The Scorpio® TS Total Knee System components are intended for single-use, and are labeled for cemented use only in the United States. The components feature a posterior cruciate ligament (PCL) substituting design. This system is intended for use when the cruciate ligaments are absent, inadequate, or cannot be preserved during the operative procedure, especially when anterior-posterior stability is impaired due to the absence of the posterior cruciate ligament and/or patella. The collateral ligaments may or may not be intact. The system is also designed to allow compensation for bone loss through the use of blocks and/or wedges.
Device Story
Scorpio® TS Total Knee System is a cemented, PCL-substituting artificial knee replacement. Components include femoral parts, tibial trays (ported/non-ported), tibial inserts, and bone augmentation (blocks/wedges). Designed for surgical implantation by orthopedic surgeons in hospital settings to address severe knee instability, ligamentous deficiency, or revision cases. Femoral components feature a closed cam box for increased constraint and attachment mechanisms for stem extensions/augments. Tibial trays offer optional screw fixation or cement pressurization via a ported keel. Tibial inserts provide A/P and varus/valgus constraint via a raised eminence. System restores joint stability and compensates for bone loss, improving patient mobility and reducing pain associated with degenerative or post-traumatic joint disease.
Clinical Evidence
Bench testing only. Fatigue testing performed on ported-style tibial trays to ensure strength parity with commercially available trays. Mechanical testing performed on the attachment mechanism for augmentation components to ensure strength parity with predicate systems.
Indicated for patients with painful, disabling joint disease (degenerative, rheumatoid, or post-traumatic arthritis), post-traumatic loss of knee function, moderate varus/valgus/flexion deformity, or revision of previous knee replacement. Specifically for patients with absent/non-functioning PCL, severe anteroposterior instability, or severe instability secondary to compromised collateral ligament integrity. Bone augmentation indicated for patients with bone loss requiring salvage of previous unsuccessful procedures.
Regulatory Classification
Identification
A knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a knee 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 femoral component made of alloys, such as cobalt-chromium-molybdenum, and a tibial component or components and a retropatellar resurfacing component made of ultra-high molecular weight polyethylene. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).
Predicate Devices
Scorpio® Posteriorly Stabilized (PS) Total Knee System (K962152)
Scorpio® Cruciate Retaining (CR) Total Knee System (K974566)
Scorpio® Total Knee Universal Dome and Recessed Patellar Components (K972967)
7000 Series Total Knee Modular Tibial Component (K915192)
7000 Series Total Knee Modular Femoral Component (K925372)
Osteonics Series 7000 Total Knee Tibial and Femoral Augmentation Blocks and Wedges (K920524)
Howmedica Duracon® Total Stabilizer (TS) Extension Stems and Offset Adaptors
Submission Summary (Full Text)
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MAR - 6 2000
K994128
Scorpio® Total Stabilizer (TS) Total Knee System
# 510(k) Summary Scorpio® Total Stabilizer (TS) Total Knee System
#### Submission Information
| Name and Address of the Sponsor: | Howmedica Osteonics Corp.<br>59 Route 17<br>Allendale, NJ 07401-1677 |
|----------------------------------|----------------------------------------------------------------------|
| Contact Person: | Terry Sheridan Powell |
| Date of Summary Preparation: | December 3, 1999 |
**Device Identification**
| Proprietary Name: | Scorpio® Total Stabilizer (TS) Total Knee<br>System |
|------------------------------------|-----------------------------------------------------|
| Common Name: | Artificial Total Knee Replacement System |
| Classification Name and Reference: | CFR §888.3353 |
#### Predicate Device Identification
The subject devices are substantially equivalent to the following competitive and/or Osteonics devices, which have previously been determined substantially equivalent by FDA:
- K962152: Scorpio® Posteriorly Stabilized (PS) Total Knee System Femoral, Tibial . Insert, and Patellar Components (sponsor: Osteonics)
- . K974566: Scorpio® Cruciate Retaining (CR) Total Knee System Femoral and Tibial Insert components (sponsor: Osteonics)
- K972967: Scorpio® Total Knee Universal Dome and Recessed Patellar Components . (sponsor: Osteonics)
- . K915192: 7000 Series Total Knee Modular Tibial Component (sponsor: Osteonics)
- K925372: 7000 Series Total Knee Modular Femoral Component (sponsor: Osteonics) .
