The MAXFRAME AUTOSTRUT System is indicated for the following treatments in adults, and in both children (3-12) and adolescents (12-21) in which growth plates have fused or will not be crossed with hardware: • fracture fixation (open and closed) • pseudoarthrosis of long bones • limb lengthening (epiphyseal or metaphyseal distraction) • joint arthrodesis • infected fractures or nonunions • correction of bony or soft tissue deformities • correction of segmental defects.
Device Story
External fixation system for orthopedic correction; comprises control system, software, and six motor-powered, length-adjustable hexapod struts. Used with MAXFRAME multi-axial correction system. Struts are telescopic rods (stainless steel/aluminum) with polymeric motor adapter. Provided sterile. System automates distraction/correction processes previously performed manually. Healthcare providers use the control system and software to manage strut adjustments; output facilitates precise bone segment manipulation for limb lengthening or deformity correction. Benefits include controlled, automated mechanical distraction to promote bone healing and alignment.
Clinical Evidence
No clinical data provided. Substantial equivalence supported by bench testing, including mechanical testing, shelf-life validation, packaging validation, sterilization validation, and biocompatibility evaluation.
Technological Characteristics
External fixation system; six motor-powered, length-adjustable hexapod struts. Materials: stainless steel, aluminum, and polymeric motor adapter. Sterilization: ethylene oxide. Connectivity: integrates with MAXFRAME multi-axial correction system (K161417). Software: previously cleared under K202810.
Indications for Use
Indicated for adults, children (3-12), and adolescents (12-21) with fused growth plates or where hardware does not cross growth plates for fracture fixation, pseudoarthrosis, limb lengthening, joint arthrodesis, infected fractures/nonunions, and correction of bony/soft tissue deformities or segmental defects.
Regulatory Classification
Identification
Single/multiple component metallic bone fixation appliances and accessories are devices intended to be implanted consisting of one or more metallic components and their metallic fasteners. The devices contain a plate, a nail/plate combination, or a blade/plate combination that are made of alloys, such as cobalt-chromium-molybdenum, stainless steel, and titanium, that are intended to be held in position with fasteners, such as screws and nails, or bolts, nuts, and washers. These devices are used for fixation of fractures of the proximal or distal end of long bones, such as intracapsular, intertrochanteric, intercervical, supracondylar, or condylar fractures of the femur; for fusion of a joint; or for surgical procedures that involve cutting a bone. The devices may be implanted or attached through the skin so that a pulling force (traction) may be applied to the skeletal system.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.
July 26, 2023
Depuy Synthes Mitchel Bartko Regulatory Affairs Specialist III 1301 Goshen Parkway West Chester, Pennsylvania 19380
Re: K231922
Trade/Device Name: DEPUY SYNTHES MAXFRAME AUTOSTRUT System Regulation Number: 21 CFR 888.3030 Regulation Name: Single/multiple component metallic bone fixation appliances and accessories Regulatory Class: Class II Product Code: KTT Dated: June 29, 2023 Received: June 29, 2023
Dear Mitchel Bartko:
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. 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 located 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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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 803) for devices or postmarketing safety reporting (21 CFR 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 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-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.
