The Freedom® Metal Backed Tibial Component consists of a cobalt-chrome molybdenum (CoCrMo) tray and a UHMWPE insert that are designed to be used with the Freedom® Total Knee System. The Maxx Orthopedics' Freedom® Total Knee System is indicated for patients with severe knee pain and disability due to:

Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
Correction of functional deformities.
Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, and/or prior patellectomy.
Moderate valgus, varus, or flexion trauma.
Knee fractures untreatable by other methods.

The Maxx Orthopedics' Freedom Total Knee System is intended for cemented use only. This device is for single use only.

Device Description

The Maxx Orthopedics' Freedom® Metal Backed Tibial Component and Ultra High Molecular Weight Polyethylene (UHMWPE) insert are compatible with the Maxx Orthopedics Freedom® Total Knee System subject of K082019. The Maxx Orthopedics' Freedom® Total Knee System subject of K082019 is comprised of a femoral component, tibial component and patella component.

The Freedom® Metal Backed Tibial Component and UHMWPE insert are intended to be used with the Freedom® Total Knee System. The proposed metal backed Tibial Component and UHMWPE insert will be used in place of the all-poly tibial component with the Freedom® Total Knee System.

The proposed metal backed tibial component consists of a cobalt-chromiummolybdenum tray, and the insert is made from UHMWPE. These components are intended for cemented application to replace the articulating surface of the proximal tibia in a measured resection.

The tibia base components are designed with a keel portion which extends into the proximal tibial medullary canal. The more distal portion of the tibial base has a flat plate that rests on the patient's tibial plateau region. On the underside of this plate are cement recesses allowing allow for cement interdigitation which helps to provide rotational stability. The Freedom® Knee tibial inserts have an interlocking relation to the tibial base. The Freedom® Knee femoral components articulate with the bearing base (proximal) surface of the tibial inserts. The articulating surface of these inserts is identical to the articulating surface of the all-poly liner components mentioned in the already cleared Freedom® Total Knee System (K082019).

AI/ML Overview

Here's a breakdown of the acceptance criteria and study information based on the provided text:

1. Acceptance Criteria and Reported Device Performance

The document does not explicitly state numerical acceptance criteria for performance metrics (e.g., minimum fatigue life, maximum wear rate). Instead, the acceptance is based on demonstrating mechanical and functional similarity to predicate devices and adherence to relevant guidance documents.

Acceptance Criteria (Implied)	Reported Device Performance
Mechanical and functional similarity to the parent Freedom UHMWPE Tibial Component and other legally marketed knee systems.	"Mechanical and functional testing described in K082019 and in Section 8 demonstrates that the Freedom® Metal Backed Tibial Component are mechanically and functionally similar to the parent Freedom UHMWPE Tibial Component and other legally marketed knee systems." Additionally, "The proposed and predicate devices are made of biocompatible materials and are technological designed and identical in materials." "The articulating surface of the proposed Maxx Orthopedics Freedom® femoral and tibial components, are similar to the articulating surface of the predicate systems and are functionally equivalent devices."
Adherence to Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses; Guidance for Industry and FDA.	"Evaluations were performed to determine the material and mechanical characteristics of the Maxx Orthopedics' Freedom® Metal Backed Tibial Component and the Freedom® Total Knee System according to the Class II Special Controls Guidance Document..." "The verification and validation testing performed which demonstrated that the Metal Backed Tibial Component functions as intended and is safe and effective for its intended use."
Substantial Equivalence to Predicate Devices (Exactech Optetrak Total Knee Tibial Components K030686)	The FDA's 510(k) clearance letter explicitly states, "We have reviewed your Section 510(k) premarket notification... and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices..." The document highlights that "The proposed Maxx Orthopedics' Freedom® Metal Backed Tibial Component and the predicate devices are identical in that they all consist of a cobalt-chrome molybdenum (CoCrMo) tray and a UHMWPE insert." and both "have been designed to mimic the normal knee geometry." and "are available in a variety of tibial tray and insert sizes."

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

The document does not specify a "test set" in the context of clinical data or human-interpreted data. The performance testing describes mechanical and functional testing, not a clinical study on patients. Therefore, information regarding sample size and data provenance (country of origin, retrospective/prospective) for a test set is not applicable or provided.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

This information is not applicable as the document describes mechanical and functional testing of a medical device, not a study requiring expert interpretation of diagnostic data to establish ground truth.

4. Adjudication Method for the Test Set

This information is not applicable for the same reasons as point 3.

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

This information is not applicable. The document describes the mechanical testing and substantial equivalence of a knee implant, not an AI or imaging diagnostic device. Therefore, MRMC studies are not relevant.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

This information is not applicable. The device is a physical knee implant, not an algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

For the mechanical and functional testing, the "ground truth" would be established by engineering standards, material specifications, and biomechanical performance requirements derived from the Class II Special Controls Guidance Document and comparisons to predicate devices. This is not the same as a clinical "ground truth" established by pathology or expert consensus.