- K920524: Osteonics Series 7000 Total Knee Tibial and Femoral Augmentation Blocks . and Wedges (sponsor: Osteonics)
- K960279: Legacy Constrained Condylar Knee (CCK) (sponsor: Zimmer) .
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## Device Description
The Scorpio® TS Total Knee System consists of new femoral components, tibial trays, tibial inserts, and femoral and tibial augmentation. The system will be used in conjunction with existing, predicate patellar components, tibial tray screws, femoral and tibial stem extensions, and femoral and tibial stem extension offset adaptors.
## Femoral Components:
The Scorpio® TS Total Knee System Femoral Components share many of the design features originally featured in the predicate Scorpio® Posteriorly Stabilized Total Knee System Femoral Components. The subject components, however, have been modified to address the revision and femoral TS situations discussed in the Indications section of this submission. Briefly, the modifications involve closing the cam box (to facilitate use with more constraining tibial insert configurations), providing an attachment mechanism for femoral stem extension and offset adaptor attachments, and providing attachment mechanisms/surfaces for new bone augmentation components.
## Tibial Trays:
There are two tibial tray styles for the Scorpio® TS Total Knee System: non-ported and ported. Each is available with one of three surfaces on the underside of the tray designed to improve the cement-component interface: the basic, grit-blasted surface roughening, the cast-in waffle pattern, or the MicroStructured® porous coating. The tibial trays features screw holes for optional use with bone screws for supplemental fixation, or for optional use with bone augment components (attached to the tray with screws). If supplemental tibial bone screws are used, then tibial bone augments cannot be used (because both require the same screw holes), and vice versa. The trays are compatible with subject Scorpio® TS Inserts, or with predicate Scorpio® PS or CR Inserts.
## Non-ported Style
The non-ported style tibial tray is nearly identical to the predicate Osteonics® Series 7000 Total Knee Tibial Trays, differing only slightly in the configuration of the central post. The central post on the predicate trays extends beyond the swept-back fins of the delta-fit keel. The central post of the new, subject trays is slightly shortened so that it is nearly flush with the bottom of the keel. The threads at the distal end of the post have also been modified to accept the predicate Howmedica Duracon® Total Stabilizer (TS) Extension Stems and Offset Adaptors.
#### Ported Style
The ported-style trays are identical in design to the non-ported style trays, except with a hole in the A/P direction through the central post of the keel. This hole allows a two-step cement procedure to fill and pressurize the metaphyseal region around the keel. The technique consists of:
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1) cementing on the tibial tray with cement only on the periphery of the tray, and allowing the cement to harden (cure).
2) injecting cement through the port hole in the central post until the metaphyseal region is pressurized (felt as resistance against cement gun).
Pressurization of the metaphyseal region may benefit the cement/bone interface.
## Tibial Inserts:
The Scorpio® TS Total Knee System Tibial Inserts feature a raised tibial eminence with an interior reinforcing pin that is slip-fit into the tibial tray. This insert provides anterior/posterior constraint as well as varus/valgus constraint. It is similar in constraint level to the predicate Zimmer Legacy Constrained Condylar Knee (LCCK).
In keeping with the design theory behind the predicate Osteonics tibial inserts, the bearing surface of the subject inserts employs a single medial lateral (M/L) radius. The bearing surface also incorporates a posteriorly sloping, raised tibial eminence. The inserts come in a range of thicknesses. They feature the same locking mechanism as the predicate Scorpio® Inserts, and the same articulating geometry as the predicate Scorpio® CR Inserts.
