K220186 · Conmed Corporation · GAT · May 13, 2022 · General, Plastic Surgery
Device Facts
Record ID
K220186
Device Name
Zone Specific AIM
Applicant
Conmed Corporation
Product Code
GAT · General, Plastic Surgery
Decision Date
May 13, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.5000
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Zone Specific AIM™ Device is an implantable suture retention device which facilitates percutaneous or endoscopic soft tissue repairs, including repair of meniscal tears.
Device Story
Handheld, disposable, single-use device for all-inside meniscal repair; facilitates percutaneous or endoscopic soft tissue fixation. Surgeon operates device to sequentially deploy PEEK implants and UHMWPE (Hi-Fi) suture into soft tissue. Device removed post-deployment, leaving behind suture/implant construct. Enables stitch repair via multiple needle access configurations (25° curved, 15° reverse) and suture management wheel. Provides mechanical fixation for meniscal tears; assists in tissue approximation to promote healing. Used in clinical/OR settings.
Clinical Evidence
Bench testing only. Verification and validation testing included reliability, ultimate fixation strength, cyclic testing, biocompatibility, shelf-life, MR safety, packaging, labeling, and sterilization. Bacterial endotoxin testing met established limits.
Indicated for percutaneous or endoscopic soft tissue repairs, including meniscal tears. Contraindicated in patients with insufficient tissue quality/quantity, poor blood supply, active sepsis/infection, inability to follow post-op directions, foreign body sensitivity/allergies to implant materials, or tears inappropriate for repair.
Regulatory Classification
Identification
Nonabsorbable poly(ethylene terephthalate) surgical suture is a multifilament, nonabsorbable, sterile, flexible thread prepared from fibers of high molecular weight, long-chain, linear polyesters having recurrent aromatic rings as an integral component and is indicated for use in soft tissue approximation. The poly(ethylene terephthalate) surgical suture meets U.S.P. requirements as described in the U.S.P. Monograph for Nonabsorbable Surgical Sutures; it may be provided uncoated or coated; and it may be undyed or dyed with an appropriate FDA listed color additive. Also, the suture may be provided with or without a standard needle attached.
Special Controls
*Classification.* Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA.” See § 878.1(e) for the availability of this guidance document.
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May 13, 2022
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CONMED Corporation Orjada Dervishleri Regulatory Affairs Specialist 11311 Concept Boulevard Largo, Florida 33773-4908
Re: K220186
Trade/Device Name: Zone Specific AIM™ Device Regulation Number: 21 CFR 878.5000 Regulation Name: Nonabsorbable poly(ethylene terephthalate) surgical suture Regulatory Class: Class II Product Code: GAT, MBI Dated: February 12, 2022 Received: February 14, 2022
Dear Orjada Dervishleri:
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.
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
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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 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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
For:
Laura C. Rose, Ph.D. Assistant Director DHT6C: Division of Restorative, Repair, and Trauma 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
510(k) Number (if known)
K220186
Device Name Zone Specific AIM™
Indications for Use (Describe)
The Zone Specific AIM™ Device is an implantable suture retention device which facilitates percutaneous or endoscopic soft tissue repairs, including repair of meniscal tears.
| Type of Use (Select one or both, as applicable) | |
|--------------------------------------------------------------------------|-------------------------------------------------------------------------|
| <div> <span>☑ Prescription Use (Part 21 CFR 801 Subpart D)</span> </div> | <div> <span>☐ Over-The-Counter Use (21 CFR 801 Subpart C)</span> </div> |
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## 510(k) SUMMARY
In accordance with the requirements of the Safe Medical Device Act of 1990 and 21 CFR 807.92, CONMED Corporation is hereby submitting the 510(k) Summary of Safety and Effectiveness for 510(k) Number K220186.
#### I. SUBMITTER
CONMED Corporation 11311 Concept Blvd Largo, Florida 33773
Phone: 727-392-6464
Contact Person: Orjada Dervishleri Date Prepared: May 13th, 2022
### II. DEVICE NAME
| Device Name: | Zone Specific AIM™ Device |
|----------------------|------------------------------------------------|
| Classification Name: | Suture, Nonabsorbable, Synthetic, Polyethylene |
| Regulatory Class: | Class II, per 21 CFR Part 878. 5000 |
| Product Codes: | GAT, MBI |
#### III. PREDICATE/ LEGALLY MARKETED DEVICE
| Device Name: | ConMed Linvatec Sequent™ Meniscal Repair Device |
|---------------|-------------------------------------------------|
| Company Name: | ConMed Linvatec |
| 510(k) #: | K102339 |
#### IV. DEVICE DESCRIPTION
The Zone Specific AIM™ is an all-inside meniscal repair device that sequentially deploys implants and suture. The device is composed of peek implants and ultra-high molecular weight polyethylene (UHMWPE) suture (Hi-Fi). The handheld, disposable device, provided sterile for single use, is removed at the end of the repair leaving behind a suture/implant construct. The anchor, suture, and disposable handheld device are EO Sterilized.
