The Trabecular Metal Vertebral Body Replacement System is comprised of vertebral body replacement devices intended for use in the thoracolumbar spine (T1-L5) to replace a collapsed, damaged or unstable vertebral body due to tumor or trauma (i.e., fracture). The Trabecular Metal Vertebral Body Replacement is intended for use with supplemental internal spinal fixation systems. The Trabecular Metal Vertebral Body Replacement may be used with bone graft.

Device Description

The Trabecular Metal Vertebral Body Replacement (VBR) System is designed to be used as a replacement for a diseased or damaged vertebral body and the adjacent disc when spinal surgery is indicated. The Trabecular Metal VBR System is wholly comprised of Trabecular Metal Porous Tantalum deposited on a vitreous carbon skeleton) and is available in a variety of configurations to accommodate the anatomical requirements of different patients.

AI/ML Overview

This document does not contain information about studies that prove the device meets acceptance criteria as typically found for AI/ML medical devices.

The provided text (K070754) is a 510(k) summary for a physical medical device: the "Trabecular Metal™ Vertebral Body Replacement System." This type of device is a physical implant, not an AI/ML diagnostic or prognostic tool.

Therefore, the requested information regarding acceptance criteria, device performance, sample sizes, ground truth, expert opinions, MRMC studies, or standalone algorithm performance does not apply to this document.

The "Performance Data" section states: "The results of testing and analyses conducted demonstrate that the worst cases of the proposed System adequately meet the predetermined requirements established for its mechanical performance."

This refers to mechanical and material testing (e.g., fatigue strength, compression testing, biocompatibility) for a physical implant, not the kind of performance data, acceptance criteria, or study design relevant to AI/ML algorithms.

To directly answer your request based on the provided text, while acknowledging it's not an AI/ML device:

1. A table of acceptance criteria and the reported device performance:

Acceptance Criteria	Reported Device Performance
Predetermined requirements established for its mechanical performance (e.g., strength, durability)	The worst cases of the proposed System adequately meet these predetermined requirements.

2. Sample size used for the test set and the data provenance: Not applicable. This refers to mechanical testing of physical implants, not data from a test set for an algorithm.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for an AI/ML algorithm is not relevant to mechanical testing.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: Not applicable. This is a physical implant, not an AI assistance tool for human readers.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done: Not applicable.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): Not applicable in the context of AI/ML. For a physical device, the "ground truth" would be established engineering standards and specifications.

8. The sample size for the training set: Not applicable.

9. How the ground truth for the training set was established: Not applicable.

Summary

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K070754

Page 1 of 2.

510(k) Summary

AUG 3 1 2007

Submitter:	Zimmer Trabecular Metal Technology, Inc.10 Pomeroy RoadParsippany, New Jersey 07054
Contact Person:	Jennifer P. HarakalSenior Specialist, Regulatory AffairsTelephone: (973) 576-0133Fax: (973) 884-8795
Date:	March 16, 2007
Trade Name:	Trabecular Metal™ Vertebral Body Replacement System
Common Name:	Vertebral Body Replacement Device
Classification Name andReference:	Spinal Intervertebral Body Fixation Orthosis21 CFR § 888.3060, MOP

DEVICE DESCRIPTION

INDICATIONS FOR USE

DEVICE TECHNOLOGICAL CHARACTERISTICS AND COMPARISON TO PREDICATE DEVICE(S)

Zimmer Trabecular Metal Technology, Inc. has submitted documentation demonstrating the substantial equivalence of the proposed System to its predicate devices. The subject

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K070754

Page 2 of 2

System is similar to its predicate devices with respect to intended use/indications for use, materials, and basic principles of operation.

PERFORMANCE DATA

The results of testing and analyses conducted demonstrate that the worst cases of the proposed System adequately meet the predetermined requirements established for its mechanical performance.

SUBSTANTIAL EQUIVALENCE

The Trabecular Metal™ Vertebral Body Replacement System is substantially equivalent to its predicate devices with respect to intended use/indications for use, technological characteristics and basic principles of operation. As demonstrated by supporting performance data, these technological differences do not present any new issues of safety or effectiveness.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Image /page/2/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three lines representing its body and wings. The eagle is facing right. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

AUG 3 1 2007

Zimmer Trabecular Metal Technology % Ms. Jennifer P. Harakal Senior Regulatory Affairs Specialist 10 Pomeroy Road Parsippany, NJ 07054

Re: K070754

Trade/Device Name: Trabecular Metal™ Vertebral Body Replacement System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: MOP Dated: July 18, 2007 Received: July 19, 2007

Dear Ms. Harakal:

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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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); 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.

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Page 2 - Ms. Jennifer P. Harakal

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number (800) 638-2041 or (240) 276-3150 or the Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,
Mark A. Milken

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known): _ K0 70754

Device Name: Trabecular Metal" Vertebral Body Replacement System

Indications for Use:

Prescription Use X (Part 21 CFR 801 Subpart D)

AND/OR

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

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Page 1 of 1

Marle A. Miller

(Division Sign-Off) (Division Sign of General, Restorative, and Neurological Devi

510(k) Number

Regulation Number and Section

§ 888.3060 Spinal intervertebral body fixation orthosis.

(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.