K223548 · Medacta International S.A. · MBH · Jan 20, 2023 · Orthopedic
Device Facts
Record ID
K223548
Device Name
GMK Sphere & GMK SpheriKA Cementless
Applicant
Medacta International S.A.
Product Code
MBH · Orthopedic
Decision Date
Jan 20, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3565
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The GMK knee cemented prosthesis is designed for cemented application in total knee arthroplasty if there is evidence of sufficient sound bone to seat and support the components. The use of the cementless GMK femur is limited to cases in which the surgeon considers the bone quality to be sufficient for cementless applications. The GMK 3D Metal Tibial Baseplate is indicated for cemented application if there is evidence of sufficient sound bone to seat and support the components. This knee replacement system is indicated in the following cases: - Severely painful and/or disabled joint as a result of arthritis, theumatoid arthritis or polyarthritis - Collagen disorders, and avascular necrosis of the femoral condyle - Post traumatic loss of joint configuration - Primary implantation failure Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement. The screwed tibial augments are for screwed fixation to the tibial baseplate. In case a semi-constrained liner is used, an extension stem must be implanted both on the tibial and on the femoral components. In case a GMK Revision or GMK Sphere Revision tibial tray is used, an extension stem must be implanted. It is not possible to implant tibial wedges and extension stems with the GMK 3D Metal Tibial Baseplate. Limitations for use for GMK Sphere/GMK SpheriKA used with kinematic alignment GMK Sphere and GMK SpheriKA can be implanted in kinematic alignment. In this case, this knee replacement system is indicated for: - Severely painful and/or disabled joint as a result of arthritis, traumatoid arthritis or polyarthritis - Collagen disorders, and/or avascular necrosis of the femoral condyle - Moderate valgus, varus, or flexion deformities.
Device Story
The GMK Sphere & GMK SpheriKA Cementless is a line extension of the GMK Total Knee System, consisting of femoral components for total knee arthroplasty. These implants are designed for cementless fixation, intended for use in patients where surgeons determine bone quality is sufficient. The device is implanted by orthopedic surgeons in a clinical/hospital setting. The components are manufactured from cobalt-chromium-molybdenum alloy with a double-layer coating of titanium plasma spray and hydroxyapatite to facilitate bone integration. The device replaces damaged joint surfaces to restore function and reduce pain. Clinical decision-making is guided by the surgeon's assessment of bone quality and joint deformity. The device provides a mechanical solution for joint replacement, with no software or algorithmic components involved.
Clinical Evidence
No clinical studies were conducted. Substantial equivalence is supported by non-clinical performance testing, including mechanical property testing of porous-coated femoral components, Scanning Electron Microscopy (SEM), cross-sectional area analysis, and X-ray diffraction (XRD) of coating features. Biocompatibility was assessed per ISO 10993 standards.
Technological Characteristics
Substrate: Cobalt-chromium-molybdenum alloy (ISO 5832-4). Coating: Double-layer titanium plasma spray (ISO 13179-1) and hydroxyapatite (ISO 13779-2). Fixation: Cementless. Form factor: Femoral components in various sizes. Sterilization: Not specified. No software or electronic components.
Indications for Use
Indicated for patients with severely painful/disabled joints due to arthritis, rheumatoid arthritis, polyarthritis, collagen disorders, avascular necrosis of the femoral condyle, post-traumatic joint loss, or primary implantation failure. When used with kinematic alignment, indicated for moderate valgus, varus, or flexion deformities. Requires sufficient bone quality for cementless application.
Regulatory Classification
Identification
A knee joint patellofemorotibial metal/polymer porous-coated uncemented 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 is designed to achieve biological fixation to bone without the use of bone cement. This identification includes fixed-bearing knee prostheses where the ultra high molecular weight polyethylene tibial bearing is rigidly secured to the metal tibial base plate.
Special Controls
*Classification.* Class II (special controls). The special control is FDA's guidance: “Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses; Guidance for Industry and FDA.” See § 888.1 for the availability of this guidance.
Predicate Devices
LEGION Porous Plus HA Primary Femoral Components (K091543)
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January 20, 2023
Medacta International S.A. % Chris Lussier Senior Director, Quality, Regulatory and Clinical Research Medacta USA 3973 Delp Street Memphis, Tennessee 38118
Re: K223548
Trade/Device Name: GMK Sphere & GMK SpheriKA Cementless Regulation Number: 21 CFR 888.3565 Regulation Name: Knee Joint Patellofemorotibial Metal/Polymer Porous-Coated Uncemented Prosthesis Regulatory Class: Class II Product Code: MBH Dated: November 23, 2022 Received: November 25, 2022
Dear Chris Lussier:
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.