# Femoral Augmentation:
Distal femoral augmentation is available in 5mm, 10mm, and 15mm thicknesses. Posterior femoral augmentation is available in 5mm, 10mm, and 15mm thicknesses. These augment pieces are attached with a hex-head screw to the subject Scorpio® TS Femoral Components. They are compatible with the predicate PS or CR Scorpio® Femoral Components, but must be affixed via bone cement (not through screw fixation) to those predicate devices.
# Tibial Augmentation:
Tibial augmentation is available in the following configurations:
- . Half blocks for medial or lateral coverage in 5mm or 10mm thicknesses.
- . Full coverage blocks 10mm thick.
- . Full coverage 5° wedges, which can be flipped to accommodate a medial or lateral deficiency.
The wedges are attached to the trays with bone cement. The blocks are attached to the trays by placing one or more screws (depending on the type of augment) through the tray and threading them into the augments. The augments feature a cement recess pocket.
# Intended Use:
The Scorpio® TS Total Knee System components are intended for single-use, and are labeled for cemented use only in the United States. The components feature a posterior cruciate ligament (PCL) substituting design. This system is intended for use when the cruciate ligaments are absent, inadequate, or cannot be preserved during the operative procedure, especially when anterior-posterior stability is impaired due to the absence of the posterior cruciate ligament and/or patella. The collateral ligaments may or may not be intact. The system is also designed to
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allow compensation for bone loss through the use of blocks and/or wedges.
#### General TKR Indications
- Painful, disabling joint disease of the knee resulting from: degenerative arthritis, . rheumatoid arthritis or post-traumatic arthritis.
- t Post-traumatic loss of knee joint configuration and function.
- Moderate varus, valgus, or flexion deformity in which the ligamentous structures can be . returned to adequate function and stability.
- . Revision of previous unsuccessful knee replacement or other procedure.
Additional Indications for Posterior Stabilized (PS) or Total Stabilized (TS) Components:
- Ligamentous instability requiring implant bearing surface geometries with increased . constraint.
- . Absent or non-functioning posterior cruciate ligament.
- . Severe anteroposterior instability of the knee joint.
- . For Total Stabilizer (TS) Components Only: Severe instability of the knee secondary to compromised collateral ligament integrity or function.
Indications for Bone Augmentation Wedges:
- Painful, disabling joint disease of the knee secondary to: degenerative arthritis, . rheumatoid arthritis, or post-traumatic arthritis, complicated by the presence of bone loss.
- . Salvage of previous unsuccessful total knee replacement or other surgical procedure, accompanied by bone loss.
#### Statement of Technological Comparison:
The substantial equivalence of the subject device is supported by a comparison of the subject device to the above-cited predicate devices. A comparison of the subject and predicate devices in terms of intended use, materials, and design follows.
#### Intended Use
The Scorpio® TS Total Knee System components share intended uses as the predicate Osteonics Series 7000 Modular Tibial and Femoral Knee System Components.
#### Materials
The Scorpio® TS Total Knee System components are manufactured from UHMWPE and CoCr alloys. These materials have been commonly used in the manufacture of total knee systems for decades, and are the same materials used in the manufacture of the predicate knee systems.
#### Design
The subject femoral components are basically a blend between the predicate Scorpio® PS Femoral components and the predicate Series 7000 Modular Femoral component. The subject femoral components incorporate the epicondylar-based center of rotation featured on the predicate Scorpio® PS Femoral components, and the box-style housing (to allow attachment of
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stem extensions and additional constraint) featured on the predicate Series 7000 Modular Femoral components.
The subject tibial trays, which come in non-ported and ported styles, are a modification to the predicate 7000 Series Total Knee Modular Tibial Components. The main difference is the central post. The subject travs feature a central post which has been slightly shortened so that it is nearly flush with the bottom of the swept-back keel. In addition, the ported-style tray differs in that it features a cement port, to allow pressurization of the cement in the metaphyseal region.
