CT images used to create a 3D model of the bone for surgical planning | CT images used to create a 3D model of the bone for surgical planning | SAME | | -Preoperative planning workstation | TPLAN three-dimensional preoperative planning workstation | TPLAN three-dimensional preoperative planning workstation | SAME | | -Surgical planning system | Technician guided surgical planning with surgeon review and approval on a desktop planning station | Technician guided surgical planning with surgeon review and approval on a desktop planning station | SAME | | -Bone Marker Arrays for bone registration and tracking | Active markers on femur and tibia mounted onto the bones via an attachment assembly. | Active markers on femur and tibia mounted onto the bones via an attachment assembly. | SAME | | -Surgical Exposure | Similar to traditional surgical exposure | Similar to traditional surgical exposure | SAME | | -Patient/Robot Registration | Preoperatively determined landmarks are compared to intraoperatively identified landmarks to complete patient bone registration. | Preoperatively determined landmarks are compared to intraoperatively identified landmarks to complete patient bone registration. | SAME | | -Camera Tracking Technology | Six camera overhead tracking with a wide-angle field of view | Six camera overhead tracking with a wide-angle field of view | SAME | | -Cut guide positioning | Robotic device places bone pins in the correct plane, then cutguide or drill block is attached to the pins and bone. | Robotic device places bone pins in the correct plane, then cutguide or drill block is attached to the pins and bone. | SAME | | -Intraoperative planning changes | Implant position can be adjusted along bone axis only, preserving the intended implant positioning philosophy. | Implant position can be adjusted along bone axis only, preserving the intended implant positioning philosophy. | SAME | | -Bone Preparation Technique | A surgical saw is used to cut the bone through a cut guide. | A surgical saw is used to cut the bone through a cut guide. | SAME | | -Intraoperative Anatomic Measurements | The tracked bone arrays and bone registration data are used to determine the knee flexion angle and varus/valgus laxity. | The tracked bone arrays and bone registration data are used to determine the knee flexion angle and varus/valgus laxity. | SAME | | Product | TMINI™ Miniature Robotic System (Additional Knee Systems) | TMINI™ Miniature Robotic System | Substantial Equivalence Conclusion | | 510(k) number | Subject Device | K230202 | | | Manufacturer | THINK Surgical Inc. | THINK Surgical Inc. | | | -TKA Component Implantation Technique | Implants are secured to the bone, either with or without cement using standard surgical technique provided by the implant manufacturer. | Implants are secured to the bone, either with or without cement using standard surgical technique provided by the implant manufacturer. | SAME | | -Compatible Knee Implant Systems | - Enovis ™ EMPOWR Knee System® -Ortho Development® BKS® and BKS TriMax® Knee System -Total Joint Orthopedics Klassic® Knee System -United® U2™ Knee System | - Enovis ™ EMPOWR Knee System® | Substantially Equivalent (addition of three new implant systems) | | Performance Testing -Cutting Accuracy Verification | Passed | Passed | SAME | | -Cadaver Lab Validation Testing | Passed | Passed | SAME | | Biocompatibility Testing -Cytotoxicity | Passed | Passed | SAME | | -Sensitization | Passed | Passed | SAME | | -Intracutaneous Reactivity | Passed | Passed | SAME | | -Acute Systemic Toxicity | Passed | Passed | SAME | | -Pyrogenicity | Passed | Passed | SAME | ## Table-2: Substantial Equivalence {8}------------------------------------------------ Image /page/8/Picture/0 description: The image shows the logo for Think Surgical. The logo is composed of the word "THINK" in a bold, sans-serif font, with a blue triangle replacing the "I". Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. Risk assessment was performed on the device in accordance with ISO 14971:2019 and THINK Surgical Risk Management procedures. The risk assessment was comprised of analysis and mitigation of the risks associated with the addition of three compatible knee implant systems. The risk assessment resulted in the identification of no new clinical hazards. Each of the clinical hazards identified through this risk assessment is a previously documented hazard associated with the use of the TMINI™ Miniature Robotic System. The addition of three new implant systems does not increase the likelihood or severity of these hazards; therefore, the risks associated with the use of the device remain unchanged as compared to the predicate. #### Conclusion The TMINI™ Miniature Robotic System (Additional Knee Systems) is substantially equivalent to the predicate, TMINI™ Miniature Robotic System (K230202), in the following ways: it has the same intended use, the same technological characteristics and operating principles, and incorporates the same design and materials. Performance testing and risk analysis has demonstrated that the performance and risk profile of the TMINI™ Miniature Robotic System (Additional Knee Systems) is equivalent to that of the predicate device. The {9}------------------------------------------------ Image /page/9/Picture/0 description: The image shows the logo for Think Surgical. The logo consists of the word "THINK" in a bold, sans-serif font, with the "I" replaced by a blue, elongated triangle pointing downwards. Below the word "THINK" is the word "SURGICAL" in a smaller, sans-serif font. TMINI™ Miniature Robotic System (Additional Knee Systems) is as safe and effective as the predicate device and does not raise any new questions of safety and effectiveness; therefore, a determination of Substantial Equivalence is supported.