# 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 Ouality Center for Devices and Radiological Health
Enclosure
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### Indications for Use
510(k) Number (if known) K231922
Device Name
DEPUY SYNTHES MAXFRAME AUTOSTRUT System
Indications for Use (Describe)
The MAXFRAME AUTOSTRUT System is indicated for the following treatments in adults, and in both children (3-12) and adolescents (12-21) in which growth plates have fused or will not be crossed with hardware:
- · fracture fixation (open and closed)
- · pseudoarthrosis of long bones
- · limb lengthening (epiphyseal or metaphyseal distraction)
- · joint arthrodesis
- · infected fractures or nonunions
- correction of bony or soft tissue deformities
- · correction of segmental defects.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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## 510(k) Summary
| Sponsor | DePuy Synthes | Address |
|----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------|
| Primary Contact | Mitchel Bartko<br>Regulatory Affairs Specialist III<br>DePuy Synthes | 1301 Goshen Parkway<br>West Chester, PA USA<br>T: 908-808-6541<br>Email: mbartko1@its.jnj.com |
| Secondary Contact | Silvia De La Barra<br>Manager, Regulatory Affairs<br>DePuy Synthes | 1301 Goshen Parkway<br>West Chester, PA USA<br>T: 385-258-9397<br>Email: sdelabar@its.jnj.com |
| Date Prepared | June 29, 2023 | |
| Device Trade Name | DEPUY SYNTHES MAXFRAME AUTOSTRUT System | |
| Common Name | External Fixation System | |
| Classification | Class II | |
| Product Code | KTT (Appliance, fixation, nail/blade/plate combination, multiple components) | |
| Regulation Number | 888.3030 : Single/multiple component metallic bone fixation appliances and<br>accessories | |
| Predicate Device(s) | K202810 - Autostrut G2 | |
| Device Description<br>Summary | The MAXFRAME AUTOSTRUT System is comprised of a control system,<br>software, and six length-adjustable struts powered by a motor. The devices are<br>used in conjunction with the DePuy Synthes MAXFRAME multi axial<br>correction system (K161417), including all its parts and software, except that the<br>MAXFRAME struts are substituted with the MAXFRAME AUTOSTRUT<br>Hexapod Struts.<br>This submission is solely for the clearance of a sterile version of the<br>MAXFRAME AUTOSTRUT Hexapod Struts. The MAXFRAME<br>AUTOSTRUT Hexapod Struts are provided sterile and are comprised of<br>telescopic rods made of stainless steel and aluminum and a motor adapter made<br>from polymeric material. The MAXFRAME AUTOSTRUT Hexapod Struts are<br>available in three lengths - short, medium, and long.<br>The MAXFRAME AUTOSTRUT Control System and Software have been<br>cleared under K202810. | |
| Intended Use | | |
| Indications for Use | The MAXFRAME AUTOSTRUT System is indicated for the following<br>treatments in adults, and in both children (3-12) and adolescents (12-21) in<br>which growth plates have fused or will not be crossed with hardware:<br>• fracture fixation (open and closed)<br>• pseudoarthrosis of long bones<br>• limb lengthening (epiphyseal or metaphyseal distraction)<br>• joint arthrodesis<br>• infected fractures or nonunions<br>• correction of bony or soft tissue deformities<br>• correction of segmental defects. | |
| Indications for Use<br>Comparison | The MAXFRAME AUTOSTRUT System has the same indications for use as the<br>predicate device (AutoStrut G2 [K202810]). | |
| Technological<br>Comparison | The DePuy Synthes MAXFRAME AUTOSTRUT System has similar<br>technological characteristics (design, material and chemical composition) as the<br>predicate device AutoStrut G2 (K202810). The only differences between the<br>predicate and subject device is that the subject device struts are provided<br>ethylene oxide sterilized and packaged within sterile barrier packaging. The<br>predicate device struts are provided non-sterile and are end user steam sterilized. | |
| Non-clinical<br>Performance<br>Testing | Non-Clinical Performance Testing was performed and included Mechanical<br>Testing, Shelf-Life Validation, Packaging Validation, Sterilization Validation<br>and Biocompatibility Evaluation. The data was used for the determination of<br>substantial equivalence. | |
| Clinical<br>Performance Data | Clinical Performance Data was not necessary for the determination of substantial<br>equivalence. | |
| Conclusion | These minor differences in the technological characteristics compared to the<br>predicate do not raise different questions of safety or effectiveness. Bench<br>testing demonstrates that the sterile MaxFrame AutoStrut Hexapod Strut is as<br>safe and effective as its predicate device. Therefore, MaxFrame AutoStrut<br>System is substantially equivalent to its predicate.<br>The purpose of this 510(k) submission is to clear the sterile version of the<br>MAXFRAME AUTOSTRUT Hexapod Strut only. The MAXFRAME<br>AUTOSTRUT Control System and Software have been cleared under K202810. | |
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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.