# Ting Song -S
Ting Song, 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) K223548
Device Name
GMK Sphere & GMK SpheriKA Cementless
# Indications for Use (Describe)
The GMK knee cemented prosthesis is designed for cemented application in total knee arthroplasty if there is evidence of sufficient sound bone to seat and support the components.
The use of the cementless GMK femur is limited to cases in which the surgeon considers the bone quality to be sufficient for cementless applications.
The GMK 3D Metal Tibial Baseplate is indicated for cemented application if there is evidence of sufficient sound bone to seat and support the components.
- This knee replacement system is indicated in the following cases:
- Severely painful and/or disabled joint as a result of arthritis, theumatoid arthritis or polyarthritis
- · Collagen disorders, and avascular necrosis of the femoral condyle
- Post traumatic loss of joint configuration
- · Primary implantation failure
Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement. The screwed tibial augments are for screwed fixation to the tibial baseplate. In case a semi-constrained liner is used, an extension stem must be implanted both on the tibial and on the femoral components. In case a GMK Revision or GMK Sphere Revision tibial tray is used, an extension stem must be implanted.
It is not possible to implant tibial wedges and extension stems with the GMK 3D Metal Tibial Baseplate.
Limitations for use for GMK Sphere/GMK SpheriKA used with kinematic alignment
GMK Sphere and GMK SpheriKA can be implanted in kinematic alignment. In this case, this knee replacement system is indicated for:
- Severely painful and/or disabled joint as a result of arthritis, traumatoid arthritis or polyarthritis
- · Collagen disorders, and/or avascular necrosis of the femoral condyle
- Moderate valgus, varus, or flexion deformities.
Type of Use (Select one or both, as applicable)
| Requisition Use (Part 31 CFR 301 Subpart D) | Other Than Requisition Use (31 CFR 301 Subpart C) |
|---------------------------------------------|---------------------------------------------------|
|---------------------------------------------|---------------------------------------------------|
> Prescription Use (Part 21 CFR 801 Subpart D)
| | Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary
#### I. Submitter
Medacta International SA Strada Regina 6874 Castel San Pietro (CH) Switzerland Phone (+41) 91 696 60 60 Fax (+41) 91 696 60 66
Contact Person: Stefano Baj, Regulatory and Compliance Director, Medacta International SA Applicant Correspondent: Chris Lussier, Senior Director of Quality and Regulatory, Medacta USA Date Prepared: November 23, 2022 Date Revised: January 13, 2023
#### II. Device
| Device Proprietary Name: | GMK Sphere & GMK SpheriKA Cementless |
|--------------------------|-------------------------------------------------------------------------------------|
| Common or Usual Name: | Total Knee Prosthesis |
| Classification Name: | Knee joint patellofemorotibial metal/polymer porous-coated<br>uncemented prosthesis |
| Primary Product Code: | MBH |
| Regulation Number: | 21 CFR 888.3565 |
| Device Classification | II |
#### III. Predicate Device
Substantial equivalence is claimed to the following devices:
Primary predicate device
- LEGION Porous Plus HA Primary Femoral Components, K091543, Simth & Nephew, . Inc.
Secondary predicate devices
- . GMK Sphere, K121416, Medacta International SA (also referred to as the GMK Total Knee System)
- . GMK Sphere Extensions, K140826, Medacta International SA (also referred to as the GMK Total Knee System)
- GMK SpheriKA, K211004, Medacta International SA ●
- Vanguard Complete Knee System, K113550, Biomet Manufacturing Corp. ●
Reference devices
- Versafit Cup Double Mobility Cementless Acetabular shells, K083116, Medacta . International SA
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- Evolis Total Knee System. Cementless femur porous Ti coated, K081023. Medacta . International SA.
#### Device Description IV.
The GMK Sphere & GMK SpheriKA Cementless is a line extension to the GMK Total Knee System and includes the following devices:
- GMK Sphere Cementless Femoral Components, Left and Right, Sizes from 1 to 7 and from . 1+ to 6+ (intermediate sizes);
- . GMK SpheriKA Cementless Femoral Components. Left and Right, Sizes from 1 to 7 and from 1+ to 6+ (intermediate sizes);
- GMK SpheriKA ST Cementless Femoral Components, Left and Right, Sizes from 1 to 7 ● and from 1+ to 6+ (intermediate sizes).
The subject devices are marketed as individually packaged femoral components, designed for cementless use in total knee arthroplasty procedures where the surgeon considers the bone quality to be sufficient for cementless applications.
