Vusion® OS is indicated for use as an intervertebral body fusion device at one or two contiguous levels (L2-S1) in skeletally mature patients with degenerative disc disease (DDD) with up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These patients may have had a previous non-fusion spinal surgery at the involved spinal level(s). Vusion® OS is to be used with supplemental fixation and autogenous bone graft. Patients should have at least six months of non-operative treatment prior to treatment.

Device Description

Vusion® OS consists of implants with various widths, lengths, and degrees of lordosis. The implant is provided in widths from 9mm to 11mm, lengths from 20mm to 35mm, and heights ranging from 7mm to 16mm.The implants are made from Polyetheretherketone (PEEK Optima LT1, ASTM F2026) and contain tantalum markers (tantalum per ASTM F560), which allow radiographic confirmation of proper positioning. The implants have ridged teeth that resist rotation and migration, and holes to accommodate bone graft. The implant geometry includes a bulleted nose, fixation teeth on the superior and inferior surfaces, side windows, a graft window passing between the superior and inferior surfaces, and an insertion hole and rails for implant placement control. The implant is sold non-sterile.Vusion® OS is implanted using a standard or oblique PLIF (Posterior Lumbar Interbody Fusion) approach and is intended to be used singly or in pairs with supplemental fixation.

AI/ML Overview

Here's a breakdown of the acceptance criteria and the study information for the Vusion® OS device, based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance:

Acceptance Criteria (Non-Clinical Tests)	Reported Device Performance
Static compression testing per ASTM F2077	Mechanical test results demonstrate substantial equivalence to predicate devices.
Dynamic compression testing per ASTM F2077	Mechanical test results demonstrate substantial equivalence to predicate devices.
Static torsion testing per ASTM F2077	Mechanical test results demonstrate substantial equivalence to predicate devices.
Subsidence testing per ASTM F2267	Mechanical test results demonstrate substantial equivalence to predicate devices.
Expulsion testing per ASTM Draft Standard F-04.25.02.02	Mechanical test results demonstrate substantial equivalence to predicate devices.

2. Sample Size for the Test Set and Data Provenance:

The provided document describes non-clinical mechanical testing and does not refer to a "test set" in the context of patient data or clinical images. Therefore, information regarding human data sample size or provenance (country of origin, retrospective/prospective) is not applicable here. The "test set" consists of mechanical prototypes of the device.

3. Number of Experts and Qualifications for Ground Truth Establishment:

This information is not applicable as the study described is non-clinical mechanical testing, not a study involving expert interpretation of medical data or images.

4. Adjudication Method for the Test Set:

This information is not applicable as the study described is non-clinical mechanical testing. Adjudication methods are typically used in studies involving human interpretation of data for ground truth establishment.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

No, an MRMC comparative effectiveness study was not reported. The study focused on the mechanical properties of the device compared to predicate devices, not on human reader performance with or without AI assistance.

6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance:

This information is not applicable. The device is an intervertebral body fusion implant, a physical medical device, not an AI algorithm. Therefore, "algorithm-only" performance is not relevant.

7. Type of Ground Truth Used:

The "ground truth" for this device's evaluation was based on established engineering standards and measurements as defined by the ASTM testing protocols (e.g., F2077, F2267, F-04.25.02.02). The performance of the Vusion® OS was compared to the performance of predicate devices based on these objective mechanical measurements.

8. Sample Size for the Training Set:

This information is not applicable. The device is a physical implant, not an AI algorithm that requires a training set. The study involves mechanical testing of device prototypes.

9. How the Ground Truth for the Training Set Was Established:

This information is not applicable as there is no "training set" in the context of this device. The mechanical properties of the Vusion® OS and its predicate devices, as measured against ASTM standards, served as the basis for comparison and demonstration of substantial equivalence.

Summary

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KII 1965

OCT 2 5 2011

510(k) Summary

. . . . .

NAME OF SPONSOR:	Ortho Development Corporation12187 South Business Park DriveDraper, Utah 84020
510(k) CONTACT:	Tom HaueterRegulatory Affairs ManagerTelephone: (801) 553-9991Facsimile: (801) 553-9993Email: thaueter@orthodevelopment.com
DATE PREPARED:	June 30, 2011
PROPRIETARY NAME:	Vusion®OS
COMMON NAME:	Intervertebral Body Fusion Device
CLASSIFICATION:	21 CFR888.3080, Intervertebral Body Fusion Device.
DEVICE PRODUCT CODE:	MAX
PREDICATE DEVICES:	Vusion® TS, PS, and CS Partial VBR (K062666)Ortho Development Corp
	Vu™ ePOD& Vu™ LPOD (K082712)Theken Spine, LLC
	Ardis® Spacer (K073202)Abbott Spine Inc.

Section 5, 510(k) Summary

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Device Description

Indications for Use

Basis for SubstantialEquivalence

Vusion® OSwas evaluated in accordance with FDA Documents, Class II Special Controls; Guidance Document: Intervertebral Fusion Device, June 12, 2007, and has been found to meet criteria defined therein.

The following non-clinical tests were conducted:

Static and dynamic compression testing per ASTM F2077. ●
. Static torsion testing per ASTM F2077.
Subsidence testing per ASTM F2267. .
Expulsion testing per ASTM Draft Standard F-04.25.02.02. �

Conclusions

Based on similarities in intended use, design, materials, manufacturing methods, and packaging, Vusion® OS has demonstrated that it is substantially equivalent to the previously

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cleared predicate devices. Mechanical test results demonstrate that the proposed Vusion® OS is substantially equivalent to the predicate devices.

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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services (HHS) in the United States. The logo features a stylized depiction of an eagle or bird, with three curved lines forming its body and wings. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the bird symbol.

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

OCT 2 5 2011

Ortho Development Corporation % Mr. Tom Haueter 12187 South Business Park Drive Draper, Utah 84020

Re: K111965

Trade/Device Name: Vusion® OS Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: September 21, 2011 Received: October 11, 2011

Dear Mr. Haueter:

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

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Page 2 - Mr. Tom Haueter

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 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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely vours.

Eunel Keith

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

Enclosure

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111965

Indications for Use

510(k) Number (if known): K111965

Device Name: Ortho Development Vusion® OS

Indications for Use:

Vusion® OS is indicated for use as an interbody fusion device at one or two contiguous levels (12-51) in skeletally mature patients with degenerative disc disease (DDD) with up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These patients may have had a previous nonfusion spinal surgery at the involved spinal level(s). Vusion® OS is to be used with supplemental fixation and autogenous bone graft. Patients should have at least six months of non-operative treatment prior to treatment.

Prescription Use _ X (Part 21 CFR 801 Subpart D) AND/OR

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

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Division Sign-Off Office of In Vitro Diagnostic Device Evaluation and Safety

KIII 465 210(k)

sheet 1 of 1

Regulation Number and Section

§ 888.3080 Intervertebral body fusion device.

(a)
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.(b)
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.