The tibial inserts feature a reinforcing pin that is slip-fit into the tibial tray (same reinforcing pin determined substantially equivalent via K915192). They are similar in constraint level to the predicate Zimmer Legacy Constrained Condylar Knee (LCCK).
The subject augment components do not differ significantly in configuration (distal and posterior femoral augments, half and full tibial block augments, and tibial wedges) or in thickness or angle from existing predicate augment systems.
#### Summary
The subject Scorpio® TS Total Knee System does not feature any new materials or intended uses. The subject system does feature some new design variations; however, these are modest design differences which do not raise new issues of safety or effectiveness when compared to the predicate devices, and whose substantial equivalence is further supported by the performance testing provided within the document.
#### Performance Data:
This submission includes testing of the new mechanism for attachment of the augmentation components. This testing showed that the mechanism featured on the new subject augment components is at least as strong as the mechanism featured on predicate augment systems. This submission also includes fatigue testing of the ported-style tibial travs, which demonstrates that these trays are at least as strong as other, commercially-available tibial trays.
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Image /page/5/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized symbol resembling three abstract human profiles facing right, with flowing lines above them. The symbol is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAR - 6 2000
Ms. Terry Sheridan Powell Regulatory Affairs Team Howmedica Osteonics Corporation 59 Route 17 Allendale, New Jersey 07401-1677
Re: K994128
Trade Name: Scorpio® Total Stabilizer (TS) Total Knee System Regulatory Class: II Product Code: JWH Dated: December 3, 1999 Received: December 7, 1999
Dear Ms. Sheridan Powell:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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). You may, therefore, market the device, subject to the general control provisions of the Act. The general control provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
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#### Page 2 - Ms. Terry Sheridan Powell
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or at (301) 443-6597, or at its Internet address "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours,
Neil R.P. Ogden
James E. Dillard III
Acting Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## 510(k) Number (if known): K 994128
#### Device Name: Scorpio® Total Stabilizer (TS) Total Knee System
The Scorpio® TS Total Knee System components are intended for single-use, and for cemented use only in the United States. The components feature a posterior cruciate ligament (PCL) substituting design. This system is intended for use when the cruciate ligaments are absent, inadequate, or cannot be preserved during the operative procedure, especially when anterior-posterior stability is impaired due to the absence of the posterior cruciate ligament and/or patella. The collateral ligaments may or may not be intact. The system is also designed to allow compensation for bone loss through the use of blocks and wedges.
#### General TKR Indications
(Per 21 CFR 801.109)
- Painful, disabling joint disease of the knee resulting from: degenerative arthritis, rheumatoid . arthritis or post-traumatic arthritis.
- Post-traumatic loss of knee joint configuration and function. .
- Moderate varus, valgus, or flexion deformity in which the ligamentous structures can be . returned to adequate function and stability.
- Revision of previous unsuccessful knee replacement or other procedure. .
Additional Indications for Posterior Stabilized (PS) or Total Stabilized (TS) Components:
- Ligamentous instability requiring implant bearing surface geometries with increased . constraint.
- . Absent or non-functioning posterior cruciate ligament.
- . Severe anteroposterior instability of the knee joint.
- For Total Stabilizer (TS) Components Only: Severe instability of the knee secondary to . compromised collateral ligament integrity or function.
Indications for Bone Augmentation Wedges:
- Painful, disabling joint disease of the knee secondary to: degenerative arthritis, rheumatoid . arthritis, or post-traumatic arthritis, complicated by the presence of bone loss.
- . Salvage of previous unsuccessful total knee replacement or other surgical procedure, accompanied by bone loss.
#### (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
| | Concurrence of CDRH, Office of Device Evaluation (ODE) |
|---------------------------------------------------------------------------|--------------------------------------------------------|
| | NRO for JZD |
| (Division Sign-Off) Division of General Restorative Devices 510(k) Number | K994128 |
| Prescription Use X | OR Over-The-Counter Use |
(Optional Format 1-2-96)
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.