Vilet: Vilet (PGLA) surgical suture is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular and neurological tissues. Vilet suture is provided sterile as a single use device.

Vilet Quick: Vilet Quick (fast absorbing PGLA) surgical suture is indicated for use in superficial soft tissue approximation of the skin and mucosa, where only short-term wound support (7-10 days) is required, but not for use in ligation, ophthalmic, cardiovascular or neurological procedures. Vilet Quick suture is provided sterile as a single use device.

Device Description

Riverpoint Medical PGLA absorbable surgical sutures (Vilet and Vilet Quick) are medical devices used to secure tissues together or create wound closures during a surgical procedure or after an injury. Vilet and Vilet Quick sutures are multifilament, and are composed of braided strands of Polyglycolic-Lactic Acid (PGLA) coated with Poly(glycolide-co-L-lactide) and Calcium Stearate attached to a standard medical grade suture needle as applicable (sutures can be provided without needles as well) Available Suture sizes will be standard according to USP 32 requirements (8/0 through 3, depending on suture type).

AI/ML Overview

Here's an analysis of the provided text regarding the acceptance criteria and study for the Riverpoint Medical PGLA absorbable surgical sutures (Vilet and Vilet Quick):

This document is a 510(k) summary for a medical device and therefore primarily focuses on demonstrating substantial equivalence to predicate devices rather than providing a detailed report of a robust clinical trial demonstrating absolute performance against specific, pre-defined acceptance criteria with statistical power.

Acceptance Criteria and Reported Device Performance

The document states that the Riverpoint Medical PGLA sutures (Vilet and Vilet Quick) meet current performance requirements for synthetic absorbable braided surgical sutures unless otherwise labeled. It also explicitly mentions compliance with the requirements for diameter, tensile strength, and needle attachment strength as specified within USP 32.

Since this is a 510(k) submission, the "acceptance criteria" are generally established by the regulatory guidance for the device type, in this case, "Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA." The reported device performance is that it meets these requirements. No specific numerical targets or results are provided in this summary.

Acceptance Criteria Category	Reported Device Performance
Mechanical Properties	Meet requirements for diameter, tensile strength, and needle attachment strength as specified within USP 32.
Biocompatibility	Testing performed in accordance to ISO 10993-1. (Implies meeting established safety standards).
Resorption Characteristics	In-vitro and in-vivo resorption testing performed. (Implies meeting expected absorption profile).
Technological Characteristics	Substantially equivalent to predicate devices (e.g., braided, coated, synthetic absorbable).
Sterility	Provided sterile as a single-use device.
Material Composition	Materials selected based on known biocompatibility and established histories of use; identical or substantially equivalent to predicate devices.

Study Information

The document describes several types of performance testing, but not a single, comprehensive "study" that would typically be described with sample sizes, specific methodologies, and detailed results from a clinical trial in the way a new, novel device might. The focus is on demonstrating equivalence.

Sample size used for the test set and the data provenance:
- Test Set Sample Size: Not specified. The document mentions "Testing is performed on each lot of product to verify that requirements have been met prior to release." This implies ongoing quality control testing rather than a single fixed "test set" for a pre-market submission.
- Data Provenance: Not specified, but implied to be from internal testing conducted by Riverpoint Medical.
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This information is not applicable to the type of testing described (mechanical, biocompatibility, resorption). The 'ground truth' for these tests would be the established scientific and regulatory standards (e.g., USP 32 standards for tensile strength).
Adjudication method for the test set:
- Not applicable. The testing is objective and relies on scientific measurement against pre-defined specifications rather than expert interpretation requiring adjudication.
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:
- No. This is a surgical suture, not an AI or imaging diagnostic device.
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No. This applies to AI/software devices.
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for the performance testing described (mechanical, biocompatibility, resorption) are established scientific/regulatory standards and specifications, primarily those outlined in USP 32 and ISO 10993-1.
The sample size for the training set:
- Not applicable. This is not a machine learning or AI device.
How the ground truth for the training set was established:
- Not applicable. This is not a machine learning or AI device.

Summary

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K120556 P. 1 of 3

MAY 2 3 2012

K120556 Response 05.2012

RIVERPOINTMEDICAL
-----------------------

510(k) Summary

Submitter Information

Submitter's Name:	Riverpoint Medical
-------------------	--------------------

Address:

825 NE 25th Ave. Portland, OR 97232

(503) 517-8001 or 866 445-4923

Phone Number:

Fax Number: (503) 517-8002

Registration Number: 3006981798

Contact Person: Douglas Rowley (503) 517-8001

Date of Preparation: February 14, 2012

Device Names

Trade Names:	PGLA:Fast Absorbing PGLA:	ViletVilet Quick
Common Names:	Absorbable Surgical Sutures: PGLA
Classification Names:	General and Plastic Surgery Devices

Device Classification

FDA Class:	2
Product Classification:1. Vilet:2. Vilet Quick:	878.4493, Absorbable poly(glycolide/l-lactide) surgical suture878.4493, Absorbable poly(glycolide/l-lactide) surgical suture
Codes:
1. Vilet:	GAM
2. Vilet Quick:	GAM
Classification Panel:	All: Class II (special controls); General and Plastic Surgery

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Image /page/1/Picture/1 description: The image shows the words "RIVERPOINT MEDICAL" in a bold, sans-serif font. The word "RIVERPOINT" is on the top line, and the word "MEDICAL" is on the bottom line. The letters are all capitalized and black. The image appears to be a logo or heading.

Predicate Devices (applicable 510(k) number listed):

1. Ethicon® Vicryl® KO22269
Ethicon® Vicryl Rapide®: 2. K033746

Special Controls

FDA Guidance "Class II Special Controls Guidance Document: Surgical Sutures; Guidance for Industry and FDA" was followed during the preparation of this submission.