### V. INTENDED USE/ INDICATIONS FOR USE The Zone Specific AIM™ Device is an implantable suture retention device which facilitates percutaneous or endoscopic soft tissue repairs, including repair of meniscal tears.
### COMPARISON OF THE TECHNOLOGICAL CHARACTERISTICS WITH THE VI. PREDICATE DEVICE
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| | Zone Specific AIM™ Device<br>Proposed Device | Sequent™ Meniscal Repair Device<br>Predicate Device |
|---------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device<br>Description | The Zone Specific AIM™ is an all-inside<br>meniscal repair device that sequentially<br>deploys implants and suture. The device is<br>composed of peek implants and ultra-high<br>molecular weight polyethylene (UHMWPE)<br>suture (Hi-Fi). The handheld, disposable<br>device, provided sterile for single use, is<br>removed at the end of the repair leaving behind<br>a suture/implant construct. The anchor, suture,<br>and disposable handheld device are EO<br>Sterilized. | The ConMed Linvatec Sequent™ Meniscal<br>Repair Device is an all-inside meniscal<br>repair device that sequentially deploys<br>implants and suture. This device allows the<br>surgeon to generate multiple stitches in<br>order to create fixation points along a soft<br>tissue tear. The hand held, disposable<br>device, provided sterile for single use, is<br>removed at the end of the repair leaving<br>behind a suture/implant construct. The<br>implant encompasses a cleat which retains<br>the suture and allows the knotless feature. |
| Intended Use /<br>Indications for use | The Zone Specific AIM™ Device is an<br>implantable suture retention device which<br>facilitates percutaneous or endoscopic soft<br>tissue repairs, including repair of meniscal tears. | The ConMed Linvatec Sequent™ Meniscal<br>Repair Device is an implantable suture<br>retention device which facilitates<br>percutaneous or endoscopic soft tissue<br>repairs, including the repair of meniscal<br>tears. |
| Contraindications | 1. Insufficient quantity or quality of tissue. | |
| | 2. Blood supply limitations and/or previous infections, which may tend to retard healing. | |
| | 3. Patients with active sepsis or infection. | |
| | 4. Conditions which tend to limit the patient's ability or willingness to follow directions during<br>the healing period. | |
| | 5. Foreign body sensitivity, known or suspected allergies to implant and/or instrument<br>materials. | |
| | 6. Soft tissue tears which would not be appropriate to repair. | |
| Components | Anchor<br>Suture<br>Shaft<br>Handle<br>Protective sleeve | |
| Technological<br>Characteristics | All-Inside Implant<br>Pretied<br>Adjustable Sleeve<br>Two (2) implant configurations<br>Polyethylene suture / Peek Implant<br>Stitch Repair<br>Multiple needle access/curves (25° Curved; 15°<br>Reverse)<br>Suture management wheel<br>EtO Sterilization | Identical<br>Not pretied<br>Manually adjusted depth sheath<br>Multiple Implant configuration<br>Identical<br>Identical<br>Multiple needle access (straight; curved)<br><br>Identical<br>Identical |
The following table represents a summary of the technological characteristics between the proposed and the predicate device.
### VII. PERFORMANCE DATA
Testing has been completed to demonstrate that the Zone Specific AIM™ performs as intended and is substantially equivalent to the predicate device. Bacterial endotoxin testing was conducted and met the endotoxin limits.
Completed testing includes the following:
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## Verification Testing
- Reliability
- Ultimate Fixation Strength ●
- Transportation ●
- Cyclic ●
- Pyrogen ●
- Biocompatibility ●
- Shelf-life ●
CONCLUSION
VIII.
- MR Safety Testing ●
# Validation Testing
- . User Validation
- Packaging ●
- Labeling ●
- Sterilization ●
The Zone Specific AIM™ Device is either substantially equivalent or identical in design, materials, intended use, principles of operation, and technical characteristics to the predicate Sequent™ Meniscal Repair Device. Based upon the findings of our performance testing, the differences present no new issues of safety and efficacy, and the Infinity™ Fixation System is substantially equivalent to the Sequent™ Meniscal Repair Device (K102339).
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.