VIRTU Lumbar Spacer System

K160699 · Met 1 Technologies, LLC · MAX · Aug 1, 2016 · Orthopedic

Device Facts

• Record ID: K160699
• Device Name: VIRTU Lumbar Spacer System
• Applicant: Met 1 Technologies, LLC
• Product Code: MAX · Orthopedic
• Decision Date: Aug 1, 2016
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The VIRTU Lumbar Spacer System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels in the lumbar spine (L2-S1) with up to Grade 1 spondylolisthesis or retrolisthessis at the involved level(s). DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Patients with previous non-fusion spinal surgery at the involved level may be treated with the VIRTU Lumbar Spacer System. Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the VIRTU PLIF/TLIF System. The VIRTU Lumbar Spacer System is designed for use with autogenous bone graft to facilitate fusion. The system is also intended to be used with supplemental internal spinal fixation systems that are cleared by the FDA for use in the lumbar spine.

Device Story

VIRTU Lumbar Spacer System consists of implants, trials, and instruments for spinal fusion. Implants are placed via posterior (PLIF) or transforaminal (TLIF) approach to restore disc height and facilitate fusion. Used with autogenous bone graft and supplemental internal spinal fixation systems cleared for lumbar use. Operated by surgeons in clinical settings. Device provides structural support to the intervertebral space; benefits patients by stabilizing the spine and promoting fusion in cases of degenerative disc disease.

Clinical Evidence

Bench testing only. Testing included static axial compression (modified ASTM 2077-11), dynamic axial compression (ASTM 2077-11), expulsion (ASTM Draft Standard F-04.25.02.02), and subsidence (ASTM F2267). Results demonstrate mechanical strength sufficient for intended use.

Technological Characteristics

Implants manufactured from PEEK (ASTM F2026) and tantalum (ASTM F560). Device functions as an intervertebral body fusion spacer. Mechanical design supports axial loading and provides structural stability for spinal fusion. No software or electronic components.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous lumbar levels (L2-S1) with up to Grade 1 spondylolisthesis or retrolisthesis. Includes patients with prior non-fusion spinal surgery at the involved level. Requires at least 6 months of failed non-operative treatment.

Regulatory Classification

Identification

An intervertebral body fusion device is an implanted single or multiple component spinal device made from a variety of materials, including titanium and polymers. The device is inserted into the intervertebral body space of the cervical or lumbosacral spine, and is intended for intervertebral body fusion.

Special Controls

*Classification.* (1) Class II (special controls) for intervertebral body fusion devices that contain bone grafting material. The special control is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intervertebral Body Fusion Device.” See § 888.1(e) for the availability of this guidance document.(2) Class III (premarket approval) for intervertebral body fusion devices that include any therapeutic biologic (e.g., bone morphogenic protein). Intervertebral body fusion devices that contain any therapeutic biologic require premarket approval. (c) *Date premarket approval application (PMA) or notice of product development protocol (PDP) is required.* Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.

Predicate Devices

• PATRIOT™ Spacers (K122097)
• Interbody System (K130573)
• AccuLiF® TL-PEEK Cage and AccuLiF® TL and PL (K112095)
• PLIF Cage (K113478)

Submission Summary (Full Text)

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

August 1, 2016

Met 1 Technologies, LLC % Mr. Kenneth C. Maxwell II Regulatory and Quality Specialist Empirical Testing Corporation 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K160699

Trade/Device Name: VIRTU Lumbar Spacer System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: June 23, 2016 Received: June 27, 2016

Dear Mr. Maxwell:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

# Lori A. Wiggins -S

for Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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### Indications for Use

510(k) Number (if known) K160699

Device Name VIRTU Lumbar Spacer System

#### Indications for Use (Describe)

The VIRTU Lumbar Spacer System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels in the lumbar spine (L2-S1) with up to Grade 1 spondylolisthesis or retrolisthessis at the involved level(s). DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Patients with previous non-fusion spinal surgery at the involved level may be treated with the VIRTU Lumbar Spacer System.

Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the VIRTU PLIF/TLIF System.

The VIRTU Lumbar Spacer System is designed for use with autogenous bone graft to facilitate fusion. The system is also intended to be used with supplemental internal spinal fixation systems that are cleared by the FDA for use in the lumbar spine.

| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------------------------------------------|
| <span style="font-size:16px;">☒</span> Prescription Use (Part 21 CFR 801 Subpart D) |
| <span style="font-size:16px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |

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# 510(K) SUMMARY

| Submitter's Name: | Met 1 Technologies, LLC |
|----------------------------|------------------------------------------------------------------|
| Submitter's Address: | 154 N. Festival Dr., Ste. F<br>El Paso, TX 79912 |
| Submitter's Telephone: | 915.301.0834 |
| Contact Person: | Kenneth C. Maxwell II<br>Empirical Testing Corp.<br>719.337.7579 |
| Date Summary was Prepared: | 22 July 2016 |
| Trade or Proprietary Name: | VIRTU Lumbar Spacer System |
| Common or Usual Name: | Intervertebral Fusion Device With Bone Graft, Lumbar |
| Classification: | Class II per 21 CFR §888.3080 Device Classification |
| Product Code: | MAX |
| Classification Panel: | Division of Orthopedic Devices |

### DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION

The VIRTU Posterior Lumbar Spacer System consists of implants, trials and instruments. The VIRTU Lumbar Spacer System may be implanted bilaterally using a posterior (PLIF) approach, or as a single device employing a transforaminal (TLIF) approach.

### INDICATIONS FOR USE

The VIRTU Lumbar Spacer System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels in the lumbar spine (L2-S1) with up to Grade 1 spondylolisthesis or retrolisthessis at the involved level(s). DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Patients with previous non-fusion spinal surgery at the involved level mav be treated with the VIRTU Lumbar Spacer System.

Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the VIRTU PLIF/TLIF System.

The VIRTU Lumbar Spacer System is designed for use with autogenous bone graft to facilitate fusion. The system is also intended to be used with supplemental internal spinal fixation systems that are cleared by the FDA for use in the lumbar spine.

The indications for use for the VIRTU Lumbar Spacer System is similar to that of the predicate devices listed in table 5-1.

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### TECHNOLOGICAL CHARACTERISTICS

All implant components are manufactured from PEEK per ASTM F2026 and tantalum per ASTM F560. The subject and predicate devices have nearly identical technological characteristics and the minor differences do not raise any new issues of safety and effectiveness. Specifically the following characteristics are identical between the subject and predicates:

- . Indications for Use
- Materials of Manufacture .
- Structural Support Mechanism ●
- . Principles of Operation

#### Table 5-1 Predicate Devices

| 510k Number | Trade or Proprietary or<br>Model Name | Manufacturer | Predicate<br>Type |
|-------------|--------------------------------------------------|------------------------|-------------------|
| K122097 | PATRIOT™ Spacers | Globus Medical<br>Inc. | Primary |
| K130573 | Interbody System | Tyber Medical | Additional |
| K112095 | AccuLiF® TL-PEEK Cage<br>and AccuLiF® TL and PL | CoAlign<br>Innovation | Additional |
| K113478 | PLIF Cage | Eisertech | Additional |

## PERFORMANCE DATA

The VIRTU Lumbar Spacer System has been tested in the following test modes:

- . Static axial compression per modified ASTM 2077-11
- . Dynamic axial compression per ASTM 2077-11
- Expulsion per ASTM Draft Standard F-04.25.02.02 ●
- Subsidence per ASTM F2267

The results of this non-clinical testing show that the strength of the VIRTU Lumbar Spacer System is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

# CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the VIRTU Lumbar Spacer System is substantially equivalent to the predicate device.