Device Description

Riverpoint Medical PGLA absorbable surgical sutures (Vilet and Vilet Quick) are medical devices used to secure tissues together or create wound closures during a surgical procedure or after an injury. Vilet and Vilet Quick sutures are multifilament, and are composed of braided strands of Polyglycolic-Lactic Acid (PGLA) coated with Poly(glycolide-co-L-lactide) and Calcium Stearate attached to a standard min
suture needle as annlinghle (cutuse ann Stearate attached to a standard medical grade suture needle as applicable (sutures can be provided without needles as well) Available Suture sizes will be standard according to USP 32 requirements (8/0 through 3, depending on suture type).

Intended Uses

Vilet: Vilet (PGLA) surgical suture is indicated for use in general soft tissue approximation and/or ligation, including use in gorient son thissue cardiovascular and neurological tissues.

Vilet suture is provided sterile as a single use device.

Vilet Quick suture is provided sterile as a single use device.

Safety and Effectiveness

Each variety of absorbable suture has been designed and manufactured to be substantially equivalent to the predicate devices listed for safety and effectiveness. Materials used were selected broend on known biocompatibility and established histories of use in the medical device industry for implantable devices, and are identical or substantially equivalent to the materials used in the predicate devices listed. Riverpoint Medical Vilet and Vilet Quick PGLA absorbable sutures have been designed to meet the requirements for diameter, tensile strength, and needle attechment strength

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Image /page/2/Picture/2 description: The image shows the words RIVERPOINT and MEDICAL stacked on top of each other. The text is in a bold, sans-serif font. The word RIVERPOINT is on the top line, and the word MEDICAL is on the bottom line. The text is black and the background is white.

as specified within USP 32 unless stated otherwise on labeling. Testing is performed on each lot of product to verify that requirements have been met prior to release.

Technological Characteristics

The Riverpoint Vilet and Vilet Quick PGLA sutures within this submission have substantially equivalent technological characteristics as the predicate devices listed. As with the predicate devices, Riverpoint Vilet and Vilet Quick PGLA sutures are braided. A coated, synthetic absorbable surgical sutures. Riverpoint Vilet and Vilet and Vilet Quick PGLA sultures are provided sterile for one-time use only, and meet USP requirements unless stated otherwise within labeling.

Performance Data

Per FDA's Special Control Guidance Document: Surgical Sutures, performance testing, including mechanical testing in accordance to USP for synthetic absorbable sulture, biocompatibility testing in accordance to ISO 10993-1, and in-vitro as well as in-vivo resorption testing has been performed to further ensure substantial equivalence with the predicate devices listed. All testing performed has demonstrated that Riverpoint's Vilet and Vilet Quick PGLA sutures meet current performance requirements for synthelic absorbable braided surgical sutures unless otherwise labeled, and that they are substantially equivalent to the applicable predicate devices.

Conclusion

Based on the information provided within this 510(k) submission, Riverpoint Medical concludes that the proposed suture products are substantially equivalent to the predicate devices listed according to the requirements of the Federal Food, Drug, and Cosmetic
Act Act.

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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three stripes forming its body and wing. The eagle is enclosed in a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the perimeter.

Public Health Service

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

MAY 2 3 2012

Riverpointe Medical % Mr. Doug Rowley 825 NE 25th Avenue Portland, Oregon 97232

Re: K120556 Trade/Device Name: Vilet Vilet Quick Regulation Number: 21 CFR 878.4493 Regulation Name: Absorbable poly (glycolide/L-lactide) surgical suture Regulatory Class: Class II Product Code: GAM Dated: May 10 , 2012 Received: May 16, 2012

Dear Mr. Doug Rowley:

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

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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); 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/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Mark N. Melkerson
Director

Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use Statement

510(k) Number:	Unknown at this time
Device Name:	Polyglycolic-Lactic Acid (PGLA) Absorbable Surgical Suture
Trade Name:	Vilet

Indications for Use:

PGLA surgical suture is indicated for use in general soft tissue approximation and/or ligation, including use in ophthalmic procedures, but not for use in cardiovascular and neurological tissues.

PGLA suture is provided sterile as a single use device.

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)

(Division Sign-Of Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K120556

Page 1 of 1 510(k) Indications for Use Statement - PGLA Suture

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Indications for Use Statement

510(k) Number:	Unknown at this time
Device Name:	Fast Absorbing Polyglycolic-Lactic Acid (PGLA Quick) Absorbable Surgical Suture
Trade Name:	Vilet Quick

Indications for Use:

Page 1 of 1

Fast absorbing PGLA surgical suture is indicated for use in superficial soft tissue approximation of the skin and mucosa where only short-term wound support (7-10 days) is required, but not for use in ligation, ophthalmic, cardiovascular or neurological procedures. PGLA Quick suture is provided sterile as a single use device.

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 (

Evaluation (ODE)

Kariel Kune for MXM

Division Sign Off

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K120556

510(k) Indications for Use Statement - PGLA Quick Suture

Regulation Number and Section

§ 878.4493 Absorbable poly(glycolide/l-lactide) surgical suture.

(a)
Identification. An absorbable poly(glycolide/l-lactide) surgical suture (PGL suture) is an absorbable sterile, flexible strand as prepared and synthesized from homopolymers of glycolide and copolymers made from 90 percent glycolide and 10 percent l-lactide, and is indicated for use in soft tissue approximation. A PGL suture meets United States Pharmacopeia (U.S.P.) requirements as described in the U.S.P. “Monograph for Absorbable Surgical Sutures;” it may be monofilament or multifilament (braided) in form; it may be uncoated or coated; and it may be undyed or dyed with an FDA-approved color additive. Also, the suture may be provided with or without a standard needle attached.(b)
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.