8. The Sample Size for the Training Set

This information is not applicable. The device is a physical knee implant, not a machine learning model that requires a training set.

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

This information is not applicable for the same reasons as point 8.

Summary

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1. SPONSOR

Maxx Orthopedics, Inc. 2260 Butler Pike Suite 100 Plymouth Meeting, PA 19462

APR - 7 2009

Contact Person: Nach Dave Telephone: 732-718-1385

Date Prepared: March 26, 2009

2. DEVICE NAME

Proprietary Name:	Freedom® Metal Backed Tibial Component
Common/Usual Name:	Metal-backed tibial component
Classification Name:	Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis.

3. PREDICATE DEVICES

. Exactech Optetrak Total Knee Tibial Components subject of K030686.

4. DEVICE DESCRIPTION

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5. INTENDED USE

The Freedom® Metal Backed Tibial Component consists of a cobalt-chrome molybdenum (CoCrMo) tray and a UHMWPE insert that are designed to be used with the Freedom Total Knee System. The Maxx Orthopedics' Freedom® Total Knee System is indicated for patients with severe knee pain and disability due to:

. Severe knee joint pain, loss of mobility, and disability due to: rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
Correction of functional deformities. .
. Post-traumatic loss of knee joint contour, particularly when there is patellofemoral erosion, dysfunction, and/or prior patellectomy,
. Moderate valgus, varus, or flexion trauma.
Knee fractures untreatable by other methods. .

The Maxx Orthopedics' Freedom Total Knee System is intended for cemented use only. This device is for single use only.

6. TECHNOLOGICAL CHARACTERISTICS AND SUBSTANTIAL EQUIVALENCE

The proposed Maxx Orthopedics' Freedom® Metal Backed Tibial Component and the predicate devices are identical in that they all consist of a cobalt-chrome molybdenum (CoCrMo) tray and a UHMWPE insert.

Both the proposed component and the predicate devices have been designed to mimic the normal knee geometry. Both the proposed and predicate devices are available in a variety of tibial tray and insert sizes that are intended to mimic normal human anatomy. The articulating surface of the proposed Maxx Orthopedics Freedom® femoral and tibial components, are similar to the articulating surface of the predicate systems and are functionally equivalent devices. Both the proposed and predicate

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devices are made of biocompatible materials and are technological designed and identical in materials.

7. PERFORMANCE TESTING

Mechanical and functional testing described in K082019 and in Section 8 demonstrates that the Freedom® Metal Backed Tibial Component are mechanically and functionally similar to the parent Freedom UHMWPE Tibial Component and other legally marketed knee systems. Evaluations were performed to determine the material and mechanical characteristics of the Maxx Orthopedics' Freedom® Metal Backed Tibial Component and the Freedom® Total Knee System according to the Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses; Guidance for Industry and FDA. The verification and validation testing performed which demonstrated that the Metal Backed Tibial Component functions as intended and is safe and effective for its intended use.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Image /page/3/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or a stylized human figure.

APR - 7 2009

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Maxx Orthopedics, Inc. % Mary McNamara-Cullinane, RAC Senior Regulatory Consultant Medical Device Consultants, Inc. 49 Plain Street North Attleboro, Massachusetts 02760

Re: K090411

Trade/Device Name: Freedom Total Knee Metal Backed Tibial Components Regulation Number: 21 CFR 888.3560 Regulation Name: Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis Regulation Class: Class II Product Code: JWH Dated: March 26, 2009 Received: March 27, 2009

Dear Ms. McNamara-Cullinane:

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. Ilsting 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

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Page 2 - Mary McNamara-Cullinane, RAC

forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. 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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

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): K090411

Device Name: Maxx Orthopedics' Freedom® Metal Backed Tibial Component

Indications for Use:

Severe knee joint pain, loss of mobility, and disability due to: rheumatoid ● arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
Correction of functional deformities. .
Post-traumatic loss of knee joint contour, particularly when there is . patellofemoral erosion, dysfunction, and/or prior patellectomy.
Moderate valgus, varus, or flexion trauma. .
. Knee fractures untreatable by other methods

The Maxx Orthopedics' Freedom Total Knee System is intended for cemented use only. This device is for single use only.

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

Over-The-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY) Concurrence of CDRH, Office of Device Evaluation (ODE)

Charlane Phillips

Division of General, Restorative, and Neurological Devices

510(k) Number K090411/5001

Regulation Number and Section

§ 888.3560 Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis.

(a)
Identification. A knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented 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 includes prostheses that have a femoral component made of alloys, such as cobalt-chromium-molybdenum, and a tibial component or components and a retropatellar resurfacing component made of ultra-high molecular weight polyethylene. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).(b)
Classification. Class II.