The GMK Sphere & GMK SpheriKA Cementless implants are manufactured from cobaltchromium-molybdenum alloy (Co-Cr-Mo) according to ISO 5832-4:2014 Implants for Surgery -Metallic Materials-Part 4: Cobalt-Chromium-Molybdenum Casting Alloy with double-layer coating composed of Titanium plasma spray according to ISO 13179-1 Implants for surgery--Plasma-sprayed unalloyed titanium coatings on metallic surgical implants -- Part 1: General requirements and Hydroxyapatite according to ISO 13779-2 Implants for surgery - Hydroxyapatite - Part 2: Thermally sprayed coatings of hydroxyapatite on the internal surface pockets.
#### V. Indications for Use
The GMK knee cemented prosthesis is designed for cemented application in total knee arthroplasty if there is evidence of sufficient sound bone to seat and support the components.
The use of the cementless GMK femur is limited to cases in which the surgeon considers the bone quality to be sufficient for cementless applications.
The GMK 3D Metal Tibial Baseplate is indicated for cemented application if there is evidence of sufficient sound bone to seat and support the components.
This knee replacement system is indicated in the following cases:
- Severely painful and/or disabled joint as a result of arthritis, traumatic arthritis, rheumatoid . arthritis or polyarthritis
- Collagen disorders, and avascular necrosis of the femoral condyle .
- Post traumatic loss of joint configuration ●
- Primary implantation failure
Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement.
The screwed tibial augments are for screwed fixation to the tibial baseplate. In case a semiconstrained liner is used, an extension stem must be implanted both on the tibial and on the femoral
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components. In case a GMK Revision or GMK Sphere Revision tibial tray is used, an extension stem must be implanted.
It is not possible to implant tibial wedges and extension stems with the GMK 3D Metal Tibial Baseplate.
# Limitations for use for GMK Sphere/GMK SpheriKA used with kinematic alignment
GMK Sphere and GMK SpheriKA can be implanted in kinematic alignment. In this case, this knee replacement system is indicated for:
- . Severely painful and/or disabled joint as a result of arthritis, traumatic arthritis, rheumatoid arthritis or polyarthritis
- . Collagen disorders, and/or avascular necrosis of the femoral condyle
- Moderate valgus, varus, or flexion deformities.
#### Comparison of Technological Characteristics VI.
The subject GMK Sphere & GMK SpheriKA Cementless and the predicate devices (K121416, K140826. K211004) share the following characteristics:
- sizes and design:
- substrate material;
- biocompatibility:
- device usage:
- sterility: ●
- shelf life: and ●
- packaging.
The subject GMK Sphere & GMK SpheriKA Cementless differ from the predicate devices (K121416, K140826, K211004) with respect to:
- . fixation: and
- . coating.
The presence of a double-layer coating of the subject devices with respect to the predicate is justified by the different fixation method: cementless for the subject devices and cemented for the predicate (K121416, K140826, K211004). This difference does not raise any new issue related to subject devices' safety and effectiveness since it is shared with the primary predicate LEGION Porous Plus HA Primary Femoral Components (K091543) and with the additional predicate Vanguard Complete Knee System (K113550) and is supported by performance data.
#### VII. Performance Data
Based on the risk analysis, testing was conducted according to written protocols. The following tests and rationales are being provided in support of a substantial equivalence determination:
# Non-Clinical Studies:
- . PERFORMANCE TESTING
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- GMK Sphere porous coated femoral components mechanical properties o
- о GMK SpheriKA porous coated femoral components mechanical properties
- Scanning Electron Microscopy analysis of Medacta GMK Sphere femoral components o
- Cross Sectioned Area of the coated implant surfaces of the Medacta GMK Sphere O femoral component
- o XRD analyses comparing the coating features deposed in the Medacta GMK Sphere femoral component and on planar samples made of CoCr
- PYROGENICITY
- Bacterial Endotoxin Test (LAL test) was conducted according to European O Pharmacopoeia \$2.6.14 (which is equivalent to USP chapter <85>)
- Pyrogen test according to USP chapter <151> for pyrogenicity determination O
- O The subject devices are not labeled as non-pyrogenic or pyrogen free
- BIOCOMPATIBILITY assessment as per ISO 10993 series and FDA Biocompatibility Guidance document Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process"
- SHELF-LIFE evaluation
# Clinical Studies
- . No clinical studies were conducted.
# VIII. Conclusion
Based on the above information, the GMK Sphere & GMK SpheriKA Cementless implants can be considered substantially equivalent to the identified predicate devices.
Substantial equivalence has been demonstrated through a comparison of intended use, design, and technological characteristics, as well as performance evaluations.
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.
