Kinos Axiom Total Ankle System

K232595 · Restor3D · HSN · Nov 28, 2023 · Orthopedic

Device Facts

• Record ID: K232595
• Device Name: Kinos Axiom Total Ankle System
• Applicant: Restor3D
• Product Code: HSN · Orthopedic
• Decision Date: Nov 28, 2023
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3110
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Kinos Axiom Total Ankle System is indicated for patients with ankle joints damaged by severe rheumatoid, posttraumatic, or degenerative arthritis. The Kinos Total Ankle System is additionally indicated for patients with failed previous ankle surgery. The Kinos Axiom Total Ankle System is intended for cement use only.

Device Story

Fixed-bearing, semi-constrained total ankle replacement system; replaces articulating surfaces of tibial-talar joint. System comprises tibial implant, bearing implant, and talar implant. Tibial implant features modified stem for tibial fixation; additively manufactured from Ti-6Al-4V. Used by orthopedic surgeons in clinical settings to restore joint alignment, reduce pain, and provide flexion-extension movement. Implanted via surgical procedure using bone cement. Benefits include motion preservation and pain relief for patients with severe arthritis or failed prior surgery.

Clinical Evidence

Bench testing only. Performance testing included strength testing per ASTM F2665, bone stability testing, porous surface characterization, and biocompatibility testing per ISO 10993-1:2018.

Technological Characteristics

Fixed-bearing, semi-constrained ankle prosthesis. Tibial implant additively manufactured from Ti-6Al-4V (ASTM F2924). Intended for cemented fixation. System includes tibial, bearing, and talar components.

Indications for Use

Indicated for patients with ankle joints damaged by severe rheumatoid, post-traumatic, or degenerative arthritis, or failed previous ankle surgery. Intended for cement use only.

Regulatory Classification

Identification

An ankle joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace an ankle joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces and has no linkage across-the-joint. This generic type of device includes prostheses that have a talar resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a tibial resurfacing component made of ultra-high molecular weight polyethylene and is limited to those prostheses intended for use with bone cement (§ 888.3027).

Predicate Devices

• Kinos Axiom Total Ankle System (K192778)
• Infinity Total Ankle System (K140749)

Reference Devices

• restor3d TiDAL Lumbar Interbody Fusion Device (K220523)
• Apex 3D Total Ankle Replacement System (K210390)

Submission Summary (Full Text)

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November 28, 2023

restor3d Brianna Prindle Head of Regulatory 4001 E. NC 54 Highway Suite 3160 Durham, North Carolina 27709

Re: K232595

Trade/Device Name: Kinos Axiom Total Ankle System Regulation Number: 21 CFR 888.3110 Regulation Name: Ankle Joint Metal/Polymer Semi-Constrained Cemented Prosthesis Regulatory Class: Class II Product Code: HSN Dated: September 13, 2023 Received: September 13, 2023

Dear Brianna Prindle:

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.

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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).

Your device is also subject to, among other requirements, the Quality System (QS) 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 ([e-mail]) or phone [phone] or 301-796-7100).

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Sincerely,

# Lixin Liu -S

Lixin Liu, Ph.D. Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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# Indications for Use

Submission Number (if known)

K232595

Device Name

Kinos Axiom Total Ankle System

#### Indications for Use (Describe)

The Kinos Axiom Total Ankle System is indicated for patients with ankle joints damaged by severe rheumatoid, posttraumatic, or degenerative arthritis. The Kinos Total Ankle System is additionally indicated for patients with failed previous ankle surgery. The Kinos Axiom Total Ankle System is intended for cement use only.

Type of Use (Select one or both, as applicable)

> Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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# 510(k) Summary

Date Prepared: November 26th, 2023

In accordance with the requirements of 21 CFR 807.92, this information serves as a Summary of Safety and Effectiveness for the use of the Kinos Axiom Total Ankle System.

#### A. 510(k) Sponsor:

restor3d, inc. 4001 E. NC 54 Highway, Suite 3160 Durham, North Carolina, 27709

### B. Primary Correspondent:

Brianna Prindle Head of Regulatory [phone] (direct) [e-mail]

#### C. Premarket Notification:

| Trade Name: | Kinos Axiom Total Ankle System |
|----------------------|----------------------------------------------------------------|
| Common Name: | Total Ankle Replacement |
| Classification Name: | Ankle joint metal/polymer semi-constrained cemented prosthesis |
| Regulation Number: | 21 CFR 888.3110 |
| Product Code: | HSN |
| Classification: | II |
| Review Panel: | Orthopedic |

#### D. Indications for Use:

The Kinos Axiom Total Ankle System is indicated for patients with ankle joints damaged by severe rheumatoid, post-traumatic, or degenerative arthritis. The Kinos Total Ankle System is additionally indicated for patients with failed previous ankle surgery. The Kinos Axiom Total Ankle System is intended for cement use only.

#### E. Predicate Devices:

The Kinos Axiom Total Ankle System is substantially equivalent to the following devices:

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| 510(k) | Trade Name | Manufacturer |
|----------------------------|--------------------------------------------------|--------------------------------------------------|
| Primary Predicate Device | | |
| K192778 | Kinos Axiom Total Ankle System | Restor3d, Inc.<br>Cleared under Kinos<br>Medical |
| Secondary Predicate Device | | |
| K140749 | Infinity Total Ankle System | Wright Medical |
| Reference Device | | |
| K220523 | restor3d TiDAL Lumbar Interbody<br>Fusion Device | restor3d, Inc. |
| K210390 | Apex 3D Total Ankle Replacement<br>System | Paragon 28, Inc. |

# F. Device Description:

The subject Kinos Axiom Total Ankle System is an implant and instrument system designed to preserve motion in patients with ankle arthritis or previously failed ankle surgery. The device is a fixed bearing and semi-constrained implant construct, intended for replacement of the articulating surfaces of the ankle that have been affected by a disease state or injury. The device provides limited mobility to a patient by restoring alignment of the articulating surfaces, reducing pain, and providing flexion-extension movement within the ankle joint. The device is intended to be used with bone cement. The subject Kinos Axiom Total Ankle System consists of three implant components - a tibial implant affixed to the tibia, a bearing implant assembled to the tibial implant and a talar implant affixed to the tibial implant and bearing implant, assembled intraoperatively, function together and articulate with the talar implant to create a fixed bearing prosthesis, replacing the articulating surface of the tibial-talar joint. The subject line extension tibial implant is additively manufactured from Ti-6A1-4V (ASTM F2924) and features a modified stem for fixation into the tibia.

# G. Performance Testing:

The modified device was subjected to the following performance testing and/or analyses to establish substantial equivalence in comparison to the predicate device.

- O Strength Testing per ASTM F2665
- O Bone Stability Testing
- Porous Surface Characterization O
- 0 Biocompatibility per ISO 10993-1:2018

#### H. Substantial Equivalence Comparison:

Substantial equivalence of the line extension tibial implant to the predicate device is based on the following:

- The line extension tibial implant and predicate device have the same ● indications for use and the same intended use.
- The line extension tibial implant and predicate device share similar ●

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performance characteristics, design, and sizes (dimensions are comparable to those offered by predicate systems).

- Changes in technological characteristics, including material and o manufacturing methods, are not shown to raise any different questions of safety or effectiveness.
# I. Conclusion:

Based on comparison of the intended use, indications for use and technological characteristics, the subject Kinos Axiom Total System is substantially equivalent to the predicate Kinos Axiom Total Ankle System. The change in material specification to ASTM F2924 for the addition of additive manufacturing, minor changes in dimensions and sizes and changes in technological characteristics do not raise any different questions of safety or effectiveness.